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Section 508 Compliance

1. Overview of 508 Compliance Requirements

Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794d) mandates that all electronic and information technology (EIT) developed, procured, maintained, or used by the federal government must be accessible to individuals with disabilities. The purpose of this regulation is to ensure that technology-based deliverables, including electronic documents, websites, software, and digital training materials, are usable by all personnel, including those who rely on assistive technologies. All digital materials provided—such as reports, web-based platforms, training modules, and software—must meet the accessibility standards established under 36 CFR Part 1194, which aligns with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA. Safeware’s compliance with these regulations and guidance requires a systematic approach to reviewing, testing, and certifying all deliverables before submission to the government, as outlined in the following.

2. Applicable FAR Clauses

The FAR provides explicit guidelines for accessibility requirements in federal contracts. FAR Subpart 39.2 addresses the integration of Section 508 requirements into acquisitions, ensuring that all deliverables meet accessibility standards unless an official exception is granted. Under FAR 39.203, any ICT (information and communication technology) that is included in this contract must conform to the applicable accessibility standards unless an exception is justified under FAR 39.204. Additionally, FAR 52.239-1 outlines the requirement for privacy and security safeguards, which includes ensuring compliance with federal accessibility policies. FAR 52.204-21 further requires contractors to ensure that covered information systems are accessible and secure. To maintain compliance with these regulations, all deliverables will undergo rigorous accessibility evaluations, ensuring alignment with federal standards before acceptance.

3. Steps to Ensure 508 Compliance

Achieving Section 508 compliance involves a structured approach that integrates accessibility considerations at every stage of development, review, and submission. Safeware adheres to the following steps to ensure all deliverables meet accessibility requirements:

3a. Establishing 508 Compliance Oversight

A 508 Compliance Officer will be designated to oversee all accessibility-related activities. This individual will be responsible for ensuring that all electronic deliverables conform to Section 508 standards, coordinating internal audits, and maintaining documentation of compliance efforts. Additionally, all project staff, including subcontractors, will receive mandatory training on Section 508 requirements to ensure uniform understanding and execution of accessibility standards. We will use a 508 Compliance Checklist for all deliverables, including accessibility elements such as keyboard navigation, screen reader compatibility, color contrast, and alternative text descriptions for non-text elements.

3b. Ensuring Accessibility in Electronic Documents and Reports

All electronic documents, including Word, PDF, Excel, and PowerPoint files are formatted in accordance with 508 compliance standards before submission. This means that every document will be structured using proper heading hierarchies, ensuring logical navigation for users of screen readers. Additionally, all non-text content, including images, tables, and graphs, must be accompanied by alternative text descriptions to ensure accessibility for users who rely on screen readers. PDFs will be tagged and structured to allow for proper reading order, and scanned documents must undergo optical character recognition (OCR) processing to ensure text is selectable and readable by assistive technologies. For Excel files, proper cell labeling will be implemented, ensuring that screen readers can interpret and navigate through spreadsheet data without confusion. PowerPoint presentations will include closed captions for embedded multimedia and slide titles for easier navigation.

3c. Ensuring Accessibility in Web-Based Content and Training Materials

For web-based platforms, including online portals, training materials, and software applications, all content will comply with WCAG 2.1 Level AA standards. This includes ensuring that all interactive elements, such as forms, buttons, and navigation menus, are fully operable using keyboard commands alone, without requiring a mouse. Web content will be tested for contrast ratios, ensuring text and background colors meet the required 4.5:1 contrast ratio for readability. Additionally, multimedia content such as training videos will be equipped with closed captions and transcripts to accommodate users who are deaf or hard of hearing. Web-based forms and interactive content will be structured to prevent keyboard traps, ensuring that all elements can be navigated using standard keystrokes. All error messages and alerts will be designed to be screen-reader friendly, providing clear guidance for users with visual impairments.

 

For software deliverables, user interfaces will be tested for compatibility with assistive technologies such as JAWS, NVDA, and VoiceOver screen readers. Developers will adhere to ARIA (Accessible Rich Internet Applications) guidelines to enhance accessibility for complex web applications.

3d. Conducting 508 Compliance Testing and Validation

To ensure compliance, all deliverables will undergo a multi-step testing and validation process before submission. This process will include both automated and manual testing methodologies. Automated testing will be performed using industry-standard tools, which can include:

 

  • Adobe Acrobat Accessibility Checker, which verifies PDF compliance with 508 standards.

  • Axe Accessibility Scanner, which performs comprehensive accessibility scans.

  • WAVE Web Accessibility Evaluation Tool, which identifies accessibility issues in web-based content.

Following automated testing, manual reviews will be conducted to validate the results. Safeware testers will use assistive technologies such as JAWS and NVDA screen readers to ensure usability. Documents and websites will be manually tested for logical reading order, keyboard navigation, and alternative text accuracy.

4. Certification and Reporting of Compliance

For each deliverable, a Section 508 Conformance Statement will be submitted, confirming that the product has been tested and meets all accessibility requirements. Additionally, for ICT deliverables such as software, a Voluntary Product Accessibility Template (VPAT) will be provided, detailing how the product complies with accessibility standards. All compliance documentation, including test results, remediation plans, and compliance reports, will be maintained and made available for audit upon request by the government. In cases where a deliverable cannot fully meet Section 508 standards, a justification under FAR 39.204 will be provided, along with a remediation plan detailing how accessibility will be addressed in future updates or through reasonable accommodations.

5. Ongoing 508 Compliance Monitoring and Training

Ensuring sustained 508 compliance requires ongoing monitoring and workforce training. Periodic accessibility audits will be conducted to assess compliance across all deliverables. These audits will help identify any areas that require remediation and ensure that all updates and modifications remain accessible. Annual 508 compliance training will be mandated for all project personnel, ensuring they remain up to date with federal accessibility standards and best practices. Training will cover document accessibility, web accessibility, assistive technology compatibility, and compliance testing methods. A 508 Help Desk will be established to address accessibility-related concerns and provide guidance on resolving any issues that may arise during the contract period.