Thread Subject: Re: Group D: 21 (l) and 22(n) accessible forms

Note

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From: Fratkin, Mike
Date: Wed, Nov 29 2006 12:10 PM

The web requirements for Section 508 do not cover form elements. The
only reference is in 1194.22(n) which is specific to electronic forms.
When we see an issue with a form element we reference this standard and
the reply is typically that the application is not an electronic form.
So if 1194.22(n) is not clarified then form or interactive elements need
to be added.

Mike Fratkin
SSA


[Gregg wrote:]Hmmmm

I think there is a crossed something here.

I'm not sure if the CURRENT 508 covers all form elements, but a good set
of requirements should. There is nothing on a form that doesn't also
appear in
other web content (and software too for that matter). So those
elements or
components need to be accessible wherever they are. Fields, labels,
prompts, cues, whatever. So forms should end up being accessible and a
special forms provision should not be needed.

If all the aspects of forms are not covered in current 508 language -
then we need to fix the language.

That being said - I don't have any objection to keeping a special
provision that talks just about forms, even if that provision is
redundant. Forms are so important, and people purchasing are not able
to even understand some of the software access provisions, that I think
having a single provision on forms that they can point to and say "do
you meet that" can be very important.


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
> Thatcher
> Sent: Wednesday, November 29, 2006 10:12 AM
> To: 'TEITAC Web/Software Subcommittee'
> Subject: Re: [teitac-websoftware] Group D: 21 (l) and 22(n) accessible

> forms
>
> Jim Tobias wrote:
> > > Andi asked:
> > > > Does anyone know why the Access Board thought that the other
> > > > provisions were insufficient for the special case of forms?
>
> > I think this was all about PDF at the time.
>
> I disagree with the idea that the requirement on forms can be drawn
> from other aspects of the 508 Standards. There is nothing in 508
> outside of 22(n) {and 21(l)} that requires that prompting information
> be available to screen reader users.
>
> Correct labeling of form elements is relatively rare on the web in
> part because often, even usually, the labeling is not necessary and
> screen readers pick up the correct prompts. For forms, however,
> "often" or "usually" is not good enough. From controls must be
> correctly labeled so that screen reader users can be absolutely
> confident that the prompt they hear is in fact the intended prompt for

> each control, not a screen reader's best guess.
>
> WCAG20 SC 1.3.1 does address this issue:
>
> "Information and relationships conveyed through presentation can be
> programmatically determined, and notification of changes to these is
> available to user agents, including assistive technologies"
>
> However, I think the wording of 1.3.1 is too far removed from this
> very serious problem and I think it should be addressed directly.
>
> So Proposal:
>
> 22(n) For any interactive object, prompting information that is
> visually evident can be programmatically determined.
>
> The nature of the objects, their name, role and state, must be
> available through other parts of the standards; this deals only with
> the "prompts" or "cues".
>
> Jim
>
> Accessibility Consulting: http://jimthatcher.com/
> 512-306-0931
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
> Tobias
> Sent: Tuesday, November 28, 2006 6:39 AM
> To: 'TEITAC Web/Software Subcommittee'
> Subject: Re: [teitac-websoftware] Group D: 21 (l) and 22(n) accessible

> forms
>
>
> > -----Original Message-----
> > From: Bailey Bruce [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Tuesday, November 28, 2006 7:24 AM
> > To: TEITAC Web/Software Subcommittee
> > Subject: Re: [teitac-websoftware] Group D: 21 (l) and 22(n)
> accessible
> > forms
> >
> > Andi asked:
> > > Does anyone know why the Access Board thought that the other
> > > provisions were insufficient for the special case of forms?
>
> I think this was all about PDF at the time. Agencies were moving to
> PDF for publishing documents and creating online forms. Some felt
> that an accessible alternative could be demanded for the former, but
> not as easily for the latter.
>
> Note for how narrow a time window this "special" federal regulation
> was actually needed: less than a year, certainly.
> We should make an effort to present-proof as well as future-proof our
> recommendations.
>
>

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