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:

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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. 

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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.

News Flash: Section508.VA Document on Creating Accessible PDFs is not compliant with Section 508- go figure!!!

http://www.section508.va.gov/support/tutorials/pdf/Creating_Accessible_PDF_Tutorials_with_Acrobat_XI.pdf

Check it yourself, doesn't pass the most rudimentary technical check, let alone a "human" review.

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.