Section 508 PDF Remediation: Get Jiggy with 1194.22

Question: You are working on an RFP for a governmental agency, and the requirements include delivering a Section 508 compliant PDF document. What does this mean, and how can you get this job done?


Answer: Here is a sample 508 RFP requirements/specifications from a government contract offering, the boilerplate, so to speak:

All electronic and information technology (EIT) procured through this solicitation must meet the applicable accessibility standards at 36 CFR 1194, unless an agency exception to this requirement exists. 36 CFR 1194 implements Section 508 of the Rehabilitation Act of 1973, as amended. 

In accordance with the above, in addition to the work requirements specified in the Statement of Work, contractors/vendors must ensure that all EIT that they provide either: (1) meets the technical provisions of the Section 508 Access Board Standards applicable to a given procurement (see below); or (2) uses designs or technologies as alternatives to those prescribed in the specified technical provisions, provided they result in substantially equivalent or greater access to and use of a product for people with disabilities. 

The following standard, from Subpart B of the regulations, will be applicable to PDFs delivered via this contract:

 1194.22 Web-based intranet and internet information and applications. 

(Note:The standards do not require the installation of specific accessibility-related software or the attachment of an assistive technology device, but merely require that the EIT be compatible with such software and devices so that it can be made accessible if so required by the agency in the future.)

Question: How can I make sure my documents meet 1194.22?

Answer: Contact and deal directly with a reputable, knowledgeable Section 508 remediator.  Ask questions, make sure they know what they are doing, that they are not just a pass-through. You may want to learn about the process, or maybe not (some clients just want us to make this particular headache go away... <8^) - we at EDCS are glad to tell you as much or as little as you care to know, as the end result is the same: we remediate your document and deliver a Section 508 compliant PDF that meets all 13 requirements of 1194.22, and the documentation to prove your due diligence.

Under Subpart B: Technical Standards, we see the applicable requirements for PDF compliance, §1194.22.  This is NOT our interpretation of compliance, this is the language in the regulation.  Ten of these sixteen standards apply to PDF format. Meet these ten requirements - as all EDCS-certified documents do - and rest assured that your documents are in complete compliance.

Here's the regs, we've struck-through the ones that aren't applicable to PDF:

1194.22 Web-based intranet and internet information and applications.

(a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).
(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.
(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.
(d) Documents shall be organized so they are readable without requiring an associated style sheet.
(e) Redundant text links shall be provided for each active region of a server-side image map.
(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.
(g) Row and column headers shall be identified for data tables.
(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
(i) Frames shall be titled with text that facilitates frame identification and navigation.
(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.
(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.
(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).
(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
(o) A method shall be provided that permits users to skip repetitive navigation links.
(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.






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