What is Section 508?
Section 508 is part of the 1998 amendment to the U.S. Rehabilitation Act of 1973. It requires all federal information and communication technology (ICT) to be accessible to people with disabilities.
This applies regardless of whether these individuals work for the federal government. This section prohibits discrimination based on disability in federal programs, programs receiving federal aid, or employment.
It obligates federal agencies to provide employees and the public with disabilities access to information comparable to that available to others. The section establishes requirements for ICT that is developed, maintained, procured, or used by the federal government and its agencies.
It applies to all federal organizations when they develop, procure, maintain, or use electronic and information technology (EIT). The updated Section 508 accessibility standards include specific scoping and technical requirements for ICT.
These requirements ensure accessibility and usability for people with disabilities.
What is a VPAT?
A VPAT, or Voluntary Product Accessibility Template, is a standardized document completed by a manufacturer or vendor of an ICT product or service. It illustrates the degree to which the product or service conforms to established accessibility standards.
The Information Technology Industry Council (ITI) created the VPAT in partnership with the General Services Administration (GSA) in 2001. This initiative aimed to strengthen compliance with accessibility requirements and provide a basis for matching ICT product features to these standards.
VPAT Editions
The VPAT is available in four distinct editions:
- The VPAT WCAG (Web Content Accessibility Guidelines): WCAG 2.1 or ISO/IEC 40500
- The Section 508 VPAT
- The European Union (EU) VPAT
- The VPAT International (INT)
The VPAT WCAG focuses on web content accessibility for people with disabilities and older individuals whose abilities may change with age. These WCAG standards provide a common definition and benchmark for accessible digital content.
The Section 508 VPAT details how information technology (IT) products and services comply with the revised Section 508 accessibility standards. It considers conditions where adhering to these standards might place an unreasonable strain on an organization.
Alternative Formats and Methods
Alternate formats for information may include, but are not limited to, Braille, American Standard Code for Information Interchange (ASCII) text, large print, recorded audio, and various electronic formats.
Alternate methods involve different ways of providing information, such as product documentation, to individuals with disabilities. These methods can include voice, fax, relay service, TTY, internet posting, captioning, Braille, text-to-speech synthesis, and audio description.
A significant advantage of the VPAT Section 508 document is that it circumvents the need to decode the technical requirements specified in the Section 508 Accessibility Standards. The ITI has already deciphered these standards and itemized the Section 508 accessibility requirements within the 508 VPAT itself.
Furthermore, the Section 508 VPAT incorporates the WCAG requirements for making web content accessible. This means that if an ICT product or service includes both hardware and digital content, a single Section 508 VPAT allows for documenting the accessibility of both in one comprehensive report, eliminating the need for separate Section 508 ACR and WCAG VPAT ACRs.
The EU VPAT is specifically designed for documenting the accessibility of ICT products and services intended for public procurement in Europe. Similarly, the VPAT INT is used for products and services publicly procurable on an international scale.
Both the VPAT INT and the EU VPAT include accessibility criteria and technical specifications for digital content, aligning with those provided in the VPAT WCAG. Notably, the VPAT-INT encompasses all the accessibility criteria and technical specifications found across the other three accessibility standards.
Who needs a Section 508 VPAT?
All organizations directly or indirectly governed by Section 508 are required to complete or update a VPAT. This includes all U.S. federal agencies and any government agency receiving federal aid.
Any private company working as a contractor for a U.S. federal agency also needs a Section 508 VPAT. Since these agencies must procure accessible EIT, manufacturers or vendors wishing to sell their ICT products or services to them must provide a current VPAT.
Creating or updating a Section 508 VPAT ACR
Whether you represent a small or micro-enterprise (SME) or a large corporation, your ICT products or services must be VPAT compliant to be considered in procurement processes by federal organizations and entities receiving federal funding.
To create or update your VPAT ACR, follow these steps:
- Download the appropriate edition of the VPAT from the ITI website.
- Identify which sections of the Technical Standards apply to your product or service. Note that multiple sets of Technical Standards may apply, so review the entire VPAT document carefully.
- Analyze each relevant section of the VPAT to determine if your product or service meets the specified criteria.
- Select the conformance level that best describes your product or service from the five categories: "supported," "partially supported," "not supported," "not applicable," and "not evaluated."
- Provide detailed explanations of how your product or service complies with or fails to comply with the relevant accessibility requirements.
- Go back to the VPAT document’s Summary Table and document the overall level of compliance for your product or service in each applicable section.
- Ensure every line and column in the VPAT’s table section is filled out completely.
- Confirm that the Remarks and Evaluation column includes detailed explanations supporting the accuracy of your answers.
- Thoroughly check the completed VPAT ACR to ensure every fillable part is completed and accurate.
Once you've ensured the document is complete and free of mistakes, you can publish the VPAT ACR on your company’s website or provide an accessible link for interested parties to review.
Need help with creating or updating your Section 508 VPAT?
You can learn to create or update your VPAT ACR by reviewing a Section 508 VPAT example. Alternatively, you can call (626) 486-2201 to schedule an appointment with our VPAT accessibility experts, who are ready to provide the assistance you need. Our consultations are always free of charge!