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Slide Notes

This presentation was made as part of Standards Australia's Accessibility Forum on 4 February 2016. The purpose of the forum was to launch the campaign to have the European Standard EN 301 549 adopted, using the direct text adoption fast track process, as an Australian standard. This work is being sponsored by the Department of Finance, the Human Rights Commission, and the Australian Communications Consumers Advocacy Network (ACCAN).

Standards Australia Accessibility Forum 4 Feb 16

Published on Nov 18, 2015

The argument for the direct text adoption of EN 301 549 as an Australian standard

PRESENTATION OUTLINE

MAKING IT BETTER

ACCESSIBILITY & ICT PROCUREMENT
This presentation was made as part of Standards Australia's Accessibility Forum on 4 February 2016. The purpose of the forum was to launch the campaign to have the European Standard EN 301 549 adopted, using the direct text adoption fast track process, as an Australian standard. This work is being sponsored by the Department of Finance, the Human Rights Commission, and the Australian Communications Consumers Advocacy Network (ACCAN).

The Australian Public Service is committed to employing people with disability and creating inclusive work environments that reflect the diversity of the Australian community

As this slide notes, the Australian Public Service is committed to enabling the employment of people with disabilities.
Photo by gavin.jackson

NOT JUST RULES

THE PROCUREMENT FRAMEWORK
As this discussion is about accessibility in ICT procurement, it is important to note that Commonwealth procurement is subject to the Commonwealth Procurement Rules. The CPRs are a collection of rules, guidelines and best practices that, when followed, as is mandatory for non-corporate Commonwealth entities, ensure that procurement is efficient, effective, economical, and ethical.
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"base technical specifications on international standards, when they exist and apply to the relevant procurement, except when the use of international standards would fail to meet the relevant entity’s requirements or would impose greater burdens than the use of recognised Australian standards"

Division 2 of the CPRs, which generally applies to procurements above $80,000, requires the use of standards, when they exist. International standards are generally preferred.
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STANDARDS

  • European EN 301 549
  • U.S. Section 508
  • WCAG 2.0
There are three useful reference for accessibility in ICT procurement.

The use of the WCAG 2.0 AA standard for websites has been mandatory since 2014 and I won't be discussing it further today. Web guidelines are now the province of the Digital Transformation Office.

Section 508 of the USA Rehabilitation Act has been a very useful guideline for this work for some time. However, it is not strictly a standard.

EN 301 549, the European standard, is now the most useful reference for this purpose which is why we are pursuing its use for Australia.
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EN 301 549

  • Generic requirements
  • ICT with 2 way voice
  • ICT with video
  • Hardware
  • Web content
  • Documents
  • Software
  • Documentation and support services
  • ICT relay or emergency service access
The major headings of the standard are shown on this slide. Not all of these areas are covered by centralised procurement arrangements in the Commonwealth Government.

As noted, the standard and Section 508 are closely related. This is a very useful situation as it ensures that different requirements don't coexist across what is very clearly a global market for ICT.

Hardware

  • General
  • Speech output
  • Physical access
  • Mechanically operable parts
  • Tactile indication of speech
This slide shows the hardware components of the standard. They are quite detailed and I would encourage those interested or affected to examine the detail.

That said, our research shows that major hardware manufacturers meet the standards.
Photo by @llwynrt

COORDINATED PROCUREMENT

  • Telecommunications
  • Hardware
  • Data Centres
  • Major Office Machines
  • Microsoft VSA
  • Large software vendors
I'm responsible for a range of non-ICT and ICT procurement for whole of government. This slide shows the areas of ICT procurement that are managed in a coordinated fashion.

Coordinated procurement is designed to ensure that the Australian Government achieves value for money by aggregating demand where it is appropriate. Generally, this will be in commodity-like areas.

This procurement activity has a dependency of about 250,000 staff across over 100 agencies. While this seems large, it's worthwhile to compare it to industry. It's about the size of a medium sized bank. While we are a flagship customer for some vendors, our influence shouldn't be overestimated.

Results to Date

  • Major Office Machines (2013) - 38/55 compliant with 508
  • Mobile Panel (2014) - 13/13 device providers compliant with 508
We've been working on improving accessibility in ICT procurement for some time. Our work has involved checking whether standards can be applied to our coordinated hardware procurement. These next two slides demonstrate that manufacturers are largely meeting these standards now and that full compliance appears quite within reach.
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HARDWARE PANEL

  • Fully compliant with 508 or EN: 14/23
  • Partially compliant: 9/23

What will an Australian Standard Provide?

  • An agreed reference
  • A visible commitment
  • A basis for policy
  • Motivation for further effort
This slide details the advantages we expect to gain from having an Australian standard, even before we consider the beneficial effects that compliance with the standard is likely to generate for people with a disability.

LIMITATIONS

  • Software applications
  • Relative buying power
  • Fitted for versus fitted with
  • Refresh cycles
However, the adoption of EN 301 549 as an Australian standard is not a panacea.

Compliance with the standard is more difficult for bespoke application development than it is for OEM sourced hardware.

As discussed earlier, the Australian Government cannot necessarily dictate to vendors, particularly international vendors.

While it may be preferable for the majority of APS devices to be able to be fitted to assist people with disabilities, it would not be sensible to fit all devices with such capabilities in all cases. We need to manage these requirements carefully. Historically, our rationale has been to provide whatever people need when they are employed. While this can lead to delays, it has usually not been limited by cost considerations. We need to be careful not to lose sight of the required outcome.

Equipment lives are lengthening, despite the shortening technology half life. Not all equipment will ever be replaced at once, even if a standard was introduced.
Photo by State Farm

QUESTIONS?

Time for questions.
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