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RE: Standards vs. Guidelines (was: RE: Clear communication: (was RE: Re: Accessibility of "CHM" format resources)

From: Stuart Smith <Stuart.M.Smith@manchester.ac.uk>
Date: Thu, 9 Jun 2005 11:36:45 +0100
To: "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Message-ID: <20050609113645281.00000003944@marvin>

Hi Mark and all

Yardsticks have their uses and the discussion on the whole issue of standards vs. guidelines is very interesting on this list.

The problem is with yardsticks and industry is that they end up becoming the minimum. I cannot accept that accessibility become diluted to a set of technical milestones. This will not benefit the people we are trying to help.

Herein lies the crux of the issue we are talking about people. They do not fit metrics very well and I hope never will. The problem with enforcing standards on this kind of issue is that eventually the user is forced to conform. In a kind of 'my site is standards compliant therefore if you can't use it there must be something wrong with you...'. I hope that no one wants that situation. By the way I am not saying that users do not have a responsibilty to learn how to use the tools they navigate the web with, they do.

The solution is not to get rid of standards but it is not to elevate them to legislation either. Standards are the starting point of accessibility but so much of it is down to good design, intelligent layout to aid navigation and the site being well written. These cannot easily be quantified, just look at the field of graphic design to see how much can be written about the subject but so little is standardised. Aspects such as these would probably be best tested through usability.

Usability is increasingly seen in a negative way by many organisations. It is often incorrectly perceived as an expensive, time consuming irrelevant option. That does not have to be the case it can be made affordable and timely and it is achievable.

To me it seems the best way forward is to have accessibility legislation as it is needed to bring to account those people that simply don't care about others. The interpretation of that however, should be focused on a body of best practice, technical guidelines and standards being just one of them but usability techniques another. 

People are not standard.



-----Original Message-----
From: w3c-wai-ig-request@w3.org [mailto:w3c-wai-ig-request@w3.org] On Behalf Of Mark D. Urban
Sent: 09 June 2005 00:05
To: 'David Woolley'; w3c-wai-ig@w3.org
Subject: RE: Standards vs. Guidelines (was: RE: Clear communication: (was RE: Re: Accessibility of "CHM" format resources)


I appreciate your thoughtful, reasoned, response and that of many people who have replied to me re: this post.

I'm concerned that you neglect the force of regulation as law.  While it is true that many laws, such as 508 or ADA here in the States, say such things as "reasonable accommodation" or "comparable access" , current legal environs tend to force the regulations or standards (small "s") that are promulgated to become the de facto legal definition of such subjective words.  For example, a builder that follows the ADAG will generally not be held liable if a wheelchair does not fit the ramp she has constructed.  

W3C is not meant as an academic consortium, considering the world as we would wish it to be [sic].  It should exist to build a technical framework for Web technologies for use by society - which includes business, government, and all manner of citizen activities.  Thus, testable, measurable Standards (capital S) - or Recommendations as W3C puts it - should provide a framework for technical accessibility.  

I am fully aware that just because something is "able to be accessed" - the definition of accessibility - does not imply usability.  But I might argue that there is plenty of unusable content that is easily accessible - I often have trouble just navigating the W3C site! (not WAI, Judy!)

I'm not trying to suggest that accessibility is a Boolean environment - True/False, as it were.  Accessibility is a quality, and thus a site might have more or less of it.  The important thing is that we create a yardstick so that societies can pick a point along the yardstick and say "you must be there or above" and then create incentives to be above the minimum mark.
Only then will you generate the business reason for going beyond "doing the minimum" which you so eloquently describe.

A final note - I'm aware that WCAG 2.0 tries to address this issue.
However, there is still too much "do it this way" and not enough "do this and measure your success by this metric".

OK - End of rant.  My apologies to the list for the length of this email, but I wanted to put my thoughts to rest.  I'll post in another 3 years. 


-Mark D. Urban
919-395-8513 (cell)
Chair, North Carolina Governor's Advocacy Council for Persons with Disabilities

Keep up with the latest in worldwide accessibility at

-----Original Message-----
From: w3c-wai-ig-request@w3.org [mailto:w3c-wai-ig-request@w3.org] On Behalf Of David Woolley
Sent: Wednesday, June 08, 2005 3:40 PM
To: w3c-wai-ig@w3.org
Subject: Re: Standards vs. Guidelines (was: RE: Clear communication: (was
RE: Re: Accessibility of "CHM" format resources)

> The answer, of course, is that industry and governments use Standards 
> all

The demand comes from business rather more than governments.  Legislators often produce laws that depend on concepts like "reasonable force" or "without reasonable cause", or even "dangerous" or "reckless driving". 

I believe the UK disabilty legislation has terms like "equivalent service"
and "not excessive".  The UK government also publishes guidelines on that legislation, which include the warning that they are not a statement of the law.  (The US Section 508 does seem to have moved towards the testable, but I seem to remember that the ADA is still

Businesses want testable rules because most businesses aim to operate on the very edge of what is legal (or slightly over the edge - how many offices have you seen where firedoors are never left propped open unattended?).  If they have to make judgements, they risk operating too far within the law, which they perceive as reducing their profits compared with other businesses that judge the boundary more accurately.

Laws which regulate businesses generally only exist because the businesses would not otherwise do what the law demand.  Having a law puts every business at a disadvantage, because they all have to bear the compliance costs, whereas a business won't voluntarily put itself at a perceived disadvantage.

Industry guidelines often exist as self regulation, simply to prevent a government from regulating.

The other people who like to have absolute standards are testing tool developers.  Consultants also like them because it de-skills the job.

Civil services may need to use the standards because they are subject to the law or have to set an example, but that is not the same as a government.

> So, the issue here for me (as both a regulator and an implementer) is 
> that the WAI has consistently failed to write measurable, testable 
> standards

Absolutely testable standards should form part of the technology standard, not a separate accessibility one, e.g. HTML mandates img elements have alt attributes.  However, where the real problems arise is in the subjective areas.  It is easy to comply with having an alt attribute (even if many sites don't) but it requires human judgement to decide whether the value of the attribute is appropriate, and that is not something that can be done with absolute repeatability.  Many pages that comply with the testable "must have alt" rules do not comply when you make a human judgement about whether the attribute is appropriate.
Received on Thursday, 9 June 2005 10:36:49 UTC

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