Section 508: Your Questions Answered

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.

 

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:

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.

Text-equivalents

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

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.”

Documents

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.

Tables

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.

Frames

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):

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.

Conclusion

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:

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!

Resources

Official Section 508 Web site
http://www.section508.gov/

Frequently Asked Questions about Section 508 (presented by the Section 508 Government site)
http://www.section508.gov/index.cfm?FuseAction=Content&ID=73

Alternative Web Browsing
http://www.w3.org/WAI/References/Browsing

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

Vischeck
http://www.vischeck.com/vischeck/

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
http://www.visionconnection.org/Content/Technology/AssistiveTechnologies/default.htm

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

http://www.learningsolutionsmag.com/articles/253/section-508-your-questions-answered

Additional Resources:

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

 http://www.learningsolutionsmag.com/articles/249/hidden-disabilities-is-your-e-learning-fully-section-508-compliant

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

http://www.learningsolutionsmag.com/articles/282/more-than-compliance-accessible-e-learning-that-makes-a-difference 

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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