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Products Exempt from Section 508
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Products Exempt from Section 508

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Doug

Say, you're going to go buy some blank CD-ROMs, is 508 involved?

Speaker 2

No, because they're blank.

Speaker 3

Is there a way to feel them and tell which side is up and which side is down, or whether it's CD-R or CD-RW? I mean there's other ways you can kind of code the stuff, by which containers they come in or something like that. I have a hard enough time telling which is which if it's not in the original box that it came in to begin with.

Doug

Would you consider a CD-ROM information technology?

Speaker 4

Not a blank one, no. Not once it's burned.

Doug

So, a blank one, you would say no?

Speaker 4

No, because there's no information on it.

Doug

Right, I would agree. It is just like a blank piece of paper. But, you know you can argue it either way. It's like a chip waiting to store stuff on it. Is a hard disk under 508?

Speaker 3

If it's blank no, but once you put information on it, then I guess it would be.

Doug

Well, a hard disk is probably electronic and information technology. And yes, I think you could say and so then is a blank CD, you could consider it. The next question though, because remember, it isn't the fact that it has information on it. It's the fact that it has the capability of storage, transmitting, converting or whatever, information technology. So, let's go back to our blank CD. What rules apply? First of all, are there any exemptions?

Speaker 4

You don't need it, until you put information on it.

Doug

We're going to assume it's not being used by the military (laughing). I'm going to assume that a blank CD-ROM is totally accessible until you put information on it.

Speaker 5

The hard disk, wouldn't that be different once you put an operating system on it?

Doug

I think the hard disk would be covered even if it was totally empty, because it does have the ability to store information, just like the CD-ROM. Let's say the CD-ROM is compliant. A blank hard disk, does it violate any rules?

Speaker 5

Well, I use an external hard drive just to store files and there is no operating system on it.

Doug

What about an external one that you never touch?

Mark

I guess, setting aside whether it's covered or not, I'm having a hard time envisioning which subpart of 508, which criteria, which technical, functional criteria you can apply to a hard drive to evaluate its accessibility.

Doug

Exactly, you're going in the right direction.

Speaker 6

Right, because it's electronic but until you actually...

Doug

It's information technology for sure, look at the definition.

Speaker 3

It's electronic technology, until you put information on it, isn't it?

Doug

You can put information on it. It is still the technology, rather it has information on it or not.

Mark

I guess the only thing that I could think of that you could apply to it is you could evaluate rather the accompanying documentation, for example, or the software that often accompanies hard drives...those you can evaluate against a particular criterion. But, the hard drive, until it becomes part of an information system strikes me as rather difficult to evaluate in a 508 context.

Doug

Nothing applies. Right. Same thing, memory chips? The key is how does the end user interact with it? The end user doesn't interact directly with the hard disk. There's an operating system in between and that's what can be accessible of inaccessible.

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