508 Refresh is done!

So we’ve been waiting a long time for the Section 508 refresh to finish. There’s even a time lapse of Matt Damon waiting for the updated rule:

Matt Damon's aging scene from Saving Private Ryan

But it’s here. Finally, actually here. Published on January 18th, and in effect in one year. You can read the entire thing online (scroll to the end for the appendix to find the actual rule) or just keep reading for the parts I found interesting.

As expected, it looks like the new rule matches pretty closely with WCAG 2.0:

For Section 508-covered ICT, all covered Web and non-Web content and software – including, for example, Web sites, intranets, word processing documents, portable document format documents, and project management software – is required, with a few specific exceptions, to conform to WCAG 2.0’s Level A and Level AA Success Criteria and Conformance Requirements

There’s also a safe harbor for the new rule:

…the Revised 508 Standards include a “safe harbor” provision for existing (i.e., legacy) ICT. Under this safe harbor, unaltered, existing ICT (including content) that complies with the existing 508 Standards need not be modified or upgraded to conform to the Revised 508 Standards

In other words, if your existing stuff is compliant with the old 508 standards, and you don’t alter it, you’re ok. The access board also clarified what an alteration is:

 “Alteration,” in turn, is defined as a change to existing ICT that affects interoperability, the user interface, or access to information or data

And they clarified what existing ICT (including content) is:

ICT that has been procured, maintained or used on or before January 18, 2018.

I’m not entirely sure to what extent changes to existing content matter. In other words, if you update just part of a web page that’s compliant under the old rules, but not the new rules, are you obligated to bring the entire page up to the new rules?

The old standards didn’t do a very good job of specifying which types of content were covered; the new standards clarify this:

First, in proposed E205.2, the Board proposed that all public-facing content comply with applicable technical requirements for accessibility. Public-facing content refers to electronic information and data that a Federal agency makes available directly to the general public.

In this case, while most of us aren’t Federal agencies, our school receives Federal money, so this still applies to us. This section goes on:

Second, in proposed E205.3, the Board proposed that non-public-facing electronic content covered by the 508 Standards be limited to the following eight categories of official agency communications: (1) emergency notifications; (2) initial or final decisions adjudicating an administrative claim or proceeding; (3) internal or external program or policy announcements; (4) notices of benefits, program eligibility, employment opportunity, or personnel action; (5) formal acknowledgements of receipt; (6) survey questionnaires; (7) templates and forms; and (8) educational and training materials.

You can ignore the word “proposed” in those two quotes – there’s further clarification that these were the categories adopted, in addition to this one:

…the Board has added a ninth category to final E205.3, requiring that “intranet content designed as a Web page”…

Since the new 508 requirements cover not only web pages, but all ICT (Information and Computing Technology), there was some concern that the WCAG 2.0 standards (which were written primarily for the web), wouldn’t apply to non-web ICT. In the end, it was determined that some of the WCAG 2.0 standards don’t make sense:

Specifically, non-Web documents and non-Web software need not comply with WCAG 2.0 Success Criteria 2.4.1 Bypass Blocks, 2.4.5 Multiple Ways, 3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification.

I’m seeing a lot of WAI-ARIA in modern web apps, but:

WAI-ARIA is a valuable specification, but the technology it addresses is too narrow for our Standards and Guidelines to require its use at this time.

So in other words, you can use WAI-ARIA to comply with a WCAG 2.0 standard, but the use of WAI-ARIA isn’t required.

To sum it up, the new 508 rules (at least, the part that applies to web pages) are just the WCAG 2.0 guidelines, with this change:

For non-Web software, wherever the term “Web page” or “page” appears in WCAG 2.0 Level A and AA Success Criteria and Conformance Requirements, the term “software” shall be substituted for the terms “Web page” and “page”. In addition, in Success Criterion in 1.4.2, the phrase “in software” shall be substituted for the phrase “on a Web page.”

Later this month there’ll be two webinars on the updated rules. I’ll be attending one of them, and will be sure to update this post if my understanding of any of the above was incorrect.

If you’d like a lot of detail on the differences between the old 508 rules and WCAG 2.0, you can follow along with the posts I’ve been writing, complete with examples and how the guidelines apply to Lane.

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