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. 

What You Need To Know About Accessible Links

Below is a link to some great,  common sense accessibility advice, fifteen rules to code by- thanks to Gian Wild.  Gian rightly focuses on practical accessibility  rather than compliance with mostly outdated regulations (like the 18 year-old Section 508!) A few excerpts:

Rule 6: Restrict the number of text links on a page

This is important because users see links as a form of navigation: they know they are not on the right page so they are looking for links that will take them to where they want to go.

If there are a lot of links on a page, it makes it that much harder to navigate a site.

And of course, screen reader users can pull out all the links in a page, so if there are hundreds of links then reading through them all is a nightmare.

Ok, so how many links are too many? That’s the ‘How long is a piece of string’ question, and depends on the type of site that you have.

Just bear in mind the users that are navigating from link to link when you’re constructing your pages.

Rule 11: The case for underlining links

People expect links to be underlined. When they see underlined text they expect it to be a link (which is why you should never underline text in the online world unless you are representing a link).

WCAG2 does recommend that you underline your inline text links, but also allows developers to meet the accessibility criterion if they use a contrast ratio of 3:1 with surrounding text and providing additional visual cues on focus for links or controls where color alone is used to identify them.

This requires that your text links contrast sufficiently with surrounding text (the W3C has a list of link colors that contrast appropriately with black text and a white background) and there is an additional visual cue when the link receives mouse or keyboard focus.

This visual cue can be an underline (go on, make those links underlined!), bold, italic or increase in font size or it can be the addition of a glyph or image. It can be implemented through CSS as this only needs to be a visual indicator.

But remember to add a:focus to a:hover!

The article:
https://www.sitepoint.com/15-rules-making-accessible-links/

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:

​

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.

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.

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.

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.

EDCS Levels of Service

Total accessibility is the goal of every EDCS remediation. Contrary to common belief, passing an automatic check alone does not ensure accessibility. Un-tagged content, inactive URLs, and incorrect reading order are examples of errors that are overlooked by Adobe Acrobat's autochecks. A document that is blank to a screen reader can be made to pass but is obviously not accessible or compliant.

Structured documents are accessible documents. Comprehensive remediation adds value to documents, for both sighted and sight-impaired users.

Bid Request Form

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Complete remediation includes these services:

• Determine if the PDF file has been properly tagged. Verify tagged elements are properly sequenced and applied. Ascertain that tag list follows document reading order exactly for optimum reading order and reflow for screen readers
• Style tags applied appropriately to all text
• Correct pagination added to thumbnails
• URLs checked/activated
• Bookmarks added (documents over 9 pages)
• Table of Contents made active
• All internal and external active links made BLUE (optional)
• Correct properties, initial view settings, correct tab order, "fast view" set, custom properties removed, language set
• Tables scoped (header and data cells appropriately tagged); all tabular data edited/tagged as tables with scoped columns and rows; tables created where absent
• Add Alternative Text. Add informative and concise alternative text and descriptions for all non-text elements
• Artifact all table PATH (border) tags (optional)
• Removal/artifact all background graphics
• Complete Adobe Acrobat Pro 11 accessibility report showing no errors or warnings
• Complete HHS checklist (optional)
• Spot check with screen reader (JAWS or equivalent)
• Complete Quality Check

Exclusions or additions to the listed services at client's request. Deliverables include remediated PDF and time-stamped validation reports from Acrobat Pro 11: "Accessibility Full Check", and agency checklist if requested. Please provide guidelines/requirements at time of bid request.

Fillable Form PDFs- add these services:

• Creation/edit of form fields
• Tool tips added to form fields.
• Formatting applied to form field (date, currency, etc.)

Note: Remediation limited to form documents created in Acrobat.

Minimum specifications:

• No character encoding errors present
• Document created with editable fonts
• Alternate text descriptions of graphics/figures included or provided by client
• Document properties (Title, Author, Subject, Keywords) provided by client

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Terms and Conditions

All bid requests will include expected time frame for the job, date of document delivery from client to EDCS and date of remediated document delivery from EDCS to client. Bids provided by EDCS are valid for 30 days. EDCS will evaluate documents requiring remediation and deliver a quotation of price per page for desired level of remediation  and any additional charges that may be incurred to complete the remediation. Our evaluations are thorough, but there are sometimes issues that do not show in our evaluation that may make some documents impractical or impossible to remediate into accessible documents. EDCS reserves the right to inform client of any documents that fall into this category prior to document remediation; documents will not be remediated and remediation charges for these documents will be subtracted from final invoice. At client’s request, and upon agreement from EDCS, documents not remediated due to aforementioned issues, or any pre or post-remediation document processing or editing, will be charged at $100 per hour. Services not specifically required for compliance may be excluded from remediation, at client's request. Documents 50 pages or less are subject to a $50 short-document administrative fee.  

 Bid Request Form

Terms effective 12/11/2013

Interpreting Section 508 Regulation 1194.22

Look here for answers to your specific questions about what makes a PDF document compliant with Section 508- but don't squeeze your brain too hard, as there's not much "specifying" going on. It all comes down to interpretation- what is "accessible" and "usable"?

Here's an excerpt from the regulation, the part that applies to remediating PDF documents:

§ 1194.22 Web-based intranet and internet information and applications.

(a) A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

(d) Documents shall be organized so they are readable without requiring an associated style sheet.

(e) Redundant text links shall be provided for each active region of a server-side image map.

(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

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

(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.

(i) Frames shall be titled with text that facilitates frame identification and navigation.

(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

(o) A method shall be provided that permits users to skip repetitive navigation links.

(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Section 508 News: One More Battle in the Fight for Equality in the Workplace

From Gary Wunder, on the NFB.org website, a great article about the realities of accessibility. We're not there yet...

" Government and industry have been slow to acknowledge the technological challenges the blind are beginning to face as we perform the routine duties of keeping a house and cooking our meals, but as early as 1998 the federal government acknowledged the need for technology usable by the blind in places of employment by adopting Section 508 of the Rehabilitation Act. In a nutshell the law says that anything built or purchased by the federal government must be accessible to people with disabilities, including the blind. The law covers everything from office computers to the copy machine, but the reality of federal compliance falls far short of the promises so eloquently proclaimed in the statutes of our land."

"Section 508 must make real in the federal workplace the promises it boldly proclaims as the law of the land."

Read the article

Department of Homeland Security Sued for Section 508 Violations

On April 26, 2013, Michael Leiterman, a lawyer for the Department of Homeland Security (DHS)  filed a suit against his employer, "for violating federal anti-discrimination laws that require the federal government to provide equal opportunity to people with disabilities", citing Section 508 of the Americans with Disabilities Act (ADA)

Section 508 is an amendment to the Rehabilitation Act, passed by Congress in 1998. This amendment specifies that government agencies must make all electronic and information technology available to people with disabilities. Since its adoption in 1998, the digital realm has exploded, making Section 508 compliance even more necessary to ensure accessibility for people with disabilities.

The lawsuit alleges that DHS is in violation of the Act “by purchasing, developing, and implementing inaccessible technology, using inaccessible training and testing platforms and materials, requiring Mr. Leiterman to provide accessibility  testing, troubleshooting, and correction for CBP’s technology, failing to provide reasonable accommodations for his disability, and denying him a promotion because of his disability and the agency’s inaccessible technology.”

Mr. Leiterman, who is blind, has worked at Customs and Border Protection (“CBP”), a division of the United States Department of Homeland Security (“DHS”), since August 2006. The lawsuit alleges multiple instances of violations, including inaccessible documents, intranets, and online training modules.

The brief...

The "Curb Cut" shows how accessibility helps the entire population

Many people think that accessibility regulation just benefit those with disabilities (an estimated 24 million Americans!) but the value is much more broadly felt.

Accessibility offers advantages that go beyond ensuring usability for persons with disabilities. Many technologies first designed to assist persons with disabilities were later adopted because of their value to everyone. Consider the advantage curb cuts provide. Although first created for people in wheelchairs, they make access for cyclists and parents with strollers easier. Universal accessibility can help ensure that

everyone has access to the tools and information they need to learn and communicate.

Electronic documents are often evaluated for its usability and accessibility in order to be compliant with Section 508. Though the terms are often used interchangeably, there is a difference. Even if the document is "accessible", there may still be serious usability problems that make it equally difficult for any person, disabled or non-disabled, to use it.

Usability focuses on how intuitive and easy it is for all people to use. Usable designs are consistent and simple to learn to use. Usability and accessibility often go hand-in-hand.

Accessibility is determined by how barrier free the technology is. Accessibility problems are those that make it more difficult for persons with disabilities to use an application or service than for a non-disabled person.

The key to accessibility is that it should be easy for everyone to use, including persons with disabilities.