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Re: Issues: Part 3 - #44 and #45 - Exemption

From: Jon Gunderson <jongund@staff.uiuc.edu>
Date: Mon, 22 Nov 1999 16:00:47 -0600
Message-Id: <4.1.19991122155501.00c9fce0@staff.uiuc.edu>
To: ehansen@ets.org, w3c-wai-ua@w3.org
The issue of conformance of assistive technologies has been addressed by
the group many times.  The current consensus is that the guidelines are
primarily designed for mainstream technologies.  An assistive technology
can still comply with the guidelines if they satisfy the checkpoints.
Essentially the guidelines make no distinction between technologies,
individual developers can decide if they want to comply.

URL to group consensus:


At 01:21 PM 11/22/99 -0500, ehansen@ets.org wrote:
>Mark Novak wrote:
>"Changes are flying pretty fast, so it has been tough to keep up, but I'm 
>confused as to why User agents that are designed and developed exclusively 
>for people with disabilities "would be exempt" from these guidelines?"
>My response:
>The 5 November 1999 version of the UAAG indicates the definition of 
>"applicable checkpoint" that:
>"If a user agent offers a functionality, it must ensure that all users have 
>access to that functionality or an equivalent alternative."
>I hope that I am correct in my understanding that the equivalent 
>alternative could be provided either (1) within (or "by") the user agent 
>itself or (2) by working well with other user agents that are able to 
>provide an equivalent alternative. This requirement is fine for user agents 
>that are intended for general audiences (i.e., all users, including people 
>with disabilities), but I am concerned that some assistive technologies are 
>so specialized in purpose, that they are only usable by people in one 
>disability group, or perhaps even only by one person with a highly unique 
>disability profile. Without the exemption, wouldn't such assistive 
>technologies then be obliged to provide their functionality to "all users"? 
>I think we need to think about how the UAAG document would apply to 
>assistive technologies such as single-switch input devices, wheelchairs, 
>screen reader software, braille devices, hearing aids and other prosthetics,
> screen magnification software, telephone-audio-based Web browsers, and 
>technologies ts that translate one kind of computer data into an accessible 
>from (e.g., text to braille, braille to audio, etc.). All these 
>technologies are user agents in the sense of being used by some people with 
>disabilities to access Web content. Must they be made usable by "all users",
> including people without disabilities? That seems too tall of an order and 
>may have unintended negative consequences.
>At the very least, I highly recommend making the change that I previously 
>recommended that changes the first sentence mentioned earlier to: 
>"If a user agent offers a functionality, it must ensure that <CHANGE> 
>people with disabilities </CHANGE> have access to that functionality or an 
>equivalent alternative." (my revised definition of "Applicable 
>checkpoint"). This change from "all users" to "people with disabilities" is,
> in my view, essential because:
>1. It keeps the UAAG document within scope. We have no authority except as 
>it relates to accessibility, i.e., use by people with disabilities. 
>2. It may limit the unintended negative consequences by potential reducing 
>(or minimizes increased burden) on developers.
>What about the exemption itself?
>There may be alternatives to this exemption. One could obviously redefine 
>the scope of this document to say that UAAG pertains only to graphical Web 
>browsers and multimedia players and not really to these other technologies. 
>However, I think that that would unnecessarily limit the scope of the 
>document. One could also redefine concept of "user agent". At least in my 
>own mind, I see user agents has being able to contain (or being assemblages 
>of) other user agents. And I think that it would be hard establish a 
>minimal level of functionality for something to be classed as a user agent. 
>(I would think that small, low-functionality user agents are the ones that 
>might be most prone to lack or to lack good interfaces to equivalent 
>alternatives.)  In the absence of redefining these terms and the document 
>scope, then I think that the exemption may be appropriate.
>I may be over-reacting to this issue, but I think that people who 
>understand both the document and assistive technologies should examine how 
>they might impinge upon each other. I would not want to see developers of 
>highly specialized assistive technologies for, say, a single disability 
>group (e.g., deaf-blind) be hindered by unnecessary requirements for 
>accessibility for all other disability groups as well as people without 
>Eric G. Hansen, Ph.D.
>Development Scientist
>Educational Testing Service
>ETS 12-R
>Rosedale Road
>Princeton, NJ 08541
>(W) 609-734-5615
>(Fax) 609-734-1090
>E-mail: ehansen@ets.org 

Jon Gunderson, Ph.D., ATP
Coordinator of Assistive Communication and Information Technology
Chair, W3C WAI User Agent Working Group
Division of Rehabilitation - Education Services
College of Applied Life Studies
University of Illinois at Urbana/Champaign
1207 S. Oak Street, Champaign, IL  61820

Voice: (217) 244-5870
Fax: (217) 333-0248

E-mail: jongund@uiuc.edu

WWW: http://www.staff.uiuc.edu/~jongund
WWW: http://www.w3.org/wai/ua
Received on Monday, 22 November 1999 17:02:46 UTC

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