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From: Mark Berning
Date: Wed, Dec 06 2023 8:38AM
Subject: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
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Hello,

I am reaching out to seek advice and insights on a PDF accessibility
challenge our school district is currently facing.

In our district, we regularly post PDFs online for both contract bids and
school lunch nutrition data. The nature of these documents varies, with
contract bid PDFs often containing hundreds of pages and extensive
technical data, including graphs, charts, tables, schematics, and technical
drawings—resembling maintenance manuals for industrial equipment. These
documents are typically replaced every few weeks with new ones from updated
contract bids, making remediation a challenging task. I am aware of
third-party services such as PlanetBids that serve as online repositories
for RFP documents. However, the documents are still not considered
accessible.

Additionally, we routinely upload 300-400 pages of school lunch nutritional
data tables every month. While these are comparatively easier to remediate,
the sheer volume poses a significant challenge as they are replaced monthly.

Assuming these documents are required to be posted online, do you have
experience or insights into similar situations? I would greatly appreciate
hearing about your approaches to posting and PDF remediation.

Thank you in advance for your time and assistance.

Best regards,
--
Mark Berning
Web Developer
Escondido Union School District
= EMAIL ADDRESS REMOVED =
x10176
760-432-2191

From: chagnon@pubcom.com
Date: Wed, Dec 06 2023 11:35AM
Subject: Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
← Previous message | Next message →

We've worked with many universities/colleges and local school districts on their materials.

The best solution is to make better, more accessible source documents, and export them to accessible tagged PDF. Depending on the document's complexity (tables, lists, footnotes, etc.), you should have a better PDF that doesn't need much remediation at all. Some call this "born accessible."

Remediating and fixing crappy PDFs is a royal PITA — pain in the "anatomy" — that wastes everyone's time and money.

"Born accessible" is a critical workflow strategy for those who must frequently update source documents and make them "live" on websites for public use.

Feel free to contact me directly if you'd like more information. We're here to help!

— — —
Bevi Chagnon | Designer, Accessibility Technician | = EMAIL ADDRESS REMOVED =
— — —
PubCom: Technologists for Accessible Design + Publishing
consulting • training • development • design • sec. 508 services
Upcoming classes at www.PubCom.com/classes
— — —
Latest blog-newsletter – Simple Guide to Writing Alt-Text

-----Original Message-----
From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of Mark Berning
Sent: Wednesday, December 6, 2023 10:39 AM
To: = EMAIL ADDRESS REMOVED =
Subject: [WebAIM] Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices

Hello,

I am reaching out to seek advice and insights on a PDF accessibility challenge our school district is currently facing.

In our district, we regularly post PDFs online for both contract bids and school lunch nutrition data. The nature of these documents varies, with contract bid PDFs often containing hundreds of pages and extensive technical data, including graphs, charts, tables, schematics, and technical drawings—resembling maintenance manuals for industrial equipment. These documents are typically replaced every few weeks with new ones from updated contract bids, making remediation a challenging task. I am aware of third-party services such as PlanetBids that serve as online repositories for RFP documents. However, the documents are still not considered accessible.

Additionally, we routinely upload 300-400 pages of school lunch nutritional data tables every month. While these are comparatively easier to remediate, the sheer volume poses a significant challenge as they are replaced monthly.

Assuming these documents are required to be posted online, do you have experience or insights into similar situations? I would greatly appreciate hearing about your approaches to posting and PDF remediation.

Thank you in advance for your time and assistance.

Best regards,
--
Mark Berning
Web Developer
Escondido Union School District
= EMAIL ADDRESS REMOVED =
x10176
760-432-2191

From: Mark Berning
Date: Wed, Dec 06 2023 11:58AM
Subject: Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
← Previous message | Next message →

I agree that it would be nice to start with accessible source documents but
in our case the documents are provided by third party software or third
party vendors. We do not create the PDFs. Curious if other state/federal
agencies have refused inaccessible PDFs from third parties.

On Wed, Dec 6, 2023 at 10:36 AM < = EMAIL ADDRESS REMOVED = > wrote:

> We've worked with many universities/colleges and local school districts on
> their materials.
>
> The best solution is to make better, more accessible source documents, and
> export them to accessible tagged PDF. Depending on the document's
> complexity (tables, lists, footnotes, etc.), you should have a better PDF
> that doesn't need much remediation at all. Some call this "born accessible."
>
> Remediating and fixing crappy PDFs is a royal PITA — pain in the "anatomy"
> — that wastes everyone's time and money.
>
> "Born accessible" is a critical workflow strategy for those who must
> frequently update source documents and make them "live" on websites for
> public use.
>
> Feel free to contact me directly if you'd like more information. We're
> here to help!
>
> — — —
> Bevi Chagnon | Designer, Accessibility Technician | = EMAIL ADDRESS REMOVED =
> — — —
> PubCom: Technologists for Accessible Design + Publishing
> consulting • training • development • design • sec. 508 services
> Upcoming classes at www.PubCom.com/classes
> — — —
> Latest blog-newsletter – Simple Guide to Writing Alt-Text
>
> -----Original Message-----
> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> Mark Berning
> Sent: Wednesday, December 6, 2023 10:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: [WebAIM] Inquiry Regarding Handling PDF Accessibility Challenges
> in School District Practices
>
> Hello,
>
> I am reaching out to seek advice and insights on a PDF accessibility
> challenge our school district is currently facing.
>
> In our district, we regularly post PDFs online for both contract bids and
> school lunch nutrition data. The nature of these documents varies, with
> contract bid PDFs often containing hundreds of pages and extensive
> technical data, including graphs, charts, tables, schematics, and technical
> drawings—resembling maintenance manuals for industrial equipment. These
> documents are typically replaced every few weeks with new ones from updated
> contract bids, making remediation a challenging task. I am aware of
> third-party services such as PlanetBids that serve as online repositories
> for RFP documents. However, the documents are still not considered
> accessible.
>
> Additionally, we routinely upload 300-400 pages of school lunch
> nutritional data tables every month. While these are comparatively easier
> to remediate, the sheer volume poses a significant challenge as they are
> replaced monthly.
>
> Assuming these documents are required to be posted online, do you have
> experience or insights into similar situations? I would greatly appreciate
> hearing about your approaches to posting and PDF remediation.
>
> Thank you in advance for your time and assistance.
>
> Best regards,
> --
> Mark Berning
> Web Developer
> Escondido Union School District
> = EMAIL ADDRESS REMOVED =
> x10176
> 760-432-2191
>
>
> > > > >


--
Mark Berning
Web Developer
Escondido Union School District
= EMAIL ADDRESS REMOVED =
x10176
760-432-2191

From: Elizabeth Thomas
Date: Wed, Dec 06 2023 3:15PM
Subject: Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
← Previous message | Next message →

For any of these documents, can you post the content in a format other than PDF? For example, if the school lunch nutrition data is data tables, could you instead post these as CSV or Excel files? Then you would just need to set up the structure once, and as long you keep the same structure, you wouldn’t need to remediate those files every month. We have done this for many of our regularly updated excel files, and it has saved a lot of time and work. (And I also think it’s easier to read a data table in excel than in a PDF).
We also have some annual data files that come from SAS (and are then posted as PDFs). For these files, there is a lot of work done in SAS so that even if each PDF isn’t manually remediated, they still are very accessible.
The technical documents are a little more challenging. When working with vendor-created content, we have included language in the contract about meeting our accessibility guidelines (current version of WCAG at Level AA and PDF U/A). However, even then, we have had issues with documents having pretty significant barriers for people with disabilities.
Do the technical documents usually have the same general sections and format every month? Could you provide a template that is as accessible as possible and guidelines for how the vendor should handle graphs, images, tables, etc? For example, provide guidelines such as “don’t indicate meaning using only color. In a column graph where the series are indicated using different colors, add data labels with the series names.”
I could talk about PDFs all day, so I’ll stop now!
I hope some of this was at least a little helpful.
-Elizabeth Thomas
New Jersey Department of Education

> On Dec 6, 2023, at 10:38 AM, Mark Berning < = EMAIL ADDRESS REMOVED = > wrote:
> Hello,
>
> I am reaching out to seek advice and insights on a PDF accessibility
> challenge our school district is currently facing.
>
> In our district, we regularly post PDFs online for both contract bids and
> school lunch nutrition data. The nature of these documents varies, with
> contract bid PDFs often containing hundreds of pages and extensive
> technical data, including graphs, charts, tables, schematics, and technical
> drawings—resembling maintenance manuals for industrial equipment. These
> documents are typically replaced every few weeks with new ones from updated
> contract bids, making remediation a challenging task. I am aware of
> third-party services such as PlanetBids that serve as online repositories
> for RFP documents. However, the documents are still not considered
> accessible.
>
> Additionally, we routinely upload 300-400 pages of school lunch nutritional
> data tables every month. While these are comparatively easier to remediate,
> the sheer volume poses a significant challenge as they are replaced monthly.
>
> Assuming these documents are required to be posted online, do you have
> experience or insights into similar situations? I would greatly appreciate
> hearing about your approaches to posting and PDF remediation.
>
> Thank you in advance for your time and assistance.
>
> Best regards,
> --
> Mark Berning
> Web Developer
> Escondido Union School District
> = EMAIL ADDRESS REMOVED =
> x10176
> 760-432-2191

From: chagnon@pubcom.com
Date: Fri, Dec 08 2023 4:06AM
Subject: Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
← Previous message | Next message →

Mark B. wrote: " Curious if other state/federal agencies have refused inaccessible PDFs from third parties."

Yes, Mark. Many of our government clients are rejecting inaccessible ICT, and they are pushing back on contractors — and, of course, their sub-contractors — to provide fully accessible ICT. HHS is a key agency that started doing this about 10–12 years ago, see https://www.hhs.gov/web/governance/digital-strategy/it-policy-archive/hhs-policy-section-508-compliance-accessibility-information-communications-technology.html

The law is very clear:
E201.1 Scope
ICT that is procured, developed, maintained, or used by agencies shall conform to the Revised 508 Standards.

You can view the regulation at https://www.access-board.gov/ict/

If states, schools, and school districts have adopted the federal standard, then what you receive from 3rd parties must be accessible.
In our opinion, it is the responsibility of the content's owner or author or publisher to provide it in an accessible format. It is not the school's responsibility to fix bad ICT — that is cost-prohibitive, and every school has to fix the same crappy inaccessible ICT over and over at an insane cost to the public and tax payers.

— — —
Bevi Chagnon | Designer, Accessibility Technician | = EMAIL ADDRESS REMOVED =
— — —
PubCom: Technologists for Accessible Design + Publishing
consulting • training • development • design • sec. 508 services
Upcoming classes at www.PubCom.com/classes
— — —
Latest blog-newsletter – Simple Guide to Writing Alt-Text

-----Original Message-----
From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of Mark Berning
Sent: Wednesday, December 6, 2023 1:59 PM
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices

I agree that it would be nice to start with accessible source documents but in our case the documents are provided by third party software or third party vendors. We do not create the PDFs. Curious if other state/federal agencies have refused inaccessible PDFs from third parties.

On Wed, Dec 6, 2023 at 10:36 AM < = EMAIL ADDRESS REMOVED = > wrote:

> We've worked with many universities/colleges and local school
> districts on their materials.
>
> The best solution is to make better, more accessible source documents,
> and export them to accessible tagged PDF. Depending on the document's
> complexity (tables, lists, footnotes, etc.), you should have a better
> PDF that doesn't need much remediation at all. Some call this "born accessible."
>
> Remediating and fixing crappy PDFs is a royal PITA — pain in the "anatomy"
> — that wastes everyone's time and money.
>
> "Born accessible" is a critical workflow strategy for those who must
> frequently update source documents and make them "live" on websites
> for public use.
>
> Feel free to contact me directly if you'd like more information. We're
> here to help!
>
> — — —
> Bevi Chagnon | Designer, Accessibility Technician |
> = EMAIL ADDRESS REMOVED = — — —
> PubCom: Technologists for Accessible Design + Publishing consulting •
> training • development • design • sec. 508 services Upcoming classes
> at www.PubCom.com/classes — — — Latest blog-newsletter – Simple Guide
> to Writing Alt-Text
>
> -----Original Message-----
> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> Mark Berning
> Sent: Wednesday, December 6, 2023 10:39 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: [WebAIM] Inquiry Regarding Handling PDF Accessibility
> Challenges in School District Practices
>
> Hello,
>
> I am reaching out to seek advice and insights on a PDF accessibility
> challenge our school district is currently facing.
>
> In our district, we regularly post PDFs online for both contract bids
> and school lunch nutrition data. The nature of these documents varies,
> with contract bid PDFs often containing hundreds of pages and
> extensive technical data, including graphs, charts, tables,
> schematics, and technical drawings—resembling maintenance manuals for
> industrial equipment. These documents are typically replaced every few
> weeks with new ones from updated contract bids, making remediation a
> challenging task. I am aware of third-party services such as
> PlanetBids that serve as online repositories for RFP documents.
> However, the documents are still not considered accessible.
>
> Additionally, we routinely upload 300-400 pages of school lunch
> nutritional data tables every month. While these are comparatively
> easier to remediate, the sheer volume poses a significant challenge as
> they are replaced monthly.
>
> Assuming these documents are required to be posted online, do you have
> experience or insights into similar situations? I would greatly
> appreciate hearing about your approaches to posting and PDF remediation.
>
> Thank you in advance for your time and assistance.
>
> Best regards,
> --
> Mark Berning
> Web Developer
> Escondido Union School District
> = EMAIL ADDRESS REMOVED =
> x10176
> 760-432-2191
>
>
> > > archives at http://webaim.org/discussion/archives
> >


--
Mark Berning
Web Developer
Escondido Union School District
= EMAIL ADDRESS REMOVED =
x10176
760-432-2191

From: Ryan E. Benson
Date: Fri, Dec 08 2023 4:57AM
Subject: Re: Inquiry Regarding Handling PDF Accessibility Challenges in School District Practices
← Previous message | No next message

Good Morning

I formerly worked under HHS, and helped develop many of our accessibility
policies, including the one Bevi linked and the accessibility part of the
acquisition regulations. The one that Bevi linked is the general policy,
which doesn't quite allow the rejection of PDFs. The acquisitions policy
opens the door for that. The regs are found at Part 339—Acquisition of
Information Technology | HHS.gov
<https://www.hhs.gov/grants-contracts/contracts/contract-policies-regulations/hhsar/part-339-acquisition-information-technology/index.html>,
which lays the groundwork. Acquisitions should have the language linked to
under 339.203-70, which allows us to reject indirectly.

Instead of saying everything must be accessible or else, it says document
the accessibility of the deliverable, BUT we get to double check before
formally accepting. The secret is most vendors provide a perfect HHS
Checklist or VPAT. Most know on this list knows that perfect accessibility
is largely unattainable. Part of my job in my former agency is to get in
front of contract officers and program people to tell them to check the
stuff and/or my team before acceptance. I'd always find something, so i had
to tell the appropriate people to reject it, have the vendor fix this list
of stuff, and after another check, it can be accepted.

--
Ryan E. Benson


On Fri, Dec 8, 2023 at 6:07 AM < = EMAIL ADDRESS REMOVED = > wrote:

> Mark B. wrote: " Curious if other state/federal agencies have refused
> inaccessible PDFs from third parties."
>
> Yes, Mark. Many of our government clients are rejecting inaccessible ICT,
> and they are pushing back on contractors — and, of course, their
> sub-contractors — to provide fully accessible ICT. HHS is a key agency that
> started doing this about 10–12 years ago, see
> https://www.hhs.gov/web/governance/digital-strategy/it-policy-archive/hhs-policy-section-508-compliance-accessibility-information-communications-technology.html
>
> The law is very clear:
> E201.1 Scope
> ICT that is procured, developed, maintained, or used by agencies shall
> conform to the Revised 508 Standards.
>
> You can view the regulation at https://www.access-board.gov/ict/
>
> If states, schools, and school districts have adopted the federal
> standard, then what you receive from 3rd parties must be accessible.
> In our opinion, it is the responsibility of the content's owner or author
> or publisher to provide it in an accessible format. It is not the school's
> responsibility to fix bad ICT — that is cost-prohibitive, and every school
> has to fix the same crappy inaccessible ICT over and over at an insane cost
> to the public and tax payers.
>
> — — —
> Bevi Chagnon | Designer, Accessibility Technician | = EMAIL ADDRESS REMOVED =
> — — —
> PubCom: Technologists for Accessible Design + Publishing
> consulting • training • development • design • sec. 508 services
> Upcoming classes at www.PubCom.com/classes
> — — —
> Latest blog-newsletter – Simple Guide to Writing Alt-Text
>
> -----Original Message-----
> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> Mark Berning
> Sent: Wednesday, December 6, 2023 1:59 PM
> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> Subject: Re: [WebAIM] Inquiry Regarding Handling PDF Accessibility
> Challenges in School District Practices
>
> I agree that it would be nice to start with accessible source documents
> but in our case the documents are provided by third party software or third
> party vendors. We do not create the PDFs. Curious if other state/federal
> agencies have refused inaccessible PDFs from third parties.
>
> On Wed, Dec 6, 2023 at 10:36 AM < = EMAIL ADDRESS REMOVED = > wrote:
>
> > We've worked with many universities/colleges and local school
> > districts on their materials.
> >
> > The best solution is to make better, more accessible source documents,
> > and export them to accessible tagged PDF. Depending on the document's
> > complexity (tables, lists, footnotes, etc.), you should have a better
> > PDF that doesn't need much remediation at all. Some call this "born
> accessible."
> >
> > Remediating and fixing crappy PDFs is a royal PITA — pain in the
> "anatomy"
> > — that wastes everyone's time and money.
> >
> > "Born accessible" is a critical workflow strategy for those who must
> > frequently update source documents and make them "live" on websites
> > for public use.
> >
> > Feel free to contact me directly if you'd like more information. We're
> > here to help!
> >
> > — — —
> > Bevi Chagnon | Designer, Accessibility Technician |
> > = EMAIL ADDRESS REMOVED = — — —
> > PubCom: Technologists for Accessible Design + Publishing consulting •
> > training • development • design • sec. 508 services Upcoming classes
> > at www.PubCom.com/classes — — — Latest blog-newsletter – Simple Guide
> > to Writing Alt-Text
> >
> > -----Original Message-----
> > From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> > Mark Berning
> > Sent: Wednesday, December 6, 2023 10:39 AM
> > To: = EMAIL ADDRESS REMOVED =
> > Subject: [WebAIM] Inquiry Regarding Handling PDF Accessibility
> > Challenges in School District Practices
> >
> > Hello,
> >
> > I am reaching out to seek advice and insights on a PDF accessibility
> > challenge our school district is currently facing.
> >
> > In our district, we regularly post PDFs online for both contract bids
> > and school lunch nutrition data. The nature of these documents varies,
> > with contract bid PDFs often containing hundreds of pages and
> > extensive technical data, including graphs, charts, tables,
> > schematics, and technical drawings—resembling maintenance manuals for
> > industrial equipment. These documents are typically replaced every few
> > weeks with new ones from updated contract bids, making remediation a
> > challenging task. I am aware of third-party services such as
> > PlanetBids that serve as online repositories for RFP documents.
> > However, the documents are still not considered accessible.
> >
> > Additionally, we routinely upload 300-400 pages of school lunch
> > nutritional data tables every month. While these are comparatively
> > easier to remediate, the sheer volume poses a significant challenge as
> > they are replaced monthly.
> >
> > Assuming these documents are required to be posted online, do you have
> > experience or insights into similar situations? I would greatly
> > appreciate hearing about your approaches to posting and PDF remediation.
> >
> > Thank you in advance for your time and assistance.
> >
> > Best regards,
> > --
> > Mark Berning
> > Web Developer
> > Escondido Union School District
> > = EMAIL ADDRESS REMOVED =
> > x10176
> > 760-432-2191
> >
> >
> > > > > > archives at http://webaim.org/discussion/archives
> > > >
>
>
> --
> Mark Berning
> Web Developer
> Escondido Union School District
> = EMAIL ADDRESS REMOVED =
> x10176
> 760-432-2191
> > > at http://webaim.org/discussion/archives
> >
> > > > >