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508 and SEWP

NOTE: Most of this information is extracted from the Section 508 FAQ page. Please refer to the FAQ link at the www.section508.gov web site. The document is purely informational. It neither creates new policies nor changes existing policies and should not be considered official, formal policy or procedure. Agency personnel must consult appropriate officials within their agencies for formal advice.
What is 508?
Section 508 of the Rehabilitation Act, requires that federal agencies make their electronic and information technology accessible to people with disabilities went into effect June 21, 2001.
Where can I get Official Information on 508?
The official 508 Government Web page is: www.section508.gov
Are products on SEWP 508 compliant?
The requiring agency (i.e., the agency with the need for EIT) is responsible for ensuring that the acquisition complies with section 508. See FAR 39.203(b)(3). This responsibility remains with the requiring agency irrespective of the vehicle used to complete the transaction.
How do I determine and document if a product is 508 compliant?
For the most part, the actual 508 technical requirements for compliance are easily met and documented. A suggested, but not required, method for checking and documenting requirements and compliance is through the use of 2 Web sites:
  1. Print off a copy of the Voluntary Product Accessibility Template from the Information Technology Industry Council. While this is provided for Vendors, it is also useful as a checklist for compliance. Locate the Section applicable to the IT products being purchased.
  2. If a criteria listed in this template is unclear, go to the "Guide to the Section 508 Standards for Electronic and Information Technology " website (www.access-board.gov/sec508/guide/index.htm) which provides an explanation of the various criteria in easy to understand language.
  3. Contact the vendor for any needed clarification
  4. Check off the criteria which are applicable and have been met by the product as documentation that 508 compliance was met
What Technology is covered by 508?
The standards provide criteria specific to various types of technologies, including:
  • software applications and operating systems
  • web-based information or applications
  • telecommunication products
  • video and multimedia products
  • self contained, closed products (e.g., information kiosks, calculators, and fax machines)
  • desktop and portable computers
Is documentation covered by 508?
The standards address access to all information, documentation, and support provided to end users (e.g., Federal employees) of covered technologies. This includes user guides, installation guides for end-user installable devices, and customer support and technical support communications. Such information must be available in alternate formats upon request at no additional charge. Alternate formats or methods of communication, can include Braille, cassette recordings, large print, electronic text, Internet postings, TTY access, and captioning and audio description for video materials.
Are there exceptions to 508 compliance?
Yes. Agencies are not required to acquire EIT that meets the technical provisions of the Access Board's standards if the acquisition:
  1. is a micro-purchase made prior to January 1, 2003 (FAR 39.204(a));
  2. is for a national security system (FAR 39.204(b) and 36 CFR 1194.3(a));
  3. is acquired by a contractor incidental to a contract (FAR 39.204(c) and 36 CFR 1194.3(b));
  4. is located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment (FAR 39.204(d) and 36 CFR 1194.3(f));
  5. would impose an undue burden on the agency (FAR 39.204(e) and 36 CFR 1194.2)
In addition, agencies are not required to fundamentally alter their needs in order to comply with section 508.
What documentation does SEWP require if an order is to be excepted from 508 compliance?
Any SEWP Delivery Order which is to be excepted from 508 compliance must include which of the 5 exceptions noted above are the reason for the exception on either the Delivery Order itself or the cover sheet accompanying the Delivery Order.
How is the "back office" exception applied?
  Hardware
Two conditions must be met before an agency uses this exception when procuring a product.
  1. The agency must intend to locate the product in a physical space frequented only by service personnel.
  2. The use of the product by the service personnel must be for maintenance, repair or occasional monitoring.
If both conditions are met, the product does not have to meet the standards. Hardware that might meet these dual conditions includes: telephone equipment placed on racks in a "closet" or small room and network routers and storage devices or servers located in rooms or areas frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment.
  Software
Software which is installed or operated on a product which falls under this exception would be exempt from the standards if the software application could only be operated from the physical place where the product is located. This might include specialized diagnostic software. By contrast, if the software could be operated from a remote workstation, the software would be subject to the Access Board's standards irrespective of who is using it since the product interface is not located in a physical space which meets the criteria for this exception.
Does 508 require all accessibility options to be built into all IT purchases?
Self-contained products, such as kiosks and copiers, that do not permit a user to install or connect assistive technology, must be designed so that an end user can operate the product, without having to modify it. However, for most products -- such as software, web pages, and computers -- achieving compatibility with assistive technology is the goal of the standards.
Who determines 508 compliance?
While a vendor may assert compliance, the agency must determine whether a standard is met through equivalent facilitation in accordance with agency guidance and in consultation with, if necessary, the agency 508 coordinator and/or other agencies with technical expertise in accessible EIT, such as the Access Board. Acquisition of EIT that meets the applicable technical provisions of the Access Board's standards is the shared responsibility of requiring activity officials and contracting officials.
Does section 508 require contractors to manufacture EIT that meets the applicable Access Board's technical provisions?
No. Section 508 requires the government to purchase EIT that meets the applicable technical provisions of the Access Board's standards, with certain exceptions. Agencies are responsible for ensuring that they undertake their acquisitions for EIT consistent with the requirements of section 508, as implemented in the Access Board's standards and the FAR -- which includes identifying applicable section 508 provisions to interested contractors. Similarly, agencies 'not contractors' are responsible for making determinations regarding whether any exceptions apply. In turn, contractors wishing to do business with the government must provide products and services that meet (either directly or through equivalent facilitation) an agency's stated requirements, including applicable technical provisions from the Access Board's standards as identified by the agency.