Categories
Accessibility Technology

Digital Accessibility: 2015 Annual Legal Update

Presenter:  Lainey Feingold & Linda Dardarian

This is the second presentation I attended on Wednesday, March 4 at the #CSUN15 conference.  Thankfully, it’s in the same room as the 9:00 AM session, so I didn’t have to pack up my stuff and rush off to another room!  I have not attended this session in the past, as I tend to favor the more technical sessions.  However, I hear great things about this annual session, so I decided to see if the good press would bear out.  As we’re about to get started, this is truly a “standing room only” session…a good sign? Anyway, this session covers only the last 12 months.

Lainey:  Linda Dardarian could not appear because she’s covering a case of hardwood floors that have too much formaldehyde in it (!)

“Toolbox” metaphor was used liberally throughout this presentation

US DOJ

Slow bureaucrats or Accessibility Champions?  I say, they are accessibility champions in the realm of digital accessibility!  The law is but one tool in the accessibility champion’s toolbox.  The question at issue is really a civil rights question:  do people have the right to access digital content?

Accessibility Champions

Here’s just some of the work by the DOJ around the country:

  • National Museum of Crime & Punishment
  • Nueces County:  project civic action
  • DeKalb, IL (+3) online app accessibility
  • FL County Court records
  • FL state police
  • Peapod grocery delivery
  • Lucky stores

DOJ:  web sites have long been considered covered by the ADA.

 

DOJ Requires…

  • Apply to web and mobile
  • WCAG 2.0 is standard
  • Web accessibility coordinator
  • Independent consultant
  • Train all staff
  • POst a policy
  • Home page AIP (Accessibility Information Page)
  • Add to performance evaluations (this is interesting)
  • Usability Testing

Regulations?

  • 508 (Access Board finally issues 508 refresh)
  • Applies to purchases by the Federal government

What

  • Broad application of WCAG AA as standard
  • Covered electronic content [public facing +8 categories of non-public facing content]
  • Expanded interoperability reqs
  • Real time text functionality

When

  • Feb 27, 2015 (published in Federal Register)
  • May 28, 2015 (open for comment until)
  • Final Rule Published
  • Becomes effective +6 months after Final Rule publishing

ADA Web Regulations?

  • We just don’t know exact dates…
  • We’re waiting for Title 2 (public sector) and Title 3 (private sector) dates of publication.  They never hit these deadlines.
  • See www.ada.gov for more info

Legal Advocacy

  • DOJ is not the only player in this space…
  • Toolbox metaphor was used liberally throughout this presentation

Watch (streaming video/education services)

  • NAD (National Association of the Deaf) & VUDU
  • NAD and Netflix
  • NAD and Apple
  • Harvard and MIT (edX open courseware)

Learn

  • Math in Seattle (online education services)
  • Student loans (department of education and loan agencies)
  • Youngstown State/University of Cincinnati (course, registration materials).  This applied to both public and private institutions!
  • LSAC (similar to SAT; testing accommodations).  As of now, they are fighting this.

Read

  • Scribd (unlimited online books – “the Netflix of books”).  This was filed in Vermont because the Netflix case was brought there.  They tried to get the case thrown out of court.  Judge seems to understand the issues involved, so I’m hopeful…
  • HathiTrust:  the authors guild sued a collaboration of educators for conversion of materials for educational purposes.

Stay Healthy

  • Communicating print information to blind people via “talking pill bottles”
  • Caremark
  • Walgreens
  • Sutter
  • Kaiser

So much of this information is still inaccessible, including web sites, applications, and more.

Work

  • ACB v GSA
  • Marriott case (software inaccessible to employees)
  • Homeland Security (employee not able to access online content)
  • Montgomery County (NFB handling for employee who can’t use software)

Be Prepared

Digital content is really important for emergency preparedness, and it MUST be accessible to people with disabilities.

  • New York City
  • Washington DC

Bank

  • Cardtronics:  ATM (Automatic Teller Machines)
  • NY banks (settlement with 12 New York banks)

Travel

  • SoCal Taxi case
  • Airline Kiosk case (rules don’t kick in for 10 years after case won, which was 2 years ago)

Shopping

  • eBay (web 2.0 sustainability agreement)
  • RedBox case wrapped up this year

Wrinkles

  • 9 circuit court of appeals will hear digital access cases
  • Cullen v Netflix
  • Earll v Ebay (verification process that used phone – obviously this doesn’t work for Deaf / Hard of Hearing)

CVAA

  • Captioned Clips
  • Extended Waiver for ereader

International

Lots going on around the world, we don’t have enough time to cover that here!  We really need to have a three hour session for this…

Start and End

Phone calls and feedback from the customer.  You have to make your voice heard!

Other Sessions at CSUN, be sure to look up these sessions!

Q & A

 

Categories
Accessibility Technology

The Implementation of PDF/UA and Standardized Access to PDF Content

Presenter:  Karen McCall of Accessibil-IT, Head of Quality Control and Training.  @accessibilit

This is my first post of the CSUN 2015 conference, and the first presentation I attended on Wednesday, March 4 at the #CSUN15 conference.  I have a particular interest in this topic because the latest round of accessibility remediation and content updates my web team and the folks I work with at CSUN are addressing is the vast number of Word and PDF documents posted on the CSUN web site.  I’ve also read a little bit about the PDF/UA ISO standard (thanks @WebAIM list serve!) and am interested in seeing how – or if – this has any impact on the work my colleagues will be doing where “the rubber meets the road.”

Accessibil-IT swagAccessibil-IT folks handed out some “accessible IT swag” just before the presentation:  a key-shaped USB stick.  Nice 🙂  They claim it’s the best swag offered at the conference…we’ll just have to see about that!

This session is divided into two parts:  brief powerpoint slide presentation, then a demonstration of an Adobe Acrobat Pro document that is PDF/UA compliant with Jaws screen reader.

Karen has been working with Adobe PDF for about 15 years, and has written books, given training sessions, contributed to the standard and much more during that time.  She’s also a Canadian delegate to the standards committee.  Contributes to both user experience perspective and technical standard.

This is written into the newly published US section 508 refresh:  documents will conform to all Level A and AA success criteria in WCAG 2.0 or ISO14289-1 [PDF/UA-1].

PDF Accessibility 101

  1. if a PDF is not tagged, it is not accessible
  2. Just because a document HAS tags, doesn’t mean it’s accessible
  3. Read out loud text-to-speech tool is NOT A SCREEN READER

What is PDF/UA?

  • Initiated by AIIM (association for information and image management and adobe systems in 2004
  • Responsible for establishing a set of standards for crating accessible PDF
  • A technical standard for software developers
  • An implementation strategy for achieving accessibility within a PDF
  • designed around the same barrier-free principles behind the methodology of WCAG

Why do we need PDF/UA?

  • To achieve a reliability of expectations from one PDF to the next
  • PDF/UA success criterion are broken down into three parts:
  1. File conformance [ISO 14289-1]; file conformance [ISO 32000-1]
  2. Reader conformance
  3. Viewer conformance

Having a published standard will make machine-readability much easier for vendors like Google, Microsoft and others (think creation & conversion).  Human QA is still going to be needed, but to a somewhat smaller extent.

Question:  will book publishers be required to adhere to this standard?  Not at this time, but we are notifying publishers that there actually IS a published international standard now.  This is part of the reason why we come and give presentations like this at #CSUN15.

Question:  Does the standard cover forms?  Yes, but there’s a distinction between XFA forms and forms created Adobe Acrobat.

As of today, NVDA is currently the only AA-compliant PDF/UA reader.

What’s Different with PDF/UA?

  • It provides developers a framework to build accessibility into their application or output file from the start
  • It eliminates perceived “best practices” or “user preference” from organizational document accessibility practices
  • It’s based on semantics and established document authoring logic

PDF/UA compliant documents will provide a more consistent user experience, which is important for users

  •  Provides a prescriptive PDF interaction model which addresses a broad range of disabilities and facilitates the use of many adaptive technologies.
  • Leverages the applicable WCAG principles for the best in general usability.

Question:  Does it allow for reflowable text?  Yes.

Question:  How does it provide for tagging diagrams?  There is an implementation guide published by AIIM that describe how to do this.  I recommend you have a look at the “Matterhorn Protocol,” which provides a checklist that describes how document remediators should do this.  The PAC (PDF Accessibility Checker) does something similar (note:  PAC developer is xYMedia, their web site is in German) .  Neither of these tools eliminate the need for human quality assurance.  A comment from the audience highlighted the usefulness of the PAC for people who are new to PDF remediation.  The PAC tool is not itself accessible with JAWS (the devs know about this and are working on it), but it’s actually a great “in your face” way of showing you mistakes in the document.

Demonstration of a PDF/UA-compliant document showed some of the useful features for end-users.  This included use of keyboard shortcuts for document navigation by headers, images, links, tables and more.

 

 

 

Categories
Accessibility Technology

CSUN 2014 Web Track Mega Post

As usual, I like to make a post that sums up my entire conference experience…I call this the “Mega Post.”  As you may have guessed from the titles of the sessions I attended, I’m interested in the web track.  If the web is your bag, you just might find all this helpful.

Enjoy!

 

Friday, March 21

 

Thursday, March 20

 

Wednesday, March 19

 

Tuesday, March 18

 

Monday, March 17

Categories
Accessibility Technology

How to Win the Accessibility 3-Legged Race

This is my second session from the third day at the CSUN conference.  This description of this session from the event guide says that “We need accessible web products from our design agencies.  How do we make sure they deliver on that?  We provide practical advice drawn from experience.”  These guys definitely have the best session titles, and all their sessions I’ve attended were entertaining and had great usable content.  The very first slide has My Little Pony, so we’re definitely off to a strong start.  This might be my last post of the conference, since I have a train to catch.  Onward!

 

Presenter:

 

RESOURCES

 

George and Billy talked a bit about themselves and what they do.  They then said they’d help us with the often awkward “agency-client handshake.”  #awkwardhug

 

Agenda

  1. Set yourself up for success
  2. Create strategy and stick to it
  3. Be realistic about your team’s a11y knowledge
  4. Use testing tools AND test with users
  5. ABC always be closing

Round-the-room discussion

 

If you ask a simple question as a client like “is the product keyboard accessible” and they come back with Ctrl-Shift-Alt-F2-w-t-f”  That will tell you a lot about the company.  Common excuses and comments:

  • An excuse is “on our web site we sell ___ so blind people will not visit our web site.
  • Accessible web sites are ugly

 

Set yourself up for success

  • Ask lots of questions.  Early on.
  • If you see a lot of checklists early on, that is often something to be concerned about.
  • If you’re in an AGENCY:  “we need an accessible web site” is not a good requirement.  Read between the lines…is it a legal requirement, or do they have corporate buy-in?  What if you’re the only agency who is successful in delivering accessible web products?  Make it something that you can sell, list it on your web site!
  • If you’re a CLIENT, talk to your peers.

 

Create a Strategy and Stick to It

  • AGENCY:  work the client to develop milestones and figure out how to get there.  Make it an integral part of your workflow, it’s becoming a competitive advantage.  Bake it in at every stage.  Your account/project manager needs to clearly articulate how accessibility is done.
  • CLIENT:  ask one question:  what’s your accessibility strategy?  Pro tip:  if you have style guides / development guidelines that include accessibility, share those with the agency.  Compromise is OK as long as it’s realistic.

 

Be realistic about your team’s accessibility knowledge

  • AGENCY:  use your strongest web guy for the job; your SharePoint guy ain’t gonna cut it!
  • You need your whole team to know accessibility.  Teamwork, not “the one guy who knows VoiceOver”
  • Start small, ask your team to take the short online AODA / Customer Service course (a google search will turn this up).  Pro tip:  put a requirement in your RFP that the agency must take  this course.  It won’t make them experts, but it will give them a baseline knowledge.
  • CLIENT:  testing only with screen readers is not going to cut it.
  • Make sure you’re comfortable with the agency’s accessibility knowledge.  Don’t get into meetings / calls with the sales team, ask for the PM, BAs, designers, etc.  Ask for examples of their work with other accessible projects.  If the agency has no proven knowledge of accessibility, hire a third party.

 

Use testing tools AND test with users

  • Find the testing tools that work for you and use them.  It needs to be a part of your workflow.
  • AGENCY:  Test with users with disabilities.  You don’t need to invest in expensive testing tools. Just turn on VoiceOver on your Mac or High Contrast Mode in Windows.  Other tools we recommend are WebAIM WAVE toolbar, aViewer, Web Accessibility Toolbar, Color Contrast Analyzer, etc.
  • CLIENT:  Test with users with disabilities or at least simulate with assistive technologies.  Use automated testing tools, especially for regularly-posted content.  Be smart about prioritizing:  1 big issue on 1 page versus 1 small issue on 80 pages.

 

Always be Closing

  • “We’ll just do it in phase 2” never happens
  • Use MVP (minimum viable product) for accessibility
  • Write a report that clearly depicts the accessibility results.
  • Do good work and don’t be afraid to show the client you can do it again, this is your chance to articulate that in the report.
  • CLIENT:  spot-check, then sign-off on it.  It’s better to launch with some accessibility issues than not launch at all. Planning for some remediation is OK.  Ask the agency to report on the results of their accessibility strategy/work completed.  HINT:  you don’t actually care how they report.  Major benefit?  You flip the accessibility process upside down!  You’re basically asking for two things:  do the accessibility work and tell me about what you did.
Categories
Accessibility Technology

Making Accessibility Compliance Claims – VPATs and GPATs

This is my first session from the third day at the CSUN conference.  This description of this session from the event guide says that “methods and techniques for developer valid, defensible claims of accessibility compliance in public sector procurements including VPATs and GPATs.”  In my experience working with vendors of IT products and services, one thing I’ve learned is that while they may say they have a VPAT,  we often provide the vendor with tips and guidance that they then sell right back to us!  This is the first time I’ve been in a session put on SSB BART Group, I’m curious to see what they’re all about.  The Arizona Wildcats pep team was outside making some noise, which was kinda fun.

Presenters:

  • Tim Springer, SSB BART Group
  • Matt Arana, SSB BART Group

 

RESOURCES

 

SSB has been around for about 20 years, we’re a completely accessibility-focused group.  They cover pretty much the gamut of technology platforms and have done a huge number of audits and reviews.

 

A compliance claim is “An official statement of compliance of [something] with a [standard/guideline]”

  • Section 508 does not currently define a conformance claim process
  • WCAG has a conformance claim process

Compliance claims are often used in procurement, regulatory, and litigation situations.  Some causes for concern include claims without substance, claims against nebulous requirements and claims that are false.

 

Laws, Standards and Guidelines

  • WCAG is published by W3C; there are two versions, 1.0 and 2.0.
  • From the basis of most web accessibility standards, including 508

WCAG is strongly aligned with EU and 508 laws.  508 is purely a federal law.

CVAA (US) requires communication and video that go over the Internet to be accessible.  Primarily targeted at communications software and equipment manufacturers, video service providers and producers of video content.

ADA is a US civil rights law, and application to IT is tricky.  There are no technical standards for compliance.

 

Scope of Coverage:  If it has to do with 1s and 0s, it may be impacted

  • 508:  all EIT
  • ADA: public and employee facing EIT
  • CVAA:  Communications and video EIT
  • May also see information and communication technology (ICT) used

Where are you selling, who’s buying, and what are the risks?  These should be considered as part of your “go to market strategy.”

 

VPATs

  • VPAT is a registered trademark of the ITIC:  Information Technology Industry Counsel
  • Current version 1.3, ITIC accessibility policy page has this
  • VPATs have been largely superseded by WCAG compliance claims, especially in the private sector.
  • WCAG is likely to be globally harmonized on

 

GPAT

  • A GPAT is Government Product (or Service) Accessibility Template
  • Takes general procurement language and puts it into a document that can be used.  GSA quick links provides GPAT formats for procurement types; BuyAccessible Wizard can generate them de novo.
  • Government may accept a VPAT in lieu of a GPAT
  • While formatted differently, they contain materially the same information.

GPAT and VPATs look essentially the same, but GPAT includes more formalized details about total supported provisions (full, partial, not).  This allows for easier scoring of products.  However, the GPAT may not supersede the VPAT due to lack of awareness, and is more likely to be superseded globally by WCAG compliance claims.  A healthy discussion followed about the trickier aspects of VPAT/GPAT statements of full | partial | not supported.

 

Statement Creation

What are actually trying to do?  Make it accurate, and it should be done by someone who understands both the system and accessibility.  Have some documentation behind the process…claims should be well justified based on the demonstrable accessibility of your system.  This is good from both a regulatory and sales perspective.  So…you really should do some internal testing for audit purposes.

 

Auditing Requirements and Constraints

Technical Reqs (1194.21-1194.26), Functional Reqs (1194.31), and Support Reqs (1194.41).  Automatic testing makes up about 25% of the actual testing you need to do on a product to ensure it’s accessible.  Manual testing makes up close to 50% of that effort.  Global testing makes up about 25% of total testing and represents systemic testing, i.e. error messaging, color palettes, etc.  Technical testing is not easy, you need a lot of domain expertise to do it properly.

 

Audit Approach

Technical testing is broken down each section into best practices.  508 testing is broken down into about 130 separate tests to make sure a tool’s sample pages are web-accessible.  Functional testing involves real-world use cases tested by people with disabilities; can they accomplish the task in the use case?