Introduction

Section 508 of the Rehabilitation Act, as amended by the Workforce Investment Act of 1998 (P.L. 105-220) requires that when Federal agencies develop, procure, maintain, or use information and communication technology (ICT), it shall be accessible to people with disabilities. Federal employees and members of the public who have disabilities must have access to, and use of, information and data that is comparable to people without disabilities The Americans with Disabilities Act (ADA) prohibits discrimination against people with disabilities in several areas, including employment, transportation, public accommodations, communications and access to state and local government' programs and services.

The Joint Training Committee (JTC) and participants in the National Air Pollution Training Program prioritize accessibility for participants in the program. The JTC, training event organizers, and training providers are expected to make good faith efforts to ensure that the program provides people with disabilities equal access to the training resources. The JTC Delivery Workgroup developed this guide to provide best practices for disability accommodations to the participants in the National Air Quality Training Program that are developing training content, procuring training contractors, organizing training events, and teaching courses.

This guide presents best practices for the primary components of the national training program: training services procurement, training content, training event registration, live event management, and post-event follow-up. Associated with each of the components of the training program are requirements to ensure that people with disabilities have equal access to the training services. Mandatory (Level 1) and optional (Level 2) requirements present program managers with different levels of training access to consider when planning training events. Descriptions of these requirements are included below, and a checklist is provided to facilitate ADA/508 compliance in the training event planning process.

This guide also includes links to ADA/508 compliance resources for building knowledge on accessibility in the national air pollution training program.

Training Program Best Practices

ADA/508 compliance best practices are categorized into the primary elements of a training program. While the tasks required for ADA/508 compliance are distributed to stakeholders in each of the different program elements (i.e., the contracting organization, trainers, or event hosts), ultimately it is the contracting organization's responsibility to define success and ensure compliance with the training program accessibility goals.

Organizations that procure and offer training services should have a clear definition of an ADA/508 compliant training program. Resources should be dedicated to identifying and tracking goals toward compliance, and polices should be put in place to correct non-conforming activities. The following organizational elements should be implemented by contracting organizations (i.e., SLT air programs, MJOs, and U.S. EPA) within the the national air pollution training program as part of their good-faith effort to ensure access to all:

Create an ADA/508 Compliance Statement
Gain a clear understanding of the requirements for ADA/508 compliance within the training program
Designate an Accessibility Manager for your organization
Define Key Performance Indicators (KPIs) for training accessibility
Charge the Accessibility Manager with tracking the performance of the organization against the KPIs
Implement procedures to identify and correct non-compliance and/or divergence from your organization's KPIs
Implement procedures to field and respond to complaints about accessibility deficiencies in your organization's training program

Example ADA/508 Compliance Statement:

[Organization] is committed to ensuring equal access to training resources across all segments of our community

Training Services Procurement

General Procurement Requirements

When procuring training services, ensure the following elements are included in procurement announcements:

State the commitment of the funding agency to accommodating the needs of people with disabilities, and to ensuring equal access to training.
Require training contractors to demonstrate a commitment ADA/508 compliance.
Require training contractors to meet a minimum level of content and delivery accommodations (Level 1), and to make a good-faith effort at meeting more extensive accommodations (Level 2).
Provide to contractors a checklist with Level 1 and Level 2 disability accommodation requirements.
Distribute procurement instruments (e.g., RFPs, RFQs, solicitations, contracts) in formats that comply with ADA/508 requirements, and make training funding opportunities accessible to all.

Training Contract Requirements

Contracts for training services should include basic requirements to ensure equal access to the content and services, including:

Powerpoint presentations and Word documents will be screened through and pass the Microsoft Accessibility Checker
Training contractors will comply with and provide evidence of compliance to ADA/508 Level 1 access requirements
Training contractors will make good faith efforts to comply with ADA/508 Level 2 access requirements

Basic requirements of online training

The online delivery platform (i.e., the webinar system) meets Web Content Accessibility Guidelines (WCAG: https://www.w3.org/TR/WCAG21)
The online delivery platform provides the option for viewers to enable automated closed captioning
All streamed video content will use subtitles

Basic requirements of classroom training

Instructors will use audio amplification when speaking to the participants

Draft Contract Language

Include the following language in training contracts to ensure that the training event is compliant with ADA/Section 508 requirements.

ADA/Section 508 Compliance
 
Section 508 of the Rehabilitation Act, as amended by the Workforce Investment Act of 1998 (P.L. 105-220) requires that when Federal agencies develop, procure, maintain, or use information and communication technology (ICT), it shall be accessible to people with disabilities. Federal employees and members of the public who have disabilities must have access to, and use of, information and data that is comparable to people without disabilities The Americans with Disabilities Act (ADA) prohibits discrimination against people with disabilities in several areas, including employment, transportation, public accommodations, communications and access to state and local government' programs and services. 

The Joint Training Committee (JTC) and participants in the National Air Pollution Training Program ("The Program") prioritize accessibility in The Program. The JTC, training event organizers, and training providers are expected to make good faith efforts to ensure that The Program adequately accommodates training participants with disabilities. 

The Web Content Accessibility Guidelines (WCAG: https://www.w3.org/TR/WCAG21) and WCAG 2.1 Quick Reference (https://www.w3.org/WAI/WCAG21/quickref) are resources to help training professionals comply with ADA and 508 Standards when developing web-based, online content. Section508.gov provides resources for creating accessible digital products, such as Word, Power Point, and PDF files (https://www.section508.gov/create/). 

The Contractor shall deliver work that complies with the Level 1 requirements and make a good faith effort to comply with Level 2 requirements as listed in the JTC Training Accessibility Guideline Checklist (https://www.ladco.org/wp-content/uploads/Training/JTC/ADA-508-Training-Guideline-Checklist-10Dec2021.pdf).

Reference Materials

Buy Accessible Products and Services

Training Event Registration

Ensure registration portals meet ADA/508 requirements. Web-based registration should conform to the latest WCAG.
All web-based content with information about the training event conforms to the latest WCAG
At a minimum, encourage training participants to request specific needs and provide contact information to make requests. Ideally, ask about specific disability accommodations such as physical, communication, or dietary restrictions

Training Content

Require that all training content is ADA/508 compliant
All virtual training should use closed captions
All streaming content during trainings should use captions
Training materials should be provided in printed formats with larger, sans serif fonts (black text on white background) upon request

Reference Materials

Live Training Event Management

The physical training venue meets ADA requirements
Classroom trainings should use microphones for all lectures and question/answer sessions
If food is provided, advanced planning is made to accommodate dietary restrictions or accessible dining options
If people are traveling to the event, accommodations are made for accessible lodging and transportation

ADA Compliance Checklist for virtual trainings (US EPA)