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Electronic Information Resources Accessibility Policy

Chapter 1: Overview

Chapter 2: Website Accessibility and Usability

Chapter 3: Functional Performance Criteria for Websites and Applications

Chapter 4: Electronic Forms

Chapter 5: Software Applications and Electronic Information Resources

Chapter 6: Testing and Validation

Chapter 7: Multimedia, Audio, and Video Files and Products

Chapter 8: Telecommunication Products and Systems

Chapter 9: Self-Contained Products and Office Equipment

Chapter 10: Procurement and Contracts for Electronic and Information Resources

Chapter 11: Spanish Language Translation

Chapter 12: Training

 

Chapter 1: Overview

It is the policy of the Texas Facilities Commission (TFC) that all agency electronic information resources and web sites shall be accessible to individuals with disabilities and with limited English proficiency (LEP).

1.1 Purpose and Scope

The purpose of this policy manual is to align the policies of Texas Facilities Commission with DIR accessibility rules in Title 1 Texas Administrative Code Chapter 206 Subchapter B and Chapter 213 Subchapter A. The rules at 1 TAC 206 Subchapter B align Texas accessibility standards for electronic information resources and state Web sites with Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794d) (hereafter, Section 508). Requirements in this policy manual are intended to ensure accessibility for both state employees and members of the public.

1.1.1 State Employees

In the development, procurement, maintenance, and use of electronic and information technology, 1 TAC §213.17 requires state agencies to provide employees with disabilities the same access to and use of information as employees without disabilities, unless such requirement imposes a significant difficulty or expense to the agency.

State agencies shall take reasonable steps to ensure that employees with disabilities have reasonable access to perform their job duties.

1.1.2 Members of the Public

1 TAC §213A requires state agencies to provide members of the public with disabilities seeking information with access to and use of information and data that is comparable to that provided to members of the public without disabilities, unless such requirement imposes a significant difficulty or expense.

1.1.3 Individuals with Limited English Proficiency

1 TAC §206.52(2), pursuant to §2054.116 Government Code, requires that agencies make reasonable efforts to ensure that Spanish-speaking persons of limited English proficiency can meaningfully access online state agency information.

1.1.4 Electronic and Information Resources

1 TAC §213.1(5) Electronic and information resources - Includes information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term electronic and information resources includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.

All electronic and information resources addressed in this policy manual must meet the Texas accessibility standards for Electronic and Information Resources, which comply with the applicable specifications for state agencies contained in 1 TAC Subchapter B, §213.10 - §213.16 . Specific requirements for telecommunications products, multimedia content, and software are addressed in other sections of this policy manual.

See Chapter 10.2.1 for Examples of EIR

1.2 Policy Application

This policy manual applies to, but is not limited to, electronic and information resources developed, procured, maintained, or used by

  • Texas Facilities Commission directly, or
  • TFC vendors and/or service providers whose contract terms require the use of electronic and information resources. See Chapter 10.6.1 Applying Accessibility Standards.

1.3 Compliance

TFC shall ensure that electronic and information resources comply with applicable provisions described in this policy manual, unless such requirements impose a significant difficulty or expense.

In determining whether compliance imposes a significant difficulty or expense, the agency shall consider all TFC resources available to the program or program component for which the electronic and information resources are being developed, procured, maintained, or used.

1.3.1 Exception for Significant Difficulty or Expense

If the agency determines that compliance with any provision described in this policy manual imposes a significant difficulty or expense, the agency will submit the Accessibility Exception Request Form to the commission with an explanation why, and to what extent, compliance will create a significant difficulty or expense.

The agency shall focus on circumstances in which the benefit of non-compliance is relatively minor and the cost of compliance is relatively great.

TFC staff may submit requests for an exception to one or more requirements described in this policy manual, together with appropriate documentation, to the commission. The commission has the discretion to assign a designee to evaluate requests for exceptions and make recommendations; however, pursuant to Sec. 2054.460, Government Code, the final decision by the commission is binding and may not be appealed.

1.3.2 Alternative Methods of Access

When compliance imposes a significant difficulty or expense, the agency shall provide information and data through a different means of access without delay.

Alternative methods of access include, but are not limited to,

  • alternative accessible document types (e.g., PDF)
  • braille,
  • teletypewriter (TTY),
  • captioning,
  • text to speech synthesis, and
  • recorded audio.

See Chapter 10.3.4 Access by Alternative Means

1.3.3 General Exceptions

The provisions of this policy manual do not require the installation of specific accessibility-related software or the attachment of an assistive technology device at a workstation of a state employee who does not have a disability.

Captioning

For information on captioning requirements, see Chapter 7: Multimedia, Audio, and Video Files.

Agency-Owned Products

When the agency provides public access to information or data through electronic and information technology, such as web sites or information kiosks, the agency is not required to

  • make agency-owned products available to permit access to, and use by individuals with disabilities at a location other than where the electronic and information technology is provided to the public; or
  • purchase products to permit access to, and use by individuals with disabilities at a location other than where the electronic and information technology is provided to the public.

Fundamental Alterations

The provisions of this policy manual shall not be construed to require a fundamental alteration in the nature of a product or its components.

Building Maintenance and Monitoring Equipment

Equipment located in spaces frequented only by service personnel for maintenance, repair, or occasional monitoring are exempt from the requirements described in this policy manual. Examples include environmental controls or utility metering equipment.

Note: The provisions of this policy manual do not apply to products acquired by a contractor incidental to a contract, such as the contractor's computer, telephone, fax machine, and other equipment not part of the deliverables required under the contract.

1.4 Lack of Commercial Availability

The lack of commercially available of products, including computer software, and specific technologies that would impose a significant difficulty or expense on the agency is identified under "Exceptions and Emerging Technologies" in the Accessibility Section of the State Web Site Guidelines available from DIR.

Chapter 2: Website Accessibility and Usability

Effective September 1, 2006, the Texas Facilities Commission (TFC) shall develop and publish an accessibility policy, unless granted an exception by the commission. All new and/or changed Web pages shall comply with the following Texas Web Accessibility Standards (TWAS).

2.1 Texas Web Accessibility Standards

The Texas Web accessibility standards are based on federal §508 accessibility standards. Additional criteria on accommodations for Webcasts, applets, and plug-ins have been added.

2.1.1 Text Equivalents

1 TAC §206.50(1)(A)??A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

This includes, but is not limited to,

  • images,
  • graphical representations of text (including symbols),
  • animations (e.g., animated GIFs),
  • applets and programmatic objects,
  • frames,
  • scripts,
  • images used as list bullets,
  • spacers,
  • graphical buttons, and
  • video.

The equivalent information must serve the same purpose as the visual or auditory content. For example, a text equivalent for an image of an upward arrow that links to a table of contents could be "Go to table of contents."

2.1.2 Webcasts

For complete information on Webcasts, see Chapter 7: Multimedia, Audio, and Video Files.

2.1.3 Color

1 TAC §206.50(1)(C)-Web pages shall be designed so that all information conveyed with color is also available without color.

If color alone is used to convey information, people who cannot differentiate between certain colors and users with devices that have non-color or non-visual displays will not receive the information. When foreground and background colors are too close to the same color, they may not provide sufficient contrast when viewed using monochrome displays or by people with different types of color deficits.

2.1.4 Style Sheets

1 TAC §206.50(1)(D)-Documents shall be organized so they are readable without requiring an associated style sheet.

Style sheets may be used for color, indentation, and other presentational effects, such as heading color, list item indentation, or navigation element placement, but the document content must follow a logical order.

2.1.5 Image Maps

1 TAC §206.50(1)(E)-Redundant text links shall be provided for each active region of a server-side image map.
1 TAC §206.54(1)(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.

Provide separate text links outside of the server-side image map to allow access to the same image map content.

Provide appropriate descriptions for images and hot spots of client-side image maps.

2.1.6 Tables

1 TAC §206.50(1)(G)-Row and column headers shall be identified for data tables.
1 TAC §206.54(1)(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.

In data tables, such as financial tables, column and row headers must be appropriately identified. Tables used strictly for layout do not require column and row headers.

Associate tables cells with appropriate headers.

2.1.7 Frames

1 TAC §206.50(1)(I)-Frames shall be titled with text that facilitates frame identification and navigation.

Frame titles must describe the frame's purpose.

2.1.8 Screen Frequency

1 TAC §206.50(1)(J)-Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

To avoid the risk of optically-induced seizures, no elements on the Web page should flicker at a rate of 2 to 55 cycles per second.

2.1.9 Text-only Alternative

1 TAC §206.50(1)(K)-A text-only page, with equivalent information or functionality, shall be provided to make a Web site comply with the provisions of this section, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

Create a text-only version when

  • there is no other way to make the content accessible, or
  • when it offers significant advantages for persons with certain disabilities.

Text-only versions must

  • be updated at the same time as the "main" version,
  • provide equivalent navigation as the "main" version, and
  • provide an alternative to inaccessible components (e.g., scripts, plug-ins, applets)

2.1.10 Scripting Languages

1 TAC §206.50(1)(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.

Information within all scripts shall either be text-based and directly accessible to assistive technologies, or an alternative method of accessing equivalent functionality, such as a standard HTML link, shall be provided.

2.1.11 Applets, Plug-ins, Other Applications

1 TAC §206.50(1)(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 1 TAC §1194.21.

All applets, scripts, and plug-ins (including Acrobat PDF, PowerPoint, etc.) and the content within them must be accessible to assistive technologies, or an alternative means of accessing the same information must be provided.

2.1.12 Web-Based Forms

1 TAC §206.50(1)(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.

For more information and guidelines, please see Chapter 4: Forms.

2.1.13 Skip Navigation

1 TAC §206.50(1)(O)-A method shall be provided that permits users to skip repetitive navigation links.

A method shall be provided to allow for skipping over lists of navigational menus or other lengthy lists of links. Acceptable methods may include a visible link or proper heading structure.

2.1.14 Timed Response

1 TAC §206.50(1)(P)-When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

The user shall be given the ability to control the timing of content changes.

2.2 Linking and Indexing State Websites

All new or changed HTML documents on a state agency Website that meet the criteria of a "state publication," as defined by the Texas State Library and Archives Commission, shall include the meta tags required by the Texas State Library and Archives Commission (13 TAC §3.9).

The home page of a state Website shall incorporate TRAIL metadata and shall:

  • provide links to the following State of Texas resources:
    • Texas home page;
    • Texas Homeland Security Website;
    • link policy or the site policies page; and
    • Statewide Search Website.
  • provide individual links to the following information, or to the site policies page with links to the following:
    • privacy and security policy;
    • accessibility policy;
    • contact information;
    • description of the Open Records/Public Information Act policy and procedures of the state agency; and
    • Compact with Texans.
  • all key public entry points shall provide a link to the following:
    • agency home page;
    • individual links to the following, or link to the site policies page with links to the following:
      • contact information;
      • accessibility policy;
      • privacy and security policy.

Chapter 3: Functional Performance Criteria for Websites and Applications

3.1 Overview

1 TAC §206.1(2) Accessible - A Web page that can be used in a variety of ways and that does not depend on a single sense or ability.

Web sites and web-oriented applications must be accessible to all users.

3.2 Criteria to Assist Users with Visual Impairment

1 TAC §213.15(a) - At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

The Agency must provide a method for assistive technologies (e.g., screen readers, screen magnifiers, voice recognition, etc.) to access all content and functionality within the web site or application.

Assistive technologies require specific cues for document structure and navigation, such as:

  • Text descriptions for images,
  • Logical heading structure,
  • Identified column and/or row headers for data tables, and
  • Keyboard functionality

1 TAC §213.15(b) - At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

HTML presentation must use a method that allows the user to adjust the font size. Such methods should allow end users to adjust font up to a 24 point size.

It is advisable to use san serif font styles (e.g. Arial).

3.3 Criteria to Assist Users with Hearing Impairment

1 TAC §213.15(c) - At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

The agency must provide a textual description or format of audio content.

1 TAC §213.15(d) - Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

Refer to Chapter 7: Multimedia, Audio, and Video Files and Products for complete information.

3.4 Criteria to Assist Users with Speech Impairment

1 TAC §213.15(e) - At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

Keyboard or keypad functions must be provided for any speech based input.

3.5 Criteria to Assist Users with Motor Skills Impairment

1 TAC §213.15(f) - At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Provide simple keyboard functionality for:

  • navigating documents,
  • completing forms, and
  • activating application controls.

Chapter 4: Electronic Forms

4.1 Overview

1 TAC §206.50(1)(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.

Forms must be made accessible regardless of the final method of completion and submission.

4.1.1 Forms Instructions

When necessary, instructions are included within the form to meet user needs and accessibility requirements.

Detailed instructions for each form are contained in a separate document and should address:

  • purpose,
  • manual citation (if applicable),
  • procedures,
  • usage,
  • distribution, and
  • electronic and paper retention.

4.1.2 Privacy Legend

1 TAC §206.54(2)(B) - Each non-judiciary state governmental body that collects information about an individual by means of a form that the individual completes and files with the state governmental body in a paper format or in an electronic format on an Internet site shall prominently state, on the paper form and prominently post on the state governmental body's Internet site in connection with the electronic form, that:

  1. with few exceptions, the individual is entitled on request to be informed about the information that the state governmental body collects about the individual;
  2. the individual is entitled to receive and review the information; and
  3. the individual is entitled to have the state governmental body correct incorrect information about the individual.

Forms that collect confidential information must contain a privacy legend informing users of the their right to

  • upon request, be notified of information being collected about the user,
  • receive and review the information, and
  • have incorrect user information corrected.

4.2 Translation of Online Forms

1 TAC §206.52 - To facilitate the usability of state Web sites by people with limited English proficiency, in addition to English language content, the agency should consider providing the content of their Web sites in the primary language or languages used by the people using the Web site.

To ensure meaningful access, TFC must translate their vital external website program information, including forms and documents, into Spanish. Vital information from those documents should be interpreted when translations are not available for individuals who speak Spanish. If an individual can only speak Spanish and cannot read and/or write, oral communication may be more effective (See Chapter 11: Spanish Translation).

Determining if a document (or the information it solicits) is "vital" may depend upon:

  • The importance of the program, information, encounter, or service involved; and
  • The consequence to the individual with LEP if the information in question is not provided accurately or in a timely manner.

Chapter 5: Software Applications and Electronic Information Resources

5.1 Software Applications Scope

All TFC software applications developed or procured on or after September 1, 2006, must comply with the provisions of 1 TAC §213.10. TFC Contracting and Procurement staff must review the software vendor's Voluntary Product Accessibility Template (VPAT) to ensure the vendor has completed it in a manner that certifies their software application complies with state and federal accessibility standards. Staff may need to request additional product documentation and information from the vendor to confirm a product's statement of accessibility. The agency is are strongly encouraged to conduct user accessibility testing before deploying software applications or accepting the delivery of software developed internally or under a TFC contract. All Web-based applications must also comply with the requirements in Chapter 2: Web Site Accessibility and Usability.

5.2 Overview

Accessible software applications may include features specifically designed for users with disabilities. However, they must give users more than one way of accomplishing a task. They use established standards for displaying menus and prompts that can be interpreted by assistive technology. They allow users to use the mouse alone, the keyboard alone, or a combination of the two. They rely on more than color or sound to convey information. The installation instructions, user guides, and other documentation are available in alternate formats, such as large print, braille, and electronic text.

5.3 Software Applications and Operating Systems

5.3.1 Keyboard Access

1 TAC §213.10(a) - When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

Software applications cannot be solely dependant upon a mouse. Operation, instructions, and information displayed by an application must be perceivable, operable, and reportable when using assistive technologies.

5.3.2 Compatibility with Assistive Technology and Accessibility Features of Operating Systems

1 TAC §213.10(b) - Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

5.3.3 On-Screen Focus

1 TAC §213.10(c) - A well-defined on-screen indication of the current focus s