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Upcoming Change applicable to all Purchase Cardholders
Beginning April 1, 2005, all Agency Purchase cardholders will be required to insure the acquisition of computers, software, fax machines and other items considered to be Electronic & Information Technology (E&IT) are 508 compliant.
This is an overview of cardholder responsibilities regarding documenting compliance with the 508 requirements on order logs/transactions. Please take a moment to read it. Please start documenting your order logs for E&IT as instructed in preparation of the April 1, 2005 deadline.
What is Section 508?
In 1998, Congress amended the Rehabilitation Act to require Federal agencies to make their (E&IT) accessible to people with disabilities. Inaccessible technology interferes with an individual's ability to obtain and use information quickly and easily. Section 508 was enacted to eliminate barriers in information technology, to make available new opportunities for people with disabilities, and to encourage development of technologies that will help achieve these goals. The law applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology. Under Section 508, agencies must give disabled employees and members of the public access to information that is comparable to the access available to others.
The Scope
E&IT includes information technology and equipment or interconnected system or subsystem of equipment that is used to create, convert, or duplicate data or information. E&IT also includes, but is not limited to:
- Software applications and operating systems
- Web-based information or applications
- Telecommunication products
- Video and multimedia products
- Self-contained, closed products, such as information kiosks, calculators, and fax machines
- Desktop and portable computers
What does this mean to me the cardholder or approving official?
The cardholder must ensure that any EIT supplies and services purchased meets applicable accessibility standards defined in the Architectural and Transportation Barriers Compliance Board Electronic and Information Technology (EIT) Accessibility Standards (36
CFR 1194). When acquiring commercial items, cardholders must comply with those accessibility standards that can be met with the supplies and/or services that are available in the commercial market place in time to meet delivery requirements. Approving Officials must ensure that the purchase card holders are complying with the accessibility standards in the acquisition of any EIT.
What are the Steps for Cardholders?
- Do I have an E&IT requirement?
- Which of the Access Board Standards apply? For assistance see: http://www.access-board.gov/sec508/guide/index.htm
- Conduct market research – call vendors, visit vendor Internet sites, other government agencies, etc.
- Is there a 508 compliant product available in the commercial market place?
- Commercial item and none or some (but not all) of the access board standards can be met in time to satisfy requirements?
- Obtain technical assistance of Center 508 coordinators when necessary
- Acquire 508 compliant commercially available goods/services as appropriate
- Document in the comments section of your order log and/or other files the sources contacted and whether E&IT acquired items are 508 compliant or whether market research indicates that no 508 compliant (or only partially compliant) products or services are commercially available in time to meet your delivery requirements. Keep copies of all documentation with your purchase card records.
How do I determine if a product is 508 compliant?
After determining which of the above mentioned standards apply to your order (i.e., if you are purchasing a facsimile machine, then the self contained, closed products standard would apply). The accessibility wizard found at http://www.buyaccessible.gov/ (left side of the page) may be used to determine which accessibility standards must be met. At http://www.itic.org/archives/articles/20040506/faq_voluntary_product_accessibility_templatetm_vpattm.php you will find a table that will assist you with determining which of the standards apply to commonly acquired E&IT. Then conduct market research to determine if the required product or service is available in the commercial market place. (This may be done by phone, over the Internet, reviewing vendor literature or other means).
Some useful tools are:
- GSA’s “Buy Accessible” link found at http://www.section508.gov/ to locate a specific product or service type and obtain a list of links to vendors that provide Section 508 compliant products/services. To use the site, on the left hand side of the screen type in the generic name of the product/service you are intending to purchase (i.e., facsimile); then click the radio button “buy accessible products”; and then hit the “search” bar. A list of compliant products will appear. You may click on the specific product that meets your needs, which will bring you to a list and link to vendors who supply those products. You do not need to provide a log in or user ID to use this cite. Please note that not all products contained on the site are 100% accessible. It is up to the cardholder to insure accessibility.
- The link to Advanced Search is currently under construction (located on the left-hand side of the page under Additional Links throughout the Section 508 website). When completed, you will be taken to a page that will provide three ways you can tailor your search for accessible products:
a.) Search for products by company
b.) By existence of a Voluntary Product Accessibility Template (VPAT)
c.) By product group
- The best way to determine whether a particular product is Section 508 compliant is to have the vendor provide documentation to indicate whether it satisfies all or some of the technical provisions of the Section 508 Access Board standard. Over time, more and
more products and services will become compliant.
- The Information Technology Industry (ITI) Council, a partnership between government and industry, hosts a Voluntary Product Accessibility Template (VPAT) on their site. It allows vendors who choose to participate, the ability to copy the template and complete it to describe how a particular product or service they offer conforms to Section 508 Access Board Standards. This template would be placed on the vendor’s accessible web site, and the link to the template provided to the Buy Accessible data base. If there is no VPAT on your vendor’s site, then it is suggested that you send a copy of the VPAT found at http://www.access-star.org/ITI-VPAT-v1.2.html for the specific product you are purchasing to the vendor’s Government sales person to complete. The document should be retained with your order log.
- Your purchases must comply with those applicable technical standards that can be met with supplies or services that are available in the commercial marketplace in time to meet the agency's delivery requirements. If you cannot find a commercial item that both meets applicable Access Board's technical standards and can be furnished in time to satisfy your delivery requirements – you should acquire the most conforming product that meets your overall needs. If no conforming or partially conforming products are found, then document that a conforming commercially available item is not available.
Are there exceptions to 508 compliance?
Yes, there a limited number of exceptions. However, items/services acquired with the purchase card should be for commercially available items, the exceptions will rarely if ever be appropriate. In addition, agencies are not required to fundamentally alter their needs in order comply with section 508.
Are there consequences if I don’t buy compliant products?
Yes – persons with disabilities can file administrative complaints or bring civil actions in Federal court against the agency. Court orders compelling compliance can also be issued.
What documentation is required on my Order Log?
As a minimum, you must indicate that the product or service is E&IT and identify the sources that you contacted to find commercially available accessible products, i.e. commercial vendors, internet market research, contacts with other federal agencies, etc. The file must also indicate that the goods or services:
a.) Are E&IT and either
b.) meet the applicable accessibility standards, or
c.) is for a commercial item (or service) and that some or all of the applicable Access Board standards cannot be met in time to satisfy the delivery requirements
Help Desk
The purpose of the Help Desk is to provide NASA personnel and contractors (e.g., Engineers, Software/Web Developers, Procurement Officers) with a facility to request information and assistance in complying with Section 508 of the Rehabilitation Act. The Help Desk is available via email to provide information and research regarding Section 508 compliance requirements and to coordinate requests for 508 compliance reviews.
The Help Desk is not intended to replace the market research and similar activity required by NASA policies nor is it intended to replace Center resources, but to assist Centers in areas in which they are having difficulty complying with Section 508 requirements. The E-mail address is Section508Help@hq.nasa.gov
For specific technical inquiries, the Center 508 Coordinators may be contacted. A list of Center 508 Coordinators is located at: http://www.section508.nasa.gov/coordinators.htm. |
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