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

From: Mark D. Urban <docurban@nc.rr.com>
Date: Wed, 8 Jun 2005 19:04:50 -0400
To: "'David Woolley'" <david@djwhome.demon.co.uk>, <w3c-wai-ig@w3.org>


I appreciate your thoughtful, reasoned, response and that of many people who
have replied to me re: this post.

I'm concerned that you neglect the force of regulation as law.  While it is
true that many laws, such as 508 or ADA here in the States, say such things
as "reasonable accommodation" or "comparable access" , current legal
environs tend to force the regulations or standards (small "s") that are
promulgated to become the de facto legal definition of such subjective
words.  For example, a builder that follows the ADAG will generally not be
held liable if a wheelchair does not fit the ramp she has constructed.  

W3C is not meant as an academic consortium, considering the world as we
would wish it to be [sic].  It should exist to build a technical framework
for Web technologies for use by society - which includes business,
government, and all manner of citizen activities.  Thus, testable,
measurable Standards (capital S) - or Recommendations as W3C puts it -
should provide a framework for technical accessibility.  

I am fully aware that just because something is "able to be accessed" - the
definition of accessibility - does not imply usability.  But I might argue
that there is plenty of unusable content that is easily accessible - I often
have trouble just navigating the W3C site! (not WAI, Judy!)

I'm not trying to suggest that accessibility is a Boolean environment -
True/False, as it were.  Accessibility is a quality, and thus a site might
have more or less of it.  The important thing is that we create a yardstick
so that societies can pick a point along the yardstick and say "you must be
there or above" and then create incentives to be above the minimum mark.
Only then will you generate the business reason for going beyond "doing the
minimum" which you so eloquently describe.

A final note - I'm aware that WCAG 2.0 tries to address this issue.
However, there is still too much "do it this way" and not enough "do this
and measure your success by this metric".

OK - End of rant.  My apologies to the list for the length of this email,
but I wanted to put my thoughts to rest.  I'll post in another 3 years. 


-Mark D. Urban 
919-395-8513 (cell)
Chair, North Carolina Governor's Advocacy Council for Persons with

Keep up with the latest in worldwide accessibility at

-----Original Message-----
From: w3c-wai-ig-request@w3.org [mailto:w3c-wai-ig-request@w3.org] On Behalf
Of David Woolley
Sent: Wednesday, June 08, 2005 3:40 PM
To: w3c-wai-ig@w3.org
Subject: Re: Standards vs. Guidelines (was: RE: Clear communication: (was
RE: Re: Accessibility of "CHM" format resources)

> 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

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 23:05:08 UTC

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