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RE: 508 vs. W3C

From: Martin Sloan <martin.sloan@orange.net>
Date: Mon, 12 Aug 2002 22:00:04 +0100
To: "'Simon White'" <simon.white@jkd.co.uk>, "'Charles McCathieNevile'" <charles@w3.org>, "'Michael R. Burks'" <mburks952@worldnet.att.net>
Cc: "'RUST Randal'" <RRust@COVANSYS.com>, "'WAI IG'" <w3c-wai-ig@w3.org>, "'Steve Vosloo'" <stevenvosloo@yahoo.com>
Message-ID: <002501c24243$41544900$d92d073e@Bertie>

Hi Steve,

Saying what is *required* by law re accessibility and Disability
legislation is a very difficult question. As I guess those of you who
have read my paper that Simon refers to will know, I have advocated that
Single-A would be the likely requirement in the UK should the Courts
come to consider the issue.

However that does not mean that a good counsel could not persuade a
court that what they are really looking for is Double or even Triple-A
compliance (admittedly the latter is unlikely). This is one of the
problems of using framework legislation and codes of practice etc - it
is very difficult for the layman to know what is actually required of
him. Even though the UK Code of Practice does now make reference to the
Web it merely says that an inaccessible is site is probably a breach of
the Act, but offers no guidelines as to what an 'inacccessible site'
constitutes. Which as we all know is a very ambiguous term..

So, with the usual disclaimers etc I would argue that Single-A is the
minimum that should be aimed for. I think this is reasonable given that
that is what the UK government currently requires of its sites in line
with the eEurope initiative. However, if it is a new site I would
strongly suggest aiming for Double-A on the grounds that as you are
starting from scratch there is arguably a greater expectation for you to
comply with legislation and the guidelines (given that you are not
tinkering with an existing site and have blank canvas) and that with
time standards and expectations will increase.

I suppose you could argue the flipside of this in that the w3c language
is 'Must', 'Should' and 'May' and that the logical conclusion is that
the requirement is 'Must' rather than 'should'. If someone 'should' only
do something, then it is presumably not as important as the things that
he must do. It may be that in a non-rules based system like the UK that
it will be very difficult to advocate more than 'must'. Maybe it is time
for the standards to be raised?

I am currently testing a new site which should give lots of advice on
the uk legal situation and will let list members know when it goes live.

Incidentally, if any list member would like to explain to me what
diference in terms of accessibility is between the various compliance
levels I would be very grateful. ie how much more accessible a double-A
site is than a Single-A site and what the practical differences are in
terms of accessibilty.


Martin Sloan
e: martin.sloan@orange.net
t: 0131 664 8876
m: 07974 655170


-----Original Message-----
From: w3c-wai-ig-request@w3.org [mailto:w3c-wai-ig-request@w3.org] On
Behalf Of Simon White
Sent: 12 August 2002 17:58
To: Charles McCathieNevile; Michael R. Burks
Cc: RUST Randal; WAI IG; Steve Vosloo
Subject: RE: 508 vs. W3C

Dear All,
The DDA states that websites should provide a service that is no less
than that offered to non-disabled users, and it is assumed (as the UK
government is yet to provide parameters for commercial sites) that
single-A conformance is the minimum - judging by the RNIB
(http://www.rnib.org.uk) campaign for accessible web design. However, if
you look at the Guidelines for UK Government websites
k/handbookindex.htm) it will outline what the Government requires for
its own sites and those of the public sector.

Also, consider that the German administration has recently taken a
further step and asked for double-A compliance as a minimum!

Furthermore, I would have a look at Martin Sloan's take on the DDA in
the UK, available at: http://elj.warwick.ac.uk/jilt/01-2/sloan.html

Having said all this, I would agree with Charles that double-A standard
is a good target to aim for as a minimum, but if triple-A compliance is
at all possible (even if not on all pages) then I would strive for that.
I would also like to add the following: please, please, please validate
your code and CSS.

Good luck.

-----Original Message-----
From: Charles McCathieNevile [mailto:charles@w3.org]
Sent: 12 August 2002 17:47
To: Michael R. Burks
Cc: RUST Randal; WAI IG; 'Steve Vosloo'
Subject: RE: 508 vs. W3C

Well, what people do normally in this situation is consider the desires
of their customers. WCAG Priority 1 and Section 508 are different -
meeting WCAG triple-A conformance would cover you for Section 508 and
satisfy the US requirements, but meeting single-A would not.

I don't know the details of the UK Disability Discrimination Act, but I
suspect it would not be satisfied by meeting section 508. I am fairly
certain that the Australian equivalent act would not be satisfied by
Section 508.

My two cents worth of advice (and two cents in australia is now legally
worthless) is to go for about WCAG double-A in your development and
maintenance planning, and ensure that you meet Section 508 requirements
immediately. This is becuase the 508 requirement isn't complaint-driven
but rule driven, whereas I understand the UK act as being reactive.



On Mon, 12 Aug 2002, Michael R. Burks wrote:

>buy the book Constructing Accessible Web Sites which Jim Thatcher and 
>several others wrote.  It is published by Glasshous, a company in the 
>UK, and is available at: 
Steve had actually asked:
>needs to be made accessible. The pressure for accessibility is coming 
>from the US. I'd like to know what their options are ... do they:
>    1) Make the site 508 and WCAG Priority 1 compliant
>    2) Make it only 508 compliant. Will this satisfy the Disability 
>Discrimination Act of the UK?
>    3) Make it only WCAG Priority 1 compliant? Will this satisfy the US

>pressure coming from the Federal funders of the site?
>    All input would be greatly appreciated.
>    Thanks
>    Steve
>    Steve Vosloo
>    Division Manager
>    Usability Junction
>    Tel:    + 27 (0) 21 409 7961
>    Fax:   + 27 (0) 21 409 7050
>    Cell:   + 27 (0) 83 463 0012
>    Web:  www.usabilityjunction.com

Charles McCathieNevile    http://www.w3.org/People/Charles  phone: +61
409 134 136
W3C Web Accessibility Initiative     http://www.w3.org/WAI  fax: +33 4
92 38 78 22
Location: 21 Mitchell street FOOTSCRAY Vic 3011, Australia
(or W3C INRIA, Route des Lucioles, BP 93, 06902 Sophia Antipolis Cedex,

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