First Impressions of ICT Accessibility Standards and Guidelines

Terrill Thompson
Technology Accessibility Specialist
UW Information Technology
University of Washington

April 30, 2010

The U.S. Access Board released its Draft Information and Communication Technology (ICT) Standards and Guidelines in March 2010. These are intended to update the existing Section 508 Standards, as well as the guidelines for Section 255 of the Telecommunications Act. The Access Board is soliciting public comment on the new Standards and Guidelines (hereinafter referred to as "The Refresh") through June 21. Additional information, including a link for submitting public comments, is available on the Access Board's Section 508 Homepage.

This document contains my rough notes after an initial read of the 95-page draft. This doesn't reflect the opinions of The University of Washington, nor DO-IT or any of its funding sources. I'm not even sure if it will ultimately reflect my final opinions, but this represents my first reaction upon reading this document recently on a long flight. To summarize, these standards and guidelines are much more comprensive than the previous Section 508 standards, but it's extremely challenging to sift through. Therefore many of my observations focus more on organizational and linguistic issues than on technical substance. As a person who spends a lot of time working to persuade web and software developers to comply with standards and create accessible content and products, I think it's critical that these standards be understandable.

I welcome feedback, either on the UW AccessibleWeb discussion list, or on my blog at terrillthompson.com.

Overall Structure

• Previous standards included a normative standards document, and a separate informative Guide to the Standards which explained each standard in detail. The WCAG 2.0 assumes a similar approach, by separating the WCAG 2.0 specification from a set of supplemental documents. The current draft of the Refresh has normative and informative content combined, which interrupts the flow of the document and reduces its readability.
• Related to the above, if Advisory content is integrated within the standards document, how easily can it be updated? Presumably it would be desirable to have this capability.
• Having two Chapter 1's is weird.
• Why does the 508 Chapter 1 start with "E" and the 255 Chapter 1 start with "C"?
• The overall outline of the original 508 standards would seem to still be applicable to the Refresh. Why not preserve that outline for consistency between versions?
  • Subpart A- General
    • Section 508 Application and Administration
    • Section 255 Application and Administration
  • Subpart B - Functional Performance Criteria (was Subpart C in original 508, but I think good to bring forward as it presents the big picture)
  • Subpart C - Technical Standards
    • Chapters 3 - 9
  • Subpart D - ICT Support Documentation and ICT Support Services (same as "Information, Documentation, and Support" in original)
  • Subpart E - Amendments to the ADAAG
• At a minimum, the technical standards should be organized collectively.
• A "General" sub-section (X.1) is provided for some sections, but not all. It is unclear what the distinction is that deems a General sub-section to be necessary. For example, Section 302 includes a General section, and contains only one additional sub-section (302.2) plus an Advisory section. In contrast, Section 306 does not have a General section, but includes both an Advisory section and an Exception. Section 402 doesn't have a General section either, but has three sub-sections. In most if not all cases, the General section is self-referring and recursive (e.g., "406.1 ICT shall conform to 406") and makes the standards difficult to read.
• The self-referencing is particularly burdensome when there are deep layers of sub-sub-sections. For example, 502.1 states that ICT with certain characteristics "shall conform to 502". If we read on, we find in the next section, Section 502.2, that text alternatives for non-text content shall conform to 502.2.1 or 502.2.2. Following this there is an Adivsory section before we finally get to 502.2.1, which at long last is an actual rule (albeit a difficult to understand one).
• If sections include exceptions, these are often stated before the rule is stated, as in Sections 405.2, 405.3, 413.2, etc. These should be reorganized so that exceptions to the rule are stated only after the rule has been completely defined (including both the rule itself and the Advisory content, if the latter remains in the final document).
• Other than the "General" sections, the sub-sections have linguistically inconsistent labels. For example, there are:
  • Starting with a preposition (in the style established in the Functional Criteria section), e.g., "302.2 WIthout Attachment of Assistive Technology"
  • Nouns describing accessibility characteristics, without the preposition (e.g., "303.2 Alternate Identification of Control", "403.2.2 Independent Volume Control", "403.3 Resizable Text").
  • Nouns describing general charactersistics, without accompanying accessibility modifiers (e.g., "307.3 Height","404.2 Keyboard interface", "413.2 Authoring Tools", "410.4 Object Information")
  • Verbs (e.g., "403.2.1 Pause or Stop Audio", "405.2.2 Extend", "406.2 Bypass Blocks of Content", and my personal favorite "E108 Best Meets")
  • Words too ambiguous to tell whether they're nouns or verbs ("411.2.3 Change Notification")
  • Commandments (e.g., "305.1 Not only color", "407.3 No Change of Context from Change of Settings", "508.2.3 No Duplicate Attributes")

Audience

• The audience is often unclear, and seems to switch back and forth. The W3C approach, having WCAG, ATAG, and UAAG as separate documents makes much more sense, so audience members don't have to struggle to figure out whether a standard applies to them. Examples:
  • 404.5 Visible Keyboard Focus Indicator. As explained in the Advisory note, "When a user relies on the keyboard to ineract with content, this provision requires a visible cursor so that the user can visually determine the component with which the keyboard operations will interact at any point in time." Who is responsible for providing this visible keyboard focus indicator? The web developer? Or the browser developer?
  • 409 User Preferences and 410 Interoperability with Assistive Technology are user agent standards. Previous and subsequent sections are applicable to all ICT. Maybe it would help to sort by audience, or at least to clearly identify the audience for each section.
  • 410.4 Object Information - "programmatically determinable using platform accessibility services" is probably understable to most platform developers, but many others who are reading this will be puzzled. I respect the need for platform neutrality, but it would help if the Advisory note did mention a few accessibility services by name to clarify what's being described here (e.g., MSAA, User Interface Automation, IAccessible2, AT-SPI, OS X Accessibility API). Otherwise it all sounds too euphemistic.
• Advisory 501.1 states "This chapter is oriented toward authors, rather than developers". However, this text is buried. It should be more prominent, and communicated throughout the document, not just in this one place.

Comments on Specific Chapters and Sections

• E107 WCAG 2.0 Harmonization. I was hoping for better harmonization, i.e., "In order for ICT to meet the requirements of Section 508, it must comply with WCAG Level AA, ATAG, and UAAG". If this document represents harmony, it's very discordant harmony. The differences between WCAG 2.0 and the Refresh document are much greater than the differences between WCAG 1.0 and the original Section 508 standards, although E107 makes it possible to pick a standard and focus on that, rather than try to comply with both. That said, this section seems to contain redundant requirements by including the phrase "all corresponding WCAG 2.0 Success Criteria and Conformance Requirements". If ICT already meets WCAG 2.0 at Level AA, why does it also need to meet "all corresponding WCAG 2.0 Success Criteria and Conformance Requirements" in Chapters 4, 5, and 6? Is this not redundant?
• 202.11 "Minimize Photosensitive Seizure Triggers". This is the only item in Section 202 that does not begin with either the word "With" or "Without". For consistency, I suggest revising to "Without Triggering Photosensitive Seizures"
• The word "usable" appears throughout The Refresh but is not defined in E111 or C109 (Definitions Sections).
• 301.1 "required by Chapter 1" does not specify which Chapter 1.
• 402.3 Alternate CAPTCHA requires "an alternative form of CAPTCHA using an output mode for a different type of sensory perception". This does not address accessibility for the deaf-blind or persons with cognitive/processing disabilities
• 403.3 Resizable Text includes the Exception "Images of text, including text used for captioning, are not required to support the ability to be resized". Why not? Closed captions should resizable, and there are plenty of examples of current technology supporting this (including YouTube).
• 405.2 Control Over Time Limits. Exception 3 says "When the time limit is at least eight hours, no user control over the default time limit is required". Why 8 hours? Why not 5? Seems arbitrary.
• 405.2.3.1 Expiration warning "The user shall be warned at least twenty seconds before a time limit expires". Is twenty seconds enough? Is there research to support this?
• 405.2.3.2. Multiple Extensions "The user shall be able to extend a time limit at least ten times". Why ten?
• 406.2 Bypass Blocks of Content. The best practices described in the Advisory section don't mention that a method should be visible, e.g., visible "same page" links, so keyboard-only sighted users and screen magnification users can benefit
• 409.2 User Preferences - refers to a mode of operation that "uses user preferences for platform settings". This is difficult to read - Consider changing "uses" to "respects" or "honors", or some other change that fixes this tongue twister.
  • Also, this sub-section only requires applictions to honor user preferences for color, contrast, font type, and focus cursor. There are many other accessibility-related user preferences, such as keyboard features, mouse features, magnification, etc. Therefore, this sub-section should not limit which user preferences are honored. I recommend changing "for color, contrast..." to "such as color, contrast..."
• 411 Compatible Technologies. This section, which applies specifically to user agents but doesn't claim such, includes 411.2 User Interface Components, which has sub-sections covering both ARIA and tables. It seems odd that tables is the only specific user interface component that is singled out here. Are tables the only possible UI component that are not covered by 411.2.1 - 411.2.3?
• 413.4 Templates "When templates are provided with authoring tools, at least one template for each template type shall conform to Chapter 5 (Electronic Documents)". Why only one? The "Accessible Template" is a ghetto approach. All templates should be accessible. Otherwise authors will use the inaccessible templates to create inaccessible content.
• 502.2.2 - Each of the sub-sub-sections of this sub-section are the same other than the object they describe. In 502.2.2.1, audio or video content requires that "text alternatives shall provide descriptive identification of the non-text content". 502.2.2.2 requires the same of Test or Exercise. 502.2.3 requires the same of Sensory Experience. Do we really need all these sub-sub-sections, or can they be consolidated? Also, what exactly is "descriptive identification"? It doesn't seem to be defined anywhere, and 502.2.2.1 has no Advisory content, which is where clarification is most needed (e.g., is "descriptive identification" different from "video description"?)
• 502.2.2.2 Test or Exercise. This is a very challenging requirement to meet. Therefore, more examples are needed in the Advisory section, especially examples demonstrating how to describe questions like "Based on the following graph, identify..." and "Which of the following images..."
• 502.2.2.4 CAPTCHA "text alternatives that identify and describe the purpose of the non-text content shall be provided". Identifying the purpose does not let the person in. If this requirement is intended to be met in conjunction with 402.3, the latter should be cross-referenced here (and vice-versa).
• 502.3 Audio or Video Content. This is the more general A/V requirement, but it's confusing here since A/V was covered previously (though less comprehensively) under 502.2.2. The problem is once again organizational. Some requirements are organized by feature (e.g., "Descriptive Identification"), whereas others are organized by product category (e.g., "Audio or Video Content").
• 503.2.2 Forms. Requires labels, but what about other form elements that increase accessibility such as fieldsets and optiongroups?
• 503.3 Logically correct reading sequence. This should also include logically correct tab order. In the Advisory section, it says "An example is a sidebar item that might reasonably be read before, or after, or in the middle of the main content. Content authors and developers have flexibility..." This might not be a problem for screen reader users, but it's arguably not true of tab order for keyboard users. In the U.S., tab order should reflect the standard reading direction, which is left to right and top to bottom. Otherwise sighted keyboard users, especially those using magnification, can easily get disoriented.
• 503.4 This rule uses negative language ("shall not rely solely on those characteristics..."), whereas most other rules are written in the positive. Consider revising (e.g., "When providing instructions for understanding and operating content, avoid instructions that rely solely on those characteristics...")
• 504.2 "Text and Images of Text Contrast Ratio". This is awkward. What are "Images of text contrast ratio"?
• 504.2.1 "Large-scale text" is hyphenated here, but not hyphenated in 504.2.2, nor in the Definitions section (E111.5). As a result, Ii tried searching for "Large-scale text" and failed to find a definition.
• 504.3 Resize and Reflow Text. This section appears to include an Advisory note (stylized in a grey box), but it doesn't say "Advisory".
• 505.2 Document Titles. "Documents shall have titles that describe topic or purpose." What is a title? Is this referring solely to the title element, or should all documents also have a top-level heading so the title can be clearly visibly ascertained?
• Advisory 603.2 says "This best practice is not a requirement." Is any Advisory content a requirement?
• Advisory 603.2 also says "An example where this would be a fundamental alteration is a radio broadcast". Is this is exception? If so, shouldn't it be in an Exceptions section?
• Could 603.3 (captions for interactive audio content) and 603.4 (captions for video) swap positions, since 603.4 is arguably more common?