EIR Accessibility Exception Requests

With many Texas State agencies developing their information technology accessibility compliance plans, there is a need for accessibility exception requests (based on TAC 213.37 and TAC 217.37. While you could consider this a big fat loop hole that allows agencies to say…”We need an accessibility exception.” I see it as an opportunity.

Every exception form that is filled out will need to be reviewed by that agency’s accessibility coordinator. And the head of that agency will have to approve any exceptions, while documenting how reasonable accommodations will be handled as well as setting a time limit on the exception.

Every exception is a chance to help people see that making IT accessible is often easier than documenting exceptions. And if the agency understands the principles of universal accessibility, then the effort to make IT compliant ends up benefiting everyone.

With that said, I’m collecting a list of Electronic Information Resources (EIR) Accessibility Exception Requests to share with my colleagues. I hope you find this information helpful and that you use it to knock down barriers between people and information technology.

EIR Accessibility Exception Requests

You may wonder why a girl in Texas is referencing a university in California. Well, while CSU is far from Texas, they have taken a leadership role in accessible IT. In fact, CSU’s Accessibility Technology Initiative is a great model to examine. Closer to home, the Texas HHS Accessibility Center is another excellent state agency accessibility program

Are there any other EIR Accessibility Exception Request forms that you have found helpful? I’d love to know about them!

4 comments

  2. California State University also suggests documenting the following for all exceptions:

    Request that the vendor describe their capacity to respond to and resolve any complaint regarding accessibility of products or services. Require the name of a person and contact information for addressing accessibility questions and issues with the product.

    For every E&IT product or service accepted under the contract that does not conform to the accessibility standards (sole source, commercial non-availability, or a product that meets some but not all of the standards) and for which an exception does not apply, request from the vendor a plan and timeline by which accessibility standards will be incorporated into the product.

  3. Exceptions are fine and even more necessary due to the poorly written TAC 213.

    The real question is… How do you like broad exceptions for entire divisions or programs in an organization? How about entire classes of resources? The rules define no boundaries. You could do public info requests for the approved exceptions and see how agencies are actually using them. Most agencies aren’t even bothering, and some that are have broad exceptions. And rightly so, to be in compliance. No other choice.

  4. Ahh…but the reality is…it does not matter what exceptions an organization grants. An exception doesn’t protect you from lawsuits. It is just a process to make you think deeper about what you are doing.

    I always think…if I were standing before a judge in a court of law, would I be able to defend this exception as reasonable? Or would the judge look at me and say “you WILL make this accessible.”

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