Electronic Content Accessibility Requirements
Presented by 
Norman B. Robinson 
on the behalf of the U. S. Access Board

Electronic Content?
Electronic Content 
As It Relates To 
Section 508 Technical Standards

Notes:
Why refer to electronic content instead of electronic information & technology as referenced in Section 508? Because to end-users the impact is to their electronic content. Additionally, when looking at how the technical standards are organized (e.g., software & os, web, etc.) this speak to _types_ of content. Finally, we want to avoid discussion on the finer details of legal compliance. We want to focus on making all content as accessible as possible, and how the technical standards support that goal.

  Outline of E&IT Accessibility Standards
•	Preamble
–	Hint:  Read this last!

•	Subparts (A – D)‏
–	General (A)‏
–	Technical Standards (B)

–	Functional Performance Criteria (C)

–	Information, Documentation, and Support (D)‏

•	http://www.access-board.gov/sec508/standards.htm

Notes:
If one looks at the Section 508 of the Rehabilitation Act, either as published in the Federal Register on December 21, 2000 or available online from the Access Board’s web site, you’ll see they are organized into four (4) subparts and include a preamble or published discussion of the standards.

In this presentation I want to focus on the Technical Standards.

Getting Technical?

•	Subpart C – Functional Performance Criteria

–	§ 1194.31   Functional performance criteria.
•	Six small paragraphs

Notes:
Before we can focus on the Technical Standards I need to bring your attention to Functional Performance Criteria. It is Subpart C, which only has one section numbered 1194.31. It contains six very short paragraphs.
Often, in the rush to get to the technical details, people forget about, or technical people creating or designing E&IT are not aware of, the functional performance criteria.

The Goals

•	§ 1194.31   Functional performance criteria.

•	(a) At least one mode of operation and information retrieval 

that does not require user vision 

shall be provided, 

or support for assistive technology used by people who are blind or visually impaired shall be provided.

Notes:
The goals outlined in the functional performance criteria are remarkably simple.

In brief, one mode that does not require user vision

The Goals

•	§ 1194.31   Functional performance criteria.

•	(b) At least one mode of operation and information retrieval 

that does not require visual acuity 
greater than 20/70 

shall be provided in audio and enlarged print output working together or independently, 

or support for assistive technology used by people who are visually impaired shall be provided.

Notes:
one mode that does not require user vision greater that 20/70

The Goals

•	§ 1194.31   Functional performance criteria.

•	(c) At least one mode of operation and information retrieval 

that does not require user hearing 

shall be provided, 

or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

Notes:
one mode that does not require user hearing

The Goals

•	§ 1194.31   Functional performance criteria.

•	(d) Where audio information is important for the use of a product, 

at least one mode of operation and information retrieval shall be provided 

in an enhanced auditory fashion, 

or support for assistive hearing devices shall be provided.

Notes:
one mode that supports users who are hard of hearing

The Goals

•	§ 1194.31   Functional performance criteria.

•	(e) At least one mode of operation and information retrieval 

that does not require user speech 

shall be provided, 

or support for assistive technology used by people with disabilities shall be provided.

Notes:
one mode that does not require user speech

The Goals

•	§ 1194.31   Functional performance criteria.

•	(f) At least one mode of operation and information retrieval 

that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength

shall be provided.

Notes:
one mode that can be used by users with limited mobility.

The Goals

•	Functional Performance Criteria establishes the goals for accessible electronic content.

Notes:
That content is information and is presented using technology – electronic information & electronic technology

The Goals

•	Functional Performance Criteria establishes the goals for accessible electronic content.

•	Ask yourself, with the goals established, how can we ensure the electronic content we have is accessible?

Notes:
What would you do with all of the technologies available today, with all the different technologies used by your agency or created by your developers for use by others, if you didn’t have anyone to tell you what was required? How successful do you think you would be in choosing the right approach?

The Goals

•	Functional Performance Criteria establishes the goals for accessible electronic content.

•	Ask yourself, with the goals established, how can we ensure the electronic content we have is accessible?

•	The answer: Section 508 Technical Standards 

Notes:
I want to bring your attention to the fact there are many technical standard bodies or groups that set standards. In some instances the standards from one group conflict with standards from another group, either by accident, design, or when implemented in the real world. Although there are standards that address accessibility, accessibility is often an addition requirement and not the primary goal of the standard.

It has been said “The great thing about standards is that there are so many to choose from” –

The Section 508 Technical Standards address the need for specific guidance by setting the specific technical standards needed for accessibility.

     Subpart B — Technical Standards

§ 1194.21 Software applications and operating systems.
§ 1194.22 Web-based intranet and internet information and applications.
§ 1194.23 Telecommunications products.
§ 1194.24 Video and multimedia products.
§ 1194.25 Self contained, closed products.
§ 1194.26 Desktop and portable computers.

Notes:
This presentation will focus on software applications, operating systems (which IS software btw), web-based information and web-based applications.

If we have additional time, I will go into why the other standards aren’t as directly related to electronic content accessibility or are covered by the software and web provisions.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards.  

Notes:
Not just visuals (highcontrast shown here) but soundsentry, mousekeys, stickykeys, etc.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards.  

(b) ...Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

Notes:
support.microsoft.com/kb/126449 applies to every version of MS Windows. There are equivalents for other operating systems.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes.  The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes.  The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

Notes:
We have text focus on a web page link – difficult to see here and normally difficult anyway – as well as the highlight of the “File” on the file menu and “Close Window” option, indicating that if the user were to use the enter key the “close window” option would activate.

Component Object Model (COM) is an interface standard for software componentry introduced by Microsoft in 1993. It is used to enable interprocess communication and dynamic object creation in any programming language that supports the technology. 
Microsoft® Active Accessibility® is a COM-based technology that provides a standard, consistent mechanism for applications and Active Accessibility clients to exchange information. This technology was integrated into the Microsoft Windows® operating system beginning with Windows 98 and continues to be updated with each new release. 
COM is primarily used with Microsoft Windows 
In an MFC program, you rarely need to call the Windows API directly. 
MFC was introduced in 1992 with Microsoft's C/C++ 7.0 compiler for use with 16-bit versions of Windows as an extremely thin OOP/C++ wrapper for the Windows API. 
Microsoft's emphasis on MFC has been reduced in favor of their .NET Framework. 

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes.  The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

Notes:
We have text focus on a web page link – difficult to see here and normally difficult anyway – as well as the highlight of the “File” on the file menu and “Close Window” option, indicating that if the user were to use the enter key the “close window” option would activate.

Component Object Model (COM) is an interface standard for software componentry introduced by Microsoft in 1993. It is used to enable interprocess communication and dynamic object creation in any programming language that supports the technology. 
Microsoft® Active Accessibility® is a COM-based technology that provides a standard, consistent mechanism for applications and Active Accessibility clients to exchange information. This technology was integrated into the Microsoft Windows® operating system beginning with Windows 98 and continues to be updated with each new release. 
COM is primarily used with Microsoft Windows 
In an MFC program, you rarely need to call the Windows API directly. 
MFC was introduced in 1992 with Microsoft's C/C++ 7.0 compiler for use with 16-bit versions of Windows as an extremely thin OOP/C++ wrapper for the Windows API. 
Microsoft's emphasis on MFC has been reduced in favor of their .NET Framework. 

     Subpart B — Technical Standards

The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

DEVELOPERS are responsible for knowing how to program using the appropriate language, tools, and application programming interface (API).

The specific code will vary based on the language and technology used.

Notes:
We have text focus on a web page link – difficult to see here and normally difficult anyway – as well as the highlight of the “File” on the file menu and “Close Window” option, indicating that if the user were to use the enter key the “close window” option would activate.

Component Object Model (COM) is an interface standard for software componentry introduced by Microsoft in 1993. It is used to enable interprocess communication and dynamic object creation in any programming language that supports the technology. 
Microsoft® Active Accessibility® is a COM-based technology that provides a standard, consistent mechanism for applications and Active Accessibility clients to exchange information. This technology was integrated into the Microsoft Windows® operating system beginning with Windows 98 and continues to be updated with each new release. 
COM is primarily used with Microsoft Windows 
In an MFC program, you rarely need to call the Windows API directly. 
MFC was introduced in 1992 with Microsoft's C/C++ 7.0 compiler for use with 16-bit versions of Windows as an extremely thin OOP/C++ wrapper for the Windows API. 
Microsoft's emphasis on MFC has been reduced in favor of their .NET Framework. 

                                             
     Subpart B — Technical Standards

The focus shall be programmatically exposed so that assistive technology can track focus and focus changes.

TESTORS are responsible for knowing how inspect to include using assistive technology.

Including your developers in testing will produce better results no matter the language or technology used.

Notes:
We have text focus on a web page link – difficult to see here and normally difficult anyway – as well as the highlight of the “File” on the file menu and “Close Window” option, indicating that if the user were to use the enter key the “close window” option would activate.

Component Object Model (COM) is an interface standard for software componentry introduced by Microsoft in 1993. It is used to enable interprocess communication and dynamic object creation in any programming language that supports the technology. 
Microsoft® Active Accessibility® is a COM-based technology that provides a standard, consistent mechanism for applications and Active Accessibility clients to exchange information. This technology was integrated into the Microsoft Windows® operating system beginning with Windows 98 and continues to be updated with each new release. 
COM is primarily used with Microsoft Windows 
In an MFC program, you rarely need to call the Windows API directly. 
MFC was introduced in 1992 with Microsoft's C/C++ 7.0 compiler for use with 16-bit versions of Windows as an extremely thin OOP/C++ wrapper for the Windows API. 
Microsoft's emphasis on MFC has been reduced in favor of their .NET Framework. 

Assistive Technology?

from § 1194.31   Functional performance criteria:

•	(a) ...or support for assistive technology used by people who are blind or visually impaired shall be provided.
•	(b) ...or support for assistive technology used by people who are visually impaired shall be provided.
•	(c) ...or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
•	(d) ...or support for assistive hearing devices shall be provided.

•	(e) ...or support for assistive technology used by people with disabilities shall be provided.

Notes:
What is assistive technology?

      Assistive Technology (AT)‏

•	Assistive Technologies:	
–	Screen Reader
–	Software Screen Magnifier
–	Voice Recognition
–	Alternative Keyboards / Pointing Devices
–	On-screen Keyboard

•	AT complements Information Technology
–	Used to test; simulation of your end user's experience.	
–	Verifies developed applications are accessible.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology.  When an image represents a program element, the information conveyed by the image must also be available in text.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology.  When an image represents a program element, the information conveyed by the image must also be available in text.

•	E.g., Alert, Caret, Client (area), Cursor, HScroll, Menu, Sizegrip, Sound, Sysmenu, Titlebar, VScroll, Window.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology.  When an image represents a program element, the information conveyed by the image must also be available in text.

•	E.g., Alert, Animation, Application, ButtonDropDown, ButtonMenu, Caret, Cell, Character, Chart, Checkbutton, Clock, Column, Combobox, Cursor, Dialog, Listitem, Radiobutton.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology.  When an image represents a program element, the information conveyed by the image must also be available in text.

•	E.g., Animate, Busy, Checked, Collapsed, Default, Expanded, Focused, Haspopup, Hottracked (mouse), Invisible, Pressed, Protected, Readonly, Selected, Selectable.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology.  When an image represents a program element, the information conveyed by the image must also be available in text.

•	Cut, Copy, Paste, Undo, Delete...

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(e) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application’s performance.

Notes:
Note visual similarity between the x for close screen and the x for delete. This could arguably be confusing and a possible 508 violation.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(f) Textual information shall be provided through operating system functions for displaying text.  The minimum information that shall be made available is text content, text input caret location, and text attributes.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(g) Applications shall not override user selected contrast and color selections and other individual display attributes.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(i) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

•	Click on the red dot or box to continue...

Notes:
Number 42 made up of dots is difficult to see among circle of other dots. Three boxes: green, yellow and red, are labeled with text to identify them.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

Notes:
Screen showing range of color and ability to select preferred color.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.

Notes:
Same screen as previous slide but in greyscale.

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

•	User interface elements and screen items that flash or blink can cause seizures or other involuntary responses, particularly if they flash in high intensity, with high contrast, and in the frequency range between 2 and 55 cycles per second (2.0 Hz and 55.0 Hz). 

     Subpart B — Technical Standards

§ 1194.21   Software applications and operating systems.

•	(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

•	Use standard controls that provide textual information about form controls.
•	Provide Keyboard Access.
–	logical order, logical navigation (tab, arrow keys).
•	Ensure on-screen focus matches input location.
•	Label fields and data input fields.
•	Alert user before timeout.

     Subpart B — Technical Standards

key points about § 1194.21 Software applications and operating systems.

•	No specific coding cited.
•	Use standard development frameworks.
•	Developers must be skilled and aware.
•	New technologies often consider accessibility after release.

•	Your web browser is software!

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).

<img src=”dhs-logo.gif” alt=”DHS Logo”>
     
Notes:
Department of Homeland Security webpage.

Full Text Equivalent
example 1 of 2

Figure 2 shows an oval rock.  The top of the rock is in its natural state, but as we go down towards the bottom, bits of the rock have been chipped away, until the bottom has become thin, pointed and sharp.  
End of Figure 2 

Notes:
Fig. 2:  A Flint Fist Hatchet of the Early Stone Age, Found in an Ancient Bed of the Nile.
http://www.w3.org/2000/08/nba-manual/

Full Text Equivalent
example 2 of 2

Figure 91 dash one is a diagram in two parts.  In both drawings, each end of a large, rectangular shaped wire loop is connected to a cylindrical shaped dry cell, one end to the positive terminal, the other end to the negative.  In each diagram, there is a switch along the length of the wire a short distance from the dry cell.  The switch in the first drawing is open; in the second drawing it is closed.  As is indicated by arrows, the current in the second diagram flows in a counter-clockwise-direction.  In each diagram, a compass needle is placed beneath a horizontal leg of the wire rectangle.  The compass needle in the first diagram, through which no current is flowing, is parallel to the wire; in the second, through which current passes, the needle is at right angles to the wire.  Text.

Notes:
Figure 91-1, an illustration of an open circuit and closed circuit.
http://www.w3.org/2000/08/nba-manual/

 Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).

<img longdesc="FlowchartExample_LD.html"
alt="Description: This graphic describes the administrative steps, technical steps, and coding process for canned and live requests." src="LongdescAttributeImage.gif">

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).

•	Missing ALT text is never good; use blank “ ” if needed.
•	How would you describe over the phone?
•	Descriptive identification may be enough!
–	ABC Logo versus description of ABC Logo

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

•	CAPTIONING
–	“I said...”
•	AUDIO DESCRIPTION
–	BANG! (car backfires)‏
–	additional commentary describes body language, expressions and movements

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Notes:
Green, yellow and red boxes labeled textually with name of the associated color

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(d) Documents shall be organized so they are readable without requiring an associated style sheet.

Notes:
Three different Zen Garden webpages demonstrating cascading style sheet

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(e) Redundant text links shall be provided for each active region of a server-side image map.

–	Links:
•	North America
•	South America
•	Europe
•	Africa
•	Australia
•	Japan
•	China

Notes: Map of the world

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

Notes:
Map of the world

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(g) Row and column headers shall be identified for data tables.

•	Caption or Summary tags
•	Table Header <th> tag
•	Table Data <td> tag

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
•	Axis, Scope, rowspan, colspan attribute tags

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(i) Frames shall be titled with text that facilitates frame identification and navigation.

•	The FRAMESET element defines a row or a column in a frameset.
•	The FRAME element specifies a document that is to be displayed in a frame.
•	The NOFRAMES element is used to indicate content that should be displayed when the browser used is unable to display frames. 
•	Provide meaningful title attributes for each <FRAMESET> and <FRAME> tag.

•	Avoid the use of Frames!

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

–	Same as SOFTWARE (k)‏
•	User interface elements and screen items that flash or blink can cause seizures or other involuntary responses, particularly if they flash in high intensity, with high contrast, and in the frequency range between 2 and 55 cycles per second (2.0 Hz and 55.0 Hz). 

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way.  The content of the text-only page shall be updated whenever the primary page changes.

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

–	When authors do not put functional text with a script, a screen reader will often read the content of the script itself in a meaningless jumble of numbers and letters. Although this jumble is text, it cannot be interpreted or used.
–	Events created with JavaScript (asynchronous JavaScript and XML (Ajax), parsing, updating content must be accessible – be aware of limitations in browsers.
–	JavaScript is required more often; but should degrade gracefully.

JavaScript
•	Test the event handlers you use!
–	Work well:  onClick, onLoad, onUnload
–	Questionable:  onBlur, onFocus
–	Problematic:  onMouseOver, onMouseOut
–	Best to Avoid:   onChange, onDblClick, onMouseDown, onMouseUp
•	Remember the ALT text when using a graphic to invoke a function

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

–	(That would be the Software Standards)‏

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

–	Close to 1194.21 (L):
•	Use standard (web) controls that provide textual information about form controls.
•	Provide Keyboard Access.
–	logical order, logical navigation (tab, arrow keys).
•	Ensure on-screen focus matches input location.
•	Label fields and data input fields.
•	Alert user before timeout.

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(o) A method shall be provided that permits users to skip repetitive navigation links.

–	Screen reader users have to listen to everything in a linear fashion. Scanning to the main content involves listing to all header navigation unless there is a way to skip to the main content – a “skipnav”.

      Subpart B — Technical Standards 
Notes: Image of USDA TARGET web page

      Subpart B — Technical Standards 
Page has four headings and forty-six linksTARGET Center Home Page dash Internet ExplorerTable with one column and one rowThis page link skip navigation linksalt plus one Table endTable with one column and thirty-two rowsTable with three columns and one rowLinkGraphicUnited States Department of Agriculture Departmental AdministrationGraphicTARGET CenterTable endGraphicTARGET photo banner, Service That Works.Table with fifteen columns and one rowLinkGraphicTARGET Homealt plus four LinkGraphicAbout TARGETalt plus five LinkGraphicNews slash Eventsalt plus six LinkGraphicServicesalt plus seven LinkGraphicPublicationsalt plus eight LinkGraphicHelpalt plus nine LinkGraphicContact UsTable endTable with four columns and twenty-one rowsTable with one column and five rowsGraphicSearch TARGETEdit GraphicBrowse by SubjectLinkGraphicAssistive Technologyalt plus ten LinkGraphicErgonomicsalt plus eleven LinkGraphicEducationalt plus twelve LinkGraphicSection five hundred eight Compliancealt plus thirteen LinkGraphicTemporary Disabilityalt plus fourteen LinkGraphicEmergency Preparednessalt plus fifteen LinkGraphicInterpretive Servicesalt plus fifteen Table endTable with one column and fifteen rows You are here colon Link HomeHeading level one Up Next at TARGET GraphicPhoto of the New Target Center Thursday, September twenty-five th TARGET Center two point zero Join us for a special event introducing TARGET Center two point zero and  take a closer look at the newly redesigned Center.  Visit our Link Web Connect site at nine am EST on September twenty-five th for a special...

      Subpart B — Technical Standards 

§ 1194.22   Web-based intranet and internet information and applications.

–	(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

–	Web pages can be designed with scripts so that the web page disappears or "expires" if a response is not received within a specified amount of time. Sometimes, this technique is used for security reasons or to reduce the demands on the computer serving the web pages. Someone's disability can have a direct impact on the speed with which he or she can read, move around, or fill in a web form. For instance, someone with extremely low vision may be a slower-than-average reader. A page may "time out" before he is able to finish reading it. Many forms, when they "time out" automatically, also delete whatever data has been entered. The result is that someone with a disability who is slow to enter data cannot complete the form. For this reason, when a timed response is required, the user shall be alerted via a prompt and given sufficient time to indicate whether additional time is needed.

Challenges
•	Completely Automated Public Turing test to tell Computers and Humans Apart (CAPTCHA)‏

•	A CAPTCHA is a program that can generate and grade tests that most humans can pass, but current computer programs can’t pass.  For example, humans can read distorted text as the one shown below, but current computer programs can’t:

•	Should websites use an audio CAPTCHA as well as a visual one?  Absolutely!  Audio CAPTCHAs help visually impaired individuals navigate the Web.

•	The CAPTCHA Project is a project of the School of Computer Science at Carnegie Mellon University:  http://captcha.net
•	
•	Introduction to “Inaccessibility of CAPTCHA”  http://w3.org/wai/intro/captcha

Notes:  Picture of CAPTCHA with audio option

non-HTML
Flash / PDF / Word, etc.
•	1194.22(m):
–	When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).
•	Applies to Flash and Java apps.
•	Applies to viewers and readers, not so helpful for non-HTML documents.

Disadvantages of non-HTML web formats
•	Accessibility standards very HTML-centric
•	Accessibility features were afterthoughts
•	Some structures, like multi-level data tables, not supported.
•	May required specialized tools
•	Accessibility techniques may not map directly to 1194.21 provisions

Notes: Specialized market for service bureaus.
Specialized tools can be expensive, time consuming, and have a steep learning curve.

PDFs
•	Accessibility is possible but not automatic
•	Free Adobe Reader conforms to 1194.21
–	Even includes speech synthesis!
–	Under best circumstances, complaints still likely
•	Know why you are posting PDFs
–	Is consistency with print version really necessary?
–	Does it give a good feeling?  Is it just a bad habit?
–	http://www.alistapart.com/articles/pdf_accessibility
•	Cheap (or free) and easy output (print to PDF) usually results in inaccessible PDF files
–	At least for non-trivial source material
•	Use resources from champion for format:
–	http://www.adobe.com/accessibility/

Notes:
3 Kinds of PDF:  image only, image w/ text, tagged
	image only guaranteed to be inaccessible, have to test other two types.
It is an open standard.
PDF/UA may come out.
PDFs are not more secure.
Formats like DOC and PDF predates HTML by about a decade.  If they were not so bad in the first place, we never would have had HTML and the Web!

Is print held in too high esteem?

PDF:  What to do
•	Test output with Adobe Reader
–	Listen to every page
•	View -> Read Out Loud
–	Compare to visual presentation
•	Use Acrobat Professional
–	Acrobat Standard is not enough
–	Walk tag tree, make sure it matches
•	May need third party product
–	NetCentric CommonLook
•	May need to hire a service

Notes:
Tag tree needs to correspond to match visual presentation.

Modern textbooks have side bars and information balloons.  There is no single reading order.

MS Office: Word
•	Generally very accessible
•	Free readers conform to 1194.21
•	Text boxes, water marks, text art generally not accessible
–	Can use “Normal” View to get sense of what a screen reader user will miss.
•	Doesn’t really support data tables
•	Use resources from champion for format:
–	http://www.microsoft.com/enable/

Notes: Microsoft site is good for all MS products of course.

Word: What to Do
•	Use styles for headers and repeated formatting
•	In-line Clip Art and images okay
–	Select (or right click) -> Format -> Picture -> Web (tab) -> Alternative Text
•	Keep data tables simple
–	headers only in topmost row or leftmost column only
•	When in doubt, save as plain text

MS Office: Excel
•	Generally very accessible
–	But remember spreadsheets are intimidating for most people!
•	Free reader is not accessible!
–	Risky to assume public audience has MS Office
•	Most derived charts and graphs not directly accessible
–	The data driving the figures is available, but is that enough?
•	Avoid temptation to convey information with formatting
–	E.g., Do not only use color

Excel: What to Do
•	Make it easy to find header rows and columns
•	Make it easy to find any comments
–	Use left most column or separate sheet or document
•	Use white space very sparingly
–	Do not use empty columns for spacing
•	Adjust column padding instead
–	Avoid multiple empty rows
•	Adjust row height instead
•	When in doubt, save as text (tab delimited)‏

MS Office: PowerPoint
•	Not very accessible
–	Possible but cumbersome to use with screen reading software
•	Free reader is not accessible!
–	Risky to assume public audience has MS Office
•	Most images (especially charts and graphs) are not accessible
•	Objects in slide view particularly vexing
•	Save as Web Page feature is disappointing

Notes:
Reading order may be random, or follow creation order.

Bullets may read as characters.

Visually, hard to spot accessibility problems.

PowerPoint: What to Do
•	Ensure outline view stands alone
–	Is there other information in slide?
•	One option:  Repeat all content in Speaker Notes area
–	This includes text from main slide, any alternative text, and any long text descriptions as needed.
•	May need third party product
•	Accessible Web Publishing Wizard 
•	When in doubt, save as Outline/RTF

Notes:
Probably Speaker Notes or RTF version will need supplemental textual details.

Software requirements not found under .22
•	From software standards:
–	1194.21 (a) Keyboard Accessibility
–	1194.21 (b) Honor Access Features
–	1194.21 (c) Input Focus
–	1194.21 (d) UI Element Sufficiency
–	1194.21 (e) Consistent Bitmap Images
–	1194.21 (f) Textual Information via OS
–	1194.21 (g) Honor Visual Preferences
–	1194.21 (h) Control over Animation
–	1194.21 (j) Setting Color & Contrast

Notes:
These apply to Java, Flash, AJAX, all viewers.
Adobe Acrobat Reader, Windows Media Player, etc.

not explicitly stated but remember the web browser is SOFTWARE

Testing Suggestions
•	Ask vendors:
–	Which specific 508 provisions apply?
–	How does the website meet those requirements?  
(describe conformance)‏
–	May I have a copy of the testing report?

•	Don’t rely exclusively on repair tools.

•	Pitfalls of learning AT on your own.

Software Standards
•	ISO/FDIS 9241-171
–	Ergonomics of human-system interaction
•	Part 171: Guidance on software accessibility
•	W3C WAI User Agent Accessibility Guidelines 2.0
–	http://www.w3.org/TR/UAAG20/
•	First Public Working Draft 12 March 2008
•	HFES 200 Human Factors Engineering of Software User Interfaces
–	canvass draft 2006 (2008 version expected soon)‏
•	JTC 1 Special Working Group on Accessibility 
–	http://www.jtc1access.org/
•	Recent June 2008 meeting (site not yet updated)‏

Notes:
Listed here by maturity?

FD is “Final Draft”
http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=39080

http://www.hfes.org/publications/ProductDetail.aspx?ProductId=76

Accessible Software Developer Resources
•	Look to platform champions
–	Microsoft Active Accessibility (MSAA) and “UI Automation”
•	MSDN Library > Win32 and COM Development > User Interface > Accessibility
•	http://msdn.microsoft.com/en-us/library/ms753388.aspx
–	Sun
•	http://java.sun.com/javase/technologies/accessibility
–	Apple
•	http://developer.apple.com/ue/accessibility
–	IBM
•	http://www.ibm.com/able/
–	IAccessible2 (cross platform API)‏
•	http://linuxfoundation.org/en/Accessibility/IAccessible2

Notes:
Again, look to platform champions.

MSAA 2.0 includes “Object Inspector”
Search on “Active Accessibility 2.0 SDK Tools”
Accessible Event Watcher, Accessible Explorer, and Inspect Objects.

MSDN > MSDN Library > Win32 and COM Development > User Interface > Accessibility 
http://msdn.microsoft.com/en-us/library/aa163285.aspx

MSDN > MSDN Library > .NET Development > .NET Framework > Windows Presentation Foundation > Accessibility
http://msdn.microsoft.com/en-us/library/ms753388.aspx

ADC Home > Reference Library > Guides > User Experience > Accessibility > Accessibility Overview
http://developer.apple.com/documentation/Accessibility/Conceptual/AccessibilityMacOSX

Questions?
Norman B. Robinson 
norman.b.robinson@dhs.gov