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Re: Procurement requirements around accessible digital books

From: Greg Alchin <gregalchin@me.com>
Date: Fri, 18 Dec 2020 14:48:21 +1100
To: W3C EPUB 3 Community Group <public-epub3@w3.org>
Message-Id: <15CC4D85-557E-42A9-BC27-1C7A34373A5D@me.com>
Dear All
I am working with education providers in Australia and we are in the process of developing a consistent approach around the implementation of accessibility requirements in the procurement of digital books and textbooks. Just as we don’t buy a car or house that isn’t built to standard nor do Education providers buy books that are not to standard. 

Essentially participating school systems will advise their Principals they should not  procure a digital book that doesn’t meet accessibility standards. 
Publishers will need to certify that each book  meets those standards for that book to be considered as fit for procurement. 

I anticipate a go live some time around March/April 2021 with a phased implementation during 2021 and a hard cut off beginning November 2021.

Outlined below is a draft of the current requirements document.Any and all constructive comment and feedback is most welcomed..
Digital book procurement requirements

<<Insert Education provider>> requires that any digital product (content, digital book, software hardware or services) it procures must be designed to provide equal access of use for all their intended users, be they students, staff or community. This procurement requirement supports us  to meet our obligations under the United Nations Convention on the Rights of Persons with Disabilities <https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-disabilities.html>, Disability Discrimination Act <https://www.legislation.gov.au/Details/C2018C00125> (DDA), the Disability Standards for Education <https://www.legislation.gov.au/Details/F2005L00767> (DSE), Marrakesh Treaty <https://www.communications.gov.au/policy/policy-listing/marrakesh-treaty-people-print-disability> and Australian Standard 301 549 <https://infostore.saiglobal.com/en-au/standards/as-en-301-549-2016-100620_saig_as_as_211428/> (Accessibility requirements suitable for public procurement of ICT products and services). To achieve our obligations, <<Insert Education provider>> will only consider procuring digital books that meet the following technical requirements:  

Technical requirements

1.  Designed to the EPUB 3 standard <https://www.w3.org/publishing/epub3/epub-spec.html> as outlined by the Publishing@W3C's EPUB 3 Working Group. 

2.  Compliant with the content conformance and discovery requirements <https://w3c.github.io/epub-specs/epub33/a11y/#sec-access-pub> for verifying the accessibility of EPUB publications.

3.  Works seamlessly with the inbuilt accessibility features/assistive technologies found on mainstream devices running iOS 14, iPadOS 14, macOS 11,  Windows 10 or above, Android and Chrome OS. 

4.  Capable of providing the structure, technical functionality, and design to meet the following functional performance statements:

Usage with no or limited vision
Usage without perception of colour
Usage without hearing
Usage with limited hearing
Usage with no or limited vocal capability
Usage with limited manipulation or strength
Usage with limited reach
Minimize photosensitive seizure triggers
Usage with limited cognition, language or learning


Any digital product procured by <<Insert Education provider>> as of or after the << date TBA>>, that fails to meet these requirements is deemed not fit for purpose and entitles the purchaser to a full and immediate refund. Payment of products that are partially compliant will be held over until such time as compliance has been achieved. 

Publisher certification

We certify that our publication meets these NSW Department of Education procurement requirements and can on request provide technical evidence of the products accessibility compliance.

 <<insert title>>,

<<insert ISBN>>:     Publication date:

Name:                                                                                    Position:


Signature:                                                                  Date:


Greg Alchin | Inclusioneer
ALL EQUAL - inclusive content, services and spaces
M: +61403273063 | E:all.equal@icloud.com <mailto:all.equal@icloud.com>

“I am an Inclusionista. I choose to design to include and enable rather than unknowingly exclude and disable. Inclusive design drives innovation in how we live, learn and work.” 

Received on Friday, 18 December 2020 03:56:44 UTC

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