The Truth About the Refresh: WCAG 2.0 It I!

In January 2017, the U.S. Access Board issued the Information and Communication Technology (ICT) Standards and Guidelines, updating its existing Electronic and Information Technology Accessibility Standards under Section 508 of the Rehabilitation Act of 1973, (“508 Standards”), and the Telecommunications Act Accessibility Guidelines under Section 255 of the Communications Act of 1934 (“255 Guidelines”). These Standards are now in effect as of January 18, 2018.

How does this affect the requirements for PDF compliance with Section 508?

The new rules are a lot to digest, as the encompass accessibility regulations for a huge range of electronic information technology.  Most of it does not pertain to our services at Accessibility In Mind (AIM). Let’s see what the final regulatory analysis said about PDFs:

The requirements for one specific type of electronic documents—those stored in PDF—are established by referencing the applicable ISO standard. PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content.

Makes sense, but after comments were received, we got the final ruling, PDF/UA is no longer referenced:

The intent of the proposed IBR of PDF/UA–1 in the NPRM was to make conformance assessment of PDF documents easier, assuming that, in the future, PDF/UA–1 would become widely adopted. WCAG 2.0 strongly informed the development of PDF/UA–1. With the exception of the contrast requirement, PDF/UA–1 includes most accessibility requirements relevant to the PDF format, including textual equivalence for static graphical elements. However, PDF/UA–1 does not address scripting or the use of PDF files as a container for video. Therefore, the end user would still have to reference WCAG 2.0 for some requirements to ensure that a PDF file is fully accessible. Because WCAG 2.0 can be used as a sole standard for PDF compliance, and PDF/UA–1 cannot, the Board finds WCAG 2.0 to be appropriate as the sole standard for PDF files. Therefore, in the final rule, we have removed the reference to PDF/UA–1 from E205.4, C203.1, and 602.3.

Reference: https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines

WCAG 2.0 It Is

Wouldn’t it be great if PDFs used the same structure and protocols as web content, like HTML and all of it’s children? Sorry, not where we are. PDFs have their own specific way of doing and describing content, Adobe made sure of that.

Here’s WCAG 2.0; see if you can find much specific to PDF tags. Nothing there.  In many ways, it is a broadening of the regulation, rather than a guide to how you create any specific content. For example, Principle 4, “Robust”

Content must be robust enough that it can be interpreted reliably by a wide variety of user agents, including assistive technologies.

Below that you will find the guidelines, which say that whatever “markup language” you use, make sure your “tags” are correctly formatted:

Start and end tags that are missing a critical character in their formation, such as a closing angle bracket or a mismatched attribute value quotation mark are not complete.

That is a no-brainer, but if you want help making sure your PDFs are accessible, you need to work to a guide that’s in the “language” of your content. It is logical: the Access Board couldn't write specs for each and every conceivable markup language, it had to be general. 

Accessibility in Mind is covering all bases: We're dedicated to providing remediated documents that are as accessible and compliant as is technologically possible; to that end we will guarantee our documents are compliant with WGAG 2.0, and that they conform with PDF/UA’s much more relevant criteria.

PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content to ensure accessibility for people with disabilities who use AT such as screen readers, screen magnifiers, and joysticks to navigate and read electronic content.

The International Standard for Accessible PDF Technology (PDF/UA-1) provides a roadmap for remediating, testing, and ensuring accessible PDFs that are “universally accessible”.

Accessibility is our goal here at AIM, and we are “refreshed” and ready! All documents remediated by Accessibility In Mind are compliant with WCAG and PDF/UA-1

What Do You Mean, Accessibility In Mind?

“Accessibility In Mind”  means thinking about accessibility EARLY in the production process. We work with our clients to create procedures that reduce the time and cost of remediation. Using best practices can save 25-50% on post-production needs, so we like to be involved as early as possible, reviewing drafts, so we can help you understand the remediation process and how a few basic steps can make it go smoothly and quickly.

All AIM-remediated PDFs are guaranteed compliant with Section 508, and with the new “ICT Refresh”, following the specifications of PDF/UA-1 (ISO Standard 14289),  as specifically referenced in the Information and Communication Technology (ICT) Standards and Guidelines (updated Section 508 of the Rehabilitation Act, January 18,2018

The AIM Difference:

#1: Accessibility In Mind is a dedicated Section 508 and PDF/UA compliance service.

We are not a design/print house that does remediation on the side- remediating PDF documents, making them accessible and compliant, is our ONLY service.  Find the home page of our competitors if you want to know what their main business is, then come back to AIM for your Section 508 work!

#2: We are not a middle-man, taking a commission and passing the work on to contractors.

When you work with AIM you are dealing DIRECTLY with Section 508 expert remediators, and paying less– often 30-50% less– than through other vendors. Deal direct, SAVE TIME AND MONEY!

Do You Feel Section 508 Refreshed? The New ICT Rules Are in Effect

*******SUPERSEDED....INCORRECT INFORMATION**********

In January 2017, the U.S. Access Board issued the Information and Communication Technology (ICT) Standards and Guidelines, updating its existing Electronic and Information Technology Accessibility Standards under Section 508 of the Rehabilitation Act of 1973, (“508 Standards”), and the Telecommunications Act Accessibility Guidelines under Section 255 of the Communications Act of 1934 (“255 Guidelines”). These Standards are now in effect as of January 18, 2018.
How does this affect the requirements for PDF compliance with Section 508?
The new rules are a lot to digest, as the encompass accessibility regulations for a huge range of electronic information technology.  Most of it does not pertain to our services at Accessibility In Mind (AIM), let's see what the actual rule says about PDFs:

The requirements for one specific type of electronic documents—those stored in PDF—are established by referencing the applicable ISO standard. PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content.

The new ruling provides much more specific requirements than the original rules, as it references the detailed guidelines of PDF/UA-1. PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content to ensure accessibility for people with disabilities who use AT such as screen readers, screen magnifiers, and joysticks to navigate and read electronic content.

This is a major leap forward, as the 20-year old Section 508 regulations didn't know what a PDF was, let alone what made a PDF accessible. Various agencies created their versions of their interpretations, most notably HHS (last update here is 2013) with no consensus reached. This left clients and remediators with the responsibility to actually create and publish accessible documents, and the ability to claim compliance with little fear of reprisal.

The International Standard for Accessible PDF Technology (PDF/UA-1) finally provides a roadmap for remediating, testing, and ensuring accessible PDFs that are compliant with the "refreshed" rules.

Accessibility is our goal here at AIM, and we are "refreshed" and ready! All documents remediated by Accessibility In Mind are compliant with PDF/UA-1

Choosing a Remediator for Section 508 Document Compliance Services

Increased monitoring of accessibility and enforcement of the regulations of Section 508 are driving health care organizations and government contractors all over the country to get "legal" with the ADA and avoid possible litigation and penalties. This often manifests itself in an executive directive to "find out what we should be doing and how much it will cost."

You may be the person in your organization tasked with this research job. How can you find out what is necessary and practical, not to mention legal? If you are a lawyer, you can certainly wade right into the statutes and interpret their intent and meaning, but how does a lay-person find good information, and the best advice possible?

It may be like being asked to find out how you might replace the foundation of your office building, and not knowing why you need to do it, or the first thing about construction. Where to do you start?

DO NOT assume that a "508 Services" offer on a website menu means the company actually does that kind of work, or that anybody in the company has more than a passing knowledge of both the regulation and the process for conformance. They may just be a pass-through in a related business (most often related to publishing and document preparation). You may fill out a form and request information, general, or specific to a document, hoping to learn something from the response.

You will get a reply from the company's 508 contact, and if your request was specific,  a bid and an "evaluation" of your document- certainly an invitation to tell them more about your situation. This may be helpful, but doesn't really tell you much about the most important piece of the puzzle, the remediator. That is the specialist who actually does the work. The remediator is not a salesperson trying to make a commission, but an expert who can answer questions about your documents and the process of making them compliant.

When doing 508 research, look for knowledgeable sources, beware of a sales pitch.

How do you buy a pig in a poke? A "poke" is a bag that obscures what's inside. You buy the bag, you may or may not get the pig. Section 508 compliance may seem like that: you send your document off, it comes back a few days later looking essentially the same, maybe with active TOC and bookmarks. You've been told that it passes this or that  508 checker- a machine check-- and it probably does. Did you get a compliant document? You hope so, and deliver the document to your client. But what happens then? The document may go straight to publication without further review, or your client may have reviewers (who may be other contractors, btw) that WILL know the difference. The good ones know what makes a document accessible, and that's what you want to deliver

Interview potential remediators, see if they can answer tough questions about your job. If they are just a sales person, realize that they are just a middleman adding their commission to the costs. Look for expertise, it's your only man.

Get References

This goes without saying, not sure why we are saying it. You may not know much about Section 508 or the process of compliance remediation, but any established remediator should be glad to put you in contact with satisfied clients. Look especially for repeat clients, which is a remediator's highest compliment.

A Long Road For the Disabled: Accessible Information and Ancient Regulation, a Brief History of Section 508 and the "Refresh"

Technology evolves at lightning speed- regulations for accessibility, not so much.

Section 508 became effective in 2000- how can 17 year-old regulations apply to today's enormous, ubiquitous electronic information flow? Smart phones, tablets, "always on" connectivity weren't part of life in 2000, and regulations written in the 20th century, essentially "pre-internet", can't be expected to be relevant. Add to that the proliferation of new devices to deliver information; the iPhone came out in 2007, the iPad in 2010-- were certainly not being considered when Section 508 was born. Those of us with "access" consume massive amounts of information electronically, a quantum leap in a few short years. But accessibility is far from universal. Are we getting anycloser to implementing sensible rules to ensure that technology today and in the future is accessible to all?

The original standards requiring electronic and information technology to be "accessible", the 1998 Section 508 amendment to the Rehabilitation Act of 1973, has an unarguably fair premise:  Universal access to the internet and electronic documents, with a mandate to "eliminate barriers in information technology, to make available new opportunities for people with disabilities, and to encourage development of technologies that will help achieve these goals."

It was "mandated" that the rules be regularly reviewed and updated, but guess what? There may have been some reviews, but no updates SINCE 1998. Different government agencies have interpreted the rules and created their own checklists, most notably the HHS checklist which has had no substantial changes since it was originally published in 2007. "Every man for himself" seems to be the guiding principle.

The Access Board has been meeting sporadically over the years, and finally agreed and published an update. Federal agencies will be required to comply with the revised Section 508 standards beginning on January 18, 2018 (unless budget cuts and de-regulation takes over...).

Here's a brief timeline of how we finally got here:

February 3, 1998 –Original Telecommunications Act Accessibility Guidelines
December 21, 2000 –Original Section 508 Standards
July 6, 2006 –Members named to Advisory Committee (TEITAC)
April 3, 2008 –TEITAC presents final report
March 22, 2010 –Draft proposed rule (ANPRM) to update the Section 508 standards and Telecommunications Act guidelines
December 8, 2011 –Revised draft proposed rule (2nd ANPRM)
February 27, 2015 –Proposed rule (NPRM) published in Federal Register
January 18, 2017 –Final rule published in FR

"Only" 7 years passed from the first drafts of an update to publication in the Federal Register, but 18 years will have passed between the original standards and this much-needed update. Whew....makes me tired to think about it.

Head over to Section508.gov for their toolkit for the refresh, and let's get accessible and compliant!!! One tiny step in the right direction, I guess we should be cheering.

Let's Stop With the Stupid.

"An accommodation is a means or method outside of Section 508 standards designed to assist users with disabilities in cases where the application of current Section 508 standards is neither feasible nor helpful."

Look here, https://www.hhs.gov/web/section-508/accessibility-accomodation/index.html, a sensible approach to documents that should NOT be "remediated" for compliance with Section 508. You are wasting your time and yours or your client's money.

Example: A map. How are you going to describe a map in words that in any way is "equivalent" to what a sighted user gets. 

Example: Documents with large tables."It is unreasonable to expect a person using a screen reader to sit through the audible reading of a long table."

Much as we would like accessibility to be universal, we can't climb every wall, no one can. 

WCAG and Section 508: PDF Requirements

PDF/UA clarifies and simplifies the PDF-specific technical requirements to meet WCAG 2.0.

WCAG 2.0 is regarded as the primary standard for web accessibility by national governments around the world, and is referenced in the U.S. Access Board's new rules that updates accessibility requirements for information and communication technology (ICT) in the federal sector covered by Section 508 of the Rehabilitation Act. The six-year process of updating these requirements constitutes the first refresh since Section 508 was created in 1998. The rule is slated to go into effect in March, 2018, and references WCAG 2.0 and PDF/UA as the standard for compliant PDFs.

Creating PDFs that meet the WCAG 2.0 success criteria requires specific PDF authoring and remediation techniques. WCAG 2.0 was developed as a technology-independent standard and provides individual (normative) success criteria for accessibility which are general enough to apply across technologies, including a growing set of techniques for HTML, CSS, Scripting, PDF, Flash, and more. The Access Board's update states that all electronic documents must "conform to all Level A and AA Success Criteria in WCAG 2.0 or ISO 14289-1 (PDF/UA-1)." This proposal for accessible electronic support documentation is derived from the existing guidelines, but would newly require PDFs to comply with PDF/UA.

WCAG  does not presently represent a complete set which encompass all technical requirements for accessibility in all PDF documents. This is where PDF/UA provides help. PDF/UA provides normative technical specifications for the use of the PDF format, defining proper structure and syntax to enable reliable access. This includes identification of necessary tagging structures, how to specify alternative text for images, how to ensure correct Unicode mappings for character glyphs, and many other file, page and object-level specifications, as well as how Reader applications and assistive technologies can fully process PDF/UA conforming files to maximize accessibility.

PDF/UA defines the technical specifications to enable PDF documents to meet WCAG 2.0, but WCAG 2.0 has additional requirements which require an author’s attention. The areas where WCAG 2.0 has additional requirements include time-based media (guideline 1.2), scripting and actions (e.g. success criteria 3.2.1 and 3.2.2), and certain types of content (e.g. success criteria 2.4.4). For these and other additional requirements, the W3C’s technique documents (both general and PDF-specific techniques) provide guidance for authors interested in complying with WCAG 2.0.

WCAG 2.0 summarizes web accessibility using four broad design principles:

1. Content must be perceivable.
2. Interface elements in the content must be operable.
3. Content and controls must be understandable.
4. Content must be robust enough to work with current and future technologies.

These concepts are refined and delineated in the PDF/UA specifications; please refer to this article on PDF/UA for more information: http://508compliantdocumentconversion.com/pdfua-and-section-508/

AIIM, the governing body for ISO standards, published a document that shows how to achieve WCAG 2.0 through the use of the PDF/UA standard. It can be found here: http://www.aiim.org/Research-and-Publications/standards/committees/PDFUA/WCAG20-Mapping