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Re: 508 rule L and WCAG 6.3

From: Charles McCathieNevile <charles@sidar.org>
Date: Thu, 13 Mar 2003 17:59:21 +0100
Message-ID: <3E70B8E9.7090609@sidar.org>
To: Phill Jenkins <pjenkins@us.ibm.com>
CC: w3c-wai-ig@w3.org

I agree that 508 and WCAG are different. 508 would seem to allow, 
according to the letter, text like "this applet is inaccessible" as an 
appropriate replacement, with the proviso that there is a system wihch 
meets 508's user agent requirements and which could have dealt with the 

WCAG requires that people can use the content without the script. It 
also requires that for people whose user agent can handle the 
technology, the onject is written so it is compatible with the user 
agent. As an example, it is possible in an interactive SVG image to 
include audio descriptions of the visual rendering, which can be 
triggered with voice commands. Under 508 it seems OK to simply have "you 
can't see this" provided to people without an accessible SVG viewer, so 
long as such a thing exists. Under WCAG 6.3 there needs to be some way 
to operate the functionality without an SVG viewer (although as Anthony 
said this seems counter to the spirit). It is also required by WCAG 8.1 
that the SVG in question does have accessibility features used - it is 
not clear that this is required by 508 either.

So I agree with David that the Section 508 requirements seem a little 
underspecified here in terms of ensuring actual accessibility to people.

just my 2 cents worth...

Charles McCathieNevile          Fundacion Sidar

Phill Jenkins wrote:

>I would also summarize by saying that WCAG 1.0 Checkpoint 8.1 (see note 1)
>is more the same as 508 paragraph L, in fact I agree with Jim that 508 and
>WCAG are more like exact opposites here. WCAG 1.0 is much older and focused
>on removing the need for JavaScript while 508 is more forward thinking and
>is focused on making JavaScript directly accessible.  WCAG 8 says:
>"Guideline 8. Ensure direct accessibility of embedded user interfaces."
>Ensure that the user interface follows principles of accessible design:
>device-independent access to functionality, keyboard operability,
>self-voicing, etc.
>    8.1 Make programmatic elements such as scripts and applets directly
>    accessible or compatible with assistive technologies [Priority 1 if
>    functionality is important and not presented elsewhere, otherwise
>    Priority 2.]
>WCAG 1.0 is a little contradictory here, if the web site meets 6.3, i.e.,
>runs with JavaScript turned off, then there would be no need to meet 8.1
>and make the JavaScript directly accessible.  In my opinion, the need to be
>able to run without JavaScript is not a pure accessibility requirement now
>that assistive technologies have and can be made to directly support
>JavaScript.  Use of JavaScript may still be of concern to some due to
>security fears and older technology that doesn't support JavaScript, but
>the important thing is to get it right in WCAG 2.0 by better defining what
>directly accessible JavaScript is.
>Removing this difference between 508 and WCAG 1.0 is a very important part
>in harmonizing the standards.
>Note 1 WCAG 8.1 checkpoint http://www.w3.org/TR/WCAG10/#gl-own-interface
>Note 2 WCAG 8.1 techniques
>Phill Jenkins,
>IBM Research Division - Accessibility Center
>11501 Burnet Rd,  Austin TX  78758    http://www.ibm.com/able
Received on Thursday, 13 March 2003 11:59:48 UTC

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