IBM Comments to WCAG 2 May 17 Working Draft

Hello WCAG Working Group,
IBM is submitting the following comments on the May 17 WCAG 2.0 working 
draft.
Thank you,
Andrew LaHart
IBM Human Ability and Accessibility Center

The following comments are for the document: Web Content Accessibility 
Guidelines 2.0 (WCAG 2.0) 

1) Location: 2.2.1 Timing

Comment: The text “(for example, "hit any key")”, is a poor example 
because it is rarely possible for ANY to be used.  Also, users have been 
known to be confused by this prompt.

Suggested change:  Change (for example, "hit any key") to (for example, 
"press the space bar").

2) Location: 2.2.1 Timing, Essential Exception bullet

Comment:  “Time limits that can not be extended further without 
invalidating the activity” seems to be a clarification of what “essential” 
means rather than an additional idea. Suggest simplifying. 

Suggested change: Change “the time limit is part of an activity where 
timing is essential and time limits can not be extended further without 
invalidating the activity” to “the time limit can not be extended further 
without invalidating the activity.”

3) Location: 2.4.3 Focus Order 

Comment: Please add an example in the How to section of this guideline to 
show an example of a form (like composing an email message) in a Web page 
with left side and top navigation bars. If the form controls all have 
tabindex values greater than zero and the navbars have no tabindex values, 
will this page meet the success criteria?

4) Location: 2.4.5 Multiple Ways

Comment: Please clarify what is meant by the term "content". Does content 
only include visible content or does it also include alternative content 
such as alt text, title text, etc. Please clarify.

Suggested change: Make “content” a link to the glossary term “content”.

5) Location: 2.4.9 Section Headings

Comment:  Please change this guideline from “Section Headings” to “Section 
Headings and Titles”. This is because the heading element is not the only 
sufficient technique. Developers can also use the title attribute of a 
frame and ARIA live region properties as well to meet this guideline.

Suggested change: Change “Section Headings” to “Section Headings and 
Titles” or something similar.

6) Location: 2.4.9 Level Headings 

Comment: This may not be testable. If the content doesn’t include any 
headings, then what constitutes a section? The text would be all 
paragraphs, so would this require putting a heading on every paragraph?

7) Location:  Important New Terms Used in WCAG 2.0, under sufficient 
techniques section

Comment: These two sentences are hard to understand: 
“Note that it is not necessary to meet a success criterion using one of 
the sufficient techniques that have been documented by the WCAG working 
group. There may be other techniques which are not documented by the 
working group that would also meet the success criterion.”

Suggested Change: Change the first sentence to “It may be possible to meet 
a success criterion without  using any of the techniques listed.”  The 
positive version of the sentence is easier to understand.

8) Location: Important New Terms Used in WCAG 2.0, under Programmatically 
Determined  section:

Comment: The reference hyperlinks for user agents and assistive 
technologies should go two sentences earlier, the first time they are 
used. 

9) Location: 3.3 Help users avoid and correct mistakes

Comment: Minor sentence change

Suggested Change: Change “Help users avoid and correct mistakes” to “Help 
users avoid mistakes and correct them”

10) Location: 3.3.1 Error Identification 

Comment: The word automatically is not needed in this sentence: “If an 
input error is automatically detected…”

Suggested change: Delete the word “automatically”.

11) Location: 3.3.3 Error Prevention (Legal, Financial, Data) 

Comment: There should be a sentence indicating the preference order of #1, 
#2, and #3. (1 is the best, 3 can be a waste of time)


The following comments refer to the test procedures in the Techniques for 
WCAG 2.0 document.

12) Location: Technique H2: Combining adjacent image and text links for 
the same resource

Comment: A new code sample would be helpful

Suggest change: Add the following code sample as a failure for this 
technique:

        Example: the image has a text alternative which is a duplicate of 
the link text
        <a href="products.html">
          <img src="products.gif" alt="Products page"/>
          Products page
        </a>

13) Location: Technique: H21: Not specifying background color, not 
specifying text color, and not using CSS that changes those defaults

Comment: #3 and #4 in the test procedure uses the term “image”, although 
it is not clear what kind of image the document is referring to. Also, the 
last part of the technique is about "not using CSS that changes those 
defaults", but there are no test procedures to verify that CSS is no being 
used. 

Suggested Change: Change “image” in #3 and #4 to “image used as a 
background”. Also, add a test procedure to show how users can test that 
CSS is not being used. 

14) Location: Technique H39: Using caption elements to associate data 
table captions with data tables

Comment: The test procedure and expected results are confusing. 

Suggested change: Rewrite the test procedures as suggested below: 
Procedure
        1. For each table, determine whether the content has a 
relationship with other content in both its column and its row.
        If “no," the table is a layout table, if “yes." the table is a 
data table.
        2. If the table is a layout table, check that the table does not 
include a caption element
        3. If the table is a data table and it includes a caption element, 
check that the caption identifies the table
        4. If both a summary attribute and a caption element are present 
for this data table, check that the summary does not duplicate the caption
Expected Results
        For layout tables, #2 is true.
        For data tables, #3 and #4 are true

15) Location: H52: Using the body of the applet element

Comment: This technique is already covered under technique "H35: Providing 
text alternatives on applet elements". 

Suggested change: Remove this technique

16) Location: Technique H64: Using the title attribute of the frame 
element

Comment: Please add information and testing procedures for the iframe 
element.

17) Location: Technique H73: Using the summary attribute of the table 
element to give an overview of data tables

Comment: The test procedure should also test for layout tables. (This 
situation is similar to the suggested test procedure for technique H39 
above)

Suggested Change:
Procedure
        1. For each table, determine whether the content has a 
relationship with other content in both its column and its row:
        If “no," the table is a layout table, if “yes." the table is a 
data table.
        2. If the table is a layout table, check that the summary 
attribute is not present or summary attribute is null
        3. If the table is a data table and a summary is present, check 
that the summary attribute describes the table's organization or explains 
how to use the table
        4. If both a summary attribute and a caption element are present 
for this data table, check that the summary does not duplicate the caption
Suggested Expected Results
        For layout tables, #2 is true.
        For data tables, #3 and #4 are true