Social Security Administration Response to Proposed WCAG 2.0

The Social Security Administration welcomes the opportunity to comment on the proposed WCAG 2.0 standards.  In general, SSA finds that the general content of the proposed standards addresses many shortcomings of the previous version of the standards.   In addition, the baseline concept for establishing a testing environment provides excellent direction for accessibility and validation testing.   However, SSA has some concerns that should be addressed before the final version is published.

§         The principles are broken down into 4 simple components - perceivable, operable, understandable and robust, which we agree is an excellent way to structure the standards at a high level.  However, the explanations and further breakdown tend to be confusing and navigation through the 400 plus pages is unwieldy.  As a result - it can be difficult to determine if appropriate standards exists to guide development activities. 

§         Specific techniques for meeting the guidelines are very scientific and precise, however from a pragmatic perspective will be difficult to implement due to focus on mathematic calculations to address unfamiliar issues such as luminosity and audio levels. 

§         Success criteria in some cases are very general and in need of further definition to support proper implementation (for example:  minimal level of accessibility is defined as the target - but the criteria for meeting this requirement are not defined). 

§         The guidelines do not address the following:

§         Alt text for images, links, etc. that are normally exposed by mouse over capabilities must also be accessible by the keyboard.

§         For error handling, there must be a way for users to know where errors are in a form and be able to navigate directly to the input in error.

§         Guidelines for creating HTML documentation and Help must be stated and Help using navigational techniques must also be documented for accessibility.

§         Informational text and instructions within web applications must have a focal point achieved by using tab indices of zero or some equivalent technique.

§         Applets and plug-ins used with web pages or applications must be referenced with specific guidelines for accessibility.

§         Standardized keyboard navigation through frames. 

§         Search facility guidelines for navigation and focus.

§         Mark-up of textual information for carets and other pointers.

§         Avoiding conflicts between browser and web application commands.

 

§         In addition, we recommend the W3C address the following items at a later date:

§         Guidelines should provide additional guidance and examples are needed to address user navigation to errors once they are identified. 

§         Guidelines should address keyboard access, however additional guidance is needed for when to assign hotkeys, defining logical tab order, hotkeys shown on buttons, and defining tab indices for text focus and search functionality.  Also, guidance is needed to determine what is an acceptable number of keystrokes to perform the equivalent of one mouse action to provide comparable access.

§         Guidelines should address e-learning considerations, such as navigation, registration, administration, courseware, simulations, test taking, and reporting results.

§         Guidelines should address context sensitive help built into the HTML structure.

§         Guidelines should address table navigation for magnification users.


 
Respectfully,
Robert Baker
 
____________________________________________ 
[ robert baker ] 
section 508 coordinator 
accessibility resource center 
social security administration 

410.966.7602 
robert.c.baker@ssa.gov 

"Accessibility for Everyone" 
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