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Everyone Wins with Section 508
On June 21st, 2001, federal agencies faced the daunting task of implementing Section 508 law. Section 508 requires strict compliance with specific automation standards that dramatically increase accessibility for people with disabilities. In 2001, government analysts projected that Section 508 compliance could cost the Federal government hundreds of millions of dollars. Fortunately for the United States Patent and Trademark Office (USPTO), these grim cost projections never materialized. In fact, Section 508 has become a rewarding benefit at no additional cost.
This success stems from the USPTO approach to integrating Section 508 into the way it does business. USPTO incorporated Section 508 standards into the development of its software and web based products at the beginning of the process. Inclusion of the standards at any other time in the process can easily result in "retrofitting," which has been proven to multiply the cost of the product, and delay production scheduling.
Employees and contractors are trained to create compliant products. Training is offered twice a year and includes multiple levels of courses in different subcategories of the law. For example, there are 100-level courses offered in most subcategories that discuss each standard and provide some non-technical methods for testing compliance. For example, 1194.23(f) requires that "for incremental volume control, at least one intermediate step of 12 dB of gain shall be provided." The USPTO non-tech test is if you can turn it on and increase the volume, then it likely meets the standard. There are 200-level courses that are more technical and provide participants with "hands-on" techniques for creating compliant software, web, and e-learning/multimedia products. The USPTO also has an evaluator assist developers in determining if a product is compliant well before it goes to final testing.
As with most new processes, there is always some degree of reluctance to adopt change. However, as developers have come to appreciate that compliance is mandatory, they have created methodologies to build compliant products within both budget constraints and production schedules. The realization that USPTO will strictly enforce Section 508 compliance was the critical turning point in IT product development.
The results from changes in the development process turned out to be more far-reaching and beneficial than just meeting the requirements of the law.
According to one of the major private-sector companies under contract with USPTO, creating compliant products is "really quite simple." The standards "force developers to create applications that all have the same look, consistency, and navigational capabilities. The resulting applications were easier to test, possessed higher quality, reduced user-learning time, and promoted confidence with the client."
Another major USPTO contractor stated that Section 508 provided them for the first time with "clearly defined standards for software development." Based on the standards, they built components for creating compliant software and collaborated with the USPTO Web Master to develop compliant templates for web-based applications. Using these proven standardized approaches ensure compliant products -- and much more! The web templates and software components allow anyone to create compliant web products or interfaces. For example, 508 standard 1194.22(M) requires that when a plug-in or an applet is required, a web page provide a link to an accessible page where the necessary application can be downloaded. Part of the USPTO web template is a link that takes the user to a collection of plug-ins and other miscellaneous viewers that might be required for viewing all content on the USPTO website. Thus, developers have one less standard to create a solution for-this one is done for them. And it's helping. A contractor once estimated that a task would cost $30,000. Using a template, the USPTO was able to do the task internally for only $4000.
The templates and components are:
- Reusable, enabling employees and contractors to create products faster, since there is considerably less development time; cheaper since there is less labor or resources required; and better since the final product is consistent with other products.
- Are proven to be compliant, which facilitates earlier review and acceptance of products by management, plus results in faster inspections and approvals by the quality testing organization.
- Can be used on different types of technologies. Most software and web programs are designed for specific technologies (e.g., proprietary software), which limit their use on other types of technologies. Since the Section 508 standards are not written for a specific technology, the templates and components are effective on most applications, tasks or products.
- Result in faster and more effective training of employees and contractor personnel on both creating and using products.
- Enable users to more easily adapt to other mandatory coding requirements (e.g., security web standards).
- Have significantly lowered in-house development costs since requirements are now understood more quickly and require simple, non-complex development practices and tools.
As the one contractor stated, they "do not price Section 508 compliance as a separate cost on the task. Instead (they) simply follow the (applicable) standards, and enjoy the benefits of productivity gains and lower cost through reuse." They now consider creating compliant products a smart way to do business. The USPTO has also found that some contractors have adopted the standards approach internally and use it for doing more cost effective business with their other customers.
From an accessibility perspective, the most important benefit of Section 508 is the proven enhanced support to the USPTO employees with disabilities. With a Section 508 compliant IT infrastructure, the USPTO can provide substantially faster and more effective accessibility solutions and support. In addition to these benefits, Section 508 saves the USPTO an estimated $1+ million annually in maintaining accessibility to it employees with IT-related disabilities.
These benefits unequivocally prove the value of Section 508. However, it must be stressed that the benefits can only be realized from a mature program that includes the following characteristics:
- Strict enforcement of the standards. Create products to the standards, not to a technology or specific assistive device such as JAWS.
- Training of employees and contractors on creating 508 compliant products. As one contractor said: "the training caused a new era of cooperation amongst the development, test and client organizations. The various organizations started developing and testing to the same sheet of music." A critical point to the success of the USPTO 508 program was the training instructors. These were not the typical contract instructors who provided philosophical theories on how to create compliant products but rather individuals who were actually creating compliant products and taught from personal experience. This results in proven concepts that have created products that are compliant, accessible and usable. This is particularly important because a compliant product does not necessarily mean that it is accessible or usable. In other words, a compliant product simply means that it meets specific Section 508 standards, but that does not guarantee that manufacturers´ assistive technology will make use of the application´s accessibility features.
- Strict enforcement of the program. Once people accept the mandatory requirements of the law, they turn their ingenuity and energy to creating more effective methodologies to work within the new framework.
The USPTO has determined such a Section 508 program does work and provides enhanced benefits. Instead of costing money, the program actually saves the organization funds and results in faster and better products. The employees and customers with disabilities have greatly improved IT accessibility. And, the contractors have adopted Section 508 techniques to create better products for the USPTO, themselves, and their other customers. Everyone is winning with Section 508.
