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California State University, Long BeachCalifornia State University, Long Beach

ATI Training Outline for Campus End Users

Section I

Introduction to the ATI Section 508 Compliance

CSU adopted the compliance per Coded Memorandum AA-2007-04 http://www.calstate.edu/acadaff/codedmemos/AA-2007-04.pdf

The Coded Memorandum initially adopted provides timelines to ensure access to Electronic and Information Technology (E&IT) for all individuals with disabilities. E & IT is defined in part, as “any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information.” ATI Section 508 Compliance is applicable to campus auxiliaries.

“The Americans with Disabilities Act of 1990 (ADA) and Section 504 of the Rehabilitation Act of 1973 require that qualified individuals with disabilities be provided equal access to programs, services, or activities. California Government Code 11135 applies Section 508 of the 1973 Rehabilitation Act, as amended in 1998, to State entities and to the CSU. 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 CSU policy statement on accessibility was articulated in Executive Order 926, and the tasks and timelines described herein reflect implementation steps for EO 926.”

In cases where achieving accessibility is either not possible, or where assistive technology is not available, or a general exception is applicable, an equally effective alternative access plan (EEAAP) must be developed, documented, and communicated.

Section 508 includes a set of accessibility standards for six categories of electronic and information technology (E&IT) including web applications, hardware, software, computers, telecommunications, video, multimedia, and self-contained closed products i.e. copiers, fax machines, Kiosks, etc.

Excluded Items: Anything whose principle function is not information, Examples: Microwave ovens, thermostats, and medical equipment, even if they are electronic.

How it affects CSULB

The CSU is required to purchase E&IT products and services that conform to the standards established for each category of covered items per Executive Order 926. As such the campus must evaluate accessibility standards for E&IT products and services it buys, creates, uses, and maintains.

Section II

ATI Section 508 Standard Subparts A, B, C, & D:

Subpart A: General

Subpart A explains what is exempt (1194.3), defines terms (1194.4), and generally recognizes alternatives to what is required that provide equal or greater access (1194.5).

Subpart B: Technical categories of standards (May require more than one)

  1. Software and operating systems, Standard 1194.21, i.e. Adobe, Windows XP
  2. Web-based internet and intranet information & applications, Standard 1194.22
  3. Telecommunication products, Standard 1194.23 (phone and voice mail systems)
  4. Video and multimedia products, Standard 1194.24 (videos, TV tuners and displays)
  5. Self-contained, closed products, Standard 1194.25 (printers, fax machines and kiosk)
  6. Desktop and portable computers, Standard 1194.26 (Dell and Hewlett Packard)

Subpart C: Functional performance criteria, Standard 1194.31

Completion by manufacturer/vendor is always required. Products must provide at least one mode of operation and information retrieval for users with visual, mobility, hearing and speech issues.

Subpart D: Information, documentation, and support documentation, Standard 1194.41

Completion by vendor always required. Products documentation must be accessible in alternate ways for disabled to receive information regarding the product such as manuals, and braille at no charge. Documentation must include information about accessibility features such as support services and call centers, chat on line.

Section III

Voluntary Product Accessibility Template (VPAT) Guide, Appendix C

  1. What is a VPAT?
    A form developed for manufacturers to show how well their products comply with the 508. (Snapshot of a VPAT to be provided)
  2. Who is responsible for submitting a VPAT?
    End- user should obtain form from vendor/manufacturer or previously obtained CSU source.
  3. How to find existing VPAT’s on a vendor’s website.
    In the Search box of a manufacturer/vendor website try the following:
    • VPAT – Voluntary Product Accessibility Template
    • 508 Standard/Compliance
    • Disabled/Accessibility
  4. Finding VPATS:
    • CSU Sources (other campuses who have purchased the same item)
    • Vendors or manufacturers (send the vendor or manufacturer Appendix C VPAT Guide with form attached)
    • Websites for manufacturers have a Section 508 Accessibility Section (Hewlett Packard, Apple, Microsoft etc.)
    • Web searches using buzz words such as “accessibility”, “Section 508”, “VPAT”, etc.
    • Contact Purchasing when a vendor will not submit the VPAT or you cannot find one.
    • Public Sector Sources (GSA: Accessibility Research Center ( http://buyaccessible.net/VARC/ )
  5. What to do when a vendor stonewalls and does not submit a VPAT
    • Contact buyer and determine course of action.

Section IV

Market Research: (Analysis to be completed by Purchasing)

  1. Products that meet the functional requirements and are 508 compliant
  2. If one product meets more of the 508 standards than others
  3. Products previously purchased and still are compliant/conformant i.e. desktop computer contracts.
  4. When only one product meets functional specifications (sole source) http://daf.csulb.edu/forms/financial/purchasing/sole_source_brand.pdf
  5. Helpful websites for market research ( http://buyaccessible.net/VARC/ )

Section V

General Exceptions (Purchasing will review for approval)

  1. Back Office (users do not interact with the product – maintenance workers only, in special locations – example computer servers)
  2. Commercial Non-Availability of Conformant Product
  3. Fundamental Alteration (making it accessible would change it too much)
  4. Undue Burden (The ADA does not require businesses to furnish any communication aids or services that place an undue burden on the business. An undue burden is defined as "significant difficulty or expense." It is evaluated on a case-by-case basis, relative to the business’s overall resources.

    When supplying a particular communication aid or service would cause an undue burden, a business must provide another communication aid or service that still is effective but is less difficult or costly, if one is available.

    Example of Undue Burden: The cost to hire a deaf interpreter to assist in guiding tours of a small college may be prohibitive but they can offer a handheld device that gives written directions and narratives.

Section VI

Product Evaluation

  1. When to test a product. (Products are tested when compatibility with assistive technology is desired or when a VPAT cannot be acquired.)
  2. When to incorporate assistive technology. (When the product is not accessible to the person it was meant for)
  3. When to incorporate an EEAAP (Equally Effective Alternative Access Plan. (When product fails to comply but is essential)

Section VII

ATI Section 508 Electronic & Information Technology Product Checklist

  1. Simple tool to manage 508 in the procurement process
  2. Provides detail information regarding the information technology product(s)
  3. Allows Purchasing to evaluate the risk to the campus and provide approvals for procurement card purchases if applicable.

Section VIII

Impact to the University

The new standard is not based on dollar threshold but impact (risk) to the University.

  1. What are the criteria for evaluating impact?
    • How many users will be affected
      • One user only
      • Staff or Faculty only
      • Students, Staff, Faculty and the public at large
    • Product is not compliant
      • Product fits into an exemption category
      • Product requires an EEAAP

Section IX

Roles and Responsibilities

  1. Requestor is expected to:
    • Find products/services that are compliant
    • Determine which technical standard applies to the requested product/service. See Checklist, Section II. (Note: Sections 1194.31 & Section 1194.41 always apply unless Back Office)
    • Complete Checklist, ATI Section 508 Electronic & Information Product Checklist on Purchasing website, and turn into Purchasing before preparing a requisition. (Low impact purchases within the procurement card dollar threshold may be approved by Purchasing in place of doing a purchase order.)
    • Obtain VPAT form from vendor
    • Submit Requisition, VPAT, and Checklist to Purchasing Department.
  2. Purchasing is Expected to:
    • Perform Market Research
    • Assess for Low or High impact acquisition
    • Authorized Procurement Credit Card Purchase
    • Grant or Approve General Exceptions

Section X

CSU Resources

When to contact Purchasing Department:

  • When a product is new/first time acquisition
  • Donations/Gifts that include I.T. listed on this form
  • No VPAT exists
  • Questions should be directed to the purchasing contacts listed below.

Purchasing Contact

Purchasing
(562) 985-5797
purchasing@csulb.edu

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