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Re: Accessibility and its legal requirements

From: Phill Jenkins <pjenkins@us.ibm.com>
Date: Tue, 7 Jan 2003 13:44:08 -0600
To: w3c-wai-ig@w3.org
Message-ID: <OFBC0E994F.40E4694F-ON86256CA7.0069F32B@pok.ibm.com>

Isofarro wrote:

>The second issue, which certainly seems odd to me, is the issue with
>There are parts of the site which are framed (into a top banner and bottom
>menu, with the content in the middle). To make these pages compliant, only
>Checkpoint 12.1 and 12.2 seem to be required, stating:
>So that means just putting title attributes to frame elements and describe
>the purpose of frames is sufficient to make them accessible?

Checkpoint 1.1 [see WCAG] also mentions frames:

However there are two different interpretations of the checkpoint.  One is
that FRAMES themselves are non-text elements irregardless of their content
and must be usable without FRAME support.  And the second is that FRAMES
may contain content that requires text equivalents.  In other words, a
FRAMESET that only contains textual elements such as paragraphs and
headings would (in my opinion) be no less accessible than separate pages
for each frame of the same textual content - assuming the title of each
frame is equivalent to the title of each separate page. Of course there are
other printing and usability concerns with frames, but fundamentally
meeting 12.1 and 12.2 cover the accessibility concerns with FRAMES except
for the case when the content of the FRAME is a non-text element.  For
example when the content of the frame is only an image file there is no way
to include alt-text unless the content of the FRAME is an HTML file [See

I generally agree with the second interpretation, that FRAMES are just
another element of HTML and is or is not supported by the browser and/or
assistive technology.  Once the user's configuration supports FRAMES, then
to make them accessible checkpoints 12.2 and 12.2 apply.

The policy decision that needs to be made first is whether on not FRAME
sites are to be supported.  For example, a company, government, or
institution may decide to not allow FRAMESET site for various reasons -
once that policy is made, then WCAG can be applied.  If the policy only
mentions WCAG and not FRAMES specifically, that WCAG is ambiguous (in my
opinion) towards FRAMES and results in the frustration you are

[WCAG 1.0 Checkpoint 1.1]
[FRAME Techniques] http://www.w3.org/TR/WCAG10-HTML-TECHS/#frames

Phill Jenkins
IBM Research Division - Accessibility Center
Received on Tuesday, 7 January 2003 14:44:44 UTC

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