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A question of interpretation

From: <tina@greytower.net>
Date: Tue, 9 Sep 2003 04:07:22 +0200 (CEST)
Message-Id: <200309090207.h8927Qr28810@localhost.localdomain>
To: w3c-wai-ig@w3.org

  As you all know, Greytower has been involved in a large - for Sweden -
 examination of Government website accessibility. Our experiences with
 the procedure and result were documented in my article at 


  The aftermath of the examination has proven interesting - in the
 Chinese fashion[1]. It has also taken up quite alot of my time, and
 I'd like to apologise to the people who have answers by private e-mail
 outstanding from me. I will get around to it.

  Before my question, a brief background. When we bid for the contract
 with the National Audit Office, ours was one of 16. The process for
 reviewing the bids followed standard purchase procedures in Sweden,
 and we were awarded the contract with the lowest bid as per law.

  However, the process was challenged by a company known as "Funka Nu".
 The entire business is public in Sweden, and the documentation
 available from the Court. After a review, the decision - now holding
 force of law - was that granting us the contract was correct.

  When the report was made public, the clamor started up again. A
 seminar was arranged by Funka Nu to offer critique against the report.
 The 92 government departments were all invited, though the number
 attending was somewhat smaller.

  The end result has been published, and leads to my questions. For the
 Swedish speaking members of the list, this article is at 


  Now to the actual questions raised. I will do my best to faithfully
 translate Funka Nu's arguments into English, and coherently present our
 response to them. I hope that people on this list will have time to
 give their own views.

  Before starting in on the comments and counter-comments, however, it
 must be said: the scope of the National Audit Office examination was that
 of (a) "normal" (Mr. and Mrs. Doe) users, (b) the disabled, (c) immigrants,
 (d) the elderly. Personally I feel that the WCAG can benefit all groups.

  I would also like to add that the decision to include the name of our
 critics was not taken lightly. However, this critique is very public in
 Sweden. Since the WAI-IG is archived for everyone to see, and respond, I
 feel it justified. The questions raised are important to how accessibility
 work is done in this country, and by the very nature of the EU, in Europe.

   Funka Nu's comment:
    The test method used does not follow WAI's recommended procedure
    for a website audit. Among other thing a proprietary, non-free
    product has been used for the analysis. A government department,
    or other independent reviewer, can not repeat the analysis to
    compare the results. Several goverment departments have had
    difficulty obtaining the test results when questioning the

   Our answer:
    The methodology used is, as described in our article, that of the
    WAI Preliminary Review. We have changed it only in response to two
    facts: all testing could not be done online, and testing needed to
    be done speedily. There were 92 different websites to test, and only
    22 days in which to test them. We accept that the way we described
    the methodology may have lead someone to believe that a method of
    our own invention were in use.

    However: we do indeed use a proprietary, non-free, tool for our
    testing. It is an inhouse system called siteSifter. It is our
    impression that the WAI testing guidelines does not specifically
    *demand* that one of the tools on the list be used for the
    methodology to be valid. Is this impression correct ?

    If using a tools listed on 


    is a requirement, which process has been used for selecting just
    these tools ? Is there a review tool testing system in place that
    ensures tool compliance ? If so, where ? I believe that several of
    those listed are also proprietary and non-free.

    Is it really the intent of the W3C WAI that an organization should
    purchase a specific tool - be it Bobby, siteSifter, or Sitevalet - in
    order to comply with the guidelines ?

   Funka Nu's comment:
    The Audit Office has interpreted all the checkpoints literally, and as
    if these had equal value. No concessions have been made for conditions
    specific to Sweden, or the development of assistive technology since
    the guidelines were written. If a flaw has been found that goes against
    a point in WAI, this flaw has automatically led to the checkpoint being
    marked as "failed", whether or not the flaw is serious or not.

   Our answer:
    This, to us, is the most puzzling of the critique. The WCAG 1.0 checkpoints
    are divided into three sets, priority 1, 2 and 3. As such they were
    tested, and as such they have been analyzed and reported. This is clear
    from the actual report, where results for each priority has been separately

    However: the question raised is one of re-interpretation and adjustment
    of guidelines. It is argued that since, in Sweden, all visually impaired
    users are given modern, well-updated, equipment[2] of the same type[3],
    there is no point in testing for other equipment. Nor is there any need
    to correct for these "other" systems.

    An argument is made that doing so will remove focus from the actual,
    important, accessibility work.

    Again, this raises another level of questions. It is, of course, not
    possible for the WAI-IG list to comment on the intent of the European
    Union, but I can personally not find any sign that their adoption of
    the WCAG 1.0[4] include any leeway for interpretation based on perceived
    national differences. It does, quite cathegorically, state that:

      "The Guidelines aim to be compatible both with earlier technologies
       and Web design tools and also with new technologies and tools, for
       example, with new types of Web browsers such as digital assistants
       and WAP telephones." - COM(2001) 529

    leading me to conclude that the European Union, for one, does not plan
    on "dissing" older technology, nor refuse to adopt new.

    When analysing the WAI and WCAG itself, including the section marked
    as "Considerations for Specific Contexts", I can find no mention that
    the guidelines are meant to be adjusted for region-specific cultural, 
    political, or even technical details. Is my interpretation correct ?

    I can personally see no meaning in applying the WCAG for use, for
    instance in the EU, if the guidelines are to be re-interpreted for each
    country or region. It is clear that there are parts of the Union, as
    there are parts of the world, where the level of technology may not be
    as "high" as in Sweden, but that - in my view - was part of the point
    of the accessibility guidelines.

    Have I misunderstood ? A conformance to a certain priority is one
    thing, but conforming to a certain, perceived, level of technology
    would seen to go entirely against the principles of accessibility.

  Finally, claims are being made - publically - in Sweden that
 The Swedish Agency for Public Management[5], The Swedish Disability Ombudsman,
 and the Swedish W3C Office are enganged in a joint project to reinterpret
 the WCAG for Swedish "realities".

  This, frankly, worries me. The claim has been made in seminars by people
 who "ought to know". I would like to invite comment on this from WAI-IG
 members, and in particular from W3C staff.

  Hopefully this overly long posting will not hinder anyone from commenting
 freely. In short:

    - Should conformance / accessibility reviews be performed ONLY with
      the listed tools ?

    - Should the WAI WCAG checkpoints be re-interpreted based on perceived
      technological differences from region to region ?

  Thankyou in advance.

  Yours sincerely,

                                  Tina Holmboe

  "May you live in interesting times" - Chinese curse.

  This is not correct. The process of receiving equipment is not an automatic
  one, nor is received equipment necessarily kept well updated.

  With a certain danger of being misinterpreted as a "religious zealot", it
  must be said that the equipment referred to is from Microsoft, running IE
  and Jaws.

  I believe it important to note that it is WCAG *1.0* which is adopted, and
  not WCAG [enter favourite version number].

  Responsible for the guidelines used on the Swedish 24-Hour Government
  project which is the basis for all of this.

 -    Tina Holmboe                    Greytower Technologies
   tina@greytower.net                http://www.greytower.net/
   [+46] 0708 557 905
Received on Monday, 8 September 2003 22:11:26 UTC

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