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*******SUPERSEDED....INCORRECT INFORMATION**********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

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. 

FINALLY! U.S. Access Board Updates Interpretation of Section 508!

The U.S. Access Board has released a final rule that updates accessibility requirements for information and communication technology (ICT) in the federal sector covered by Section 508 of the Rehabilitation Act. The rule also refreshes guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The six-year process of updating these requirements constitutes the first refresh since Section 508 was created in 1998.

"This update is essential to ensure that the Board's Section 508 standards and the Communications Act guidelines keep pace with the ever-changing technologies covered and continue to meet the access needs of people with disabilities," states Sachin Pavithran, Chair of the Board's ICT ad hoc committee. "The Access Board is grateful for the input it received from the public and stakeholders throughout the rulemaking process which greatly enhanced the final product."

The rule jointly updates and reorganizes the Section 508 standards and Section 255 guidelines in response to market trends and innovations, such as the convergence of technologies. The refresh also harmonizes these requirements with other guidelines and standards both in the U.S. and abroad, including standards issued by the European Commission and with the Web Content Accessibility Guidelines (WCAG), a globally recognized voluntary consensus standard for web content and ICT. In fact, the rule references Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 and applies them not only to websites, but also to electronic documents and software.

"Throughout this process," according to Access Board Executive Director David M. Capozzi, "the Board worked very hard to ensure consistency with other consensus guidelines and international standards to promote global harmonization and facilitate compliance." He noted that, "ICT requirements that are closely aligned remove ambiguity, increase marketplace competition, and lead to better accessibility features and outcomes."

The updated requirements specify the technologies covered and provide both performance-based and technical requirements for hardware, software, and support documentation and services. Access is addressed for all types of disabilities, including those pertaining to vision, hearing, color perception, speech, cognition, manual dexterity, and reach. The rule, which will be published later this month in the Federal Register, restructures provisions so that they are categorized by functionality instead of by product type due to the increasingly multi-functional capabilities of ICT products. Revisions are also made to improve ICT usability, including interoperability with assistive technologies, and to clarify the types of ICT covered, such as electronic documents.

The Board released a proposed version of the rule for public comment in February 2015 and, before that, earlier drafts of the rule. The rule is based on recommendations from an advisory panel the Board chartered, the Telecommunications and Electronic and Information Technology Advisory Committee which included representatives from industry, disability groups, government agencies, foreign countries, and other stakeholders.

The rule will take effect in one year. The Section 508 standards, which are incorporated into the federal government's procurement regulations, apply to ICT procured, developed, maintained, or used by federal agencies. The Communications Act guidelines cover telephones, cell phones, pagers, computers with modems, switching equipment and other telecommunications equipment.

The Board will conduct a webinar on the rule on February 2.

New York City Sets the Pace For Accessibility, Requires Conformance With Section 508

New York City takes the lead in accessibility, passing a law in March of this year requiring that its government agency websites and electronic documents meet recognized standards WCAG 2.0 and Section 508.  This is hopefully the start of a trend making the Federal mandate universal, a giant step towards accessibility- state and local governments may follow NYC’s lead, requiring contractors and even public accommodations to conform in the absence of regulations from DOJ.

 New York City becomes the first major municipality in the United States to adopt legislation mandating accessibility standards for all of its government agency websites.  Serving a population of over 8 million, the New York City government includes more than 120 agencies staffed by approximately 325,000 employees.  This legislation will have an impact on City agencies, and access for persons with disabilities to those institutions.  It may also have an impact on future website regulations impacting businesses across the country.

“New York City is an amalgamation of cultures, heritages and languages,” Mayor Bill de Blasio said. “That is why we strive to increase inclusivity, especially when it comes to New Yorkers with disabilities. Whether it’s creating a more accessible City website, or ensuring that events hosted by City agencies have information regarding accessibility for people with disabilities, Intros. 673-A, 683-A, 881-A and 883-A strengthen our efforts to be more inclusive.”

The legislation (Intro. 683-A) was among three disability access bills that Mayor Bill De Blasio signed into law on the same day.  In addition to mandating website protocols, the legislation requires that each City agency designate a “disability service facilitator,” and publicize, among other things, the availability of wheelchair access, communication access real-time translation, sign language interpretation, assistive listening systems, and any other accommodations to be made available for all public events.

The sweeping mandate states that agencies must adopt an "Accessible Website Protocol" within 6 months. The new City law recognizess that the Web Content Accessibility Guidelines 2.0 Level AA (“WCAG 2.0 AA”) is increasingly becoming the de facto standard for website accessibility, despite the continued lack of any regulations from the U.S. Department of Justice setting a legally-required standard for state and local governments under Title II of the ADA.

Under the new law, the City must establish a website protocol within 6 months that incorporates Section 508 of the Rehabilitation Act,  WCAG 2.0 AA, or any “successor” standards.  The Section 508 standard currently applies to the federal government websites and electronic documents, and consists of a list of 16 requirements that are less rigorous than WCAG 2.0 AA.  But last year the Access Board proposed a rule that would, among other things, adopt WCAG 2.0 AA as the new website standard under Section 508.  Thus, if the City incorporates Section 508 in its website protocol, its agency websites may be subject to WCAG 2.0 Level AA once the final Section 508 regulations are issued.

“The City Council is committed to making New York a more inclusive City for all people to work and live,” City Council Speaker Melissa Mark-Viverito said. “This package of legislation will increase language access across City websites and improve access to City services for all New Yorkers.”

Chris Frank, CEO of Accessibility In Mind, a dedicated Section 508 remediation service says "It's no surprise that NYC is being proactive in requiring government services and documents to be universally accessible- it benefits all citizens, not just handicapped ones. It's like the curb cuts that make sidewalks wheel chair-friendly- they are great for walkers and bikers as well. It only makes the city more attractive, as it adds value which everyone shares."

Sample Section 508 Audit and Primer

Here's a little primer on tagging PDFs for Section 508 compliance, just four pictures worth a thousand words each- this is from an AIM document audit:

Screenreaders like JAWS read the content of standardized "tags" in PDF documents out loud. The name of the tag informs the screenreader as to what the content is- say a top-level heading <H1>, paragraph text <P>, a table <Table>, list <L>, etc. Correctly formed, ordered tags can give a blind reader almost as much information as the sighted reader has- the screenreader can scan the page and "see" the headings, lists, navigate through tables, etc.

So accessibility is all about the quality of the tags. Let's look at the doc. Well, first off, we look at the document properties. Sorry, they are empty, screenreader can't do much with that. But it doesn't matter, because, notice in the lower left, Where it says "Tagged PDF: No"? That tells the screenreader to take a hike, won't read a thing. Kind of a red flag, accessibility-wise, I'd say:

​

Easy enough to edit the meta-data and denote it as a tagged PDF, as there are some tags. Let's read!!!

First thing the screenreader would read out loud is the contents of the first tag. What do we have? look in the left column, the first tag in the document is the page number 63. Oops.... well that's not right obviously- page numbers should not be read out loud, to begin with, but we know right off we have reading order issues:

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The first section of the tag list is all page numbers. In the next section we finally get to the title page.

Below: First tag is the logo, <Figure> tag- oops....it should have "alt text" like "LA Health Plan logo" to inform our sight-impaired user. Title gag is next, I've opened it up to show what the screenreader sees, "Medi-cal Program". But the title should be tagged <H1>- this one has a <no_paragraph_style> tag that the screenreader just sees as regular paragraph text. (Note: automatic PDF checkers would "pass" this; you can tag a doc as one big <P> tag and fool them...).

Big deal, you say, but wait, it gets better:

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(What do you suppose those items to the left and outside the page are about? It is tagged content. We'll skip over it for now- certainly not content that needs to be read aloud. Sloppy tagging, at the least, hopefully just stray blank tags.The screenreader will call out "blank" and "Figure- no alternate text exists" as it passes through, doh...)

The real problem with this document, and the final slide in our lesson, comes right away after the cover page. There are NO TAGS on the body of the document. The screenreader would stop after the title page. 

​

The next tags in the tag list are for the back cover, nary a tag in between.

This document is not accessible or compliant with Section 508, I guarantee it. This doc needs a complete remediation job.

Contact http://508compliantdocumentconversion.com/ ASAP!!!!

Why Use Accessibility In Mind For Your Section 508 Remediation: 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.  Look at 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!

http://accessibilityinmind.com/

What about ISO? What does it have to do with Section 508?

ISO 14289-1 (2012) is a set of "consensus standards" that would be "incorporated by reference" into the proposed revision/update for Section 508 (refer here). It is the formal name for PDF/UA.

ISO 14289-1 (2012), Document management applications — Electronic document file format enhancement for accessibility — Part 1: Use of ISO 32000-1 (PDF/UA-1), would be incorporated by reference at E205.1 and 602.3.1. This is an international standard for accessible portable document format (PDF) files. 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 assistive technology such as screen readers, screen magnifiers, joysticks and other assistive technologies to navigate and read content. This proposed standard is new to both the 508 Standards and the 255 Guidelines. It is offered as an option to WCAG 2.0 for accessible PDFs.

Need PDFs that are compliant with Section 508, PDF/UA and ISO? Need answers right now? Call Accessibility In Mind, 919-410-7408, or visit our website.

FAQ: What fonts are compliant with Section 508?

Question: What fonts can I use? I read where you can only use system fonts Calibri, Times, Trebushi etc. and I want to use a different font for a document.

Answer: This is a common question, one that is NOT addressed in Section 508 of the Rehabilitation Act of 1973, as amended in 1998. Here's the pertinent section, "web-based intranet and internet information and applications (1194.22, sub-sections a-p)" right here.  See anything about fonts???

The regulations are not specific; various agencies have created their own interpretations and requirements. In February of this year, the Access Board published their proposal to remedy this, called the "Proposed Information and Communication Technology (ICT) Standards and Guidelines". They state, "Incorporating these standards complies with the federal mandate—as set forth in the National Technology Transfer and Advancement Act of 1995 and OMB Circular A119—that agencies use voluntary consensus standards in their regulatory activities unless doing so would be legally impermissible or impractical." And they even get more specific about their lack of specifics: "the existing 508 Standards, which contain no referenced standards."

How about that for guidance?  The proposed standards do go a long way down the long road that is accessibility, when approved. Until then, common sense is the best "voluntary consensus standard".

HHS "recommends" those fonts, but not using them does NOT mean you aren't in compliance. (HHS checklist: "Does the document utilize recommended fonts (i.e., Times New Roman, Verdana, Arial, Tahoma, Helvetica, or Calibri)?") Even with HHS, failing that checkpoint doesn't mean non-compliance; what makes a document non-compliant is if it is inaccessible. Obviously, the criteria is accessibility. The regulation does not say you have to use any particular font.

Best practice is to see if your client has a checklist or any guidance regarding their interpretation of the regs, and of course, use a readable font. Probably a no-no on the wingdings.....

More information on Section 508: http://508compliantdocumentconversion.com/

Question: I'm new to Section 508 compliance- how does"remediation" change our documents?

This is a common question from our new clients. Often all they know about Section 508 is that there is a line-item in their deliverables contract stating that they must provide a "Section 508 compliant" PDF to complete the job.  The "remediated" document returned from the compliance service looks exactly like the document sent to them. How do we know we have a compliant document.

First off, there is NO certificate that is issued by any government agency certifying compliance. Your only proof of compliance is documentation that accompanies your accessible PDF.

 Luckily, you have found a reputable document remediation service, Accessibility In Mind, and you can rest easy.  When we complete any remediation we provide our clients with documentation of the work performed, which includes accessibility reports from one or more sources:

• Acrobat 11 full accessibility report: This is the first stop, a report that shows compliance in 32 of 32 categories, and proves technical compliance.
• PAC Accessibility Check: The PAC program provides a fast way to test the accessibility of PDF files. PAC supports both experts as well as end users conducting accessibility evaluations, and is based on the Matterhorn Protocol. Matterhorn was designed to foster adoption of PDF/UA by providing a set of 31 Checkpoints and 136 Failure Conditions that help software developers exchange detailed information on PDF/UA conformance and create software to make it easier for document authors to create fully accessible PDF files and forms.
• CommonLook by NetCentric Section 508 Reports: Common Look is considered the "gold standard" for accessibility reporting, and is recommended by Health & Human Services (HHS) and is generally accepted for all government contracts.

Additionally, all AIM documents are spot-checked using JAWS, the most popular screenreader developed for computer users whose vision loss prevents them from seeing screen content or navigating with a mouse. (The read-aloud feature in Adobe Reader and Acrobat is NOT a substitute for a dedicated reader.) All AIM-remediated documents passing CommonLook accessibility checks meet HHS specifications and are guaranteed compliant with Section 508.

Undue Burden: A Legal Issue for Section 508 Compliance

Agencies can apply an exception to section 508's requirement to provide accessible and compliant documents if the creation of a compliant version would cause "an undue burden." Undue burden is defined as a significant difficulty or expense. However, the definition is not precise and is open to interpretation. Undue burden is a legal issue. Your agency should not consider such an exception without consulting legal counsel.

To determine if the undue burden exception applies, an agency must consider and thoroughly document the difficulty and expense of compliance in relation to all agency resources available to the program or component for which the product is being acquired.

When an agency qualifies for an undue burden exception, section 508 still requires it to provide an alternative means for individuals with disabilities to access the information. This means that even if the document is not accessible, the information or data it provides must be available through an alternative means of access. For example, an agency might provide a plain text version of a document that is not otherwise accessible.

Accessible and Compliant Tables

Question: There are plenty of interpretations of the Section 508 regulations. How do I know my organization is creating accessible tables?

Answer: An Accessibility Forum with over 960 individuals from more than 600 companies, associations for people with disabilities, research and standards institutes, and government agencies from throughout the US and Canada created a "Quick Reference Guide", which lists every Section 508 provision, defines terms, explains the provision, and answers, "How can I tell if this provision is met?" It may not be the law of the land, but it is very unlikely that a judge would over-rule their interpretations with their own. Below is their guidance regarding tables; they refer to HTML, but the same holds true for PDFs. Note that 1194.22(g) specifies only that row and column headers be "identified"; in a PDF the means <TH> and <TD> tags applied appropriately. 1194.22(h) deals with what may may considered "complex"tables. Additional information can be found here: http://www.w3.org/WAI/tutorials/tables/ ; note that the examples show ID tags added to the markup, but the examples are for small tables. This may not be functionally practical for large, complex tables. Some tables may not be practically accessible for use with assistive technology. Source: http://www.buyaccessible.gov/content/quick-reference-guide#1194.22

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1194.22 (g) Row and column headers shall be identified for data tables.

What does this requirement mean? Terms and Definitions: data tables - tables used to represent tabular information. Assumptions: Assume this requirement does not apply to tables used strictly for layout purposes, and assume that informed humans can reasonably consistently judge whether a table is used strictly for layout. How can I tell if this requirement is met? Identify all uses of a data table. Establish that the table is a data table which needs column and / or row headers for understanding its contents.

1. Inspect web content source to help identify appropriate data table headers. Some tips for inspection of HTML to help identify appropriate identification of data table headers:
   1. Column headers: the first data row of the table is composed of <th> elements instead of <td> elements.
   2. Row headers: the first cell of each data row is a element instead of a <td> element.Note: Tables that are used strictly for layout should avoid this markup.
   3. Apply AT to make sure row and column headers are identified. Note the use of AT as a measurement method is limited by the adequacy of algorithms and heuristic methods of the specific AT tool used. It can be used to identify problems with specific AT-E&IT interoperability but it cannot predict results with other AT or with other versions of the same AT, OS, application or accessibility architecture. AT should include the full range e.g. screen readers, screen magnifiers, alternate input devices, etc
   Note: Satisfying this requirement supports interoperability with assistive technology, such as screen readers and magnifiers, which must be able to interpret data tables. Where can I get additional information?
   1. Guide to the Section 508 Standards for Electronic and Information Technology, Web-based Intranet and Internet Information and Applications (1194.22), Updated: June 21, 2001, http://www.access-board.gov/sec508/guide/1194.22.htm#(g)
   2. The W3C WAI Web Content Accessibility Guidelines 1.0 Checkpoint 5.1 provides further guidance and techniques for this requirement athttp://www.w3.org/TR/WCAG10/#tech-table-headers
   3. W3C WAI User Agent Accessibility Guidelines 1.0 techniques for browsers, etc. to handle HTML tables: http://www.w3.org/TR/UAAG10-TECHS/topics.html#table-techniques
   4. The W3C WAI maintains a listing of various tool and services available for evaluation and repair of web pages for web content accessibility, athttp://www.w3.org/WAI/ER/existingtools.html
   5. IBM Web accessibility checklist version 5.1, checkpoint 1.3e http://www-03.ibm.com/able/guidelines/web/accessweb.html

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1194.22 (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.

What does this requirement mean? Terms and Definitions:  data tables - tables used to represent tabular information. Assumptions: Assume that informed humans can reasonably consistently judge whether the markup adequately reflects the table row and column headers. How can I tell if this requirement is met? Identify all uses of a data table that have two or more logical levels.

1. Inspect web content source to help identify appropriate multi-level data table headers. Are row and column headers associated with each data cell?
   1. Inspect the HTML find appropriate identification of multi-level data table headers by looking for various combinations of the <thead>, <col>, <colgroup>, and <th> elements, and "axis", "id", "scope", and "headers" attributes.
   Note: Tables that are used strictly for layout should avoid this markup.
2. Apply AT to make sure row and column headers are identified. Note the use of AT as a measurement method is limited by the adequacy of algorithms and heuristic methods of the specific AT tool used. It can be used to identify problems with specific AT-E&IT interoperability but it cannot predict results with other AT or with other versions of the same AT, OS, application or accessibility architecture. AT should include the full range e.g. screen readers, screen magnifiers, alternate input devices, etc

Note: Satisfying this requirement supports interoperability with assistive technology, such as screen readers and magnifiers, which must be able to interpret data tables. Where can I get additional information?

1. Guide to the Section 508 Standards for Electronic and Information Technology, Web-based Intranet and Internet Information and Applications (1194.22), Updated: June 21, 2001, http://www.access-board.gov/sec508/guide/1194.22.htm#(h)
2. The W3C WAI Web Content Accessibility Guidelines 1.0 Checkpoint 5.2 provides further guidance and techniques for this requirement athttp://www.w3.org/TR/WCAG10/#tech-table-structure
3. W3C WAI User Agent Accessibility Guidelines 1.0 techniques for browsers, etc. to handle HTML tables: http://www.w3.org/TR/UAAG10-TECHS/topics.html#table-techniques
4. The W3C WAI maintains a listing of various tool and services available for evaluation and repair of web pages for web content accessibility, athttp://www.w3.org/WAI/ER/existingtools.html
5. IBM Web accessibility checklist version 5.1, checkpoint 1.3e http://www-03.ibm.com/able/guidelines/web/accessweb.html

What's your standard? Accessibility In Mind has you covered for Section 508, PDF/UA, WCAG 2.0, HHS

Ensuring Indemnity With Documentation

Accessibility In Mind offers extensive accessibility reporting supporting all recognized standards, guaranteeing compliance. Whatever your specific requirements may be, AIM can remediate your documents to comply.

• Section 508: Section 508 was originally added as an amendment to the Rehabilitation Act of 1973 in 1986. It requires  Federal agencies to make their electronic and information technology accessible to people with disabilities. The regulations are broad in nature and are interpreted differently by different agencies. AIM can provide Section 508 specific reports certifying compliance.
• PDF/UA: PDF/UA (“Universal Accessibility”) specification, or ISO 14289, was published by the International Organization for Standardization (ISO) in August, 2014. PDF/UA requires Tagged PDF (ISO 32000-1, 14.8), and adds a variety of qualitative requirements, especially regarding semantic correctness of the tags employed. It is the first fully accessible standard ISO has ever published. AIM can provide PDF/UA specific reports certifying compliance.
• WCAG 2.0: The current version,  was published in December 2008 and became an ISO standard, ISO/IEC 40500:2012 in October 2012.It consists of 14 guidelines which are general principles of accessible design, primarily for websites, but applicable to PDF accessibility. AIM can provide WCAG specific reports certifying compliance.
• HHS: The United States Department of Health and Human Services (HHS) maintains a checklist defining their interpretation of Section 508, providing specific guidance on compliant PDF structure. AIM can provide HHS-specific reports certifying compliance.

Every remediated document is delivered with time-stamped Adobe Acrobat Pro 11 full accessibility reports, and NetCentric CommonLook reports are available for all accessibility standards. These reports prove due diligence in compliance with the most stringent requirements, and ensure indemnity from any legal challenges to document compliance.

Accessibility In Mind gives you one less thing to worry about- contact us for more information.

Is there any such thing as "Certification" for section 508 compliance?

Yes, Virginia, there is.

 AIM, formerly Electronic Document Compliance Services, is pleased to announce the availability of certificates of compliance for Section 508, PDF/UA, HHS, and WCAG 2.0. AIM can evaluate and certify compliance of any PDF, providing time-stamped accessibility reports, your insurance against any and all claims of non-compliance, guaranteed.

Contact us for a no-obligation evaluation of your documents.

EDCS To Become Accessibility In Mind

Electronic Document Compliance Services, a recognized leader in Section 508 and PDF/UA remediation services, has announced their new company name, Accessibility In Mind. 

From the company's press release:

Our mission remains constant, accessibility for all, and our singular service is document conversion and remediation- a one-stop solution to your compliance needs. Accessibility In Mind's federally certified compliance specialists complete all remediation, following industry best practices and using the latest technology, with comprehensive standards support of WCAG 2.0, PDF/UA, HHS as well as Section 508.

Health Insurance Document Specialists

We are experienced in remediation for all types of health insurance provider documents- ANOC, EOC, SOB, etc., with rapid turnaround. Complete documentation of remediation performed and compliance test reports are part of every deliverable.

Contact Accessibility In Mind and see how we can take care of your compliance needs.

Aiming to exceed your expectations: http://accessibilityinmind.com/

Estimating Costs for Section 508 Compliance Remediation

Here's a nice overview showing some real-world examples of what it takes to make documents accessible and compliant with Section 508:

Child Abuse Prevention Resource Guide for 2013 is over 80 pages (see https://www.childwelfare.gov/pubs/guide2013/guide.pdf). From design of this document to PDF conversion, this report required about 20 hours of work to ensure compliance. 

Child Maltreatment 2011 and 2012 reports (http://www.acf.hhs.gov/programs/cb/research-data-technology/statistics-research/child-maltreatment) are examples of ~250-page reports that required about 40–50 hours to fix Section 508 compliance issues and address any resulting formatting issues in the PDF.

Child Welfare Outcomes reports (http://www.acf.hhs.gov/programs/cb/research-data-technology/statistics-research/cwo) are over 400 pages, with many data tables, and may take well over 80 hours and $6–8K to make Section 508 compliant.

Overall remediation budget for about 200–225 PDFs of various sizes and complexity, most in the 2–20 page range with perhaps a quarter in the 21–200 page range, is about $250K. If most of the documents are at the high end of these page ranges, the cost (assuming a loaded rate of $80/hour) would be upwards of $300K.

These are just examples- the variation is as broad as is the variation in documents. Consult with a knowledgeable 508 remediator to find out what it takes to make your documents accessible and compliant. 

http://508compliantdocumentconversion.com/

Getting Multiple Government Agencies on the Same Page Regarding Section 508

Anyone involved in the often onerous task of remediating documents for Section 508 compliance can find themselves aiming at a moving target, depending on the specific requirements of their clients. Section 508 of the Americans With Disabilities Act contains lofty goals for universal accessibility, but does not get down into the weeds with specific guidelines for document creators. That has left the door open for "interpretation" by different agencies, and subsequently makes life difficult for remediators.

A great example comes in creating accessible hyperlinks in documents. Here's what Health and Human Services (HHS) asks in their "PDF File Checklist", section 1.8:

Do all URLs contain the correct hyperlink and display the fully qualified URL     (i.e.,http://www.samhsa.gov and not www.samhsa.gov) 

That's pretty unambiguous. HHS was the first of the government agencies to interpret the regulation and create a checklist, but that doesn't make their interpretation correct, or make documents following their interpretation more accessible than documents that see it differently.

Below is a contrary- and persuasive- argument on hyperlinks from the Social Security Administration, in their guide to creating accessible documents. Consider their logic:

When a Screen Reader is reading text and there is a link, the software will insert the word "Link" in front of the text to alert the user that this is a selectable hyperlink. Another way that Screen Readers can access the links that are in a document is for them to call up a list of links. This list will display only the text that has been marked as a link. It is important that the list of links makes sense to the user when it is read out of context. That is, the name of each link should make sense in the list when it is read in isolation.

Consider the following four examples of the same text and same link rendered using different methods:

1. Please read The SSA Online Accessibility Policy. Click Here

2. Please read The SSA Online Accessibility Policy.
http://www.ssa.gov/webcontent/accessibility.htm

3. Please visit The SSA Online Accessibility Policy.

4. Please visit The SSA Online Accessibility Policy:
http://www.ssa.gov/webcontent/accessibility.htm

If every link in the document was rendered using method #1, the list of links would read like this:

• Click Here

• Click Here

• Click Here

• Click Here

It is easy to see that individual links are not possible to read out of context. If every link was rendered using method #2, the list would read like this:

• http://www.ssa.gov/webcontent/accessibility.htm

• http://ssa.gov/pgm/links_disability.htm

• http://www.section508.gov/

This list also makes no sense in context. While we might be comfortable in normal conversation saying "go to s s a dot gov" we generally do not say to people "go to s s a dot gov slash p g m slash links underscore disability dot h t m". It is too long and it is too difficult to understand. However, when the list of links is presented this way, this is exactly how the Screen Reader will say each link.

If every link was rendered with method #3, the list would be read like this:

• The SSA Online Accessibility Policy

• SSA Disability Benefits

• GSA's Section 508 website

Using this method, all of the links make sense when spoken out of context. This is the best method to use.

What is the lesson here? It's that "compliance" with Section 508 is not defined at the granular level, but a regulation that has many interpretations. Before starting any remediation project, it is best practice to query your client for any specific requirements or checklists that are to be followed. Just remember that the goal is accessibility, with compliance merely being the by-product.

Creating accessible PDF documents with Adobe InDesign

It's always better to plan ahead for accessibility than to "add" it after the fact. InDesign allows designers to create beautiful and complex documents, but these features also can create challenges for remediation into a Section 508 compliant PDF.

 InDesign offers a direct workflow that reduces the time and effort required to produce accessible,compliant PDF documents from an InDesign layout. Most of the tasks are executed within InDesign, with fewer final steps required in Adobe Acrobat. In addition, this allows hierarchical and structural information to reside in the InDesign file, making updates faster and easier when you need to generate a revised accessible PDF document.

Here's an Adobe White Paper that can help you design with accessibility in mind.

C'mon, Medicare.gov, get compliant!!!

Section 508 Watchers out there, here's a good one:

Just got the print edition of "Medicare & You" in the mail, thought I would see if it was electronically available, which it is:

http://www.medicare.gov/pubs/pdf/10050.pdf

....but this document is not compliant with Section 508???? Does not even pass the Acrobat autocheck???? Is this possible???

We would be glad to help them...