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Re: Removing PDFs and accessibility

From: Ramón Corominas <listas@ramoncorominas.com>
Date: Thu, 29 Mar 2012 16:58:15 +0200
Message-ID: <4F747887.9090202@ramoncorominas.com>
To: Andrew Kirkpatrick <akirkpat@adobe.com>
CC: "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Hi all,

Andrew Kirkpatrick said:

 > VoiceOver with PDF documents on the Mac is not as good as
 > the Windows options but the document content can be read
 > and used.

Indeed, it is not good at all. I do not even consider PDF to be 
"accessibility supported" on Mac. As far as I know there is no reader 
for Mac that can access headings, tables, lists, or any other semantic 
tagging, nor text alternatives for images or form controls; using 
VoiceOver it is not posslbe to activate links or fill in forms within a PDF.

In practice, VoiceOver cannot read mucho more than the document's text, 
so I would say that a PDF document is not more accessible on Mac than a 
plain text file.

 > it is worth noting that AGIMO in the federal government
 > agrees that well-authored PDF documents can meet WCAG
 > 2.0 and can be used within the government to comply
 > with the National Transition Strategy

According to Conformance Requirement #4, PDF documents can only conform 
to WCAG 2.0 if the techniques used to create it are accessibility 
supported. Since accessibility support for PDF only exists on Windows 
platforms, I think the only possibility for PDFs to conform is if they 
are intended to be available only in a -Windows- closed environment 
(section 2, point c) in the technical definition of "accessibility 

 > As stated, the PDF Sufficient Techniques are now available,
 > so technically an agency can rely on PDF by using the WCAG
 > 2.0 PDF Sufficient Techniques and all applicable General
 > Techniques, and will be considered to be complying with
 > the NTS.

"Sufficient" Techniques are only "sufficient" if accessibility support 
does exist. For example, most -all?- Flash Sufficient Techniques are 
only supported on Windows platforms -and only if we "forget" that the 
Flash installer is not accessible at all-, so I would not consider these 
techniques to be "sufficient" in terms of WCAG 2.0 conformance, unless 
you are in a closed environment.

 > There are many reasons why you may want to offer HTML
 > documents, but you should also recognize that there are
 > valid reasons for using PDF documents, and if you find
 > that these reasons make sense for you, use PDF.  But,
 > when you do use PDF, follow best practices for making
 > sure the PDF documents meet WCAG 2.0.

I agree that there are many reasons to use PDF documents. Bu, in terms 
of accessibility, IMHO relying on PDF documents as the only way to 
provide information can never meet WCAG 2.0 in an open, "World Wide" Web 

Ramón Corominas
Accessibility Specialist
Technosite - Fundación ONCE
W: www.technosite.es
T: +34 91 121 0330
Received on Thursday, 29 March 2012 14:59:37 UTC

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