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Re: Checkpoint 1.1 - PDF Accessibility

From: Dey Alexander <dey.alexander@its.monash.edu.au>
Date: Wed, 03 Sep 2003 22:56:02 +1000
To: "Carey, Rachel (Hiser)" <rachelc@hiser.com.au>
Cc: w3c-wai-ig@w3.org
Message-id: <3F55E4E2.20002@its.monash.edu.au>

I'm assuming the site is an Australian government site.  If that's the 
case, you should be aware that the Human Rights and Equal Opportunity 
Commission have given some advice on the use of PDF, viz:

"The Commission's view is that organisations who distribute content
only in PDF format, and who do not also make this content available in
another format such as RTF, HTML, or plain text, are liable for
complaints under the DDA."

See: http://www.hreoc.gov.au/disability_rights/standards/www_3/www_3.html

One of the main problems with PDF concerns accessibility issues 
associated with the document format--but this is only part of the 
problem.  Even when users have the technology required to access 
information presented in this format, there can be content elements 
which have not received appropriate treatment to support accessibily 
(like using structural formatting for headings, etc. or text equivalents 
for images).  Inappropriate treatment of non-text content elements also 
apply to the use of Word, RTF and HTML documents (although when using 
Word .doc format, the additional barrier of requiring the user to have 
the relevant software to open to the document is added into the mix).

 From my (completely non-legal) understanding of the DDA, any site whose 
publishing policy was to publish inaccessible content in inaccessible 
formats and then ask disabled users to
(a) take the extra time and effort required to make contact with the 
organisation, and
(b) wait until their request for accessible information was processed, 
would have a hard time trying to resist a strong legal challenge.

Legal issues aside, I don't think there's any way that such a site could 
claim Level-A let alone Level-AA compliance.

My advice--if the organisation is concerned about policy approaches that 
support accessibility, rather than just being able to make conformance 
claims--would be to contact HREOC for advice.  If you are able, contact 
Bruce Maguire. He has an extremely pragmatic, balanced approach.

Hope that helps.


Carey, Rachel (Hiser) wrote:

> Hi all,
> We are in the process of developing a non-US government web site that facilitates the exchange of large amounts of information, most of which exists as either Word or PDF files. While the word documents contain mostly textual information, a significant proportion of the PDF files contain detailed geographic maps and plans. Understanding the information contained in these maps and plans is central to effective use of the system. 
> We have no control over the authoring of these Word and PDF files (the web site simply facilitates the movement of them), and it is critical to the success of the system that users are able to provide information in both Word and PDF format. 
> Our question is this: what steps should we take in order to ensure that the site is Level-AA compliant?
> We are proposing that a short summary be provided of all textual Word & PDF documents, along with clear directions to users on how to get in touch with someone to request the information in another format or to have it read to them (an email link or telephone number).
> For maps and plans, we are proposing that a short two sentence summary be provided, along with clear directions to users on how to get in touch with someone to either request the information in another format or to have the maps and plans described to them (an email link or telephone number). From a practical standpoint, it is going to be extremely onerous to provide detailed descriptions of the visual information contained in the system. 
> Given the above considerations about the system itself, would the suggested steps above be considered Level-AA compliant? If the proposed approach is not Level-AA compliant, what steps should we take to ensure that the system does conform with the relevant Level-AA checkpoints?
> Thanks, 
> Rachel 
Received on Wednesday, 3 September 2003 08:56:12 UTC

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