ADA/508 Compliance for the National Air Quality Training Program

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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 training resources. This guide presents an ADA/508 Compliance strategy for the training program. The strategy is targeted to the participants in the National Air Quality Training Program who are developing training content, procuring training services, organizing training events, and teaching courses.

This guide presents a draft compliance plan and best practices for the primary components of the national training program. These components include 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 these 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.

Draft ADA/508 Compliance Plan for the National Air Quality Training Program

The JTC should implement the following steps to ensure that the national training program is providing equal access to all training resources and events.

  1. Create an ADA/508 compliance statement for the national training program
  2. Develop and reach consensus on an accessible training program plan across the JTC and training stakeholders
  3. Designate an Accessibility Manager to implement the plan, monitor plan compliance, and correct non-compliance issues
  4. Engage with an outside ADA/508 compliance subject matter expert to audit the JTC and national training program to identify how to best direct resources towards providing sufficient accommodations for the community
  5. Identify and offer training on ADA/508 compliance to EPA, MJO, and SLT training coordinators
  6. Define accessibility best practices for training event sponsors, and encourage annual reporting on the implementation of these best practices by sponsors
  7. Direct training providers who participate in the program, including NOWCC staff, to resources on creating and delivering accessible training content
  8. On an annual basis, collect information on disability accommodation needs of participants 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.

Develop an Accessible Training Program Plan for your Organization

Organizations that procure and offer training services should begin by developing a plan to ensure equal access to these services. All members of the organization involved in the training program should have a clear definition of what is required for an ADA/508 compliant training program. A point person should be identified to manage ADA/508 compliance in the organization's 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 for 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 for Sponsors

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 (note: create and link to this checklist here) 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:

  • Presentations (e.g., Powerpoint) and documents (e.g., Word or PDF) will be screened through and pass an accessibility checker (e.g., Microsoft Accessibility Checker).
  • Pre-recorded videos used in the training will include an option for closed captioning
  • Pre-recorded audio used in the training will include an option for written transcripts
  • 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

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 Planning and 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
  • Secure training venues for in-person trainings that are ADA compliant
  • Training organizers should make on-site visits to meetings spaces and look for the following features when inspecting a meeting/event space:
    • Visibility: Clear signage (identifying location and directions); well-lit meeting space and adjacent areas; projection screen visible from all seating (if using projection).
    • Acoustics: Public address (PA) system; roving microphone; limit unnecessary background music; seating available near presenter for lip reading; availability of assistive listening devices; availability of a well-lit space if an interpreter is needed
    • Mobility: Accessible parking near venue; proximity to bus stop; ramp and/or elevator access; accessible bathrooms; barrier-free pathways; wide doorways and aisles to accommodate wheelchairs/scooters; no loose cables across walking areas
    • Technology: Electrical outlets in accessible seating areas to accommodate devices, laptops, etc.; extra space or work surfaces for participants that use assistive devices
    • Service Animals: Comfortable space for service animals to rest during event; accessible toileting and watering facilities nearby
  • Ensure that training venues for in-person trainings are easily accessed by ADA-compliant public transportation and lodging options

Example accessibility text for course registration (Level 1): 

(Organization name) strives to host inclusive, accessible training events that enable all individuals, including individuals with disabilities, to engage fully with the instructor and course content. To request an accommodation or for inquiries about accessibility, please contact (name, email, phone) by (date). 

To be respectful of those with allergies and environmental sensitivities, we ask that you please refrain from wearing strong fragrances to an in-person training event.

In addition to the Level 1 accessibility text, include the following example to include specific accommodation requirements from course participants (Level 2): 

I will need the following accommodations in order to participate in this session:

• Assistive listening device
• Captioning
• Reserved front row seat
• Large print
• Advance copy of slides to be projected
• Wheelchair access
• Wheelchair access to working tables throughout room
• Service animal accommodations
• Scent-free room
• Lactation room
• Gender neutral bathroom
• Diet Restrictions. List: ________________________
• Other: ________________________

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 at least 14 point, 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

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

Reference Materials

Post-Training Event Follow-Up

  • All web-based communications with information about the training event conforms to the latest WCAG
  • Transcripts of all training materials are made available upon request

Accessible Training Tools

Learn About Accessibility and 508 Compliance

Online Resources on ADA Compliance

Tips for Presenters

Here are some useful tips from Oklahoma Able Tech for presenters to consider to enable access to live, classroom-taught training content.

  • Face the audience when presenting so that those that read lips have a clear line of sight
  • Repeat questions from the audience when there is not a microphone for audience members
  • Describe visuals in your presentation
  • Think about how you would describe a visual to someone over the telephone
  • Use a microphone if available to avoid dead spots and poor audio quality
  • Make slides, multimedia and handouts accessible to make the content easy to perceive and understand
  • Speak at a medium rate so that interpreters, Communication Access Realtime Translation (CART) providers and listeners can keep up with speech
  • Spell out acronyms when they are first used in print or digital material and when speaking
  • Ask audience members to respond to questions in multiple ways, such as raising hands, nodding or speaking out
  • Summarize responses to questions asked of the audience
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