Day 90: Section 508 and the ADA

I’ve had an accessibility-heavy week! However, it’s not without it’s rewards. I’ve found that sometimes on these journeys, ideas start to synchronize, articles relevant to what I’m questioning start to emerge in my Twitter feed, and people approach me about ideas or questions they have that spur me on further. In line with a talk I’m giving this weekend and the classes I’m taking through Deque, the U.S. laws that protect the civil rights of people with disabilities kept coming into question in my mind. It’s only appropriate that I spent a little bit of time with those fundamentals today.

Things I accomplished

  • Updated my presentation slides about people with disabilities.
  • Updated my presentation slides about accessible digital documents.
  • Completed Deque’s class “Section 508: Fundamentals of the Law and Technical Standards”.

What I reviewed today

The Americans with Disabilities Act of 1990

Covers:

  • Title I (workplace)
  • Title II (state and local government services)
  • Title III (public accommodation and commercial facilities)
  • Title IV (telecommunications for speech and hearing impaired)
  • Title V (federal enforcement of ADA)

[Federal] Rehabilitation Act of 1973 (amended in 1998)

  • Section 501 (federal employment)
  • Section 502 (enables role of Access Board, which defines ICT and accessibility standards)
  • Section 504 (federally-funded programs and services, including schools)
  • Section 508 (refreshed in 2018; federally-funded information and communication technology), usually enforced with 501 or 504.

What I learned from it

Federal laws were instated to protect people with disabilities, as well as present an example to state and local governments, plus private entities. Laws focus on physical and electronic access.

Physical:

  • Architectural Barriers Act (ABA)
  • Americans with Disabilities Act (ADA)
  • Section 504 of the Rehabilitation Act

Electronic:

  • Section 508 of the Federal Rehabilitation Act
  • Americans with Disabilities Act (ADA): for state and local governments
  • Section 255 of the Telecommunications Act

The ADA is essential a blanket civil rights law that protects the equal treatment of people with disabilities. Many lawsuits are championed with the ADA.

The Section 508 refresh specifically references WCAG 2.0, Level AA:

“E205.4 under Electronic Content indicates the accessibility standards for electronic content shall conform to WCAG 2.0 Level A and AA Success Criteria and Conformance Requirements”

However, non-web documents and non-web software are not required to meet four criteria:

  • 2.4.1 Bypass Blocks
  • 2.4.5 Multiple Ways
  • 3.2.3 Consistent Navigation
  • 3.2.4 Consistent Identification

There are some ICT exceptions in Section 508. These exceptions are:

  • Legacy ICT (“Safe Harbor”; created before January 17, 2018 and compliant with previous 508 standards)
  • National Security Systems (weapons or intelligence)
  • Incidental Federal contracts
  • ICT functions located in maintenance of monitoring systems
  • Undue burden or fundamental alteration (significant difficulty or expense, or alters the fundamental nature of the ICT)
  • Best Meets (a balance between Section 508 and agency needs, if compliant ICT is not available commercially)

The only exceptions to agency official communication (as opposed to public facing) being compliant with Section 508 are any records maintained by the National Archives and Records Administration (NARA) obsolete to Federal recordkeeping statutes.

Whew! And there’s still so much to learn…

Day 89: Writing a Real Accessibility Evaluation

Today I had the joy of practicing what I’ve been learning over the last 88 days. I’ve been itching to work through a formal evaluation, and this real opportunity came up.

Things I accomplished

  • Presented an accessibility issue to an accessibility working group that I chair.
  • Wrote an official evaluation to a separate working group to present aforementioned findings in a formal way.

What I reviewed today

First, I gathered the details that I’d written down. Next, I walked through the WCAG-EM Report Tool to reaffirm my findings, as well as add to them. Lastly, I composed a formal evaluation of the features that were not in conformance with WCAG 2.1, Level AA.

The base outline of my evaluation:

  1. Overview
  2. WCAG-EM evaluation
    1. Scope
    2. Failures
  3. QA testing
    1. Automated testing
    2. Manual testing
    3. Personas
  4. Remediation recommendations

What I learned from it

The process of evaluation can take a quite a bit of time, especially for someone who is new. I had to re-read many WCAG success criteria over again, limit my scope, and deeply think about what techniques were sufficient, advisory, or failures. Additionally, I encountered some bad practice and some not-so-optimal coding solutions, but refrained from delving into those since they are were not part of the aim of conformance. It was a true learning experience, and one I hope to refine over the next few years!

Day 88: Presentation Prep – Humanizing People with Disabilities

Today I spent a lot of time preparing for a library conference talk about accessible spaces and being mindful of people with disabilities. So, rather than go into further study with Deque courses or deep-diving into accessibility laws (as originally planned), I decided to blog about the presentation I prepared for.

Things I accomplished

  • Compiled an outline and draft of slides for the presentation.
  • Interviewed three people about their disability.

What I reviewed today

My presentation is actually a co-presentation. Speaking alongside two other people, my part will specifically focus on the “who” of creating accessible workstations and spaces. Hopefully, the following outline will fit into a 15-minute time frame:

  1. What is a disability?
    1. Definition
    2. General categories
    3. Specific categories
    4. Specific disabilities
    5. Spectrums
    6. Related categories (elderly, environmental, temporary)
  2. Assistive Technologies & Adaptive Strategies
    1. Screen readers
    2. Magnification & zoom
    3. High contrast mode & custom styles
    4. Switch access and control
    5. Speech recognition
    6. Eye-tracking
    7. Augmentative and Alternative Communications (AAC)
  3. What is accessibility?
    1. Definition
  4. So, who are these people, anyway?
    1. Stephen
    2. Michael
    3. Chrissie
    4. How many Alaskans?
    5. Julie
    6. Tracy
    7. Me
    8. Who do you know?
  5. The point: They are people
  6. How can we be accommodating?
  7. Contact me

The overall intent of my talk is to humanize disabilities. What I really enjoyed about today’s preparation was the opportunity to talk with other people about their disabilities, and hear about the barriers they’ve encountered that made them feel disabled. The most fascinating part was that, out of the three people I interviewed, no one considered themselves disabled or having a disability. Only when they encountered a challenge or a complete roadblock did they consider themselves as having a disability.

Day 87: Guidelines, Laws, and Myths

My intention today was to complete the first Deque course within the WAS certification prep program. I did do that, but not without being led to more resources that I need to read through. I’ve done a little research into US laws, but I need to read them again, plus read other laws mentioned in what I reviewed today. Looks like tomorrow’s study session is laid out for me.

Thing I accomplished

Completed guidelines, laws, and myths sections of Deque’s Accessibility Fundamentals.

What I reviewed today

Guidelines

Principles, guidelines, and authoring practices help create an accessible interaction between user and website or application. These guidelines and practices ensure that a variety of disabilities are taken into consideration.

I covered these more in detail on my own, which I’ve journalled on this site, but Deque does a decent job of getting the learner started with the basic principles and guidelines, and points them to official specifications. I’ll admit, I need to go back and spend some serious review time to go over all these.

Laws

Web accessibility laws usually fit into one of the following categories:

  • civil rights: discrimination against disabilities (Americans with Disabilities Act)
  • procurement: purchasing accessible IT products (Section 508 of the Rehabilitation Act)
  • industry-specific: regulations for private industries (21st Century Communications and Video Accessibility Act, Air Carrier Access Act)

United States

Canada

Europe

Other Regions

The Web Accessibility Initiative (WAI) has a comprehensive list of international accessibility policies. Additionally, PowerMapper has a list of government accessibility standards.

Myths and Misconceptions about Accessibility

  1. It benefits only a small minority. Truth: It actually benefits everyone.
  2. It’s a short-term project. Truth: It’s on-going.
  3. It should be the last step. Truth: It needs to start at the beginning of the project and last throughout the project’s life cycle.
  4. It’s hard & expensive. Truth: Remediation is harder and more expensive than considering it throughout the life cycle.
  5. It’s ugly. Truth: Most accessibility features are not visible to everyone.

Best takeaway

“Inaccessible web sites are not just inconvenient for people with disabilities, they are blocking.”

Day 86: The point – it’s for people with disabilities, Part 2

A continuation of Part 1 as I work through the Deque courses and review who I am doing this work for.

Things I accomplished

What I reviewed today

Disabilities that I reviewed today through the Deque course:

  • deaf
  • deafblind
  • motor disabilities
  • speech disabilities
  • cognitive disabilities
  • reading disabilities
  • seizures
  • multiple disabilities

Deaf

How they may interact:

  • utilize captions and transcripts for video

Developer considerations:

  • offer transcript alongside an audio file (WCAG 1.2.1, 1.2.4)
  • offer captions alongside video with audio (WCAG 1.2.2, 1.2.9)
  • when possible, offer sign language with videos with audio (WCAG 1.2.6)

Review Day 55: Users with Auditory Disabilities.

Deafblind

How they may interact:

  • interacts with keyboard (QWERTY or braille)
  • receives information through refreshable braille display and screen reader software

Developer considerations:

  • content needs to be text or coupled with text equivalents (WCAG 1.1)
  • site functionality must work with a keyboard (WCAG 2.1)
  • markup must be structured well, using appropriate semantics (WCAG 1.3, 2.4, & 4.1.1)
  • custom elements must express themselves with a name, role, and value (WCAG 4.1.2)
  • dynamic changes in content comes with an alert for screen readers (WCAG 4.1.3)
  • videos need audio description if the audio is confusing by itself (WCAG 1.2)
  • active controls need to be clickable (WCAG 2.5)
  • offer transcript alongside an audio file (WCAG 1.2.1, 1.2.4)
  • offer captions alongside video with audio (WCAG 1.2.2, 1.2.9)
  • when possible, offer sign language with videos with audio (WCAG 1.2.6)

Motor disabilities

Motor disabilities includes a wide spectrum of varying degrees and characteristics of physical experiences, challenges, and strategies. Specific disabilities include: cerebral palsy, ALS, quadriplegia, or missing limbs. Review Day 54: Users with Motoric Disabilities.

How they may interact:

  • mouth stick on keyboard (vertical or horizontal)
  • adaptive keyboard (one-handed, expanded, raised keys, etc.)
  • switch control devices
  • speech recognition software
  • eye tracking software

Developer considerations:

  • site functionality must work with a keyboard (WCAG 2.1)
  • interactive components (links, buttons, input) need a visible focus and hover state (WCAG 1.4.13)
  • warn users about time outs ahead of time, and offer extension of time (WCAG 2.2)
  • mark interactive controls large clickable targets (WCAG 2.5.5)

Speech disabilities

The causes of speech disabilities range from learning, motor, or auditory disabilities, autism, brain injury, stroke, cancer. They may or may not have full use of their voice and how they use that voice. Some issues can be categorized as stuttering, cluttering, apraxia, dysarthria, speech sound disorders, or non-vocal.

How they may interact:

  • unaided augmentative and alternative communication (AAC): body language expressions, gestures
  • aided augmentative and alternative communication (AAC): pen & paper, boards with symbols, speech-to-text software

Developer considerations:

  • provide other input methods other than voice input (WCAG 2.5.6)

Cognitive disabilities

Cognitive disabilities cannot be easily defined due to its wide spectrum. Some characteristics may include: limited comprehension, low tolerance for cognitive overload, limited problem-solving skills, short-term memory loss, attention deficit, difficulty reading, and difficulty understanding math. Review Day 53: Users with Cognitive Disabilities. It is the most common disability, due to its wide spectrum.

How they may interact:

Developer considerations:

  • create a simple interface (WCAG 1.4.8, 1.4.12)
  • write clear, direct, and easy to understand content, which includes a mixture of images and text (WCAG 3.1, 1.3.3)
  • post shorter videos and audio tracks
  • limit the number of choices offered at one time
  • offer help features (WCAG 3.3.5)
  • design for ease of use
  • test for usability with actual users with this disability
  • strive for consistency of information, navigation, and landmarks across the website (WCAG 3.2.3, 3.2.4)
  • reduce or allow control of distracting elements (motion, animation, autoplay) on a page 2.2.2)
  • warn users about time outs ahead of time, and offer extension of time (WCAG 2.2)
  • avoid use of Captcha

Reading disabilities

This could be caused by a cognitive disability or an another underlying reason. Review Day 52: Users with Reading Difficulties.

How they may interact:

  • customize foreground and background colors
  • customize typography
  • listen to text with a screen reader
  • use a screen reader for highlight text to follow along

Developer considerations:

  • include a mixture of images and text to convey the same information (WCAG 3.1, 1.3.3)
  • use good color contrast, but avoid the highest level, like black on white (WCAG 1.4.3, 1.4.6)
  • provide flexibility of user customization of styles for text and background (WCAG 4.1.1)

Seizures

How they may interact:

  • reduce animation and pause or skip video

Developer considerations:

  • avoid using video, transitions, and animations with frequent intense flashing (WCAG 2.3)

Multiple disabilities

A person deals with two or more disabilities.

How they may interact:

  • see all considerations under blind, low vision, deaf, deafblind, motor disabilities, speech disabilities, cognitive disabilities, reading disabilities, and seizures

Developer considerations:

  • see all considerations under blind, low vision, deaf, deafblind, motor disabilities, speech disabilities, cognitive disabilities, reading disabilities, and seizures

Day 85: The point – it’s for people with disabilities, Part 1

“…if you don’t understand the challenges that people with disabilities face when using ICT products and services, you don’t really know accessibility. Knowing what challenges people face is central to knowing how to reduce or eliminate challenges.” Karl Groves, What does it take to call yourself an accessibility expert?

That about sums it up for me after working through the WAS Body of Knowledge. The only way one can evaluate websites well is to remember who could be using our sites and how their engagement and experience may differ from our own. That’s basic UX (user experience) design, but with a focus on users with disabilities, which still encompasses a wide range of people and engagement strategies.

Things I accomplished

What I reviewed today

I’m trying to bring my focus back to the “who” part of my training. Without keeping them in the front of my mind, I will not be able to properly advocate for accessibility. Deque’s course highlights the following disabilities:

  • blind
  • low vision
  • color-blind
  • deaf
  • deafblind
  • motor disabilities
  • speech disabilities
  • cognitive disabilities
  • reading disabilities
  • seizures
  • multiple disabilities

Today I read through their explanations about various visual impairments. I found it helpful to revisit things I learned about in the past about users with low vision and identifying issues for keyboard users.

Blind

How they may interact:

  • may navigate by headings, landmarks, links via screen reader software;
  • listen for title and structure details of page via screen reader software;
  • use screen reader software, keyboard, refreshable braille display, touchscreen, or voice commands for input or output

Developer considerations:

  • content needs to be text or coupled with text equivalents (WCAG 1.1)
  • site functionality must work with a keyboard (WCAG 2.1)
  • markup must be structured well, using appropriate semantics (WCAG 1.3, 2.4, & 4.1.1)
  • custom elements must express themselves with a name, role, and value (WCAG 4.1.2)
  • dynamic changes in content comes with an alert for screen readers (WCAG 4.1.3)
  • videos need audio description if the audio is confusing by itself (WCAG 1.2)
  • active controls need to be clickable (WCAG 2.5)

Low Vision

Low vision is a spectrum. It varies in degrees and characteristics.

How they may interact:

  • magnify the entire screen (with magnification software), zoom into web pages, or increase text size
  • increase contrast or invert colors with High Contrast Mode or other software
  • use screen reader to hear text
  • navigate by keyboard or mouse

Developer considerations:

  • popups, alerts, and errors should be close to the visual focus
  • color should not be the only way to relay important information (WCAG 1.4.1)
  • contrast of foreground and background should be no less than 4.5:1 (WCAG 1.4.3, 1.4.6, 1.4.11)
  • don’t disable pinch-to-zoom
  • interactive components (links, buttons, input) need a visible focus and hover state (WCAG 1.4.13)
  • controls need to look different (actionable) than text (WCAG 1.4.8)

Color-blind

This is not an either-or characteristic either. Degrees of color identification vary from person to person.

How they may interact:

  • strategies to compensate may involve asking for help to distinguish colors

Developer considerations:

  • color should not be the only way to relay important information (WCAG 1.4.1)

Day 84: Strategies and Techniques for Fixing A11y Issues

Eighty-four (84) days in, and I made it to the end of the WAS Body of Knowledge (BOK)! I’m ready to go back through all my blog posts (journaling) to review things that I’m so nervous about forgetting by April. This will include pouring over the W3C’s Web A11y Evaluation Background Reading materials. I’ll also spend the last few weeks of these 100 days to work through the Deque courses that apply to this certification, and tie together ideas that will help me be a better Web Accessibility Specialist (WAS) in practice.

Today’s study session felt less productive, due to the topic implying review and application of all the things learned to be a WAS. However, the day did not go by without some positive steps toward taking the exam.

Things I accomplished

  • My request to take the WAS certification exam was accepted today, so I registered for the exam.
  • Read over the last section of the BOK: Recommend strategies and/or techniques for fixing accessibility issues.
  • Continued further through the Deque Accessibility Basics course.

What I learned today

A specialist or expert in web accessibility should have a solid understanding of:

  • how to evaluate web content using WCAG 2.0,
  • accessible web design,
  • web technologies,
  • assistive technologies,
  • how people with different disabilities use the Web,
  • accessibility barriers that people with disabilities experience,
  • assistive technologies and adaptive strategies that people with disabilities use, and
  • evaluation techniques, tools, and methods to identify barriers for people with disabilities.

Additionally, I think this person needs to bolster their project management and communication skills. Not only will they know what they’re talking about, but help educate and encourage the people they are helping with evaluation and remediation. A teacher and project manager, of sorts. Accessibility Pro Certified: To Be or Not To Be is a wonderful article that takes into consideration the idea of certification and what makes an accessibility pro or expert.

In order to recommend remediation strategies, a specialist has to understand:

  • how to create accessible content (the first major section of the BOK)
  • identify accessibility issues (the second major section of the BOK)
  • wisely choose an appropriate remediation technique that fits the goals and limitations an organization is working within (the third major section of the BOK)

This last study topic section in the BOK made me reflect back on all the considerations that go into prioritizing remediation, which often comes down to a balance of user and business impact. It circles back nicely to the start of the BOK, where I need to fully understand what accessible content is and how inaccessible content impacts users with disabilities.

 

Day 83: Prioritizing Remediation of A11y Issues

During today’s study session, I walked away with a lot of new-to-me information and useful steps to apply to my current work.

Things I accomplished

What I learned today

When starting an accessibility remediation project, start with a site’s core functionalities. Determine the issue’s origin (markup, style, functionality), then prioritize accessibility issues by severity of:

  • impact on users: does the problem have a user workaround or are they completely inhibited (blocked) from using a core functionality?
  • legal risk: related to user impact; is it a legal risk (based on functionality block and type of organization) or just a usability issue? take note of perceivability and repeat offenders
  • cost benefit: is the ROI greater than the time invested to remediate or lawsuit that may occur?
    e.g. ROI = ((Risk Amount – Investment) / Investment) * 100
  • level of effort to remediate (impact on business): how many changes (and where) have to be made?

WCAG conformance levels and success criteria are not the way to determine priority of remediation.

As mentioned in my notes about manual versus automated testing tools, it’s always best to target low-hanging fruit to begin quickly resolving issues.

When receiving an audit to proceed to remediation, people want to know:

  • where the problems are
  • what the problems are
  • how to fix them
  • not the specific technical guidelines and success criteria

Remediation is a hard lesson to learn in realizing that if things are made accessible from the start, less time and money is wasted.

Time is money. Just because you save time taking down inaccessible materials, time is added (technical debt shifted) to help desk lines or other resources.

I really liked Michigan State University’s accessibility severity scale:

  1. Level 4, Blocker: Prevents access to core processes or many secondary processes; causes harm or significant discomfort.
  2. Level 3, Critical: Prevents access to some secondary processes; makes it difficult to access core processes or many secondary processes.
  3. Level 2, Major: Makes it inconvenient to access core processes or many secondary processes.
  4. Level 1, Minor: Makes it inconvenient to access isolated processes.
  5. Level 0, Lesser: Usability observation.

Remediation procedure levels by Karl Groves:

  • simple: prioritization: time versus impact (user-centric)
  • advanced prioritization: scoring business and user impact (broken down by user type)
    (Impact + Repair Speed + Location + Secondary Benefits) * Volume = Priority

Best quote from today’s Deque course

Accessibility does not happen by accident. It has to be purposefully planned, built, and tested for accessibility.

Day 82: Testing with Users with Disabilities

Today’s study session led me back to usability testing. This seems to be critical when it comes to adding it to our testing toolbox to check for usability and accessibility issues that escape conformance checks, alongside automated and manual testing tools.

Personally, this is one of the areas I struggle with implementing. I love reading about usability testing and case studies that people document, but I’ve not yet taken the opportunity to try doing this myself. Usually because it has it’s own added cost, as well as awkwardness to set up testing with a specific group of people. Maybe this will be my motivator to make some connections and start a plan to make this happen this year.

Things I accomplished

Read:

What I learned today

The guidelines are not all-inclusive. Some good accessibility techniques may not be in WCAG because:

  • It is difficult to objectively verify compliance with the technique
  • The writers of the guidelines did not recognize the need for the technique when writing the guidelines.
  • The technique was not necessary (or at least not anticipated) at the time the guidelines were written, because the technologies or circumstances that require the technique are newer than the guidelines.

Before bringing in users for testing, do some preliminary checks and fix known issues in order to better discover underlying accessibility and usability challenges that were not detectable by software or manual checks.

Including users in testing doesn’t have to be a full-blown usability study. Informal evaluations and brief interactions with feedback can be very helpful. Additionally, informal evaluations can happen throughout the product’s lifecycle, rather than formal usability studies that usually occur near the end of development. Bonus: informal interactions can help us all see the person clearer rather than a case study.

Never assume that feedback from one person with a disability speaks for all people with disabilities. A small-scale evaluation (only a few people within a study) is not enough to draw solid conclusions with statistical significance, even though valuable insight occurs. Try to include a variety of disabilities: auditory, cognitive, neurological, physical, speech, and visual with different characteristics. If possible, include older people, as well.

Further reading

 

Day 81: Manual vs. Automated A11y Testing Tools

Today I went into my study time with the intent to list out pros and cons of automated versus manual accessibility testing. Instead I walked away with a comparison of what each had to offer, and understanding that both are valuable when used cooperatively during website and web app development.

Things I accomplished

Submitted my request to take the Web Accessibility Specialist certification exam in early April via private proctor.

Read:

Created a comparison table to jot down ideas about manual and automated testing (see under What I learned today).

What I learned today

Manual Testing Automated Testing
Slower process Faster process
Mostly accurate Sometimes accurate
Easier to miss a link Guaranteed check of all links
Identifies proper state of elements Automated user input can miss state
Page by Page Site-wide
Assurance of conformance Misleading in assurance of conformance
Guidance for alternative solutions Yes/No (boolean) checks and solutions
Human and software Software
Context Patterns
Finds actual problems Lists potential problems
Appropriate HTML semantics HTML validation
Accurate alt text Existence of alt attribute
Heading hierarchy Headings exist
Follows intention of usability Follows WCAG success criteria
Test is/isn’t readable Programmatic color contrast
Exploratory Automated
Part of the testing process Part of the testing process
Appropriate use of ARIA Presence and validity of ARIA
In real life Hypothetical
Identifies granular challenges of usability Quickly identifies low-hanging fruit and repeated offenders

In conclusion

Deciding on testing methods and tools shouldn’t be an either-or mandate. Each has their strengths and weaknesses. Using both methods should be a part of every testing process. Why not strengthen your product’s usability by incorporating tools from each methodology into your process?