2006 Conference General Sessions




Bruce Bailey
ED OCIO ITOMS Assistive Technology Program
400 Maryland Avenue SW, FB6 BC1O1
Washington, DC 20202
Day Phone: 202—377—4932
Fax: 202—401—8469
Email: bruce.bailey@ed.gov

Presenter #2
Don Barrett
ED OCIO ITOMS Assistive Technology Program

400 Maryland Avenue SW, FD6 BC1O1
Washington, DC 20202
Day Phone: 202—377—4079
Fax: 202—401—8469
Email: dcn.barrett@ed.gov

Follows is one analytical response to the above summary quandary, hut that was only the beginning. This session will present ED’s process and internal dialog with trying to apply the 508 Accessibility Standards to Flash in actual practice.

Flash objects are web applications so use the full §1194.22 criteria, including 1194.22(m). As written, 1194.22(m) invokes the criteria §1194.21(a) through (1) for each instance of Flash content.

Taken at plain face value, Flash falls into the category of internet information and applications” (1194.22). Many of applicable (e.g., style sheets, image maps) but several are
text equivalents, multimedia).

One concern with sufficiently complex Flash content is there may be controls or other
elements that are not explicitly addressed, but that is only the case if §1194.22(m) is assumed not to be applicable. Such an assumption would be a mistake. This error may be caused by too literal interpretation, a lack of understanding, or applying a too contemporary definition or artificial segmentation to the terms involved and the phrase used: “applet, plug—in, or other application.”


At the time the Section 508 E&IT Accessibility Standard were. developed, and the W3C WAI Web Content Accessibility Guidelines )WCAG1) before that, there was not the clear distinction between web applets, plug-in, and applications that some people feel now. The use of the whole phrase, and not the atomic individual terms, was deliberate and meant to address the (then) current and (now) future technologies.

Two examples illustrate the above fact: (1) Macromedia Shockwave and Flash were known technologies at least as early as 1998 and were explicitly considered and intended to fall into the category of web applets, plug—in, and applications. (2) Java at the time, and even now under some circumstances, requires that a plug—in be preloaded. This is exactly the same situation as with modern instances of Flash and there is no confusion that Java is covered by §1194.22)m).

Some Flash content is fairly trivial) essentially being just a movie or animation) and a review against the criteria associate with §1194.22(m) will be very quick and easy. In these circumstances, accessibility is ensured by the other 1194.22 criteria.

Often, a Flash object is the only significant content on a particular web page. As a reminder, all web content on every page, including html containing a Flash object (and not just the Flash object alone), must be reviewed against the §1194.22 standards.

The Subpart C Functional Performance Criteria are meant for technologies or components for which there is no specific provision in Subpart B Technical Standards. The Functional Performance Criteria are wholly compatible with the Technical Standards and may he helpful to consider as a double check. This step is not necessary for Flash, nor for other technologies or components for which there is a specific provision.

The response to this question is intended to promote a better understanding of the requirements of Section 508 and its implementing regulations. This clarification is purely informational and neither creates new policies nor changes existing policies.

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