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

Moe

I’m afraid that your analysis and concerns are 100% correct! Everyone in the WCAG2ICT Task Force recognised that the real accessibility concerns were similar to your 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".

We recognised that if we wanted to capture the true intent of 3.2.4 and of 1194.21 in Section 508 we would need a generic term to describe things like the different views within a single software program that you refer to in your example. We also needed this term to apply to the other success criteria that refer to a set of web pages (2.4.1, 2.4.5 and 3.2.3).

Loïc Martinez Normand and I suggested “interaction context” to be the equivalent of web page (with a software program being equivalent to a set of web pages). The initial attempt to define interaction context was based on:

"Interaction contexts are the places within the user interface of a system where the users interact with all the functions, containers, and information needed for carrying out some particular task or set of interrelated tasks"

Taken from: Constantine, Larry L.; Lockwood, Lucy A.D. "Software for Use: A Practical Guide to the Models and Methods of Usage-Centered Design". Addison-Wesley Professional. 1999. [Excerpt from Chapter 6].

Some Task Force members expressed concern that this definition was insufficiently precise and that there could be many cases where it was unclear if a particular dialog box, tab, window, view, etc. was a separate interaction context. Because many of us believed that we needed such a term in order to make the correct mapping to web page, there was an exchange of hundreds of emails over a five month period refining and testing alternative definitions.

In the end we failed to reach consensus and hence the “set of software” “solution” was proposed. This simple mapping of web page to software program made it possible to reach consensus on a “correct” wording, but many of us were concerned that this interpretations of the success criteria failed to address any real-world accessibility concerns. I am therefore not surprised to hear that you also feel that the wording in the TF Note misses the real accessibility concern that 3.2.4 and 1194.21 address.

The team that drafted EN 301 549, the European equivalent to Section 508, almost unanimously reached exactly the same conclusion and, as a result felt that they had no option but to omit all of the “set of software” success criteria from the software part of EN 301 549. Because the current proposed Section 508 text just refers to the TF Note, it does not allow suppliers or procurers to make such a judgement. If they diligently want to comply they have to:


-        Puzzle over the meaning and relevance of a “set of software”;

-        Search for the rare and elusive “set of software”;

-        Evaluate whether 2.4.1, 2.4.5, 3.2.3 and 3.2.4 are met (the general feeling in the TF was that several of these are likely to be automatically met);

-        Report the successes and failures for each of these.

Whether you go through this exercise to try to meet Section 508 or you meet all the requirements in EN 301 549 and avoid having to evaluate sets of software, you will still have failed to address the real accessibility issues that 2.4.1, 2.4.5, 3.2.3 and 3.2.4 were written to address

It still worries me that a failure to get consensus on a definition of “interaction context” (or similar) has resulted in a failure to have any relevant way of applying 2.4.1, 2.4.5, 3.2.3 and 3.2.4 to software. It also means that there will be nothing relevant to replace 1194.21 in the current Section 508.

If people want the TF Note to have wordings for 2.4.1, 2.4.5, 3.2.3 and 3.2.4 that allow the true intent of these success criteria to be applied to software then it will be necessary to rethink how to map a web page to the parts of a software program that Moe refers to in her email. If none of the initial attempts at alternative definitions for “interaction context” are acceptable then perhaps some new brains can propose something that could be widely accepted.

Best regards

Mike

From: Moe Kraft [mailto:maureen_kraft@us.ibm.com]
Sent: 04 February 2016 20:10
To: public-wcag2ict-comments@w3.org
Cc: Michael Gower <michael.gower@ca.ibm.com>; Marc Johlic <johlic@us.ibm.com>
Subject: 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<http://www.w3.org/TR/2013/NOTE-UNDERSTANDING-WCAG20-20130905/consistent-behavior-consistent-functionality.html#consistent-behavior-consistent-functionality-intent-head> (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<http://www.w3.org/TR/2008/REC-WCAG20-20081211/#samefunctionalitydef> within a set of software programs<https://www.w3.org/TR/wcag2ict/#wcag2ict-def_set-of-software>are identified consistently.

Set of software programs is defined as:

  *   group of software<https://www.w3.org/TR/wcag2ict/#wcag2ict-def_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 examplethe 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
________________________________

[cid:image001.jpg@01D15FF5.4E719D70]<http://www.ibm.com/able>

Maureen Kraft
Accessibility Superhero, IBM Research
Littleton, MA / tel: 978-899-3114
Search for accessibility answers<http://ibm.biz/a11y-search> [cid:image002.jpg@01D15FF5.4E719D70]

… to know even one life has breathed easier because you have lived. This is to have succeeded. ~Ralph Waldo Emerson



[cid:image003.gif@01D15FF5.4E719D70]