Enclosure (6) to COMDTINST 5230.60A
3. Legacy systems and task orders - Legacy systems are generally those built on a variety of old
operating systems including Unisys CTOS, UNIX, and Mac OS. These systems periodically require
patches, modifications, or something less than new versions of the software, to update, enhance or
fix their processes. The incorporation of a modification or update will not necessarily make the
overarching software package subject to Section 508 enforcement. However, the modifications
themselves, as opposed to the underlying software, must conform to the provisions of the standards.
In the case of legacy systems, software patches or other modifications are likely to become so
inextricably linked to the system at large that the contractor will be unable to make any particular
software patch conform with the provisions of the standards without completely re-writing the entire
system. In a hypothetical case, rewriting the entire system is not within the scope of the task order;
but the contractor will be required to determine what can be done to make the patch conform as
much as possible. As stated earlier, agencies are not required "to retrofit" existing technologies.
However, Federal employees and members of the public with disabilities still have rights under
Sections 501 and 504 that require agencies to make information available to them in an alternate
format. In some cases, an analysis may reveal that the effort and cost of retrofitting existing
technologies may be preferable to making the information available in alternate formats.
4. USCG procurements containing EIT must include at least one of the "Section 508 Determination
and Certification for EIT Purchase Requests", Enclosures (7) through (12), in the procurement file.
Legal counsel review is required for Enclosures (11) and (12) and is recommended for Enclosure
(7). Approval levels for the certifications are found in the Certification Approval Matrix.
5. A blanket certification can be approved by the requiring official and provided to the contracting
officer for all procurements (i.e. delivery, task orders) falling under umbrella agreements such as
indefinite quantity indefinite delivery contracts and blanket purchase agreements for recurring and
repetitive buys. This blanket certification may be provided to the contracting officer in lieu of the
recurring statement of compliance for Section 508 on each purchase request. The blanket
certification must be made available to all interested parties, such as placing the certification on a
webpage relating to the EIT procurements for the program office.
2
Previous Page
