612571295_Attachment 1_PWS.pdf

Enclosure 4a, PWS Page 1 of 10 Pages

2015/Version 9

PERFORMANCE WORK STATEMENT (PWS)

Award/Mod Effective Version Date

Contract Number:

Task Order Number:

Contractor Name Tracking Number:

Follow-on to Previous Contract and Task Order Number:

1. Contracting Officer’s Representative (COR).

a. Primary COR. See DITCO Additional Text G1 - Points of Contact

b. Alternate COR. See DITCO Additional Text G1 - Points of Contact

c. Property Administrator. See DITCO Additional Text G1 - Points of Contact

2. Contract or Task Order Title. Mail Screening and Delivery Services

3. Background. A mail screening five-year (FY20-FY24) agreement was in place between DISA and the Naval Supply Systems Command (NAVSUPSYSCOM) Postal Division at Join Bolling Anacostia Base on a reimbursable basis, however, we were recently notified that they no longer had the capabilities to provide this service. Not having mail and packages screened pose a huge threat to DISA personnel and mission, as any potential contamination could lead to disruption of DISA’s services and mission and most importantly, could lead to harm to any personnel exposed. Screening the mail at an offsite facility would prevent any potentially dangerous items from delivery to DISA until fully screened and cleared.

Reference GSA Mail Center Security Guide (5th Edition). Some applicable information contained herein includes:

GSA Mail Center Security Guide (5th Edition) Section 1.1.4: Single Room Mail Center Operations: Due to their minimal mail volumes or severe space limitations, many mail center operations are required to operate from a single room and frequently share a loading dock with other organizations or tenants in the building. These types of mail centers should seek to implement as many of the security capabilities found in larger facilities as possible. There are scalable, configurable, stand-alone, negative pressure mail rooms and small blast containment systems that can provide many benefits of systems designed for multi-room mail centers with large footprints.

GSA Mail Center Security Guide (5th Edition) Section 1.2.6: Deliveries for Senior Officials Some agencies may need to give extra care and attention to letters and parcels addressed to senior officials whose names or positions have increased visibility. Coordinate with representatives from the agency security provider and management (senior executives, executive secretariat, administrators, etc.)

to establish procedures for mail addressed to senior officials as needed.

GSA Mail Center Security Guide (5th Edition) Section 4.4: Mail Screening

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For efficiency and effectiveness, mail screening processes should be well-designed and properly integrated into the overall process of receiving, sorting, and delivering mail and parcels. A best practice is to identify and map out the current end-to-end mail receiving and delivery processes before inserting screening technologies or processes. When practical, mail screening operations should take place in a location isolated from other facility operations and separate from areas where personnel are screened.

Many aspects of screening technology selection will require a solid understanding of mail and parcel volumes, accountability procedures, transfer requirements, and courier routes. This is particularly important in small mail centers where a few individuals must perform multiple tasks sequentially. Process mapping enables the mail center manager to ensure the screening workflow does not create any unexpected security violations or unnecessary contamination.

Any deviation from approved procedures can easily lead to suspicious mail or parcels being missed or the inadvertent cross contamination of other items, equipment, facilities, or employees. Most screening procedures, including the visual identification of suspicious parcels, are focused on identifying threats (biological, chemical, etc.) while a few, such as x-ray scanners and vapor trace detectors, have multi-substance capabilities.

4. Objectives. The objective of this contract is to provide support services to the Mail Distribution Branch (J413) in support of the Agency mission. The contractor will be responsible for providing the following services:

• Daily pickup of mail and packages addressed to Defense Information Systems Agency (DISA) from the United States Postal Service (USPS) post office, United Parcel Service (UPS) and Federal Express (FedEx).

• Provide offsite facility for and perform x-ray and full screening for detection of Chemical, Biological, Radiological, Nuclear, and Explosives (CBRNE).

• Maintain full accountability and chain of custody of each item processed.

• Require personnel assigned to perform screening process to have, at a minimum, a Secret clearance due to the potential classification of correspondence received by our agency.

• Contain and report any positive results to local authorities and first responders for appropriate action.

• Deliver all mail and packages with negative test results for any of the hazards listed to DISA headquarters mailroom daily.

• Provide daily manifest, including tracking numbers for accountable mail being delivered.

• Provide monthly, quarterly, or annual reports, as needed.

5. Scope. The contractor shall provide x-ray and CBRNE screening functions at an off-site facility and provide all personnel, supervision, tools, materials, equipment, automation and trucks that necessary to perform all of the services required by the Mail Distribution Branch (J413) as defined in this performance work statement (PWS). All functions must be performed to the standards set in this requirement.

6. Performance Requirements. Daily pick-up, screening and delivery of all mail and packages addressed to DISA. The contractor will be responsible for ensuring the accuracy, timeliness, and completion of all tasks described in sections 6.1 through 6.4 of this PWS.

6.1 Drivers and Transportation

6.1.1 Driver Qualifications. The contractor shall provide qualified driver(s) with proper credentials to gain access to the base for daily deliveries to DISA. To obtain access to the base, driver requires (1) primary ID (REAL ID driver's license or passport) and (1) secondary ID (S.S. card, birth certificate, voter's registration card). Names on all IDs (primary & secondary) presented for vetting must match, otherwise

Page 3 of 10 Pages the IDs will not be accepted. An authorized government representative will act as sponsor for driver(s) provided by contractor.

6.1.2 Transportation. Contractor shall provide suitable transportation in the form of a vehicle large enough to accommodate an average of fifty large size packages. Vehicle provided must be covered for protection of goods against inclement weather and must have means to secure cargo area to maintain security of goods while in transit. Vehicles driven onto Fort Meade are required to be licensed, registered, inspected, and insured according to state and local laws in order to obtain a pass for the vehicle being used. Vehicles entering the post are subject to a 100 percent identification check and all vehicles are subject to inspection by Fort Meade Force Protection personnel. NOTE: Carrying of a firearm in a vehicle while on base is prohibited.

6.2 Task 1 – Collection of Mail and Packages: Contractor shall execute daily collection of mail and packages directly from commercial carrier’s warehouse locations at the addresses provided below, keep all collections secured in a locked or sealed vehicle, maintain 100% accountability of all items under their responsibility, and deliver to contractor’s designated location for screening. Contractor shall sign and accept responsibility for all mail and packages accepted from any of the commercial carriers and keep secured at all times. Performance of this task will be validated by unscheduled checks from government personnel. For this contract, daily refers to government business days (Monday through Friday, except holidays and/or special events).

• UPS – 14841 SWEITZER RD, LAUREL, MD 20707

• FEDEX EXPRESS – 2130 BALDWIN AVE, CROFTON, MD 21114

• FEDEX GROUND – 11900 TROLLEY LN, BELTSVILLE, MD 20705

• USPS – 2789 MACARTHUR RD, FORT GEORGE G MEADE, MD 20755

6.3 Task 2 – Screening

6.3.1 Screening Facility. Contractor shall provide a facility to perform the screening function of all mail and packages. Facility must have the means to lock and secure all mail and packages brought in and under their responsibility, with access to authorized personnel allowed to process DISA mail only.

Contractor shall also provide a designated and secured area to store any DISA mail pending processing or delivery.

6.3.2 Screening Equipment. Contractor shall provide properly certified and calibrated equipment to perform screening operations. Screening equipment shall consist of any equipment capable of performing x-ray functions and CBRNE testing. Performance of this task will be validated by contractor providing proof to the COR at beginning of each fiscal year.

6.3.3 Screener Qualifications. Upon receiving mail, contractor shall provide qualified personnel to perform the screening function of all mail and packages. Screeners must possess and maintain a valid SECRET security clearance. Screeners must also maintain current industry certifications for screening/testing of CBRNE threats. Performance of this task will be validated by contractor providing proof to the COR at beginning of performance and as needed at the request of the COR.

6.3.4 Screening of Mail and Packages. Contractor is responsible for performing screening of all mail and packages brought into their facility. Screening shall consist of x-raying and CBRNE testing. For any mail that tests positive, contractor shall contact local authorities and first responders to isolate, dispose of, and formulate necessary written reports. For mail testing negative, contractor shall provide a daily report to the government showing negative results prior to attempting delivery.

6.4 Task 3 – Delivery

6.4.1 Delivery of Mail and Packages. Contractor shall deliver all mail which tested negative for any harmful substances to DISA HQ warehouse building’s loading dock, located on Fort Meade, specifically at

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6906 COOPER AVE, FORT GEORGE G MEADE, MD 20755. Delivery shall occur same day as mail was picked up from commercial carriers to DISA no later than (NLT) 1500 ET Monday-Friday (except federal holidays). Contractor shall provide a detailed manifest with tracking numbers for all items being delivered.

Government personnel from the mailroom shall sign delivery manifest after verifying accuracy.

6.4.2 Reports: In addition to daily manifests, contractor shall provide daily, monthly, quarterly, and annual workload reports to the government.

7. Performance Standards.

Performance Standard Acceptable Quality Level (AQL) Methods of Surveillance Task 6.2 Collection of Mail and Packages

Performances occur with no required re-work at least 95% of the time. Problems that occur are minor and are resolved in a satisfactory manner.

Random inspections.

Task 6.3 Screening Performance occurs 100% of the time.

Inspection of daily report and random inspection.

Task 6.4 Delivery Performances occur with no required re-work at least 95% of the time. Problems that occur are minor and are resolved in a satisfactory manner.

Random inspections.

8. Incentives. N/A.

9. Place of Performance.

Mission Location: DISA Headquarters located at 6906 COOPER AVE, FORT GEORGE G MEADE, MD.

Place of Performance:

Pick up mail from commercial carriers daily at:

• UPS – 14841 SWEITZER RD, LAUREL, MD 20707

• FEDEX EXPRESS – 2130 BALDWIN AVE, CROFTON, MD 21114

• FEDEX GROUND – 11900 TROLLEY LN, BELTSVILLE, MD 20705

• USPS – 2789 MACARTHUR RD, FORT GEORGE G MEADE, MD 20755

Perform mail screening off-site at a contractor’s facility and deliver mail to DISA at 6906 COOPER AVE, FORT GEORGE G MEADE, MD.

Secondary Place of Performance – Contingency Only. As determined by the Contracting Officer’s Representative (COR), contractor employees may be required to work at a secondary place of performance (e.g., home, the contractor's facility, or another approved activity within the local travel area) in cases of unforeseen conditions or contingencies (e.g., pandemic conditions, exercises, government closure due to inclement weather). Additionally, the contractor may be required to account for the physical location of their personnel should this information be requested by the COR. Non-emergency/non-essential contractors should not report to a closed government facility. Contractor shall prepare all deliverables and other contract documentation utilizing contractor resources. To the extent

Page 5 of 10 Pages possible, the contractor shall use best efforts to provide the same level of support as stated in the PWS.

In the event the services are impacted, reduced, compromised, etc., the Contracting Officer or the contractor may request an equitable adjustment pursuant to the Changes clause of the contract.

10. Period of Performance. See contract for period of performance.

11. Security Requirements. This section supplements Block 13 of the Government provided DD Form 254, Contract Security Classification Specification. Contractors for this contract will have access to classified information in the performance of disposal activities at the SECRET level. The following security requirements shall apply to this effort.

The contractor shall coordinate visits with site Point Of Contract (POC)s providing at least a 72-hour notice (or according to each site security requirements) prior to any site access. Contractor personnel without security clearances performing any task under this PWS must be escorted by cleared DISA personnel (civilian, military, or contractor).

References:

a. DISA End User Access Agreement, 11 February 2021

b. DISA Policy Letter, Unauthorized Connections to Network Devices, 11 September 2013

c. DISA Instruction 240-110-8, Information Security

d. DISA Instruction 240-110-36, Personnel Security

e. DISA Instruction 240-110-38, Industrial Security

f. DISA Instruction 240-110-43, Insider Threat Program

g. DISA Instruction 630-230-19, Cybersecurity

h. DoD Manual 5200.01, Vol 1-3 Information Security Program, 24 February 2012

i. DoD Manual 5200.02, Procedures for the DoD Personnel Security Program, 3 April 2017

j. DoD Instruction 5200.48, Controlled Unclassified Information (CUI), 6 March 2020

k. 32 CFR Part 117, “National Industrial Security Program Operating Manual (NISPOM)”, 24

February 2021

l. DoD Instruction 5230.24, “Distribution Statements for DoD Technical Information,” January 10,

m. DoD Instruction 8510.01, “Risk Management Framework for DoD Systems,” July 19, 2022

11.1 Facility Security Clearance. Work performed under this contract/order is up to the Secret level.

Therefore, the company must have a Secret clearance and be able to obtain an interim or final Secret Facility Clearance from the Defense Counterintelligence and Security Agency Facility Clearance Branch within 60 days after award.

11.2 Security Clearance. All personnel performing on or supporting a DISA contract/order in any way shall be U.S. citizens. The personnel security requirements for this contract/order cover the individuals supporting the Task Areas delineated in the table below. Contractor personnel must possess the interim or final security clearance eligibility delineated in the table below when performance starts.

PWS Task / Subtask

Clearance Level

Level of Classified

Access Justification for Access to

Classified Task 6.3 Screening

SECRET N/A Does not require access to any classified systems. Clearance only required due to potential classification of mail contents (up to SECRET), in the event contents are exposed.

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11.3 Investigation Requirements.

11.3.1 All personnel requiring Secret access under this contract/order shall undergo a favorably adjudicated Tier 3 (T3) Investigation formerly known as a National Agency Check, Local Agency Check and Credit Check or Access National Agency Check and Inquiries as a minimum investigation. Enrollment into Continuous Evaluation current within 5 years and, reflected in DISS, would meet the requirement for a current PR.

11.3.2 The contractor is required to have personnel cleared with an interim or final Secret (as specified in the table located in section 11.2) at contract start date. If contractor personnel is replaced during performance of the contract, replacement personnel should also have interim or final clearance Secret (as specified in the table located in section 11.2).

11.4 Visit Authorization Letters (VAL). Visit requests shall be processed and verified through the DISS to Security Management Office (SMO) DKABAA10. DISS visits for contracts/orders are identified as “Other” or “TAD/TDY” and will include the Contract/Order Number of the contract/order in the Additional Information section. Contractors that do not have access to DISS may submit visit authorizations by e-mail in a password protected .pdf to the COR/ACOR specified in DITCO Additional Text G1 - Points of Contact.

*Prior coordination with the DISA COR should be made via email to ensure the VAL/ Visit Authorization Request (VAR)/ Visit Termination Notification (VTN) process is agreed upon and properly secure.

11.4.1 VAR Package. VARs must be received via email and require pre-approval from the assigned DISA COR five business days in advance of the report date. The VAL/VAR/VTN should be sent via email to the appropriate COR. The VAL/VAR/VTN should be sent using in a locked “Zip” file in one e-mail and then followed-up by another e-mail with the password to unlock the Zipped file, because it contains sensitive information covered by the Privacy Act.

Documents to include in the VAR Package:

1. Inter-office Memorandum (IOM)

2. DD Form 254 Prime and/or Sub (Good Standing approval emails for current option year)

3. Contractor VAL signed by the Contractor Facility Security Officer (FSO)

If DISS is not available, the VAL must contain the following information on company letterhead

• Company name, address, telephone number, facility security clearance

• CAGE CODE

• Contract/Order Number

• Name, SSN, date and place of birth, and citizenship of the employee intending to visit

• Certification of personnel security clearance and any special access authorizations required for the visit (type of investigation & date and adjudication date & agency)

• Name of COR/Alt COR

• Dates or period the VAL is to be valid

11.4.2 VTN Package. The Contractor FSO will forward a VTN letter to the DISA COR identified in the PWS/TO/Sub for all employees leaving the contract/task order/subcontract.

11.4.2.3 In addition, the DISA CORs and security managers shall inform the DISA Security Office when contractor personnel are removed for cause from a contract supporting DISA. This step is being added to prevent contractor personnel removed for security related issues from returning to DISA without appropriate vetting. This step will also provide security with pertinent information to make an informed decision regarding potential contractor employees’ access to secure facilities and sensitive information.

“For Cause” is information regarding an individual that falls into one or more of the actions or incidents

Page 7 of 10 Pages that are within one of the 13 adjudicative guidelines as cited in the Security Executive Agent Directive

(SEAD) 4.

The VTN must contain the following information on company letterhead

• Company name, address, telephone number, facility security clearance

• CAGE CODE

• Contract/Order Number

• Name, SSN, date and place of birth, and citizenship of the employee

• Name of COR/Alt COR

• Termination Date

• Reason for Termination

*Any VAL/VAR submitted without the above information will be denied.*

11.5 Security Contacts. DISA Security Personnel can be contacted for Industrial or Personnel Security related issues at (301) 225-1235 or via mail at:

Defense Information Systems Agency Defense Information Systems Agency ATTN: MP61, Industrial Security ATTN: MP62, Personnel Security Command Building Command Building 6910 Cooper Ave. 6910 Cooper Ave.

Fort Meade, MD 20755-7088 Fort Meade, MD 20755-7088

For Center or Directorate-specific security related matters, contact the Directorate or Center Security Manager at:

Name: Victor L. Gonzalez, Jr.

Phone Number: (703) 217-7466 E-mail: victor.L.Gonzalez2.civ@mail.mil

11.6 Information Security and other miscellaneous requirements.

11.6.1 Contractor personnel shall comply with all local security requirements including entry and exit control for personnel and property at the Government facility.

11.6.2 Contractor employees shall be required to comply with all Government security regulations and requirements. Initial and periodic safety and security training and briefings will be provided by Government security personnel. Failure to comply with Government security regulations and requirements shall require the company to provide the Government with a written remediation/corrective action plan; furthermore, failure to comply with such requirements can be cause for removal and the contractor will not be able to provide service on this contract/order.

11.6.3. Contractor employees with an incident report in DISS who have had their access to classified suspended will not be permitted to fill positions requiring access to classified information on a DISA contract/order.

11.6.4 The Contractor shall not divulge any information, classified or unclassified, about DoD files, data processing activities or functions, user identifications, passwords, or any other knowledge that may be gained, to anyone who is not authorized to have access to such information. The Contractor shall observe and comply with the security provisions in effect at the DoD facility. Identification shall be worn and displayed as required.

11.6.5 The authority for the contractor personnel to regain access must be granted by DISA Chief of Security.

mailto:victor.L.Gonzalez2.civ@mail.mil

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11.6.5.1 DISA retains the right to request removal of contractor personnel regardless of prior clearance or adjudication status, whose actions, while assigned to this contract, clearly conflict with the interest of the Government.

11.6.5.2 DISA retains the right to revoke contractor personnel access to DISA facilities and networks, who violates one or more of Security Personnel Adjudicative guidelines, harassment or violence in the workplace while assigned to a contract clearly conflict with the interest of the Government.

11.6.5.3 If contractor employee is accused of violating state or federal laws and/or Government professional conduct policies or regulations, then the Government may require that such contractor employee be removed from Government premises and/or that such contractor employee be removed from supporting this contract, pending the duration and outcome of a Government investigation if the Contracting Officer finds that the conduct or violation alleged has the potential to negatively interfere with contract performance or operations at a Government facility. Only the Contracting Officer can make such a request on behalf of the Government. Removal of contractor employee shall not negatively impact contract performance.

11.6.6 Contractor personnel will generate or handle documents that contain Controlled Unclassified Information (CUI) at the contractor facility. Contractor personnel will have access to, generate, and handle classified material up to SECRET level only at the contractor location(s) (Ref: Block 8 Place of Performance on DD254) and listed in the place of performance section of this document. All contractor deliverables shall be marked in accordance with DoDM 5200.01, Vol. 3, DoD Information Security Program: Protection of Classified Information; DoDI 5200.48, Controlled Unclassified Information (CUI);

and DoDM 5400.07, Freedom of Information Act Program, unless otherwise directed by the Government.

The contractor shall comply with the provisions of the DoD Industrial Security Manual for handling classified material and producing deliverables. The contractor shall comply with DISA Instruction 630- 230-19, Cybersecurity.

11.6.7 The Contractor shall afford the Government access to the contractor’s facilities, installations, operations, documentation, databases and personnel used in performance of the contract/order. Access shall be provided to the extent required to carry out a program of IT inspection (to include vulnerability testing), investigation and audit to safeguard against threats and hazards to the integrity, availability, and confidentiality of data or to the function of information technology systems operated on behalf of DISA or DoD, and to preserve evidence of computer crime.

12. Government Furnished Property (GFP)/Government-Furnished Equipment (GFE)/ Government- Furnished Information (GFI). No GFP will be provided under this requirement.

13. Other Pertinent Information or Special Considerations.

a. Identification of Possible Follow-on Work. N/A.

b. Identification of Potential Conflicts of Interest (COI). None.

c. Identification of Non-Disclosure Requirements. The contractor shall obtain and maintain Non- Disclosure Agreements (NDA) for each employee assigned to the contract/TO. Initial NDAs shall be signed within one week of contract/TO award, and NDAs shall be kept current through the entirety of the period of performance as employee turnover occurs. The contractor shall ensure that all employees assigned to the contract have executed NDAs on file as of the date of the Monthly NDA Status Report, which shall include names and NDA status of all current employees assigned to the contract.

Deliverable:

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PWS

Task#

Deliverable Title

Format Due Date Distribution/Copies Frequency and Remarks

13c. Monthly NDA Status Report

Contractor determined format

No later than end of the 1st week of each month

Standard Distribution*

Monthly

(NDA

status as of the end of the previous month)

*Standard Distribution: 1 copy of the transmittal letter with the deliverable to the Primary COR.

Control Number Control Name Control Enhancement Name

CM-4 Impact Analysis IR-4(10) Incident Handling/Supply Chain Coordination IR-6(3) Incident Reporting/Supply Chain Coordination MA-6 Timely Maintenance PE-3(5) Physical Access Control/Tamper Protection PL-8(2) Security and Privacy Architectures/Supplier Diversity PM-16 Threat Awareness Program RA-9 Criticality Analysis RA-3(1) Risk Assessment/Supply Chain Risk Assessment RA-3(2) Risk Assessment/Use of All-source Intelligence SA-11 Developer Testing and Evaluation SA-5 System Documentation SA-9(3) External System Services/Establish and Maintain Trust Relationship with Providers SI-7 Software, Firmware, and Information Integrity SR-11(2) Component Authenticity/Configuration Control for Component Service and Repair SR-11(3) Component Authenticity/Anti-Counterfeit Scanning SR-12 Component Disposal SR-2(1) Supply Chain Risk Management Plan/Establish SCRM team SR-3(1) Supply Chain Controls and Processes/Diverse Supply Base SR-3(2) Supply Chain Controls and Processes/Limitation of harm SR-3(3) Supply Chain Controls and Processes/Sub-Tier Flow Down SR-4(1) Provenance/Identity SR-4(2) Provenance/Track and Trace SR-4(3) Provenance/Validate as Genuine and not Altered SR-4(4) Provenance/Supply Chain Integrity — Pedigree SR-5 Acquisition Strategies, Tools, and Methods SR-5(1) Acquisition Strategies, Tools, and Methods/Adequate Supply

SR-5(2) Acquisition Strategies, Tools, and Methods/Assessments prior to Selection, Acceptance, Modification, or Update

SR-6 Supplier Assessments and Reviews SR-6(1) Supplier Assessments and Reviews/Testing and Analysis

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SR-7 Supply Chain Operations Security SR-8 Notification Agreements SR-9(1) Tamper Resistance and Detection/Multiple Stages of System Development Life Cycle

i. Training. Contractor employees may be required to take periodic mandatory training courses provided through the agency, such as records management training and other training required by statute, regulation, DoD, or DISA policy. No other training of contractor personnel shall be provided by the Government unless authorized by the Contracting Officer.

14. Section 508 Accessibility Standards.

E206 Hardware E206.1 General. Where components of ICT are hardware and transmit information or have a user interface, such components shall conform to the requirements in Chapter 4.

E302 Functional Performance Criteria

302.1 Without Vision. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that does not require user vision.

302.2 With Limited Vision. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that enables users to make use of limited vision.

302.3 Without Perception of Color. Where a visual mode of operation is provided, ICT shall provide at least one visual mode of operation that does not require user perception of color.

302.4 Without Hearing. Where an audible mode of operation is provided, ICT shall provide at least one mode of operation that does not require user hearing.

302.5 With Limited Hearing. Where an audible mode of operation is provided, ICT shall provide at least one mode of operation that enables users to make use of limited hearing.

302.6 Without Speech. Where speech is used for input, control, or operation, ICT shall provide at least one mode of operation that does not require user speech.

302.7 With Limited Manipulation. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that does not require fine motor control or simultaneous manual operations.

302.8 With Limited Reach and Strength. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that is operable with limited reach and limited strength.

302.9 With Limited Language, Cognitive, and Learning Abilities. ICT shall provide features making its use by individuals with limited cognitive, language, and learning abilities simpler and easier.