Section 508 and the system development life cycle
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Section 508 and the System Development Life Cycle. Section 508 Coordinators Meeting Gettysburg 2009. Panelists. Kyle Zdanowski Section 508 Coordinator Internal Revenue Service - IRS Mark Rew Team Leader, Blind and Low Vision Team Computer/Electronic Accommodations Program (CAP)

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Section 508 and the system development life cycle

Section 508 and the System Development Life Cycle

Section 508 Coordinators Meeting

Gettysburg 2009


Panelists

Panelists

  • Kyle Zdanowski

    • Section 508 Coordinator

    • Internal Revenue Service - IRS

  • Mark Rew

    • Team Leader, Blind and Low Vision Team

    • Computer/Electronic Accommodations Program (CAP)

  • Norman B. Robinson

    • Office of Accessible Systems & Technology (OAST)

    • Department of Homeland Security


What is the system development life cycle

What is the System Development Life Cycle?


System development life cycle

System Development Life Cycle

  • Named differently at different agencies:

    • Enterprise Life Cycle (ELC)

    • Systems Engineering Life Cycle (SELC)

    • System Development Life Cycle (SDLC)

  • Accomplishes the same mission:

    Ensuring that appropriate activities are planned and implemented in each stage of the life cycle to increase the project’s success


Developed procured maintained or used

Developed, Procured, Maintained, or Used

Projects should be managed using a life cycle:

  • EIT contracts produce formal project deliverables

  • Development of EIT is part of a formal project

  • Procurements involve acquisitions of EIT for integration in a specific project

  • Maintenance of EIT is a part of a project’s ongoing operations and maintenance

  • Some EIT is used without formal acquisition: integrating already acquired technology or Open Source Software into your project


Where is section 508 in your lifecycle

Where is Section 508 in Your Lifecycle?

  • If at the end, many missed opportunities, with increased risk and costly repairs or replacements

  • If at the beginning, great opportunity to make an effective difference, with the target of accessibility hit more often and efficiently


Section 508 throughout the lifecycle

Section 508 Throughout the Lifecycle

1) Requirements:

  • Begin to identify applicable 508 standards

    2) Design:

  • Refine applicable 508 standards

    3) Development:

  • Develop with 508 standards in mind

    4) Implementation:

  • Test against 508 standards

    5) Maintenance:

  • Mitigate failures found after deployment


1 requirements analysis planning

1) Requirements (Analysis, Planning)

  • Partnership with clients and stakeholders

  • Determines mission and goals (including usability/accessibility)

  • Determines the expectations and sets performance benchmarks (including how accessible)

  • Maps resources and schedule


1 requirements analysis planning1

Planning for Section 508 Compliance:

Project plans must include compliance activities based on alignment with the stages of the Life Cycle

These activities are general steps taken in any Section 508 compliant life-cycle planning

Official forms standardize documentation

Official policy standardizes responsibility decision points

1) Requirements (Analysis, Planning)


1 requirements analysis planning2

1) Requirements (Analysis, Planning)

Section 508 Education/Outreach

  • Tools - GSA's Buy Accessible Wizard

  • Online Training - Guides/Tutorials

  • Briefings (to individuals, projects, or in bulk)

  • Assistive technology demonstrations


1 requirements analysis planning3

1) Requirements (Analysis, Planning)

Business Requirements and Legal Compliance

  • Identify the business requirements

    • These requirements will be used during evaluation of alternatives to determine if technologies should be commercially purchased or custom developed

  • Legal compliance:

    • Utilize standardized contract language


  • 1 requirements analysis planning4

    1) Requirements (Analysis, Planning)

    Possible Early Exception:

    • National Security Determination

      • Determine if a Section 508 National Security Exception (NSE) applies

      • If authorized, additional planning is not required for that particular EIT

        • “Distinct technology”

    • Section 508 is never waived; exceptions are specified


    1 requirements analysis planning5

    1) Requirements (Analysis, Planning)

    Section 508 Technical Compliance for Each Distinct Technology:

    • determine what Section 508 standards apply

    • determine if any other Section 508 exceptions apply

    • Provide approved Section 508 Request and Authorization Forms during any reviews

    • For Pilots: Alternative Analysis required


    1 requirements analysis planning6

    1) Requirements (Analysis, Planning)

    Determine what Section 508 standards apply:

    • Functional performance criteria (§ 1194.31 ) always apply

    • Meeting functional performance criteria should be accomplished through meeting the technical standards where possible


    Project owner responsibility and accountability

    Project Owner Responsibility and Accountability


    Accountability

    Accountability

    • Who is responsible? The project owner.

      • Project owner tests

      • 508 Program has oversite

    • Define procedures to address conformance failures


    1 requirements analysis planning7

    1) Requirements (Analysis, Planning)

    Determine what Section 508 Technical Standards apply:

    • 1194.21 Software applications and operating systems

    • 1194.22 Web-based intranet and internet information and applications

    • 1194.23 Telecommunications products

    • 1194.24 Video and multimedia products

    • 1194.25 Self contained, closed products

    • 1194.26 Desktop and portable computers


    2 design concept

    2) Design (Concept)

    • Foundation for the user experience (including the assistive technology user)

    • High-level concepts

    • Constructs prototype (One that is accessible for stakeholders who use assistive technology!)

    • Blueprint for the entire project

    • Establish and validate the technical approach (Ask, does it meet the accessibility requirements?”)


    2 design

    2) Design

    • Requirements in cases of Development and Customization

    • If the project involves development or custom integration of EIT:

      • incorporate Section 508 Functional Performance Criteria into the functional requirements documentation and

      • include applicable Section 508 Technical Standards in the technical requirements documentation

      • include both into the project’s schedule & requirements

        • traceability matrix


    2 design1

    2) Design

    • Compliance Expectations

      • All developed systems or items are expected to fully comply with all applicable technical and functional performance requirements

      • Legal compliance:

        • Standardized contract language

        • Customized contract language for functional and technical requirements


    Selection is design

    Selection is Design

    Purchasing Most Compliant Products:

    • For each commercial or government item (COTS/GOTS) used in the project:

      • Perform market research

      • Determine applicable Section 508 Technical Standards

      • Select the most accessible system or item that best meets business needs

    • Vendor accessibility claims can be validated through testing

      • Does vendor accessibility compliance documentation provide all information needed to make a decision?


    Section 508 planning

    Section 508 Planning

    • Plan for Section 508 accessibility testing against the requirements

    • Include Section 508 when developing traceability matrix, system acceptance plans, and test plans

    • Ensure schedule includes adequate time to integrate, test, and resolve any Section 508 defects

      • Test using standardized, approved testing methodologies & tools

      • Conduct interoperability test using assistive technologies

      • Ensure electronic documentation and training meets Section 508 requirements

      • Ensure any special configuration information related to assistive technologies is documented and available to the users


    3 development

    3) Development

    • Develops an implementation plan

    • Uses unit testing (Includes accessibility testing when the unit has accessibility requirements)

    • Created and use an accessibility/Section 508 check list

    • Perform end-to-end accessibility testing


    3 development1

    3) Development

    • Software Development Life Cycle

    • Developers addressing Section 508 for the first time in development are at a disadvantage

      • Increases project risk

        • Often seen in organizations lacking a SDLC

        • Increases pressure on Section 508 Program

    • Developers must test internally

      • “Throwing it over the fence”

      • Even formal IV&V requires developers to test


    4 implementation integration deployment testing

    4) Implementation (Integration, Deployment, Testing)

    • User acceptance testing (include stakeholders - to test accessibility)

    • Process metrics include accessibility bug fixes

    • Each iteration is completed with a full compile, load, and system test which includes testing for any broken accessibility

    • “I just heard something about 508...”

      • Risk of project failure

      • Increased pressure on Section 508 Program


    4 implementation integration deployment testing1

    4) Implementation (Integration, Deployment, Testing)

    Pre-Deployment Testing:

    • Test against the requirements, to include Section 508 requirements

    • Test and plan to resolve any Section 508 defects

      • Testing using standardized, approved testing methodologies

      • Conduct interoperability testing with assistive technologies

      • Ensure electronic documentation and electronic training meets Section 508 requirements

      • Ensure any special configuration information related to assistive technologies is documented and available to the users

    • Track Section 508 defects for any developed items

    • Track COTS/GOTS failures to meet Section 508 Technical Standards


    4 implementation integration deployment testing2

    4) Implementation (Integration, Deployment, Testing)

    Testing:

    • Test Plan

    • Testing Methods: Manual, Automated, with Assistive Technology

    • Test Results

    • Failure Mitigation (Short Term and Long Term)

      • Remediation Planning


    5 maintenance operations support

    5) Maintenance (Operations, Support)

    • Review and document all phases of the project

    • Process analysis (continuous improvement)

    • Configuration and change management that considers the affect on accessibility when modifications are made


    5 maintenance operations support1

    5) Maintenance (Operations, Support)

    Specific Considerations:

    • Lessons Learned

    • Maintenance or New Release

    • What is changing?

    • Do the changes affect the accessibility of the system?


    5 maintenance operations support2

    5) Maintenance (Operations, Support)

    • Remediation Plans: a plan to resolve defects

      • Document accessibility problems reported during integration and operations as Section 508 defects

      • Develop a remediation plan to include reporting any product deficiencies found (typically in test)

        • Vendor (COTS)

        • Developers (developed items)

    • Establish timelines for bringing EIT into compliance

      • Without a timeline you do not have a plan

      • Proactive approach


    508 program responsibility and accountability

    508 Program Responsibility and Accountability


    Address the challenges

    Address the Challenges

    • Lack of formal policies that include Section 508

      • Section 508 not explicitly defined in agency’s life cycle

    • Section 508 not included in change control processes

    • Section 508 not included in acquisition reviews

      • To standardize and create initial contract language

      • To standardize review and approval of contract language

        • Formal approval any general exceptions

    • Lack of standardized testing approach

    • Lack of formal Section 508 training program


    Integration into organizational culture

    Integration into Organizational Culture

    • The contract statement of work contains specific accessibility and Section 508 requirements and metrics

    • Accessibility awareness is through out the staff and life cycle

    • Accessibility questions during potential employee interview

    • Employee training (Including a base line accessible code training)

    • Part of the requirements at all phases

    • User interface specialist is knowledgeable of accessibility

    • UI specialist attends the code review meetings

    • Accessibility is part of testing and quality control

    • Risk analysis includes analyzing the risk of a unit being accessible or usable for assistive technology

    • Accessibility is considered at all phases of the methodology


    Conclusion

    Conclusion

    • Agencies should have a formal Section 508 policy that is inclusive of Section 508 in agency processes

    • A formal life cycle ensures that appropriate Section 508 activities are planned and implemented in each stage of the life cycle to increase the project’s Section 508 compliance success

    • Less impact on cost or schedule when Section 508 is part of the process

    • Significant impact on cost and schedule when Section 508 is not part of the process

    • Remediation Plans reduce ongoing risks

    • Section 508 life cycle compliance integrates with Security, Information Assurance, Privacy, and Performance Standards


    Questions

    Questions?

    • Please ask questions or briefly share your thoughts about Section 508 in the system development life cycle.


    Contact information

    Contact Information

    • Kyle Zdanowski

      Section 508 Coordinator

      Internal Revenue Service - IRS

      Information Resources Accessibility Program - IRAP

      Email: [email protected]

    • Mark Rew

      Team Leader, Blind and Low Vision Team

      TEL 703-681-8812

      FAX 703-681-9075

      Computer/Electronic Accommodations Program (CAP) visit us online www.tricare.mil/cap"

      "CAP" your wasteful ways and Reduce, Reuse and Recycle

    • Norman B. Robinson

      Office of Accessible Systems & Technology (OAST)

      Department of Homeland Security

      voice: 202-447-0322, cell: 202-834-3192

      [email protected]


    Sdlc selc references

    SDLC/SELC References

    • DHS Acquisition Instruction/Guidebook #102-01-001: Appendix B B-i Interim Version 1.9 November 7 2008


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