RE: [SEC508] Does .31 always apply?

["Mark D. Urban" <docurban@nc.rr.com>]

For the record, I emphatically agree with Gregg.  The .31 provisions are an
essential part of any evaluation of EIT.  A recent example - a phone that
met the technical standards, but was not usable by anyone with a moderate or
severe visual impairment.  

As to systems, I call .31 the "Lego" standards. Legos have a standard
interface (i.e. "accessible"). However, if you put them together in one way,
you get the police station with the neat patrol car.  Put together in
another way, you get what my nephew usually gets - a big pile of
stuck-together legos.

Regards,
-Mark D. Urban 
919-395-8513 (cell)
Chair, North Carolina Governor's Advocacy Council for Persons with
Disabilities
Keep up with the latest in worldwide accessibility at
(http://www.icdri.org/)


-----Original Message-----
From: sec508-admin@trace.wisc.edu [mailto:sec508-admin@trace.wisc.edu] On
Behalf Of Gregg Vanderheiden
Sent: Tuesday, July 18, 2006 12:58 AM
To: sec508@trace.wisc.edu
Subject: [SEC508] Does .31 always apply?


This question came up a lot early on but both the original 508 standard and
the subsequent guides are pretty clear that .31 provisions apply to all
products and product functions.  

After the technical specifications are applied the .31 provisions are used
to make sure the product as a whole is accessible.  The .31 provisions are
sort of the uber provisions.  In fact, .31 can even trump the technical
guidelines in a way.  The standard allows for equivalent facilitation.  That
is, you can meet the guidelines in a manner different than the technical
specifications if it provides the same functionality as the technical
specifications.  When you do this, you use .31 to test whether your
equivalent facilitation really provides access.  (see below)

Here are a few places form the 508 standard and the Access Board Guides that
give examples of .31 applying to all products - and to being the test you
pass after meeting the technical specifications: