Specifications

STATE OF CALIFORNIA
CALIFORNIA COMMUNITY COLLEGES
CHANCELLOR’S OFFICE
1102 Q STREET
S
ACRAMENTO, CA 95814-6511
(916)
445-8752
HTTP://WWW.CCCCO.EDU
August 2, 2002
To: Chief Instructional Officers
Chief Student Services Officers
DSPS Coordinators
Librarians
High Tech Center Directors
Community College Attorneys
From: Ralph Black
General Counsel
Subject: Closed captioning of audiovisual materials in video format
Legal Opinion M 02-22
The purpose of this advisory is to answer questions which have been raised by college officials
about the options available to colleges to ensure that students with disabilities are provided
equal, effective and legally-required access to audiovisual materials in video format.
Background
Title II of the Americans with Disabilities Act of 1990 (42 U.S.C. §§ 12131 et seq.), and sections
504 of the Rehabilitation Act of 1973 (29 U.S.C. §§ 794, as amended in 1998), prohibit
discrimination against persons with disabilities. Section 508 of the Rehabilitation Act of 1973
(29 U.S.C. 794d, as amended in 1998) and the implementing regulations (36 C.F.R. §§ 1194.1 et
seq.) issued by the federal Architectural and Transportation Barriers Compliance Board (Access
Board) require that electronic and information technology developed, purchased or used by
federal agencies must be accessible for use by persons with disabilities. Video or multimedia
products are covered by section 1194.24 of those regulations. (36 C.F.R. § 1194.24.)
The section 508 regulations are applicable to the states, and thus to the Chancellor’s Office and
its contractors and grantees, by virtue of the Assistive Technology Act of 1998. (29 U.S.C.
§ 3002.) All Chancellor's Office contracts and grants commencing after the new regulations
became effective on June 21, 2001, contain a provision requiring the contractor or grantee to
comply with the section 508 regulations. In addition, each district is asked to annually certify
that it complies with section 508 as a condition of receiving funds under the Technology and
Telecommunications Infrastructure Program (TTIP). Thus, community colleges are currently
required to ensure that information technology, or services or products purchased, leased, or
developed with TTIP funds or other funds received by grant or contract from the Chancellor's
Office (or any other state or federal agency), meet the section 508 standards. (Please see
M 02-22