March 17, 2015

508 Compliance Refresh (NPRM) Overview

Section 508 – What is the Way Forward For Accessibility?

After many years of discussion, debate, and review, the latest Section 508 refresh or NPRM (Notice of Proposal Rule Making) is on its final hearings aimed at a May 28th 2015 deadline for completion and final reading. So, what does this mean?

Section 508 is a broad sweeping law that covers and influences Information Technology Accessibility. The US government is a large organization that procures documents from millions of companies and organizations. Due to the scale that the US government works with, this far-reaching law carries significant weight. Section 508 compliance and accessibility for any electronic document is a requirement for doing business with the Federal Government and its requirements resonate across a broad range of departments, industries, and suppliers. Essentially, this means any web, document, form, or communication must be accessible.

Long in research and review, this refresh has been in the works since 2006. We should see this set into law in the fourth quarter of 2015 at the earliest. Anyone doing business with the US Federal Government will and must comply with the latest Section 508 refresh.

Crawford attended the most recent March hearings at the North Ridge Conference on Disabilities and Assistive Technologies in San Diego at California State University. The US Access Board held hearings with notable entities like the Department of Justice, Adobe, Microsoft, legal experts and other interested parties. It’s clear that there will be celebration for the disabled community if the proposed changes go into the Section 508 refresh, as the effects of this law will transcend a significant part of their day-to-day lives. With the requirements for electronic documents to be WCAG 2.0 Level AA as the test standard and Accessible PDFs that meet PDF/UA (ISO 14289-1), the trickle down effect for those that are blind, partially sighted, or have learning and cognitive disabilities will provide more equal access to all Americans.

One key remaining hurdle is to harmonize the standards globally. The European Union passed EN 301-548, a similar law to Section 508. Software companies will continue to push for a common standard that ensures a “build once for all regions” and not a “build for each region.”

Reflecting on Crawford Technologies' PRO Transform Plus PDF/UA product, CrawfordTech has worked to ensure both WCAG 2.0 Level AA and ISO 14289-1 Accessible PDF compliance is met. This solution remediates transaction documents such as statements, invoices, contracts, letters, and information generated in a structured format at high speeds and high volumes. As such, the debate to accommodate or make all documents compliant begins to fade away. Organizations can now convert documents into Accessible PDF on the fly or store them as Accessible PDFs as if they were generating regular PDFs. Section 508 will push this to happen and ensure those with visual or cognitive disabilities will have access to all documents.

As the Department of Justice continues its litigation efforts aimed at those that are not compliant, many organizations are quickly reviewing their compliance and looking to avoid potentially large penalties. The issue is around discrimination and the need to provide an all-inclusive, equal access society. We applaud the Access Board in its final push to get the NPRM passed and into its procurement regulations. Let’s hope that the final definitions will be quickly developed following the final hearings.

For organizations waiting for the requirements and testing standards to be passed, WCAG 2.0 Level AA and PDF/UA will be the path forward.

Want to learn more? Download our Document Accessibility Whitepaper, "Ensure That All Customers Can Use and Understand Your Business Documents: Understanding Accessible PDF."