[VE][64] document type does not allow element "TFOOT" here

The only method we have found to overcome this validation error is to
place the table footer <tfoot> between the table header <thead> and the
table body <tbody> in the HTML code. Unfortunately, this configuration
is not Section 508 Compliant as per U.S. Government regulations
concerning electronic data accessibility. When the disabled user employs
their screen reader to "listen" to the site they hear the table's title
and/or column heads first <thead> and then the table's source and
footnotes <tfoot> before the table's main data <tbody>. This can be
disorienting to the user, giving the impression that the table data was
skipped since the footer was read directly after the title instead of at
the end of the table where one would expect information such as end
notes.

 

Does the W3C have suggestions or can they alter their testing methods to
discourage this <tfoot> placement because it interferes with disabled
users' accessibility?

 

Thanks,

David Peabody 

Error [64]: "document type does not allow element X here" 
NOTE: Whenever possible, give the address of the document you were
checking.