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Initial WCAG-EM Comments

From: Greg Gay <g.gay@utoronto.ca>
Date: Tue, 27 Mar 2012 14:35:30 -0400
Message-ID: <4F720872.50806@utoronto.ca>
To: public-wcag-em-comments@w3.org
CC: Greg Gay <ggay@ocadu.ca>
WAC-EM Feedback

Good to see these methodologies coming together. They are surprisingly 
close to what we currently do now when evaluating Web content accessibility.

I have just a few quick comments at this stage, but will try to offer 
more as the document develops

Step 1.b  Goal of Evaluation

We have a similarly defined  “Basic Conformance” review called a 
“Followup Review” which comes after our General Review (our combined 
detailed and in-depth review as defined in WCAG-EM). All reviews we 
offer include identification of problems and suggested solutions. A 
followup (Basic Conformance) happens after the site’s developers have 
applied recommendation in the General Review, typically followed by a 
conference with the developers to address any questions or concerns 
raised by the General Review.

We have found it useful for more efficient reviews to review the 
“templates” or common navigation elements, page layouts and presentation 
structure etc. as one type of review, and have a second type of review 
that focuses on the content that appears within the templates. This 
eliminates the need to repeat common issues found across pages when 
reviewing individual pages in the review sample.  Perhaps more aptly 
named a “common elements” review. In many cases addressing the issues in 
the templates addresses a large majority of access problems for sites. 
They are also quick to produce, providing clients with an economical 
review that addresses the bulk of potential problems on a site.

Given sites now-a-days are typically template driven, in addition to 
detailed and indepth reviews, I would suggest a “common elements” review 
be included as another type or goal of evaluation. Because the issues 
associated with template accessibility tend to differ from issues 
typically identified for content, I believe a review of templates should 
be separate from a review of content, and be handled apart from the 
“Representative Sample.” The vast majority of sites implement only 2 or 
3 templates, so a review is typically inexpensive and attractive to 
organizations that want to address accessibility as best they can, but 
don’t have a big budget. We generally promote these reviews as “the most 
bang for your buck. ”

Also, our “Detailed Review” is available as an “every page” review, 
though we typically don’t do these reviews on Web sites, instead 
limiting them to Web applications that have specific release numbers. 
Only in our detailed review do we state a level of conformance, since it 
is the only type of review where we can confidently say the application 
or site conforms. Issuing a conformance statement based on a sampling of 
pages can potentially put evaluators in legal peril should a user of a 
reviewed site come across inaccessible content that was not included in 
the review sample, decide to sue a site’s owner who may in-turn sue the 

I might suggest replacing “Basic Conformance” and instead use “Basic 
Review” since conformance cannot be determined from a sampling of pages. 
  Also see comments on Section 5, below.

Step 1.c Conformance Target
Though we do suggest a conformance target that realistically reflects 
the effort that might be required to reach a level of conformance 
(Typically Level AA),  or we make target level recommendations based on 
legal requirements, we always provide a review of Level AAA items and 
encourage developers to address as many of them  as is feasible, some of 
which are relatively easy to implement. Step 1.c  reads as if  review of 
AAA items is optional.  I might suggest a little stronger language here. 
  Rather than “In many situations it is useful…” perhaps use “Reviewer 
should also evaluate Level AAA….”

Section 5. Limitations of this Methodology
As mentioned above regarding detailed reviews as the only one that can 
potentially include a conformance statement, I believe there should be 
strong language around the issuance of conformance statements, and when 
they are appropriate to make.  Inevitably suits will arise, and 
evaluators are putting their necks on the line if they start using the 
word “conformance.”

But, I’ll wait and see how this section evolves. Dates are also 
important in a conformance statement.

Received on Tuesday, 27 March 2012 18:34:12 UTC

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