- From: Brian Kelly <b.kelly@ukoln.ac.uk>
- Date: Fri, 19 Oct 2012 10:30:43 +0100
- To: public-wai-evaltf@w3.org
The Web Accessibility Initiative’s work in providing guidelines which
can help enhance the accessibility of Web resources for people with
disabilities since WAI’s launch in 1997[1]
<http://ukwebfocus.wordpress.com/#ref-01>is to be valued.
However, as might be expected (and is the case with many of the
standards which have been developed over the years by W3C), the various
guidelines which have been produced by WAI have shown to have
limitations or proven inappropriate for use in a real-world context.
Accessibility researchers and practitioners based primarily in the UK
have been pro-active in identifying limitations of the WAI model and
proposing ways in which the guidelines can be contexualised and used
where appropriate. This work dates back to 2005 when a paper entitled
“/Forcing Standardization or Accommodating Diversity? A Framework for
Applying the WCAG in the Real World
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2005/>/” was presented at
the W4A 2005 conference [2] <http://ukwebfocus.wordpress.com/#ref-02>.
Further work included papers on /Contextual Web Accessibility –
Maximizing the Benefit of Accessibility Guidelines
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2006/>/ [3], A/ccessibility
2.0: People, Policies and Processes/
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/> [4], /One World, One
Web … But Great Diversity/
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2008/> [5], /From Web
Accessibility to Web Adaptability <http://opus.bath.ac.uk/14902/>/
[6],/Developing Countries; Developing Experiences: Approaches to
Accessibility for the Real World/ <http://opus.bath.ac.uk/18724/> [7]
and/A Challenge to Web Accessibility Metrics and Guidelines: Putting
People and Processes First/ <http://opus.bath.ac.uk/29190/> [8].
The abstract for our most recent paper [8] summarised the concerns we
have regarding the WAI model (which is based on three sets of guidelines
– WCAG, UAAG and ATAG):
“/This paper argues that web accessibility is not an intrinsic
characteristic of a digital resource but is determined by complex
political, social and other contextual factors, as well as technical
aspects which are the focus of WAI standardisation activities. It can
therefore be inappropriate to develop legislation or focus on metrics
only associated with properties of the resource./
/The authors describe the value of standards such as BS 8878 which focus
on best practices for the process of developing web products and include
a user focus./“
I have concerns that the WAI’s Website Accessibility Conformance
Evaluation Methodology 1.0 working draft
<http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/> [9] could be
counter-productive if it is used by policy-makers to mandate conformance
with WCAG, rather than treating WCAG as a valuable set of guidelines
whose use should be considered in context.
The WAI model itself provides one example of such contextual issues.
WAI’s view of what it refers to as ‘/universal accessibility/‘ is that
this requires conformance with WCAG, UAAG and ATAG guidelines. Since
browsers which do not conform with ATAG are not ubiquitous it is clear
that the values of WCAG conformance will be limited. In addition the
ways in Web content is created has changed drastically since WAI was
launched and the WAI model developed. Email messages sent to WAI mailing
lists, for example, will be Web content hosted on the WAI’s mailing list
archive on the W3C Web site. It is unlikely that such content will
conform with WCAG guidelines.
A recent post entitled “John hit the ball”: Should Simple Language Be
Mandatory for Web Accessibility?
<http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/>
[10] highlighted that WAI have acknowledged that conformance with the
current WCAG guidelines will n0t, as some people mistakenly think,
address all disabilities. However, as described in the post, providing
additional guidelines for incorporation in a future version of WCAG
would be inappropriate as guidelines which mandate use of simple
language would not be welcomed by everybody, for reasons described in
the post and a more in-depth post onThe complexities of simple: What
simple language proponents should know about linguistics
<http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/>[11]
by Dominik Lukes.
Beyond the limitations of the WAI model there are the contextual factors
regarding the purposes of Web resources (which the WAI document
highlights). The WAI model was developed at a time when the Web was
being used primarily as an informational resource, although we were also
seeing examples of commercial transactions being developed. But beyond
the provision of information and the purchasing of products which are
mentioned in the WAI document, there are also more complex areas such as
learning and cultural appreciation for which there is a need to develop
a better understanding of what is meant by such areas in a Web context.
It should also be noted that clarity provided on the scope of Web
resources provided in the WAI document may ironically lead to
organisations failing to provide Web resources which may provide
accessibility benefits to some if they fail to conform fully with WCAG
guidelines. This is likely to be particularly the case in the public
sector, who may be required to provide Web sites which conform fully to
WCAG guidelines.
In addition to dangers that this may lead to online resources failing to
be deployed, there is also a need to consider the costs of providing
resources which conform fully with WCAG guidelines, particularly at a
time of economic constraints. To give a particular example a paper
entitled Supporting PDF accessibility evaluation: early results from the
FixRep project <http://opus.bath.ac.uk/24958/> [12] analysed the
provision of metadata in PDFs of (typically) peer-reviewed papers hosted
in a university’s institutional repository and concluded:
/“This means that only 10% of all PDFs processed have any likelihood of
conforming to accessibility guidelines, and even then we would require
further content level analysis to evaluate the extent to which they do
indeed conform.”/
It is felt (although further research is needed) that these findings are
likely to be the case across institutional repositories more widely.
Should we require that peer-reviewed papers should not be hosted on
institutional repositories unless they conform with WCAG guidelines? If
such a decision is made, what will the financial implications be and
will “just-in-case accessibility” be an appropriate investment of scarce
financial resources?
In light of such issues (which are discussed in more detail in the
peer-reviewed papers which have been mentioned) what actions are
appropriate for the Website Accessibility Conformance Evaluation
Methodology 1.0 working draft
<http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/>? I would suggest that
the document should explicitly mention the limitations of the WAI model
(i.e. its dependencies of ATAG and UAAG) ; the need to address contexual
factors and the need to address accessibility issues in a broader
context including the context of use and purpose of the Web resource and
the financial implications of conforming with the guidelines.
Finally I would suggest that document makes it clear that it would be
inappropriate for policy-makers and legislators to enact legislation
based solely on WCAG conformance. I would hasten to add that this is not
to suggest that no interventions need to be made. Rather I would propose
that it would be more appropriate to develop policies and legislation
based on the processes surrounding the development of Web products as
suggested in A/ccessibility 2.0: People, Policies and Processes/
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/> [4]. In the UK, such
approaches have been described in the British Standard Institute’s BS
8878 Web Accessibility Code of Practice which is described at [13].
References
1. WAI Launch Agenda, WAI, http://www.w3.org/WAI/References/agenda
2./Forcing Standardization or Accommodating Diversity? A Framework for
Applying the WCAG in the Real World/ <http://opus.bath.ac.uk/438/>,
Kelly, B., Sloan, D., Phipps, L., Petrie, H. and Hamilton, F.
Proceedings of the 2005 International Cross-Disciplinary Workshop on Web
Accessibility (W4A). ISBN: 1-59593-036-1. http://opus.bath.ac.uk/438/
3. /Contextual Web Accessibility – Maximizing the Benefit of
Accessibility Guidelines
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2006/>/, Sloan, D., Kelly,
B., Heath, A., Petrie, H. Fraser, H. and Phipps, L. WWW 2006 Edinburgh,
Scotland 22-26 May 2006. Conference Proceedings, http://opus.bath.ac.uk/402/
4./Accessibility 2.0: People, Policies and Processes
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/>/, Kelly, B., Sloan,
D., Brown, S., Seale, J, Petrie, H., Lauke, P. and Ball, S. WWW 2007
Banff, Canada, 7-11 May 2007. http://opus.bath.ac.uk/398/
5. /One World, One Web … But Great Diversity
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2008/>/, Kelly, B., Nevile,
L., Draffan, EA. and Fanou, S. WWW 2008 Beijing, China, 21-22 April
2008. Proceedings of the 2008 international cross-disciplinary
conference on Web accessibility (W4A), Beijing, China. Pages 141-147,
Year of Publication: 2008. ISBN:978-1-60558-153-8 DOI:
http://doi.acm.org/10.1145/1368044.1368078
6. /From Web Accessibility to Web Adaptability/
<http://opus.bath.ac.uk/14902/>, Kelly, B., Nevile, L., Sloan, D.,
Fanou, S., Ellison, R. and Herrod, L.
Disability and Rehability: Assistive Technology, Volume 4, Issue 4, July
2009, pages 212 – 226. DOI: 10.1080/17483100902903408
7. /Developing Countries; Developing Experiences: Approaches to
Accessibility for the Real World/ <http://opus.bath.ac.uk/18724/>,
Kelly, B., Lewthwaite, S. and Sloan, D. W4A2010, April 26-27, 2010,
Raleigh, USA. Co-Located with the 19th International World Wide Web
Conference. Copyright 2010 ACM ISBN: 978-1-4503-0045-2
DOI: 10.1145/1805986.1805992 <http://doi.acm.org/10.1145/1805986.1805992>
8./A Challenge to Web Accessibility Metrics and Guidelines: Putting
People and Processes First/ <http://opus.bath.ac.uk/29190/>, Cooper, M.,
Sloan, D., Kelly, B. and Lewthwaite, S. W4A 2012, April 16-17, 2012,
Lyon, France. Co-Located with the 21st International World Wide Web
Conference. Copyright 2012 ACM ISBN 978-1-4503-1019-2
9. Website Accessibility Conformance Evaluation Methodology 1.0 working
draft <http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/>, WAI, 20
September 2012. http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/
10. /“John hit the ball”: Should Simple Language Be Mandatory for Web
Accessibility/?
<http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/>,
Kelly, B., UK Web Focus blog, 19 Sept 2012,
http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/
11.The complexities of simple: What simple language proponents should
know about linguistics
<http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/>,
Lukes, D. Metaphor Hacker blog, 28 September 2012,
http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/
12. Supporting PDF accessibility evaluation: early results from the
FixRep project <http://opus.bath.ac.uk/24958/>. In: /2nd Qualitative and
Quantitative Methods in Libraries International Conference (QQML2010)/,
2010-05-25 – 2010-05-28, Chania. http://opus.bath.ac.uk/24958/
13. BS 8878 web accessibility standards (supersedes PAS 78) – all you
need to know <http://www.hassellinclusion.com/bs8878/> , Jonathan
Hassell, http://www.hassellinclusion.com/bs8878/
--
--------------------------------------------------------
Brian Kelly
Innovation Support Centre, UKOLN, University of Bath, Bath, UK, BA2 7AY
Phone: 01225 383943
Email: b.kelly@ukoln.ac.uk
Blog: http://ukwebfocus.wordpress.com/
Twitter: http://twitter.com/briankelly
Web: http://isc.ukoln.ac.uk/
Received on Friday, 19 October 2012 09:31:05 UTC