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Re: Standards vs. Guidelines (was: RE: Clear communication: (was RE: Re: Accessibility of "CHM" format resources)

From: David Woolley <david@djwhome.demon.co.uk>
Date: Wed, 8 Jun 2005 21:39:55 +0100 (BST)
Message-Id: <200506082039.j58KdtS03249@djwhome.demon.co.uk>
To: w3c-wai-ig@w3.org

> The answer, of course, is that industry and governments use Standards all

The demand comes from business rather more than governments.  Legislators
often produce laws that depend on concepts like "reasonable force" or
"without reasonable cause", or even "dangerous" or "reckless driving". 

I believe the UK disabilty legislation has terms like "equivalent service"
and "not excessive".  The UK government also publishes guidelines
on that legislation, which include the warning that they are not a
statement of the law.  (The US Section 508 does seem to have moved
towards the testable, but I seem to remember that the ADA is still

Businesses want testable rules because most businesses aim to operate
on the very edge of what is legal (or slightly over the edge - how many
offices have you seen where firedoors are never left propped open 
unattended?).  If they have to make judgements, they risk operating
too far within the law, which they perceive as reducing their profits
compared with other businesses that judge the boundary more accurately.

Laws which regulate businesses generally only exist because the
businesses would not otherwise do what the law demand.  Having
a law puts every business at a disadvantage, because they all
have to bear the compliance costs, whereas a business won't 
voluntarily put itself at a perceived disadvantage.

Industry guidelines often exist as self regulation, simply to prevent
a government from regulating.

The other people who like to have absolute standards are testing tool
developers.  Consultants also like them because it de-skills the

Civil services may need to use the standards because they are subject to
the law or have to set an example, but that is not the same as a 

> So, the issue here for me (as both a regulator and an implementer) is that
> the WAI has consistently failed to write measurable, testable standards FOR

Absolutely testable standards should form part of the technology standard,
not a separate accessibility one, e.g. HTML mandates img elements have
alt attributes.  However, where the real problems arise is in the
subjective areas.  It is easy to comply with having an alt attribute
(even if many sites don't) but it requires human judgement to decide
whether the value of the attribute is appropriate, and that is not
something that can be done with absolute repeatability.  Many pages
that comply with the testable "must have alt" rules do not comply
when you make a human judgement about whether the attribute is 
Received on Wednesday, 8 June 2005 21:30:14 UTC

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