ABF submission to Accessibility Requirements for People with Low Vision Working Draft

Dear W3C

I refer to the WAI’s invitation to review the Accessibility Requirements for People with Low Vision<https://www.w3.org/TR/2016/WD-low-vision-needs-20160317/> Working Draft due by 14 April 2016.

Please find below some comments from the Australian Blindness Forum (ABF). ABF is the peak body representing blindness, low vision and rehabilitation in the blindness sector in Australia. ABF represents 15 members and associates who are service providers and consumer groups in the blindness sector in Australia.

As Australia’s representative to the World Blind Union, the ABF also has strong connections with the international blind and vision impaired community.

Please find below some comments on the Working Draft provided by ABF members.

Overall comments:

·         the first half of the document is hard to follow as it is quite repetitive, even within the same paragraph. Suggest to make it more concise.

·         there are a lot of bold statements that would need to be removed or referenced appropriately:

o   For example in section 2.3: 'Some causes of low vision can be improved through surgery or medication, and it is not uncommon for someone to have deteriorating vision over several months, and then experience improved vision after treatment.' – this needs a reference or needs to be deleted.

·         the paper doesn’t mention or make reference to younger population of students with vision impairment who also have need to access electronic content, tools and technologies related to education.

·         there is jargon used which may be too technical for the person who has no experience with low vision and accessibility.

·         reading level may need to be adjusted - The Web Content Accessibility Guidelines 2.0 suggest we write content that requires reading skills no more advanced than lower secondary education level (roughly 9 years of education).

·         consistent identification  - If you use an icon to label a document in a format such as PDF, use the same icon throughout your site and write a consistent text alternative.

·         it may be useful for the paper to make reference to professionals or specialists that can assist a person to identify if they have issues with colour, contrast etc and to what extent.

·         reference to agencies that have specialists such as Orthoptists and Ophthalmologists may be useful.

·         It may be useful to include links to websites such as Blindness organisations and also Assistive/Adaptive Technology software suppliers.
Section 2.1

·         Need more precise definition of low vision.  The current definition is not very clear and does not refer to the fact that both eyes are affected when a person is considered to have low vision. Please see some reference material to assist with a more precise definition of low vision at the end of this email.*
Section 2.3

·         No mention of causes of low vision in younger population.

·         ‘Many people with decreased vision due to aging do not consider themselves as having a disability’ –this is a generic statement that may not be true or needs to be supported with a reference.
Section 2.4

·         Should say factors that impact on visual functioning rather than categories of visual impairment.

·         Replace ‘light sensitivity’ with ‘sensitivity to glare’.

·         Add ‘visual fatigue’ and ‘visual clutter’ to the list of factors that impact on visual functioning.
Section 2.4.1

·         Needs more precise definition of visual acuity.  Suggestion: Visual Acuity is a measure of the finest detail a person can perceive.

·         'Therefore, some people will have blurry vision (low visual acuity) no matter what.' This statement is not accurate and therefore not helpful, and should not be included.
Section 2.4.2

·         ‘Light sensitivity’ should be changed to ‘Glare sensitivity’. (Refer to attached article, A review of the impact of glare and fatigue on visual function, p54)
Section 2.4.3

·         Contrast sensitivity definition needs to be more succinct.  Suggestion –‘Contrast sensitivity determines the retina's ability to detect subtle differences in brightness or shading of grey between targets and their backgrounds’.

(source:  Fundamentals for Ophthalmic Technical Personnel by Cassin p167)
Section 2.4.4

·         Poor definition of Visual field.  Suggestion: “The visual field is a map of the extent of visual space seen without moving the eye” (Cassin p.219)

·         Should be 130 degrees vertical not 150 degrees.

·         Last paragraph of this section.  ‘For example, when a person with low visual acuity….to reduced visual acuity’.  This doesn't make sense and is not true.
Section 2.5:  Functional Vision

·         Paragraph after Issue 2.  Other factors – such as inflammation, medication, fatigue, environment, and task (add in lighting) – influence a person's effective (replace with functional) vision in a given situation.

·         Environmental factors include:

Add in ‘visual clutter’
Figure 10

·         Would not choose purple and green as examples of high contrast colours.  Perhaps some paler colours that are more contrasting to the black background.
Section 3.3.2

·         Would be good to include reference to any research or data that suggests fonts that are more easily read by people with vision impairment, such as sans serif font.
Section 3.3.3

·         Perhaps include words to say that capitalisation, italics, underlining can impact on the person's ability to visually discriminate individual letters or read a block of text.

*Low Vision definition

Low Vision

·         Low vision may be due to reduced visual acuity (VA) and, or reduced visual field (VF). The classification of low vision includes moderate and severe vision impairment and is thus used in the presence of visual acuity worse than 6/18 but equal to or better than 3/60, with both eyes open or the better eye, with presenting glasses or contact lenses, and in the presence of a permanent condition (Australian Government Department of Health and Ageing, 2013; World Health Organisation [WHO], 2010). Therefore children with low vision have a range of residual vision and may use a combination of magnification tools, including larger print, optical and electronic magnification aids and decreased working distance, to enable them to access printed information, such as worksheets or examinations (Farmer & Morse, 2007; Lueck, Bailey, Greer, Tuan, Bailey & Dornbusch, 2003). Children with low vision will experience difficulties when accessing visual information if they lack the appropriate tools that aid efficient use of residual vision (Lueck, Bailey, Greer, Tuan, Bailey & Dornbusch, 2003; Farmer & Morse, 2007).

·         “Low Vision – to be used for lesser degrees of vision loss, where individuals can be helped significantly by vision enhancement aids and devices”. Referenced on page 2 of the Colenbrander resource attached.

·         “The term "low vision" included in the previous revision has been replaced by categories 1 and 2 to avoid confusion with those requiring low vision care”. From the table below, it indicates that low vision is used to describe visual acuity between the range of 6/18 to 3/60. (Referenced in section H54.9 in the link below which is titled International Statistical Classification of Diseases and Related Health Problems 10th Revision (ICD-10)-WHO Version for ;2016 http://apps.who.int/classifications/icd10/browse/2016/en#/H53-H54)

-       Category

Presenting distance visual acuity

Worse than:

Equal to or better than:

0 Mild or no visual impairment

6/18
3/10 (0.3)
20/70

1 Moderate visual impairment

6/18
3/10 (0.3)
20/70

6/60
1/10 (0.1)
20/200

2 Severe visual impairment

6/60
1/10 (0.1)
20/200

3/60
1/20 (0.05)
20/400

3 Blindness

3/60
1/20 (0.05)
20/400

1/60*
1/50 (0.02)
5/300 (20/1200)

4 Blindness

1/60*
1/50 (0.02)
5/300 (20/1200)

Light perception

5 Blindness

No light perception

9

Undetermined or unspecified


* or counts fingers (CF) at 1 metre.

Note: The term visual impairment in category H54 comprises category 0 for mild or no visual impairment, category 1 for moderate visual impairment, category 2 for severe visual impairment, categories 3, 4 and 5 for blindness and category 9 for unqualified visual impairment.



Thank you for the opportunity to make comments on this working draft. Please contact me if you have any queries.

Kind regards
Jennifer


Jennifer Grimwade
Executive Officer
M 0499 018 779 | E jgrimwade@australianblindnessforum.org.au<mailto:jgrimwade@australianblindnessforum.org.au>
(Hours: Mon-Thurs 9am-3pm)

[ABFLogo (00000002)]
ABN 47 125 036 857
www.australianblindnessforum.org.au<http://www.australianblindnessforum.org.au/>
c/o PO Box 1188
Canberra  ACT  2601



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