Cleanscape Software Development Tools and Section 508 9/11/2007

The US federal government has a regulation labeled Section 508, whose purpose is to ensure that “Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities”.

Intended for our government customers, this document affirms Cleanscape’s adherence to, and commitment to adhere to, Section 508 for all current and future products produced and maintained by Cleanscape. As of this writing, those products are Fortran-lint, Cleanscape C++lint, and LintPlus. The phrase “its products”, when used in the paragraphs below, refers specifically to the above-listed products. Contact Cleanscape regarding products not on this list.

General Comments from Cleanscape regarding its products and Section 508

The last of the “micro-purchase” waivers regarding Section 508 expired April 2005. Due to their presence, Cleanscape was not even aware of Section 508 until a customer told us about it.

Cleanscape products are command-line-based with optional graphical interfaces. Because of the technology used to build our GUIs and the fact that our legacy products are command line, it happens that Cleanscape was already highly compliant to Section 508, as described below. Since we are now aware of it, Cleanscape is committed to be completely compliant to Section 508 – updates to our GUI products have been incorporated into their development schedules.

It should be noted that Cleanscape produces software development tools that are not applicable to the general computer user. Such tools should probably have been separately categorized in Section 508, as there is at least a 100:1 ratio of general users to software developers.

For many of our government customers, Cleanscape considers “software development tools” to fall into the General Exception highlighted in italics below:

§ 1194.3 General exceptions.

(a) This part does not apply to any electronic and information technology operated by agencies, the function, operation, or use of which involves intelligence activities, cryptologic activities related to national security, command and control of military forces, equipment that is an integral part of a weapon or weapons system, or systems which are critical to the direct fulfillment of military or intelligence missions.

Regarding our legacy (command-line) products: Section 1194.3 (e) states,

“This part shall not be construed to require a fundamental alteration in the nature of a product or its components.”

We believe the above section applies for command-line operation: to add access and use provisions would fundamentally alter the nature of our legacy products. However, as documented below, our products to not interfere with accessibility features offered through the OS. Since most users operate in graphical OSes, use of operating system facilities supporting assistive technology is available at all times.

Specific compliance statements for each section that Cleanscape products are applicable to begin next. Our affirmations are in italics.

Subpart B – Technical Standards – §1194.21 Software applications and operating systems.

(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

Cleanscape affirms that its products comply with this paragraph.

(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

Cleanscape affirms that its products comply with this paragraph.

(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

Cleanscape affirms that its products in GUI interface mode comply with this paragraph and in part relies on operating system facilities supporting assistive technology. This section is not applicable to the command line versions of all Cleanscape products.

(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology. When an image represents a program element, the information conveyed by the image must also be available in text.

(e) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance.

Cleanscape affirms that its products comply with this paragraph.

(f) Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.

Cleanscape affirms that its products comply with this paragraph.

(g) Applications shall not override user selected contrast and color selections and other individual display attributes.

Cleanscape affirms that its products comply with this paragraph.

(h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

Cleanscape affirms that its products comply with this paragraph.

(i) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

Cleanscape affirms that its products comply with this paragraph.

(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

Cleanscape affirms that its products comply with this paragraph.

(k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

Cleanscape affirms that its products comply with this paragraph.

(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Cleanscape affirms that its products comply with this paragraph.

Subpart C – § 1194.31 Functional Performance Criteria

(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

Cleanscape affirms that its products comply with this paragraph through use of operating system facilities supporting assistive technology.

(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

Cleanscape affirms that its products comply with this paragraph through use of operating system facilities supporting assistive technology.

(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

Cleanscape affirms that its products comply with this paragraph through use of operating system facilities supporting assistive technology.

(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

Audio information is not applicable to Cleanscape products.

(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

Speech operation is not applicable to Cleanscape products.

(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Cleanscape affirms that its products comply with this paragraph through command line mode.

Subpart D – § 1194.41 Information, Documentation, and Support

(a) Product support documentation provided to end-users shall be made available in alternate formats upon request, at no additional charge.

Cleanscape affirms that its products comply with this paragraph.

(b) End-users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.

Cleanscape affirms that its products comply with this paragraph through use of operating system documentation supporting assistive technology.

Cleanscape affirms that its products and services comply with this paragraph.

Sales and Service Office

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Franklin Springs, GA 30639

706-245-1070

Fax 706-245-1070

www.cleanscape.net

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