- From: <tina@greytower.net>
- Date: Tue, 9 Sep 2003 04:07:22 +0200 (CEST)
- To: w3c-wai-ig@w3.org
As you all know, Greytower has been involved in a large - for Sweden -
examination of Government website accessibility. Our experiences with
the procedure and result were documented in my article at
http://www.greytower.net/en/archive/articles/rrv-audit/audit0.html
The aftermath of the examination has proven interesting - in the
Chinese fashion[1]. It has also taken up quite alot of my time, and
I'd like to apologise to the people who have answers by private e-mail
outstanding from me. I will get around to it.
Before my question, a brief background. When we bid for the contract
with the National Audit Office, ours was one of 16. The process for
reviewing the bids followed standard purchase procedures in Sweden,
and we were awarded the contract with the lowest bid as per law.
However, the process was challenged by a company known as "Funka Nu".
The entire business is public in Sweden, and the documentation
available from the Court. After a review, the decision - now holding
force of law - was that granting us the contract was correct.
When the report was made public, the clamor started up again. A
seminar was arranged by Funka Nu to offer critique against the report.
The 92 government departments were all invited, though the number
attending was somewhat smaller.
The end result has been published, and leads to my questions. For the
Swedish speaking members of the list, this article is at
http://www.funkanu.se/start.asp?sida=448
Now to the actual questions raised. I will do my best to faithfully
translate Funka Nu's arguments into English, and coherently present our
response to them. I hope that people on this list will have time to
give their own views.
Before starting in on the comments and counter-comments, however, it
must be said: the scope of the National Audit Office examination was that
of (a) "normal" (Mr. and Mrs. Doe) users, (b) the disabled, (c) immigrants,
(d) the elderly. Personally I feel that the WCAG can benefit all groups.
I would also like to add that the decision to include the name of our
critics was not taken lightly. However, this critique is very public in
Sweden. Since the WAI-IG is archived for everyone to see, and respond, I
feel it justified. The questions raised are important to how accessibility
work is done in this country, and by the very nature of the EU, in Europe.
Funka Nu's comment:
The test method used does not follow WAI's recommended procedure
for a website audit. Among other thing a proprietary, non-free
product has been used for the analysis. A government department,
or other independent reviewer, can not repeat the analysis to
compare the results. Several goverment departments have had
difficulty obtaining the test results when questioning the
report.
Our answer:
The methodology used is, as described in our article, that of the
WAI Preliminary Review. We have changed it only in response to two
facts: all testing could not be done online, and testing needed to
be done speedily. There were 92 different websites to test, and only
22 days in which to test them. We accept that the way we described
the methodology may have lead someone to believe that a method of
our own invention were in use.
However: we do indeed use a proprietary, non-free, tool for our
testing. It is an inhouse system called siteSifter. It is our
impression that the WAI testing guidelines does not specifically
*demand* that one of the tools on the list be used for the
methodology to be valid. Is this impression correct ?
If using a tools listed on
http://www.w3.org/WAI/ER/existingtools.html#General
is a requirement, which process has been used for selecting just
these tools ? Is there a review tool testing system in place that
ensures tool compliance ? If so, where ? I believe that several of
those listed are also proprietary and non-free.
Is it really the intent of the W3C WAI that an organization should
purchase a specific tool - be it Bobby, siteSifter, or Sitevalet - in
order to comply with the guidelines ?
Funka Nu's comment:
The Audit Office has interpreted all the checkpoints literally, and as
if these had equal value. No concessions have been made for conditions
specific to Sweden, or the development of assistive technology since
the guidelines were written. If a flaw has been found that goes against
a point in WAI, this flaw has automatically led to the checkpoint being
marked as "failed", whether or not the flaw is serious or not.
Our answer:
This, to us, is the most puzzling of the critique. The WCAG 1.0 checkpoints
are divided into three sets, priority 1, 2 and 3. As such they were
tested, and as such they have been analyzed and reported. This is clear
from the actual report, where results for each priority has been separately
listed.
However: the question raised is one of re-interpretation and adjustment
of guidelines. It is argued that since, in Sweden, all visually impaired
users are given modern, well-updated, equipment[2] of the same type[3],
there is no point in testing for other equipment. Nor is there any need
to correct for these "other" systems.
An argument is made that doing so will remove focus from the actual,
important, accessibility work.
Again, this raises another level of questions. It is, of course, not
possible for the WAI-IG list to comment on the intent of the European
Union, but I can personally not find any sign that their adoption of
the WCAG 1.0[4] include any leeway for interpretation based on perceived
national differences. It does, quite cathegorically, state that:
"The Guidelines aim to be compatible both with earlier technologies
and Web design tools and also with new technologies and tools, for
example, with new types of Web browsers such as digital assistants
and WAP telephones." - COM(2001) 529
leading me to conclude that the European Union, for one, does not plan
on "dissing" older technology, nor refuse to adopt new.
When analysing the WAI and WCAG itself, including the section marked
as "Considerations for Specific Contexts", I can find no mention that
the guidelines are meant to be adjusted for region-specific cultural,
political, or even technical details. Is my interpretation correct ?
I can personally see no meaning in applying the WCAG for use, for
instance in the EU, if the guidelines are to be re-interpreted for each
country or region. It is clear that there are parts of the Union, as
there are parts of the world, where the level of technology may not be
as "high" as in Sweden, but that - in my view - was part of the point
of the accessibility guidelines.
Have I misunderstood ? A conformance to a certain priority is one
thing, but conforming to a certain, perceived, level of technology
would seen to go entirely against the principles of accessibility.
Finally, claims are being made - publically - in Sweden that
The Swedish Agency for Public Management[5], The Swedish Disability Ombudsman,
and the Swedish W3C Office are enganged in a joint project to reinterpret
the WCAG for Swedish "realities".
This, frankly, worries me. The claim has been made in seminars by people
who "ought to know". I would like to invite comment on this from WAI-IG
members, and in particular from W3C staff.
Hopefully this overly long posting will not hinder anyone from commenting
freely. In short:
- Should conformance / accessibility reviews be performed ONLY with
the listed tools ?
- Should the WAI WCAG checkpoints be re-interpreted based on perceived
technological differences from region to region ?
Thankyou in advance.
Yours sincerely,
Tina Holmboe
[1]
"May you live in interesting times" - Chinese curse.
[2]
This is not correct. The process of receiving equipment is not an automatic
one, nor is received equipment necessarily kept well updated.
[3]
With a certain danger of being misinterpreted as a "religious zealot", it
must be said that the equipment referred to is from Microsoft, running IE
and Jaws.
[4]
I believe it important to note that it is WCAG *1.0* which is adopted, and
not WCAG [enter favourite version number].
[5]
Responsible for the guidelines used on the Swedish 24-Hour Government
project which is the basis for all of this.
--
- Tina Holmboe Greytower Technologies
tina@greytower.net http://www.greytower.net/
[+46] 0708 557 905
Received on Monday, 8 September 2003 22:11:26 UTC