Jun 052011

Section 508: Your Questions Answered

Section 508: By Amy Kellogg, August 29, 2005

“The responsibilities you have as an instructional designer will determine how much you are involved in making a course meet Section 508 standards. While meeting Section 508 requirements involves some additional work (relative to a course that does not meet Section 508 requirements), the good news is it does not have to change the look of your course drastically. So do not be afraid of working toward meeting Section 508 standards! It is not as bad as you think!”

Many e-Learning producers in the United States have heard of Section 508, but what is it? What standards does it require? Does it affect me and my organization (even if we are in Europe or Asia, producing e-Learning for use in the United States), and if so, how? Will meeting Section 508 standards change the entire look of my course? What do I need to know about Section 508 as an instructional designer, developer, or manager?

Many of us wonder the same things and ask the same questions. In this article I will address these questions, and more, as I share experiences from actual projects. Writers and speakers often use the term “accessibility” in the same breath as “Section 508.” Aren’t they really the same thing? Well, they’re close to each other in meaning. A course designer could pay attention to accessibility, and yet not meet the requirements of Section 508. However, a course that meets the requirements of Section 508 will certainly be accessible. Accessibility means that electronic information and technology do not rely on a single sense or ability. For example, a system that requires the use of a mouse to navigate would not be accessible to people with mobility impairments that prevent them from using a mouse. One must either implement an alternative way of navigation, or the system must support an assistive technology that aids the user in navigation. Information and technology that is not accessible makes it difficult, if not impossible, for people with disabilities to obtain and use information efficiently. Thus, we have Section 508.

What is Section 508?

Section 508 is part of the Rehabilitation Act of 1973, amended in 1998. Section 508 states that electronic and information technology must be made accessible to people with disabilities. This law is based on World Wide Web Consortium (W3C) priority 1 checkpoints. (See Sidebar 1.) Note that these priority 1 checkpoints are more detailed than Section 508, so you do not have to meet all checkpoints listed under priority 1 in order to comply with Section 508.

SIDEBAR 1 W3C Priority 1 Checklist (taken from the W3C Web site)
In General (Priority 1) Yes No N/A
1.1 Provide a text equivalent for every non-text element (e.g., via “alt,” “longdesc,” or in element content). This includes: images, graphical representations of text, image map regions, short animations (e.g., animated GIFs), applets, ascii art, frames, scripts, inserted list bullets, sounds (played with or without user interaction), stand-alone audio files, synthesized speech, audio tracks of video, and video.
2.1 Ensure that all information conveyed with color is also available without color, for example from context or markup.
4.1 Clearly identify changes in the natural language of a document’s text and any text equivalents (e.g., captions) of non-text content.
6.1 Organize content logically using appropriate structural markup so the organization remains clear even when associated style sheets are turned off or are not supported.
7.1 Avoid causing the screen to flicker until user agents allow users to control it.
14.1 Use the clearest and simplest language appropriate for a site’s content.
And if you use images and image maps (Priority 1):
1.2 Provide redundant text links for each active region of an image map. [Priority 1 – if server-side image maps are used, Priority 2 – if client-side image maps are used. Redundant text links for client-side image maps are only required until user agents render text equivalents for the map links.]
1.5 Replace ASCII art with an image or explain it. [Priority 1 or Priority 2 depending on the importance of the information.]
9.1 Provide client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.
And if you use tables (Priority 1):
5.1 For data tables, identify row and column headers.
5.2 For data tables that have two or more logical levels of row or column headers, use markups to associate data cells and header cells.
And if you use frames (Priority 1):
6.2 Ensure that descriptions and text alternatives for dynamic content are updated when the dynamic content changes.
12.1 Title each frame so that users can keep track of frames by title.
And if you use applets and scripts (Priority 1):
6.3 Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent mechanisms on an alternative accessible page.
And if you use multimedia (Priority 1):
1.3 For each movie, provide an auditory description of the video track and synchronize it with the audio track.
1.4 For any time-based presentation (e.g., a movie, animation, or multimedia presentation), synchronize equivalent alternatives (e.g., captions or video descriptions) with the presentation.
And if all else fails (Priority 1):
11.4 If, after best efforts, you cannot create an accessible page, provide a link to an alternative page that uses W3C technologies, is accessible, has equivalent information, and is updated as often as the inaccessible (original) page.


Specifically, Section 508 requires that Federal employees who have disabilities have access to and use of any information and technology developed, procured, maintained, or used in Federal agencies. Additionally, Section 508 requires that people with disabilities, who are members of the public and are seeking information or services from Federal agencies, must have comparable access to and use of information or services provided by these Federal agencies. Federal agencies must consider Section 508 standards even if there are currently no users with disabilities in need of information and technology that meets Section 508 standards. However, if meeting Section 508 standards places an undue burden on an agency, the agency is not required to meet them.

Electronic and information technology includes all electronic and information technology for computing, storage, communication, presentation, control, production and duplication. It also includes computers, software, networks, peripherals, and other types of electronic office equipment. Section 508 applies to procurements made on or after June 25, 2001. Procurements before that date are not required to meet Section 508 standards. Section 508 does apply to e-Learning.

Does Section 508 impact me or my organization?

Federal departments and agencies (but not state agencies or the private sector) must meet Section 508 standards. There are some exceptions, however. For example, states receiving Federal funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998 must comply with Section 508. In addition, some states may actually require state agencies to comply with Section 508.

Furthermore, many states have their own accessibility standards and these states may require their agencies to comply. Typically these state requirements are stricter than those of the Federal Government. For example, New York adopted accessibility requirements before the federal government.

Here is a quick check list to help you determine whether your organization needs to comply with Section 508:

  • You work for and develop material for a Federal agency.
  • Your organization develops material for a Federal agency.
  • You work for an agency and develop material for an agency that receives funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998 (i.e. a State College).
  • Your organization develops material for a State agency that receives funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998.
  • You work for a State Agency residing in a state that requires fulfillment of Section 508 Standards.
  • Your organization develops material for a State Agency residing in a state that mandates fulfillment of Section 508 requirements.

If you were able to check any one of the items above, your material must meet Section 508 standards.

How are instructional designers involved in meeting Section 508?

Traditionally, instructional designers analyzed the audience, content, learning environment and desired performance level, developed learning objectives, selected delivery methods, and served as evaluators or editors. Due to more demands placed on instructional designers, their responsibilities have often expanded to include traditional roles of developers, programmers, program managers, graphic designers, and others.

When discussing how instructional designers must meet Section 508 standards, I have chosen to focus on the more “traditional” instructional design responsibilities, rather than jobs such as development and programming. I have assumed a team approach to course development, where an instructional designer, a graphic designer, a developer, and a programmer are all on board working on the same project under the direction of a manager. Therefore, if you are the only person designing and developing courses, you may need to have a more in-depth knowledge of other sections of Section 508.

Sidebar 2 a list of 16 elements that, when implemented, will ensure that a course (be it Web-based, instructor-led, computer-based, etc.) satisfies Section 508’s requirements for electronic information. While it is important to be familiar with each of these elements, I will discuss the requirements as a team of instructional designers will typically encounter them when designing or converting courses. I will amplify some of the 16 elements.

SIDEBAR 2 16 elements or requirements of Section 508

Section 508 specifies sixteen requirements that, when followed, should make electronic information accessible by people with disabilities. While there are other requirements, the sixteen elements listed here are specific to electronic information.

  1. You must provide a text-equivalent for every non-text element. This is because a screen reader will convert all non-text elements to their alternative text. This means that any image, graphic, video clip, audio clip, etc. must have a text-equivalent. If a person is using a screen reader in order to access electronic information they are unable to access information presented in the non-text elements unless those elements are given a text-equivalent. There are particular ways in which to incorporate text alternatives into electronic information. These include “alt” tags, “spacer” tags, “longdesc” (long descriptions), d-tags, or the non-text element must be described in the content. “Alt tags” are typically no more than 10 words and are used only for images that do not require detailed explanations. When you need a more detailed explanation long descriptions (longdesc) or d-links (description links) may be used. The longdesc associates an image description with the code that places the image in the page, whereas the d-link simply places a link near the image. However, many assistive technologies do not support longdesc, so it is typically best to use d-links. Use “spacer” tags to tell assistive technologies that the image contains no important information, and then the image will be skipped over.
  2. You must provide synchronized text alternatives for any multimedia presentations. Multimedia includes two or more media (i.e. video with audio). For example, if a movie is delivered via Real One Player, that movie must have a text transcript for any audio presented in the movie and this text must synchronize with the video as the movie is played. In addition, a text description of the video must also be included. By providing a transcript of the audio and a description of the video, anyone who is blind or deaf will have access to the material.
  3. Design pages so that any and all information conveyed with color is also available without color. This means that color should only be an enhancement to the content, and should never be used to convey required information or any information related to the content. For example, never state, “Click the green button to continue.”
  4. Organize documents so that they are readable without needing a style sheet. This means that Cascading Style Sheets should be used to lay out the visual appearance of the user experience, but should not be necessary in order for a user to access the content. When in question, turn off the style sheets and make sure the information or the document is still comprehensible.
  5. Use redundant text links for all server-side image maps. You can recognize a server side image map by mousing over the image and seeing coordinates displayed. Basically, there is no way to make a server-side image map accessible, thus the requirement of equivalent text links. These text links would lead a user to the same image that they would see when clicking on the server-side image map.
  6. Use client-side image maps instead of server-side image maps. The only exception is when you cannot define the regions of the map with an available geometric shape. Client-side image maps either have “alt tags” attached to each active region or use redundant text links.
  7. Identify row and column headers for data tables. Assistive technologies convert tables to words and lines, reading a cell at a time from left to right, one row at a time. When a table is more complicated, designers are encouraged to write a summary of what the table presents. Embed this summary into a table using the summary attribute.
  8. Use markup to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
  9. Title frames with text that facilitates the purpose of the frame. Frame titles are important to people using screen readers. Titles such as “middle frame” or “top frame” are of little use to the person using the screen reader. Frame titles should be more specific as to the purpose of the frame such as “Navigation bar” or “Title frame.”
  10. Design pages so as not to cause the screen to flicker with a frequency between 2 cycles per second (Hz) and 55 cycles per second. Pages, or elements on pages, that flicker at these rates have a greater chance of causing optically-induced seizures. It is also important to consider the effect that moving text or animated gifs may have on individuals with disabilities. Some people are unable to follow moving text across a screen due to either visual or cognitive impairments.
  11. If you cannot comply with Section 508 standards in any other way, a text-only page may be provided that contains information or functionality equivalent to the non-text version. Use a text-only version as a last resort to make content accessible.
  12. If pages utilize scripting languages to display content, or to create interface elements, identify the information provided by the script with functional text so assistive technology can read it. Scripts, such as JavaScript pop-up menus, must be directly accessible by assistive technologies, or there must be an alternative method for accessing equivalent functionality.
  13. If an applet, plug-in, or other application is required by the client in order to view content, the page must provide a link to the plug-in or applet. Additionally, these elements must also comply with Section 508 standards. If, for example, a PowerPoint file is required as a download, an alternative means of accessing content provided in the PowerPoint is required (PowerPoint files are not directly accessible).
  14. Electronic forms to be completed online must allow people using assistive technologies to access the information, field elements, and functionality required to complete the form. The main concern, with respect to forms, is whether or not a person with a disability (specifically blind or visually impaired) is able to determine the purpose of an input element and interact with it. For example, if there is a text entry field, a person with a visual impairment must be able to determine that the field is for text entry and must also know what type of information they are required to input into the field.
  15. Provide a method that allows users to skip over repetitive navigation links. For a person using a screen reader, repetitive links can become quite annoying. If the same links are present on every page presented to the user, then the user has to listen to the entire list of links each time they access a new page. By providing an option to skip navigation links, users are able to move directly to the main content.
  16. When a timed response is required, the user needs to be alerted to the fact the response is timed and the user must be given sufficient time to indicate that more time is required.


Typically instructional designers write the graphic or image descriptions in the tags or links (alt tags, d-links, or longdesc) that will provide information equivalent to that communicated by the image.

“Alt tag” refers to alternative text used to describe an image. These tags are short and simple and typically used when approximately 10 words or less can describe the image. For example, a page may display an image of a computer. The alt tag linked to the image might simply read “Image of a computer.” Remember, use alt tags only for images that do not require more detailed explanations.

When you need a more detailed explanation, long descriptions (longdesc) or d-links (description links) may be used. The longdesc associates an image description with the code that places the image in the page. This is in contrast to the d-link, which simply places a link near the image. Use d-links and longdesc when more information, beyond the 10 words of the alt tag, is needed to describe an image or graphic. While it is true that some assistive technologies do not support longdesc, as an instructional designer your task will be simply to write the description, passing that description on for the developer to insert into the course.

Likewise, instructional designers often write the audio scripts, video descriptions, and multimedia descriptions. Instructional designers may also need to write alt tags used in client-side image maps.

Figure 1 shows an example of an alt tag. Notice that the description given in the alt tag, “Football helmet,” is brief. However, there is no need for a more detailed description since there is no additional information conveyed by the image.

Figure 1 An example of an image that only requires an “alt tag.”

Figure 2 is a more complex image that does require a more detailed explanation. Thus, a d-link is used to provide the description.

Figure 2 This is an example of an image that requires a more detailed description, thus a d-link is used.

Here is a typical d-link text that might support the image in Figure 2:

“The image is a graphical representation of the Deficiency Report, or DR process. First, the customer or user submits a DR to the Configuration Manager, or CM. Next, the CM logs the DR and gives the DR to the PSM. Third, the PSM delegates an evaluator who performs an evaluation of the DR.

Once the evaluation is complete, the DR is sent to the CCB where it either approved or rejected. The CM will then update the status of the DR and, if approved, an implementer is assigned to the DR.”


Color is another area instructional designers must keep in mind. As they develop content, instructional designers must remember that any information presented in color must be available without color. For example, the content should not state, “Click the green button to continue.” Instead, the instructions should be, “Click the green NEXT button.”


Style sheets separate presentation from content. Use style sheets only for presentation effects, leaving the content to be present in the HTML. Presentation effects include the “look” of a page such as color and indentation. Instructional designers must make sure that content, or information significant to the content, is understandable without the use of style sheets. There are many people who use browsers that do not support style sheets. Thus, any critical information included within the style sheets would not be accessible.


Although many instructional designers may not actually format and develop the tables used in courses, they typically provide the information displayed in the table. This is important because in order for tables to meet Section 508 standards, the table formatting must identify row and column headers. Therefore, it is imperative that instructional designers include row and column header information or titles in the table text they provide to developers.

For more complex tables you may need to write a summary which describes the contents of the table. Although the developer is typically responsible for inserting this summary in the correct manner under Section 508 standards, it is the designer who must write the summarized description.


Instructional designers should keep in mind how information will be displayed to students. Will the information be displayed in tables, or will style sheets or frames shape the presentation? Tables are not recommended to present or lay out content. In the case of frames, there must be frame titles to facilitate frame identification and navigation as well as to help the user understand the purpose of the frame. Instructional designers are the best source of this information since they are most familiar with the content.

Text-only pages

If a text-only page is used, it will be the responsibility of the instructional designer to develop this page. The page must convey the same information or functionality available on the other version. The text-only version must be updated any time the other version is updated.

The review process

The Section 508 elements previously identified are the ones that an instructional designer will deal with on a regular basis. It is important, however, for instructional designers to be aware of all the Section 508 standards since designers are typically involved in the review process of the courseware.

At the very least, you should be able to question your developers or programmers. For example, if there is a table in the courseware, you should be aware of the special formatting required. If necessary, ask your developer or programmer to double check the table formatting so that it meets Section 508 standards.

Another example would be screen flicker. While you as a designer may not typically be involved in the development of graphics or other elements on the screen, you should be aware that elements which flicker at a rate of 2 to 55 cycles per second should not be used as they may cause optically-induced seizures. When you see an element that could be questionable, you need to ask your graphic designer or developer if the element meets Section 508 standards.

You may or may not be directly involved with color contrast. We discussed color previously in terms of presenting information in color, but during a review you may also come across the issue of color contrast. Can persons with low vision or color blindness view all elements on the screen? For example, Figure 3 is an image that displays a process diagram, color-coded according to the five roles listed in the lower left of the image. Most people would believe the color contrast used in the image is appropriate. However, to see this image through the eyes of one who is color blind tells a very different story. Figure 4 displays the same image as viewed by people with one particular form of color blindness.

Figure 3 Process diagram as originally colored. Figure 4 Process image as seen by a person with Deuteranope, a form of red/green color deficit.

Notice in the color deficit example, it is very difficult, if not impossible to distinguish what the Exploitation Planner is responsible for versus the Dissemination Manager. Nor is it easy to distinguish between the Production Manager’s responsibilities and those of the Spectral Analyst. Colors used in the original image would not be acceptable to use in a course that needed to meet Section 508 standards.

Will Section 508 change the look and feel of my course?

Even five years ago, it was more difficult to make electronic information Section 508 compliant, particularly if that information was presented as multimedia. However, in recent years, software companies have begun stepping up to better help designers and developers of electronic information meet Section 508 requirements. For example, the latest version of Macromedia’s Flash, frequently used in e-Learning courses, can now produce Section 508-compliant materials. Macromedia offers many accessibility tools on their Web site, including accessibility templates. In addition, some software companies have built Section 508 validation checks into their software. For example, DreamWeaver MX 2004 checks the selected pages for compliance with Section 508 standards.

Many people are under the misconception that, if they comply with Section 508, the look and feel of their course or electronic information will drastically change. In truth, the look and feel changes very little when meeting Section 508 requirements. Much of what allows electronic information to be Section 508 compliant takes place behind the scenes, invisible to most consumers of the information.

Figure 5 is a screen capture from a course created with Flash. It shows what the course looked like when it did not meet Section 508 standards. Figure 6 shows the same course after Section 508 elements were implemented.

Figure 5 A screen capture of a Flash course that does NOT meet Section 508 standards. Figure 6 A screen capture of a Flash course that does meet Section 508 standards. The d-link in the bottom right corner is the only visual change to the course.

So, what were instructional designers responsible for in this course? Since this course was multimedia (both audio and video), it required a little more work from instructional designers than may normally be the case with a course developed in basic HTML. Instructional designers had to write the script for the entire course. The script was actually developed at the beginning since audio was the main way in which the content was delivered in this course. The text version of the script was then made accessible both on the left hand side bar and under the d-link.

The second part of this course that the instructional designer needed to address was the video portion on the monitor screen. To accomplish this, instructional designers described the visual presentation on each page of the course. For example, for Figure 6, instructional designers described Faye, the Financial Manager, as appearing in the upper right corner of the screen while a graphic of the Resource Allocation Process was displayed center screen.

Instructional designers then developed a textual explanation of all the information presented in the process chart, including the areas emphasized with highlighting. Developers incorporated these descriptions into the course in a way that would allow a screen reader to automatically read the descriptions. If a screen reader was not used, then no one would ever know these page descriptions existed.

The next area related to Section 508 involving instructional designers was the review process. Developers tested how the course reacted to screen readers (the developers had access to the screen reader software, whereas the instructional designers did not). Instructional designers tested the course for accessible navigation. For example, could someone navigate through the course without the use of a mouse (i.e. using only the Tab key)?

Designers also looked at colors used in graphics, images, and on the screen to ensure there was enough contrast. If a screen or image was in question, they took a screen shot and then tested it using a program that allows viewing the image as a person with various forms of color blindness would see it. If there were questionable colors, designers would report back to their team that the colors needed enhancement or change.

The remainder of the effort fell upon developers, graphic designers, and programmers. Again, most of the Section 508-related work was “behind the scenes” of the course so that people could not detect a difference visually. Instructional designers did have to put forth a large effort in writing page and image descriptions, but unless you were a person using a screen reader, you would never be aware that those descriptions existed.

My course will not be delivered over the Web. Do I still need to comply with Section 508?

Absolutely! Remember that Section 508 applies to ALL electronic and information technology used in computing, storage, communication, presentation, control, production and duplication, as well as computers, software, networks, peripherals, and other types of electronic office equipment. The amendment does not specify that only information delivered over the Web must comply with Section 508.

I have a text version of my course, is that enough to comply with Section 508?

The requirements of Section 508 specifically state that you should use a text-only page or text-only version to meet Section 508 ONLY when compliance cannot be accomplished any other way. In other words, a textonly version is a last resort. If you choose to use a text-only version, here are four recommendations to follow (taken from JimThatcher. com):

  • Provide a clear link to the alternative page
  • Ensure that the alternative page is accessible
  • Ensure that the alternative page has equivalent information or functionality
  • Update the alternative page as often as you update the original page

The relationship between Section 508 and various standards (SCORM, IEEE, AICC, and European standards such as ARIADNE)

There is a global community working to help standardize and make online learning, education, and training scalable. These international organizations include, but are not limited to, the Institute of Electrical and Electronics Engineers (IEEE), Learning Technology Standards Committee (LTSC), the Aviation Industry CBT (computer-based-training) Committee (AICC), and the Alliance of Remote Instructional Authoring and Distribution Networks for Europe (ARIADNE). Many of the organizational acronyms may look familiar as each of these organizations has established their own set of specifications or standards for online and computer delivered learning content.

In addition, SCORM (Shareable Content Object Reference Model) is a set of Webbased-learning standards developed by The Advanced Distributed Learning (ADL) Initiative. The SCORM standards are based upon a collection of specifications adapted from many of the international sources cited previously.

When designing and developing e-Learning, you may be required to meet one or more of these standards, in addition to meeting Section 508. Which standards you are required to comply with depends on the organization for which you are working. Compliance with each set of standards will vary among your customers. While Federal organizations may require compliance with Section 508 standards, they may not require AICC compliance.

Although there may be similar or even identical elements within each set of standards, the standards required for Section 508 are not found in their entirety in any other set of standards. It is possible for content you develop to meet SCORM standards and yet not meet IEEE standards. It is also possible for your material to meet AICC standards and not meet SCORM standards. Still, it is possible for content to meet any one of these standards AND to meet Section 508’s requirements.


Section 508 applies to all electronic and information technology. This includes e-Learning, regardless of the platform which delivers it (i.e. the Web, CD-ROM, etc.) Your organization may be required to comply with Section 508 standards for any number of reasons:

  • You work for, or your organization develops material for, a Federal agency.
  • You work for, or your organization develops material for, a State Agency that receives funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998 (i.e. a State College).
  • You work or do work for a State Agency in a state that requires fulfillment of Section 508 Standards.

The responsibilities you have as an instructional designer will determine how much you are involved in making a course meet Section 508 standards. While meeting Section 508 requirements involves some additional work (relative to a course that does not meet Section 508 requirements), the good news is it does not have to change the look of your course drastically. So do not be afraid of working toward meeting Section 508 standards! It is not as bad as you think!


Official Section 508 Web site

Frequently Asked Questions about Section 508 (presented by the Section 508 Government site)

Alternative Web Browsing

W3C provides this site and lists pages of links to alternative browsers such as textbased browsers, screen readers and voice browsers.


Vischeck is a way of showing you what things look like to someone who is color blind. You can try Vischeck online, run Vischeck on your own image files, or run Vischeck on a Web page.

Vision Connection

This page provides a list of links to more information on various Assistive technologies including Braille solutions, speech solutions, etc. that users of your courses may require when completing your course material


Additional Resources:

Hidden Disabilities: Is Your e-Learning Fully Section 508 Compliant?:


More than Compliance: Accessible e-Learning that Makes a Difference:



To Discuss how these Solutions will add value for you, your organization and/or your clients, Affinity/Resale Opportunities, and/or Collaborative Efforts, Please Contact:

Tom McDonald, tsm@centurytel.net; 608-788-5144; Skype: tsmw5752

section 508, McDonald Sales and Marketing, LLC