section 508 artifacts in the systems engineering life cycle 20100307 2030
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Section 508 Artifacts in the Systems Engineering Life Cycle
DHS Office of Accessible Systems & TechnologyMarch 2010
Office of Accessible Systems and Technology (OAST) Mar 2010
Presentation Organization
2
Objective Minutes Slides
Terminology
• Section 508• Life Cycle • Terms used in presentation
10 4
The need for a Section 508 EIT Accessibility Plan 5 3
Plan and Artifacts 30 6-22
Summary 5 2
Questions 10 1
Office of Accessible Systems and Technology (OAST) Mar 2010 3
For the Federal government, the requirement for accessibility is a law known as Section 508 of the Rehabilitation Act
Section 508 of the Rehabilitation Act requires agencies to give disabled employees and members of the public access to information that is comparable to the access available to others
Section 508 as described in the Code of Federal Regulations, 36 CFR 1194, contains functional and technical standards and has been a legal requirement since June 21, 2001
Section 508 compliance is required when Federal agencies develop Electronic Information & Technology (EIT) systems
Legal compliance with Section 508 can be achieved by: Meeting the applicable standards
Qualifying for a Section 508 Exception
Section 508
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When an agency builds a system, it follows a defined process to build, buy or use technology.
A logical, ordered process to meet all the organization's requirements is referred to as a systems development life cycle
All life cycles’ stages follow the same basic order
Stages can be split, combined, or tailored to allow flexibility of different development approaches Rapid Application Development
Waterfall Method
Spiral Method
Life Cycle
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Life cycle documents are generically referred to as “artifacts” because they are enduring visible work products that can be referenced during and after a system’s development
For simplicity, Systems Engineers, Project Engineers, Project Managers and other professionals involved in a life cycle are referred to as “project managers” Project managers handle the requirements of the developed solution on the
behalf of their clients or the system owners
A “project” is a time restricted, temporary endeavor to develop solutions, systems, or software
A project plan moves through stages of a systems engineering lie cycle (SELC)
Terms
Office of Accessible Systems and Technology (OAST) Mar 2010 6
All programs or project systems developed at DHS and DHS Components must align to a standard process approach - the DHS SELC Deals with the complexity of EIT
Reduces risk of project failure
Controls costs
Section 508 is specified as a mandatory requirement in the DHS SELC
DHS Life Cycle: DHS SELC
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Those of us in the accessibility field are always saying “build accessibility in”…
However Section 508 does not specify the processes that are required to support the legal and technical approach to compliance with the law
We need to provide project managers process tools and a plan – so they can perform
We believe that most efficient approach to Section 508 compliance is to include it in the life cycle requirements
Build It In!
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Because it is expensive to retrofit software to meet accessibility standards
The cost of revision is estimated to be
1.5 - 6 times greater during development than during the design phase
60-100 times greater after release
[Pressman, 2005]
Why Is “Building Accessibility In” Cost Effective?
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A separate process should not be needed for compliance
By being an intrinsic part of the life cycle, Section 508 can be managed the same as other requirements
Project managers understand the language of requirements and costs because they focus on those aspects of development
The Section 508 EIT Accessibility Plan has great value to them
What do Project Managers Need?They Need A Plan That Includes Section 508 Requirements…
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Section 508 EIT Accessibility Plan
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For most government project managers, the main tool needed is clear plan for Section 508 compliance that maps to their own project’s life cycle
The plan document itself be updated in each life cycle stage Ensures review of the appropriate artifacts
Project updates include Section 508 in any schedule changes
Section 508 EIT Accessibility Plan
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Several steps to the project, it all begins with an idea an more planning
Stage 1: Solution Engineering & Planning
Stage 2: Requirements Definition
Stage 3: Design & Development
Stage 4: Integration & Test
Stage 5: Implementation & Operations
Project managers and developers might relate to this as a classic waterfall development approach, but it is iterative and can be adapted to rapid application development or other methods
Section 508 EIT Accessibility PlanSolution
EngineeringPlanning Requirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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Section 508 EIT Accessibility Plan Stage 1: Solution Engineering &
Planning
DHS Form 4105: National Security Exception Request and Authorization Form
It is generally known during planning if the project will involve National Security Recognized Section 508
exception
Section 508 compliance includes clearly documenting any exceptions
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Stage 1: Solution Engineering & Planning
DHS Form 4105: National Security Exception Request and Authorization Form
Or…
Section 508 EIT Accessibility PlanSolution
EngineeringPlanning Requirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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Stage 1: Solution Engineering & Planning
Identify the applicable Section 508 Technical Standards
Section 508 Applicable Standards Worksheet
Any other Section 508 Exceptions that might apply Section 508 Exceptions Worksheet
Select the most compliant product available DHS Form 4106: Most Compliant Product Market Research Form
Section 508 EIT Accessibility PlanSolution
EngineeringPlanning Requirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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Stage 1: Solution Engineering & Planning
What are you engineering?
What are you planning to buy, build, or how will you select the best products?
What is the business need?
Section 508 EIT Accessibility PlanSolution
EngineeringPlanning Requirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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Stage 1: Solution Engineering & Planning
Identify the applicable Section 508 Technical Standards
Section 508 Applicable Standards Worksheet
Any other Section 508 Exceptions that might apply Section 508 Exceptions Worksheet
Select the most compliant product available DHS Form 4106: Most Compliant Product Market Research Form
Section 508 EIT Accessibility PlanSolution
EngineeringPlanning Requirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
Office of Accessible Systems and Technology (OAST) Mar 2010 18
Section 508 EIT Accessibility Plan Stage 1: Solution Engineering &
Planning
Section 508 Applicable Standards Worksheet
Used as a documentation template Reminder to include Section
508 in other generic project documentation
Possibly unused until later in the life cycle
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Section 508 EIT Accessibility Plan Stage 1: Solution Engineering &
Planning
Section 508 Exceptions Worksheet
Clarifying any possible exceptions Informs project managers to ask
the right questions
Section 508 compliance includes clearly documenting any exceptions
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Section 508 EIT Accessibility Plan Stage 1: Solution Engineering &
Planning
DHS Form 4106: Most compliant Product Market Research Form
Compliance Requires Market Research! Custom, Commercial, or Free
Section 508 compliance includes clearly documenting analysis of alternatives
Summarizes: additional documentation required
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Initial planning complete, now at requirements definition
Stage 1: Solution Engineering & Planning
Stage 2: Requirements Definition
Stage 3: Design & Development
Stage 4: Integration & Test
Stage 5: Implementation & Operations
Project managers typically complete their initial research, finish clarifying requirements with stakeholders and have a desired approach and have selected the technologies
Design and development might still introduce new technologies
Section 508 EIT Accessibility Plan
SolutionEngineering
PlanningRequirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
Office of Accessible Systems and Technology (OAST) Mar 2010 22
Stage 2: Requirements Definition
Updated Section 508 EIT Accessibility Plan Request any Section 508 Exceptions
Identify the applicable Section 508 Technical Standards
Project’s Requirements Documents Include Section 508 Functional Performance Criteria
Include Section 508 Technical Standards
Requirements Traceability Matrix
Market Research for Most Compliant Products
Section 508 EIT Accessibility Plan
SolutionEngineering
PlanningRequirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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requirements defined, now at design and development
Stage 1: Solution Engineering & Planning
Stage 2: Requirements Definition
Stage 3: Design & Development
Stage 4: Integration & Test
Stage 5: Implementation & Operations
All developed or customized EIT fully Section 508 compliant
Documents, Plans, Schedules & Rework includes Section 508
Remediation Plans
Section 508 EIT Accessibility Plan
SolutionEngineering
PlanningRequirements
Definition Design Development Integration& Test
ImplementationOperations &Maintenance
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Section 508 EIT Accessibility Plan Stage 3: Design & Development
Developed or Customized IT must be fully compliant
Development Life Cycle If it doesn’t meet criteria for an
exception, must be compliant
Section 508 has technical requirements that must be included with each new version release
Ongoing development testing includes scheduling and fixing defects before release
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Section 508 EIT Accessibility Plan Stage 3: Design & Development
Project Plans must include Section 508
Project Plan Timelines Include time for evaluation
Include Section 508 in customer acceptance tests
Include Section 508 EIT Accessibility Plan items in planning milestones
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Section 508 EIT Accessibility Plan Stage 3: Design & Development
Section 508 Remediation Plan
During Ongoing Active Development Track defects
Verify development team notified of defects
Useful when development teams do not have external bug tracking systems for stakeholders
Dates for follow-up is key information
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Development almost done, time to test
Stage 1: Solution Engineering & Planning
Stage 2: Requirements Definition
Stage 3: Design & Development
Stage 4: Integration & Test
Stage 5: Implementation & Operations
If your organization waits until this stage to check for Section 508 compliance, there is a high risk of failure
Short area on plan, but key milestone for any development
Transitioning to operations and support
Section 508 EIT Accessibility Plan
SolutionEngineering
PlanningRequirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
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Section 508 EIT Accessibility Plan Stage 4: Integration & Test
Transition to Support Document
Establish Support for End-Users Notifying Help Desk of special
configurations
Notifying Operations of special permissions or deployment issues
Include communications to agency and staff
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All aboard! Train is leaving! Project goes live
Stage 1: Solution Engineering & Planning
Stage 2: Requirements Definition
Stage 3: Design & Development
Stage 4: Integration & Test
Stage 5: Implementation & Operations
Section 508 Remediation Plan
Design and development might still introduce new technologies
Section 508 EIT Accessibility Plan
SolutionEngineering
PlanningRequirements
DefinitionDesign Development
Integration& Test
ImplementationOperations &Maintenance
Office of Accessible Systems and Technology (OAST) Mar 2010 30
Section 508 EIT Accessibility Plan Stage 5: Implementation &
Operations
Section 508 Remediation Plan
Proactively Solving Compliance Issues Track “defects”
Verify development team notified of defects
Useful to proactively ask vendors for compliant solutions
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Shared the approach taken at DHS Incorporate Section 508 compliance into the systems development life cycle
Use a formal plan
Explained the life cycle stages Existing artifacts can be used to incorporate Section 508 requirements
Introduced a Section 508 EIT Accessibility Plan Clearly communicate to project managers required activities
Managed Section 508 compliance as requirements
Suggest cost savings by “building it in” as early as possible
Summary
Office of Accessible Systems and Technology (OAST) Mar 2010 32
We showed how the project managers efforts in using the plan and worksheets that summarize legal exceptions and technical standards works to both document the Section 508 compliance and to increase the likelihood of an accessible product
We went beyond the specific requirements of Section 508 to provide other processes such as Remediation Plans that provide for continual product and process improvement
Summary
Office of Accessible Systems and Technology (OAST) Mar 2010 33
Appendices
Section 508 EIT Accessibility Plan
Section 508 Applicable Standards Worksheet
Section 508 Exceptions Worksheet
DHS Forms: 4103: Undue Burden Exception Request and Authorization Form
4105: National Security Exception Request and Authorization Form
4106: Most Compliant Product Market Research Form
4107: Incidental to Contract Exception Request and Authorization Form
4108: Fundamental Alteration Exception Request and Authorization Form
4109: Back-Office Exception Request and Authorization Form
Section 508 Impact Report
Section 508 Remediation Plan
Office of Accessible Systems and Technology (OAST) Mar 2010 34
Presenters
Alice A. Smith
[email protected] 202-447-0364
Norman B. Robinson
[email protected] 202-447 0322