ED Web Technical Standards for Implementing Section 508

On December 21, 2000, the technical standards for implementing Section 508 of the Rehabilitation Act of 1973 as amended by the Workforce Investment Act of 1998 were published in the Federal Register. These standards set forth, in very specific terms, criteria that must be met by software, hardware, web sites, and other electronic and information technology (E&IT) to ensure its accessibility to individuals with disabilities who are either employees or customers of the Federal government. After June 21, 2001, agencies that procure E&IT that does not meet these standards, leave themselves open to either administrative complaints or private rights of action in the Federal courts by disabled individuals unable to utilize this E&IT as a result of its inaccessibility.

These standards are of particular concern to Federal webmasters, whose web sites are potentially available to every person with access to a computer, including the millions of disabled individuals who use a variety of assistive technology to access the Internet. The wide visibility Federal sites enjoy through the medium of the Internet brings with it the responsibility of ensuring that Federal web sites are as accessible as possible, meeting the sixteen 508 web-related standards to the fullest extent possible.

This document lists the various web related standards, and explains how to test documents for compliance. For additional links to assist you in complying with these standards, see Resources for Implementing the Federal Web Accessibility Standards.

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).”

Compliance with this standard can generally be verified by examination of the HTML code to ensure that all images, image map hot spots, and other non-text elements contain text descriptions. When coding alt attributes as text equivalents for graphical text, please ensure that the alt attribute replicates exactly the text which is displayed by the graphic. In complex situations, such as where JavaScript or other scripting languages are involved, the site can be tested with a screen reader to ensure that the descriptive information is properly exposed to the user. If a description is complicated or very long, a "d link" may be used. Linkscan can also be used for testing for alt tags. If you have questions about the accessibility of your non-text elements, please contact your DST representative for assistance in testing for this.

One misconceptions about section 508 and the web involves the use of the Alt attribute to provide descriptions for images and other non-textual elements. Many believe, due to the phrasing of the standard, that every image must have a verbal equivalent, which must be spoken out loud. This is far from true; the audible labeling of graphics used for formatting purposes, such as spacers, with audio descriptions actually adds to the inaccessibility of a site by creating audio litter. For those images which do not convey content or navigation information, alt= " " is recommended for use as an appropriate solution. The screen reader skips over the unimportant graphic and remains silent, keeping its verbal output to the blind user clean and informative.

“(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.”

This means that if you have RealVideo, streaming media, Flash presentation, or anything along those lines, you have to add close captioning. If you are using Flash, you need to use alt text or a "d link".

“(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.”

Color cannot be used as the sole means to convey information. For instance, if you have a form, do not say "The fields with red labels are required." You can use a character, such as an *, with the color to convey the same message (e.g. The fields marked with a red * are required.).

“(d) Documents shall be organized so they are readable without requiring an associated style sheets.”

The way to test for this is to turn off all cascading style sheets (CSS) in your browser. Unfortunately, current versions of Internet Explorer for Windows do not directly provide a mechanism to disable CSS. In order to reliably test against this standard, you will need an alternative browser application which allows you to turn off CSS (such as Firefox). Although IE does not allow you to turn off style sheets, you can simulate this by going to Tools>Internet Options. On the default page (General) select the Accessibility button (this is directly above the Apply button). Once the Accessibility dialog box opens, select the checkbox next to the three Formatting options, select OK, select OK again, and your page should look really different. If your page is still readable, it should be okay. If it is no longer readable, then you need to redo the page. If you do not have an alternative browser and are unsure whether or not your page is readable without requiring an associated style sheet, please contact your DST representative for assistance in testing for compliance with this standard. However, keep in mind that complying with this standard should not be a problem as long as you follow the ED Web Publishing Guidelines and are using the standard ED template (or "clamp").

“(e) Redundant text links shall be provided for each active region of a server-side image map.”

ED.gov does not allow server-side image maps.

“(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.”

Compliance for Standard F can be verified by examination of the underlying code. When necessary, the proper reading of the labels for the hot spots on these image maps can be verified with a screen reader. If you do not have a screen reader, please contact your DST representative.

“(g) Row and column headers shall be identified for data tables.” and “(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.”

Due to the variety of attributes which can be invoked in table construction, the complexity of the tables which can result from their use, and the inconsistency with which table attributes are handled by various screen readers, the Access Board has prepared state-of-the-art technical guidance on accessible table construction.

It is generally accepted however, to use the “scope” attribute to associate row and column headers with their corresponding cells in a rectangular table, and the header/id tags in more complex multi-level tables which contain diagonal associations. Jaws and other screen readers recognize the scope and the header/id attributes.

“(i) Frames shall be titled with text that facilitates frame identification and navigation.”

Frames are not acceptable on ED.gov without prior approval. Contact your DST representative.

“(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.”

We do not allow animation on ED.gov that would cause a page to flicker.

“(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.”

A text equivalent is a last resort for ED.gov. All HTML pages should be made accessible. If you cannot create accessible documents, then a text equivalent is necessary in order to post the information.

Non-HTML pages can be a problem, and may require an alternate version. While MS Word documents are generally accessible, do not assume that all Word documents are. If the Word document contains charts, tables, or some embedded images, then it is most likely just as inaccessible as an HTML page containing images without alt text. If your document contains any of these items, and they are not made accessible within the document, it is your responsibility to provide an alternative format. This can be in the form of an HTML version of the entire document, or just the sections that cannot be made accessible in Word, with something in the document linking to the accessible sections.

Microsoft Excel is very accessible, and embedded Excel spreadsheets in Word are accessible.

Examples of other types of documents that may need text equivalents are PowerPoint presentations or PDFs that were created using inaccessible documents (scanned images, some publishing software). Again, if you are not sure if your document is accessible, please contact your DST representative.

“(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.”

ED.gov uses scripting languages throughout the templates. JavaScript is also used within the content sections for the navigation bubbles on office pages and program pages. The scripting languages used for the templates and the bubbles have already passed accessibility testing. If it is necessary to use any other type of scripting language on your pages, please contact your DST representative before posting the page. The page will need to go through accessibility testing.

Compliance for Standard L should be tested with a screen reader, since it may not be possible by code examination alone to verify the availability of functional text to this technology. Here too, as with tables and frame titling, the Access Board is issuing technical assistance guidance on how to construct scripts, which will yield functional text for capturing by the screen reader.

“(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).”

A link to a page that contains a list of accepted file viewers and plug-ins used by ED.gov is available on every templated page. If you do not see a link to the application you are using, please contact Shelia Hamblin to discuss whether the viewer or plug-in is acceptable and if it can be added to this page. You should know that the PowerPoint and Excel viewers are not at this time accessible and are thus unusable by screen reader users. This factor underscores the need to post materials, particularly for PowerPoint presentations, in alternate formats.

“(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.”

Most forms on ED.gov require a written signature, so they do not fall under this standard. If a form is meant to be filled out online, then it must be accessible for users who have screen readers or who use other assistive devices. If a form is meant to be printed out and filled out off line, then it falls under Section 504 (reasonable accommodation), not section 508. Although there are no formal standards governing 504 and the internet, the Accessibility Team suggests you include contact information on the page for those who need assistance in filling out the form.

“(o) A method shall be provided that permits users to skip repetitive navigation links.”

ED.gov has skip navigation on both templated and non-templated pages. This skip navigation allows users with screen readers to skip the repetitive navigation on different pages. On non-templated edlite banner pages, a skipnav is provided to skip the top navigation banner. If you have additional navigation on your non-templated pages, you need to add a skip navigation so that a user can get to the main page content if desired. Do not use "skipnav" for the anchor name, as this is the name of the anchor that skips the banner navigation.

“(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.”

General content will not require a timed response. Timed responses are not used on ED.gov.

Last Modified: 06/19/2012