Comments on Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT)

Our team is currently working to map Section 508 ICT requirements to WCAG 
2.0 by following the Guidance on Applying WCAG 2.0 to Non-Web Information 
and Communications Technologies. We are concerned that the following 
Section 508 ICT requirement will be lost based on the application of 3.2.4 
Consistent Identification to set of software programs.

Current Section 508 Technical Standards identifies the following 
requirement.

1194.21   Software applications and operating systems.(e) When bitmap 
images are used to identify controls, status indicators, or other 
programmatic elements, the meaning assigned to those images shall be 
consistent throughout an application’s performance.

We are having difficulty mapping this requirement directly to 3.2.4 
Consistent Identification while WCAG2ICT states that 
This (3.2.4) applies directly as written and described in Intent from 
Understanding Success Criterion 3.2.4 (also provided below), replacing 
“web pages” with “non-web documents” and “software programs”. 
With these substitutions, this success criterion would read: (for software 
programs)
3.2.4 Consistent Identification: Components that have the same 
functionality within a set of software programs are identified 
consistently.

Set of software programs is defined as:
group of software programs that are distributed together and that can be 
launched and used independently from each other, but that are interlinked 
each with every other one such that users can navigate from one program to 
another via a consistent method that appears in each member of the set

It appears that Set of Software programs does not apply to a single 
software program that has multiple pages, views or plugins that can each 
contribute a different set of images or a different meaning to the same 
image. For example, I could have a software program that is a single 
executable has an inbox view and a calendar view. There could be an image 
button that is an 'A' in a round circle. In the Inbox view, this image 
button could have the meaning "Archive" and in the Calendar view it could 
have the meaning "Add new meeting". Today this would fail Section 508 
technical requirements however since we have a single software program 
with multiple views, this would pass 3.2.4 as Note 5: Any software program 
that is not part of a set, per this definition, would automatically 
satisfy any success criterion that is specified to apply to “sets of” 
software (as is true for any success criterion that is scoped to only 
apply to some other type of content).

In this example the different views would not be independently launched 
from each other while there would be single executable that is launched, 
unless launching is also considered the opening of different views in a 
software application. 

Please clarify the intent of the guidance that 3.2.4 applies only to a set 
of software programs and not to an individual software program that may 
have multiple pages and/or views. 

Thanks,
Maureen (Moe) Kraft
IBM Accessibility 


Maureen Kraft
Accessibility Superhero, IBM Research
Littleton, MA / tel: 978-899-3114 
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