[SEC508] Applying 1194.22 and .21 to Web apps

["Sailesh Panchang" <sailesh.panchang@deque.com>]

I am evaluating an application that uses multimedia content and
Javascripting for S508. As it is Web content 1194.22 will apply. But in this
case there are elements that appear as user interface elements to the
sighted user. These elements can also be activated from the keyboard but the
fact that  these elements are user interface elements and can be activated
is not conveyed at all by the application to assistive technology.
Therefore the "identity, operation and state of the elements" is not known
to non-visual users. So can I apply para (d) of 1194.21?
Para (l) of 1194.22 only requires functional text to be associated with
interface elements created with scripting but does not require the element
to be identified as para (d) of 1194.21does.

I remember a recent post on one of these lists where Dr. John Gunderson said
that one might have to consider 1194.21 in some cases of Web apps too. 
Or do I say this is only a Para (l) violation ?

The controls also have keyboard shortcuts that conflict with JAWS or WinEyes
and one has to use the bypass key to make them work. Any issue there? 
Thanks,
Sailesh Panchang
Senior Accessibility Engineer
Deque Systems Inc. (www.deque.com)
11180 Sunrise Valley Drive, Suite #400,
Reston VA 20191
Phone: 703-225-0380 (ext 105)
E-mail: sailesh.panchang@deque.com