Accessibility In Mind: Section 508 Document Compliance

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

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.

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:
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?

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.

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.
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?

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)
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
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
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
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/

The "Refresh":US Access Board Proposes Updated ICT Accessibility Requirements

The US access Board has released for public comment a proposed rule updating accessibility requirements for information and communication technology (ICT) in the federal sector covered by Section 508 of the Rehabilitation Act. The rule also would jointly update guidelines for telecommunications equipment subject to Section 255 of the Communications Act.

The updated proposal is "...responsive to fundamental changes, innovations, and trends in the industry, such as the widespread convergence of technologies..." according to the summary, and should help all in the industry interpret Section 508 with fresh guidance.

The proposed rule includes significant changes that would:

incorporate the WCAG 2.0 and apply associated success criteria to websites as well as to offline electronic documents and software;
require real-time text functionality (text that is transmitted character by character as it is being typed) for products providing real-time, two-way voice communication;
specify the types of non-public facing electronic content covered;
and further detail the required compatibility of covered technologies, including operating systems, software development toolkits, and software applications with assistive technology.

Specific to PDF, the proposed rules address "accessible PDF files (ISO 14289-1, Document management applications — Electronic document file format enhancement for accessibility — Part 1: Use of ISO 32000-1 (PDF/UA-1))

More information is here, and an overview of the refresh can be read here.

PDF/UA: Defining Accessible PDFs

PDF/UA is needed because while the PDF specification creates accessibility mechanisms it fails to set clear rules for actually creating (or delivering) reliably accessible PDF content.

"UA" stands for Universal Accessibility; PDF/UA designation certifies that documents are compliant with ISO Standard 14289, the new international standard for Accessible PDFs. There are approximately 25 million individuals in the US, 1 million individuals in Canada and over 30 million individuals in the EU that have difficulty reading bills, statements and other customer communications. A document that has been produced in the PDF/UA format using best practices will guide customers’ assistive technology to present that document in the most accessible way possible.

In a Nutshell:

A PDF/UA document is a PDF file that contains specific content in it's infrastructure to make its content as accessible as possible to users that require assistance to access the content, primarily using "screen readers" that allow a sight-impaired user to navigate a document as it is read aloud. The main points:

Content is tagged. The tags used describe what the content is, for example a heading, and the order of that content within the document – this guides the screen reader and facilitates navigation through the document.
Graphical elements have a text description so that a user can know what that element is.
Tables have tags for their column headings and row headings so that the user can know what the values within the table represent.
Fonts must be embedded
The language of the document is specified

These are just the basics. A protocol has been developed, the Matterhorn Protocol, that defines 136 attributes a PDF/UA document will contain. Like all PDFs, it is a document that will print and be viewed electronically uniformly across all platforms. It also contains metadata within the tags that may make such PDFs more suitable for archive and retrieval purposes and can be produced in such a way that it also conforms to the PDF/A standard for long term preservation of electronic documents.

The importance of PDF/UA documents is that they conform to the definitive standard for Accessible PDFs that the ISO (International Organization for Standardization) has published based on efforts of a global consortium of technology experts spanning almost a decade. This is a concise, prescriptive guide to using the tagging and other content storage and organization technology in PDFs to document the hierarchy and structure specific to the contents for each document type. With these tags, a PDF/UA document enables your customers’ assistive technology to present the contents in a logical order that enables comprehension, making the content both accessible and usable

A bit of history:

Back in 2000, Adobe added the capability to add “tags” within PDF files. To use an uncommon word for a moment, tags add “semantic” meaning to content within a PDF and tells us what that content is. For example, a tag might tell us that content is an image or a table. Another example is to have a heading tag applied to content within the PDF, identifying headings and their relative importance (“Heading 1” is more important than “Heading 2”). This introduction of tags is important because it started to lay the groundwork for making PDFs accessible. In 2008, Adobe’s Reference 1.7 version of PDF became a Standard (ISO 32000-1:2008). Adobe handed the ongoing management and enhancement of PDF to subject-matter expert committees around the world through the International Organization for Standardization (ISO). PDF/UA and regulatory compliance.

There are many regulations that specify what your organization’s obligations are with regard to meeting the needs of people with disabilities. An obvious example is handicapped parking spaces. In the United States these are often called ADA parking, where ADA stands for ‘Americans with Disabilities Act.’ Other examples include ramps for wheelchairs, push buttons that automatically open a door, etc. All of these are required by law.

PDF/UA documents meet or exceed the regulations set down in Section 508 of the Rehabilitation Act PDF/UA is one of many ways your organization can provide accessible electronic documents to your customers and help you meet regulatory obligations, while providing the best possible experience.

Added benefits of PDF/UA:

A PDF/UA file can also be a PDF/A file, offering a single approach to address both your long-term archiving requirements as well as accessible PDF requirements.
A PDF/UA file, due to its content tagging, makes the user experience on mobile devices much better due to text reflow as an alternative to zooming in on content in order to read it
A PDF/UA file can make content re-use easier due to the fact that the content is tagged. For example, copy & paste or extracting to HTML is more easily achieved.
A PDF/UA file can provide better search results. If your archive or search tool can utilize PDF tags, the ability to find what you are looking for can be based on the complete set of actual PDF document content.

Please contact us for more information on making your documents compliant with Section 508 and PDF/UA.

Matterhorn Protocol: http://www.pdfa.org/wp-content/uploads/2014/06/MatterhornProtocol_1-02.pdf provides 136 criteria for PDF/UA compliance, of which 47 require human judgment.