A hole in section 508

By: Peter Abrahams, Practice Leader - Accessibility and Usability, Bloor Research
Published: 9th July 2009
Copyright Bloor Research © 2009

Section 508 of the Rehabilitation Act is the law in the US that enures that US Government organisations will only buy ICT products that are accessible.

When asked about accessibility, vendors will often say their products conform to section 508 and will point to the relevant document called a Voluntary Product Accessibility Templates (VPAT). Which will say if the product is accessible and any areas that are not fully accessible.

The problem is that the VPAT only considers the accessibility of the product and not the accessibility of any outputs of the product. This means that website development tools, Content Management tools, document creation tools or any other tool that produces output that may be viewed electronically can conform to section 508 but none of their outputs do.

It is obviously important that people with disabilities should be able to use the tools. However, overall, there will be many more people with disabilities who may wish to view the outputs than will use the tools. I would suggest that the question ‘does the tool produce accessible output?’ is in fact more important than the question ‘Is the tool accessible?’.

The vendors of tools, and the creators of Section 508, would argue that creation of accessible output is the responsibility of the user of the tool not of the tool itself. Although it is true that tools cannot ensure that the output is accessible I am convinced that they can help the user.

Tools can be categorised in terms of the help they provide in producing accessible outputs:

The output cannot be made accessible whatever the user does.
The output can be made accessible but the user is not given any specific help.
The user is given help by, for example: pre-built templates that are accessible, or prompts for information required for accessibility.
The tool includes testing for accessibility that can be triggered before the user saves new outputs.

I think it would be a great move forward for accessibility if Section 508, or similar regulations, included a section where the vendor could categorise the tool into one of these four categories.

In the meantime I would suggest that vendors who are truly committed to accessibility provide this information in addition to the VPAT.

Reader Comments

Posted: 9th July 2009 | By William Lawrence :

You don't mention anywhere here about the Authoring Tool Accessibility Guidelines, or ATAG. Are you suggesting that the Access Board in their refresh of Section 508 adopt some of the ATAG success criterion?

Posted: 9th July 2009 | By Mike Paciello :

If the US Access Board approves TEITAC's recommendation, then authoring tools will be required to produce accessible output. If M/376 ever gets off the ground in the EU, they will adopt similar requirements. Here's a list of the requirements: http://tinyurl.com/nk2blk.

Posted: 10th July 2009 | By Tom :

It is a very difficult question, as there is no way to ensure that a user will create accessible output with an accessible product. Especially content management systems could do a better job prompting users for creating accessible output, but it cannot be 100 percent bullet proof. Just like you cannot only rely on testing tools to determine accessibility, at the end it is always a human decision.
A VPAT is really nothing else than a checklist made out of a set of standards. Unfortunately it is not standardized, and while they are becoming more and more useful, we still cannot totally rely on them.

Posted: 17th July 2009 | By Sailesh Panchang :

I agree with Tom above that the system of self certification for accessibility via a VPAT is not dependable. The VPAT cannot be relied upon without verification by an accessibility auditor. Expecting a vendor to categorize the product as suggested by Peter also falls into this same trap. A vendor may claim that it it produces the most accessible output just as many claim the product interface is "Section 508 compliant" . So it is up to the purchaser of the tool to check out its features and ensure that it provides a framework or interface that is accessible and allows one to use standard compliant code as needed while authoring content . Some tools may do it better than others and may be more flexible and that will differentiate one product from another. Finally one will need to use an external accessibility validator or one that is integrated into the authoring tool or CMS to do some automated accessibility checks and rely on human evaluation using assistive technologies to validate results of automated tests and to uncover remaining accessibility barriers.

There does not seem to be consensus in the TIETAC 508 refresh proposals (in their present form) on use of prompts / templates by authoring tools for creation of accessible content. It also acknowledges the difficulty of coming up with standards in this regard that are comprehensive and testable. This is in line with Peter's observation above"Although it is true that tools cannot ensure that the output is accessible... ".

Now suppose this page itself was an output of an accessible authoring tool. How would you expect it to detect that blockquotes have been used incorrectly on this page to contain comments of readers? I have seen pages where fieldset has been used as a container for all controls within a form and the legend tag is used to mark up the form's title. The tool may allow use of blockquote or fieldset but how can it detect correct usage unless it is an evaluation tool at the same time? Evaluation is an entirely different ball game and the authoring tool maker might not even want to get into that realm.
Sailesh Panchang

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