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  Gian rightly focuses on practical accessibility  rather than compliance with mostly outdated regulations (like the 18 year-old Section 508!)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/

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.

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.

Document Creators: Are you responsible for Section 508 compliance?

Let us be among the first to remind you to check the fine print in the specifications for the document you are creating right now. Is their any federal money involved? That's just one reason to make sure your document is accessible and compliant with Section 508.

These regulations have been in place since 1973, but are just beginning to be monitored and enforced; several lawsuits were required before production contracts started routinely specifying compliance with Section 508

Here's the official word:

Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. § 794d) requires the federal government to ensure that the electronic and information technology that it develops, procures, maintains, or uses is accessible to persons with disabilities. Section 508 also directs the Attorney General to submit reports to the President and Congress on the state of federal agencies' compliance with the Act's requirements. In preparation for its report, the Department of Justice conducts a survey of federal agencies to obtain information on the state of compliance with Section 508, including the Section 508 Electronic and Information Technology Accessibility Standards

.

Each federal department or agency is required by Section 508 to provide the Department of Justice with information that is needed to prepare the reports. Following below is information about the Department of Justice’s Section 508 surveys and reports.

Plan now and avoid the rush this fall- learn more about Section 508 document preparation and remediation at  Electronic Document Compliance Services website.

FAQ: What is the price per page to remediate a document and make it compliant with Section 508?

Every document is unique, and every client has different requirements, so there is no set cost per page to make a document compliant with Section 508 of the ADA. A 10 page document with numerous tables, charts and graphics may require more remediation than a 200 page mostly text document. Many of our clients have special compliance specifications– we are prepared to handle the most stringent requirements.

A typical job for a health insurance organization with 80-100 documents totaling 2000-3000 pages may be as low as $2 a page, depending on the state of the documents.  A typical single document remediation of 20 pages may cost between $2-20 per page.

We never quarrel with those who sell for less, as they know what their service is worth.  EDCS remediated documents are guaranteed accessible, not merely error-free according to an automatic check.

We will be glad to evaluate your documents, give you a report on their compliance needs and  a firm bid including turnaround time, please contact us for more information.

Tips for Document Creators: Alternate Text

Using best practices for creating accessible documents makes Section 508 compliance much less costly. Adding alternative text for images is the imperative, and needs to be done correctly:

By following the basic principles outlined here, web developers can make their web content more accessible to individuals with disabilities.

• Alternative text may be provided in the alt attribute or in the surrounding context of the image, but not both.
• Every image must have an alt attribute.
• Alternative text should:
  • presents the CONTENT and FUNCTION of the image.
  • be succinct.
• Alternative text should not:
  • be redundant (be the same as adjacent or body text).
  • use the phrases “image of…” or “graphic of…”.
• Appropriate alternative text depends heavily on the image’s context.
• Alt text of a functional image (e.g., an image within a link) should describe the function as well as the content.
• Decorative images still need an alt attribute, but it should be null (alt=”").

An indepth article on proper usage of the image alt tag can be found at the WebAim web site.

Find out more about Section 508 document compliance here: http://508compliantdocumentconversion.com/