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270 FW 4
Making Electronic and Information Technology Accessible

Supersedes Director’s Order 185, 09/29/2005

Date: September 28, 2011

Series: Information Resources Management

Part 270: IT Program Management

Originating Office: Division of Information Resources and Technology Management



PDF Version


4.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service (Service) policy for planning for and managing technology accessibility for individuals with disabilities.


4.2 What are the goals for accessibility? Our goals are to:


A. Manage technology using industry best practices;


B. Comply with applicable Service, Department, and Federal standards, policies, and regulations for ensuring accessibility; and


C. Improve productivity, efficiency, and effectiveness of our programs by eliminating barriers to electronic and information technology. 


4.3 What is Section 508?


A. In 1998, Congress amended the Rehabilitation Act of 1973 with Section 508, to require Federal agencies to make their electronic and information technology accessible to individuals with disabilities. The goal was to eliminate barriers to electronic and information technology, to make available new opportunities for individuals with disabilities, and to encourage development of technologies that will help achieve these goals.


B. When we develop, procure, maintain, or use electronic and information technology, employees with disabilities must have access to and use of information and data that is comparable to what employees without disabilities have, unless an undue burden would be imposed on the Service.


C. Section 508 also requires that members of the public with disabilities who are seeking information or services from us have comparable access to and use of information as an individual without disabilities, unless an undue burden would be imposed on the Service.


D. In the case of an undue burden, we must provide individuals with disabilities with the information and data involved by an alternative means of access that allows the individual to use the information and data.


4.4 What is the Service’s policy? It is our policy to follow the procurement practices and standards described in sections 4.7 and 4.8 and on the General Services Administration (GSA) Section 508 Web site.


4.5 What are the authorities for this chapter?


A. Section 508 of the Rehabilitation Act (29 U.S.C. 794d), as amended by the Workforce Investment Act of 1998 (P.L. 105-220).


B. 21st Century Communications and Video Accessibility Act of 2010 (P.L. 111-260).


C. Americans with Disabilities Act of 1990 (ADA), as amended by the ADA Amendments Act of 2008 (P.L. 110-325).


4.6 Who is responsible for Section 508? Table 4-1 describes our responsibilities for implementing the Section 508 program.


Table 4-1: Responsibilities for implementing the Section 508 program

These employees…

Are responsible for…

A. The Director

(1) Approving or declining to approve this policy, and


(2) Ensuring we have a program in place for implementing Section 508 requirements.

B. Regional Directors and Assistant Directors

Ensuring that the programs in their areas of responsibility follow the requirements of this policy.

C. The Assistant Director – Information Resources and Technology Management (IRTM)


(1) Developing this policy and keeping it up-to-date, and


(2) Working with program offices and Regions to ensure they are complying with this policy.


D. The Chief, Office of Diversity and Inclusive Workforce Management

Working with IRTM to ensure we are complying with this policy.

E. The Chief, Division of Contracting and Facilities Management and Regional Chiefs, Divisions of Contracting and General Services

Ensuring that contracting officers and other procurement staff understand Section 508 requirements so they incorporate those requirements into contracting and procurement requests.

F. The Assistant Director – External Affairs, through the National Web Manager

(1) Working with Web managers from the Regions and programs to ensure our web content is 508 compliant, and


(2) Assisting with employee training on strategies and best practices for accessible Web design.


4.7 What are the procurement practices the Service must use to ensure Section 508 compliance?


A. Procurement and other approving officials must consider Section 508 standards when developing or reviewing procurement requests for electronic and information technology and services, while doing research on vendors, and when developing requirements. Vendor solicitations must address compliance.


B. The GSA has assessment criteria for evaluating Section 508 compliance. The “Buy Accessible Wizard” on GSA’s Web site is available for officials when conducting and reviewing acquisitions that are subject to Section 508.


C. Solicitations for electronic and information technology and services must clearly state compliance with Section 508.


4.8 What are the Section 508 standards? GSA’s standards for accessibility are available on their Web site. Table 4-2 provides examples of a few of the standards by category. Visit the GSA Web site for detailed information.


Table 4-2: Examples of Section 508 Standards



Examples of Standards (not all-inclusive)

Software applications and operating systems

Most of these standards are related to usability for people with vision impairments.

·     Alternative keyboard navigation for people who can’t rely on a mouse.

·     Color and contrast settings must not override the user’s settings to allow for readability.

·     Electronic forms must allow people using assistive technology to access the information, field elements, and functionality required to complete and submit the form.

Web-based Internet and Intranet information

Many of these standards ensure access for people with vision impairments who rely on assistive products (e.g., screen readers) to access computer-based information.

·     Must provide a text alternative for every non-text element (e.g., graphic).

·     Web pages designed with information that relies solely on color must also be available without color.

·     If you cannot comply with the standards in any other way, we must provide a text-only page, with equivalent information or functionality and update that page whenever the Web information changes.


These standards are designed primarily to ensure access to people who are deaf or hard of hearing. This includes compatibility with hearing aids, cochlear implants, assistive listening devices, text telephones (TTYs), and video phones.

·    Telecommunications products that allow voice communication recognition and do not have TTY functionality must provide a non-acoustic connection point for TTYs.

·    Voice mail and voice response systems must be usable by people using TTYs.

·    Caller identification and other telecommunication functions must be useable both by people using TTYs and people who cannot see displays.


Video and multimedia products

These standards address both audio and video

·    All training and informational video and multimedia productions that support our

mission and that contain speech or other audio information necessary to understand the content, must be open or closed captioned.

·   Television tuners, including tuner cards for use in computers, must be equipped with secondary audio program playback circuitry.

·   All television displays 13 inches and larger, and computer equipment that includes television receiver or display circuitry, must be equipped with caption decoder circuitry that receives, decodes, and displays closed captions.


Self-contained, closed products

These are for products that have imbedded software but are often designed in such a way that a user cannot easily attach or install assistive technology (e.g., information kiosks, copiers, printers, calculators, fax machines)

·   Must be useable without requiring the user to attach assistive technology.

·   When a timed response is required, the product must have a way of alerting the user and giving them an option to request more time.

·   Color coding must not be used as the only way to convey information.

Desktop and portable computers

These standards focus on keyboards and other mechanically operated controls

·   Controls and keys must be tactilely discernable without activating them.

·   Controls and keys must be operable with one hand.

·   The status of all locking or toggle controls or keys must be visually discernible, and discernible either through touch or sound.


4.9 What resources are available to learn more about Section 508? The best place to go to begin to understand and comply with Section 508 requirements is GSA’s Section 508 Web site. It provides detailed standards, performance criteria, information on training, and additional resources.


For information on the content of this chapter, contact the Division of Information Resources and Technology Management. For information about this Web site, contact Krista Bibb in the Division of Policy and Directives Management.  

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