Enclosure (12) to COMDTINST 5230.60A
SECTION 508 DETERMINATION AND CERTIFICATION FOR ELECTRONIC AND INFORMATION
TECHNOLOGY (EIT) PURCHASE REQUESTS
TO BE COMPLETED BY THE REQUIRING OFFICIAL (PURCHASE REQUESTOR)
Undue Burden Certification
Procurement of EIT that would impose an Undue Burden.
1. Actions required. The requiring official must provide this completed document to the procurement office
with the purchase request.
2. Further explanation. Approval of undue burden claims resides with the Secretary of the Department. The
servicing legal office should screen all requiring office claims of undue burden, with legitimate claims
forwarded to G-CIE for final review before submission to the Commandant. Requiring officials must address
how they will provide alternate formats upon request and forward the signed documentation to the servicing
contracting office to place in the procurement file.
For each provision of 36 CFR Part 1194 that an agency finds to be an undue burden, the Requiring Official
must explain below why, and to what extent, compliance with each such provision creates an undue
burden. A thorough, rational explanation is required. (The format may be expanded for additional space.
Relevant attachments are encouraged. Explanations must be adequate to survive protests and litigation
challenges.)
The data and findings providing the basis for my decision are the following:
1. Products or services required to meet the agency's needs:
2. Dollar value of the acquisition, including any options. State cost both with and without compliance with the
provisions of the standards:
3. Applicable Section 508 standards (see 36 CFR part 1194) that will be unmet:
4. Market research performed to locate commercial items that meet the applicable standards:
5. The undue burden (e.g. the significant difficulty or expense the Government would incur in order to comply
with a particular standard). If the monetary expense is deemed prohibitive, explain the costs and how they
were estimated.
a. Significant difficulty of compliance:
b. Significant expense of compliance:
c. Agency resources available to the agency's program or component for which the goods or service is being
acquired:
6. Alternative means of access that will be provided for individuals with disabilities to use the information or
data. (29 U.S.C. 794d(a)(1)(B)). Include effort, labor, costs and time required in the whole process to
implement the alternative means. (This information must be sufficiently detailed since it may be used in the
procurement process technical evaluation.)