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Navigation lists and headers - best practise?

for

From: Penny Roberts
Date: Aug 23, 2006 9:10AM

This is going off at a tangent from the original post so I've started a
new thread.

In response to the thread "are there any accessibility testing best
practices" Jon Gunderson posted a link to the Functional Web
Accessibility Evaluation Tool.
I've looked at the UIUC "Best Practices" site before but I must have
missed this: http://cita.uiuc.edu/html-best-practices/nav/menus.php
Does everyone agree that it is best practice to have an h2 heading
before a ul used for navigation? I've never come across the suggestion
before so I'm interested to know how well supported (or not)+ the idea is.

Penny