GSA Government-wide Section 508 Accessibility Program

Interconnected Systems – How Does Section 508 Apply?

Tue, 07/07/2015 - 13:11 -- BuyAccessible Team

A recent question gives us some general guidance when asking a key question: “Is this ICT subject to Section 508?” Though this particular question was posed for a specific product, the guidance applies generally to any component that is part of an interconnected system but doesn't itself directly present a user interface.

We all know about those cameras typically used for surveillance monitoring. They seem to be everywhere, recording everything – especially at federal government facilities! So are they subject to Section 508 requirements?

Let’s think:

  • It seems to meet the definition of electronic and information technology found at “1194.4 Definitions” in the Section 508 Standard.
  • It is certainly an item being procured by federal agencies, thus by “1194.2 Application” the standards seem to apply.
  • It has been established that a hand-held digital camera is ICT subject to Section 508. Users need to be able to feel the buttons, and it probably uses a cord that requires a standard connector.
  • But the interface or controls for this surveillance camera are operated indirectly, typically controlled automatically or remotely through a separate computer interface.

However:

  • The surveillance camera is a part of an “interconnected system” that together includes software used for transmitting image data to a computer, otherwise working on the image file, or configuring the camera itself and a computer/monitor that is the actual point of user interface.
  • So the camera purchased alone is technically covered by Section 508, but there aren’t any standards that apply to it since users do not interact with it directly.
  • Associated software functionality and the user interface it presents would be covered (e.g. 1194.21, 1194.22. 1194.23(j)), as well as the computer/monitor that is the actual point of user interface (e.g. 1194.26).

Conclusions:

  • Section 508 standards primarily address user interfaces. Therefore a microchip or a circuit board is considered ICT, but there are no standards that apply to them. So you can’t violate 508 when buying them and they don’t need to go through an extensive 508 clearance process.
  • Just because a device transmits to a computer does not make it ICT subject to Section 508. Devices that are part of an “interconnected system” but not part of the user interface don’t require the same procurement due diligence that is required of user interface elements.