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

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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)

  • Norman B. Robinson

    • Office of Accessible Systems & Technology (OAST)

    • Department of Homeland Security


What is the 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

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?

  • 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

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)

  • 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


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, 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, 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, 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, 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, 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


    Accountability

    • Who is responsible? The project owner.

      • Project owner tests

      • 508 Program has oversite

    • Define procedures to address conformance failures


    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)

    • 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

    • 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) 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

    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

    • 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

    • 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) 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)

    • 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, 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, 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)

    • 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, Support)

    Specific Considerations:

    • Lessons Learned

    • Maintenance or New Release

    • What is changing?

    • Do the changes affect the accessibility of the system?


    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


    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

    • 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

    • 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?

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


    Contact Information

    • Kyle Zdanowski

      Section 508 Coordinator

      Internal Revenue Service - IRS

      Information Resources Accessibility Program - IRAP

      Email: 508@irs.gov

    • 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

      norman.b.robinson@dhs.gov


    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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