H65: Using the title attribute to identify form controls when the label element cannot be used

Hi All,

I have a question that I'm hoping someone may be able to help with regarding technique H65: Using the title attribute to identify form controls when the label element cannot be used.

This technique is about using a title attribute to describe a form element where a label element can't be used for whatever reason, and relates to several success criteria as listed in the link below:

http://www.w3.org/TR/2012/NOTE-WCAG20-TECHS-20120103/H65

I'm evaluating a web page where this technique has been used in a slightly different way. The descriptive title attribute has been applied to a span element that wraps the form element, rather than directly to the element itself, simplified code snippet follows:

<span title="description of form element"><input type="radio" /></span>

My question is, is this sufficient to meet the various success criteria? I kind of assumed that it wouldn't be, but when I tested with IE9 and JAWS12 it seemed to work just the same as if the title attribute was directly on the form element.

Does anyone have any experience with this? Is the JAWS / IE behaviour likely to be repeated with other browser / AT combinations?

Many thanks in advance,

Phil Spencer.