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Section 508 Compliance Policy and Procedure for Office of Spill Prevention and Response Spill Response Web site
 
BACKGROUND:    
 
California adopted the Federal Rehabilitation Act of 1973, as amended in 1998, Section 508 and referenced it by California Government Code 11135. This code ensures access by individuals with disabilities to all electronic media created or used by the state (applications, Web pages, etc.) in a format comparable to that of individuals without disability.
 
There are NO exceptions or waivers from the requirement for emergency operations beyond those provided in the code.
 
All State offices must meet this standard when posting any information to the Internet or Intranet.
 
DISCUSSION AND ANALYSIS:
 
The Office of Spill Prevention and Response (OSPR) meets this standard with its Web pages, and most of its emergency documents, especially those generated by OSPR itself. This specific issue and subsequent policy and procedure address the documents created by outside third parties not contracted directly to the State or Federal government during a spill event (incident management organizations hired by the responsible party).
 
Often the documents (incident action plans, other ICS forms, and materials) provided by the contractor do not comply with Section 508. If OSPR posts the documents to the Web, OSPR must make them compliant regardless of the situation or staffing. All documents must be immediately accessible upon posting. The code does not provide for any time delay or postponement of compliance. OSPR may argue that Section 508 compliance places an “undue burden” upon onsite responders who have duties and obligations to the actual spill response for public safety and environmental protection which must supersede document formatting. The three conditions for undue burden are:
 
1.            The difficulty or expense of compliance based on the overall funds available to the agency;
2.            The agency resources available for which the supply or service is being acquired; and 
3.            The extent to which allocating resources to Section 508 compliance would interfere with the agency’s ability to carry out its other statutorily mandated responsibilities.
 
However, were OSPR to satisfactorily argue that condition three is met, this fact would not defer OSPR’s responsibility to provide accessible information. OSPR must demonstrate due diligence in its effort to provide accessible documents on its Oil Spill Incidence page during the emergency response.
 
RECOMMENDATION:
 
To address OSPR’s 508 compliance obligations and the undue burden it places upon emergency responders in the field, the following policy may serve as documentation of OSPR’s “due diligence” to overcome these obstacles and issues in an effort to achieve compliance.
 
SECTION 508 COMPLIANCE POLICY AND PROCEDURE
FOR THIRD PARTY DOCUMENT POSTING
DURING EMERGENCY RESPONSE INCIDENTS
 
Compliance Achievement Step 1
 
If the responsible party hires an incident management contractor, OSPR responders will ask that the contractor provide an electronic form of the documents created that has the text and information embedded. A PDF form document alone is not compliant if the document is “flat” meaning the document doesn’t have the necessary information needed to be read by narrative software or other devices. It appears just as a photograph or JPG, TIF or similar image does – the text cannot be copied nor can the document be saved into an alternative format (rich text format, text format, etc.)
 
OSPR conducted an industry survey and identified the most commonly used incident management software programs were IAP and Command Pro. The manufacturers of these products indicated that a text document was achievable by doing the following:
 
1.      IAP – printing to a PDF using Acrobat driver. This requires having Adobe Acrobat on the computer. The document can then be saved into text format or tagged as appropriate through the Adobe Acrobat Program. The document should be opened. If it has the text embedded, it can be saved as rich text, Microsoft Word etc. If the text cannot be recognized, responders must use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the PDF document to text. The optical character recognition feature reads the text and creates as a sub layer to the document (leaving the document’s original structure still viewable).
 
2.      Command Pro – printing to a PDF using Acrobat driver. This requires having Adobe Acrobat on the computer. The document can then be saved into text format or tagged as appropriate through the Adobe Acrobat Program. The document should be opened. If it has the text embedded, it can be saved as rich text, Microsoft Word, etc. If the text cannot be recognized, responders will use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the PDF document to text. The optical character recognition feature reads the text and creates as a sub layer to the document (leaving the document’s original structure still viewable).
 
If OSPR receives a version that is accessible then it will post that document (or the original document and the text conversion) to achieve compliance. If this step can be taken, then no document from the contractor will be published until it is compliant.  Effort to achieve compliance in this fashion from the source document must always occur first, before moving to the next steps.
 
Compliance Achievement Step 2
 
In the event OSPR cannot secure a 508 compliant version of the documents from the third party contractor, responders will use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the scanned document into text. The optical character recognition feature reads the text, and it creates as a sub layer to the document. The image of document stays intact but can now be read by accessibility software. It also straightens the document should it appear crooked. Images in the document will still need to be “tagged” with text to describe what is there.
 
Once the text is captured, OSPR will post the compliant page to its Web site. If this step can be taken, then no document from the contractor will be published until it is compliant.
 
Compliance Achievement Step 3
 
Should OSPR be unable to achieve compliance through either of the first two steps, OSPR will take the following steps to get the document the public and achieve compliance.  
 
1.      OSPR will post the original document and place ALT text with the document link that indicates a compliant version is not available at the time of the first posting. The text will further provide a phone number the individual may call to request the information (someone to read the document, etc). OSPR must make the commitment to staff that phone line during the entire time the document is being converted to compliant form.
 
2.      Immediately upon the posting of the document to the OSPR spill page, the Operations Center in Sacramento will designate an individual to reproduce the information contained in the document in a compliant format through whatever means is available (optical scanner, retyping, etc.).
 
3.      Due diligence will be made to provide the document in accessible form within two hours of its original posting.
 
4.      Once the accessible document is posted, the ALT text and alternative contact information may be removed, and the individual staffing the phone may stand down.
 
All other documents generated by OSPR or its contractors will be created and posted in accessible form. The steps included in this procedure apply ONLY to documents provided to OSPR from third parties not under direct state authority.
 
 
 
IMPLEMENTATION:
 
By adoption of this policy and procedure, OSPR Executive demonstrates its commitment to Section 508 compliance, and it outlines a procedure that will achieve compliance with as minimal an impact as possible upon field staff responding to spill emergency.
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Section 508 Compliance Policy and Procedure for Office of Spill Prevention and Response Spill Response Web site
 
BACKGROUND:    
 
California adopted the Federal Rehabilitation Act of 1973, as amended in 1998, Section 508 and referenced it by California Government Code 11135. This code ensures access by individuals with disabilities to all electronic media created or used by the state (applications, Web pages, etc.) in a format comparable to that of individuals without disability.
 
There are NO exceptions or waivers from the requirement for emergency operations beyond those provided in the code.
 
All State offices must meet this standard when posting any information to the Internet or Intranet.
 
DISCUSSION AND ANALYSIS:
 
The Office of Spill Prevention and Response (OSPR) meets this standard with its Web pages, and most of its emergency documents, especially those generated by OSPR itself. This specific issue and subsequent policy and procedure address the documents created by outside third parties not contracted directly to the State or Federal government during a spill event (incident management organizations hired by the responsible party).
 
Often the documents (incident action plans, other ICS forms, and materials) provided by the contractor do not comply with Section 508. If OSPR posts the documents to the Web, OSPR must make them compliant regardless of the situation or staffing. All documents must be immediately accessible upon posting. The code does not provide for any time delay or postponement of compliance. OSPR may argue that Section 508 compliance places an “undue burden” upon onsite responders who have duties and obligations to the actual spill response for public safety and environmental protection which must supersede document formatting. The three conditions for undue burden are:
 
1.            The difficulty or expense of compliance based on the overall funds available to the agency;
2.            The agency resources available for which the supply or service is being acquired; and 
3.            The extent to which allocating resources to Section 508 compliance would interfere with the agency’s ability to carry out its other statutorily mandated responsibilities.
 
However, were OSPR to satisfactorily argue that condition three is met, this fact would not defer OSPR’s responsibility to provide accessible information. OSPR must demonstrate due diligence in its effort to provide accessible documents on its Oil Spill Incidence page during the emergency response.
 
RECOMMENDATION:
 
To address OSPR’s 508 compliance obligations and the undue burden it places upon emergency responders in the field, the following policy may serve as documentation of OSPR’s “due diligence” to overcome these obstacles and issues in an effort to achieve compliance.
 
SECTION 508 COMPLIANCE POLICY AND PROCEDURE
FOR THIRD PARTY DOCUMENT POSTING
DURING EMERGENCY RESPONSE INCIDENTS
 
Compliance Achievement Step 1
 
If the responsible party hires an incident management contractor, OSPR responders will ask that the contractor provide an electronic form of the documents created that has the text and information embedded. A PDF form document alone is not compliant if the document is “flat” meaning the document doesn’t have the necessary information needed to be read by narrative software or other devices. It appears just as a photograph or JPG, TIF or similar image does – the text cannot be copied nor can the document be saved into an alternative format (rich text format, text format, etc.)
 
OSPR conducted an industry survey and identified the most commonly used incident management software programs were IAP and Command Pro. The manufacturers of these products indicated that a text document was achievable by doing the following:
 
1.      IAP – printing to a PDF using Acrobat driver. This requires having Adobe Acrobat on the computer. The document can then be saved into text format or tagged as appropriate through the Adobe Acrobat Program. The document should be opened. If it has the text embedded, it can be saved as rich text, Microsoft Word etc. If the text cannot be recognized, responders must use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the PDF document to text. The optical character recognition feature reads the text and creates as a sub layer to the document (leaving the document’s original structure still viewable).
 
2.      Command Pro – printing to a PDF using Acrobat driver. This requires having Adobe Acrobat on the computer. The document can then be saved into text format or tagged as appropriate through the Adobe Acrobat Program. The document should be opened. If it has the text embedded, it can be saved as rich text, Microsoft Word, etc. If the text cannot be recognized, responders will use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the PDF document to text. The optical character recognition feature reads the text and creates as a sub layer to the document (leaving the document’s original structure still viewable).
 
If OSPR receives a version that is accessible then it will post that document (or the original document and the text conversion) to achieve compliance. If this step can be taken, then no document from the contractor will be published until it is compliant.  Effort to achieve compliance in this fashion from the source document must always occur first, before moving to the next steps.
 
Compliance Achievement Step 2
 
In the event OSPR cannot secure a 508 compliant version of the documents from the third party contractor, responders will use the “Page Capture” or “Document OCR” features of Adobe Acrobat to convert the scanned document into text. The optical character recognition feature reads the text, and it creates as a sub layer to the document. The image of document stays intact but can now be read by accessibility software. It also straightens the document should it appear crooked. Images in the document will still need to be “tagged” with text to describe what is there.
 
Once the text is captured, OSPR will post the compliant page to its Web site. If this step can be taken, then no document from the contractor will be published until it is compliant.
 
Compliance Achievement Step 3
 
Should OSPR be unable to achieve compliance through either of the first two steps, OSPR will take the following steps to get the document the public and achieve compliance.  
 
1.      OSPR will post the original document and place ALT text with the document link that indicates a compliant version is not available at the time of the first posting. The text will further provide a phone number the individual may call to request the information (someone to read the document, etc). OSPR must make the commitment to staff that phone line during the entire time the document is being converted to compliant form.
 
2.      Immediately upon the posting of the document to the OSPR spill page, the Operations Center in Sacramento will designate an individual to reproduce the information contained in the document in a compliant format through whatever means is available (optical scanner, retyping, etc.).
 
3.      Due diligence will be made to provide the document in accessible form within two hours of its original posting.
 
4.      Once the accessible document is posted, the ALT text and alternative contact information may be removed, and the individual staffing the phone may stand down.
 
All other documents generated by OSPR or its contractors will be created and posted in accessible form. The steps included in this procedure apply ONLY to documents provided to OSPR from third parties not under direct state authority.
 
 
 
IMPLEMENTATION:
 
By adoption of this policy and procedure, OSPR Executive demonstrates its commitment to Section 508 compliance, and it outlines a procedure that will achieve compliance with as minimal an impact as possible upon field staff responding to spill emergency.
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