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Re: Chronicle of Higher Education article "Colleges Lock Out Blind Students Online" Chronicle Article and form control labeling


From: John Foliot
Date: Dec 14, 2010 12:45PM

Gunderson, Jon R wrote:
> I find it interesting that people on this list were not outraged that
> less than 30 percent of the 19,722 pages tested with form controls had
> accessible labels.
> http://webaccessibility.cita.illinois.edu/data/

The problem here of course is that this important data-point is lost
amidst some of the other "Rules" that are circumspect at best, and
outright false at worst. You take a mish-mash of important requirements
and mix them in with a slew of imposed Best Practices that many disagree
with - with a net result that you taint the good with the bad. Couple that
with the hysterical reporting we see at the Chronicle of Higher Ed (fueled
by your 'report') that focuses on *RANKING* rather than looking at where
we have real problems across the board and the net result is that any good
derived by your testing is off-set by that tabloid journalist approach.

I will repeat the controversial Rules here and once again ask you to
justify how failing to meet any of them results in inaccessible web


"The page must contain at least one h1 element."
According to whom? While it is certainly good practice to ensure
each page has appropriate heading structure, nowhere (outside of the FAE
tool) is it *MANDATED* as such - a page that lacks an <h1> is not
intrinsically inaccessible. False data - False results!

"The page should contain no more than two h1 elements."
Please point to one national or international guideline or
recommendation that mandates this. Another false positive from a
mechanical tool, fueled by internal University of Illinois politics and

"The text content of each h1 element should match all or part of the title
"Each h1 element should have text content exclusive of the alt text of any
img elements it contains."
Bull Feathers! Made up standards by a small team with an agenda to
promote their internal tool - and it should be noted that failing to do
either of these things in no way makes a page "less accessible" - it just
doesn't meet their FAE Guidelines.

"For each data table, the first cell in each column must be a th element,
and each row must contain at least one th element."
Patently FALSE! In fact, the table of school rankings at the
Chronicle of Higher Ed that Jon points to in his earlier email
(http://chronicle.com/article/BestWorst-College-Web/125642/) does not meet
this "pass" criteria, yet is not "inaccessible" because of it - in fact
the size of the table (183 rows in length with little-to-no internal
navigation) is more of an access issue than the failure for each row to
start with a <th>.

The following table is perfectly acceptable and valid, and meets (as far
as I know) all required accessibility guidelines as established by both
the Section 508 Standard and W3C Guidelines (yet fails the FAE tool):

<th scope="col">Sunday</th>
<th scope="col">Monday</th>
<th scope="col">Tuesday</th>
<th scope="col">Wednesday</th>
<th scope="col">Thursday</th>
<th scope="col">Friday</th>
<th scope="col">Saturday</th>
<th scope="row">Week 1</th>


"Each th element in a complex data table must have an id attribute whose
value is unique relative to all ids on the page."
Please explain how failing to add an ID attribute to a table
header makes it less accessible.

"Each td element in a complex data table must have a headers attribute
that references the id attributes of associated th elements."
Please explain how failing to add a HEADER attribute to a table
cell makes it less accessible.

What defines "complex"? How does a mechanical tool makes this
assessment? The table code example shown above is perfectly valid, is
extremely accessible, and would fail 3 of the 5 data-table 'rules' this
testing imposes on *your* sites. This is simply unacceptable.

"Each img element with width or height less than 8 pixels should be
removed; CSS techniques should be used instead."
Really? How exactly was this determined? If I have an image that
is 9 pixels X 2 pixels than it should have alt text and not be moved to


Until such time as clarification and proof exists to back up these claims,
the entire exercise is mired in inaccuracies and confusion.

Real Problems not evaluated in your testing:

* Link text that is meaningful when taken out of context
* Alt text that is meaningful
* Ensuring that all information conveyed with color is also available
without color
* Appropriate foreground and background contrast
* The ability to interact with a page without the need to use a mouse
* The appropriate use of lists and list mark-up
* Multi-media issues: no auto-start, caption/transcripts for video
content, etc.
* No blinking, no auto-redirect, no timing-out with prior notice, etc.

I have also challenged you to clarify the fact that mechanical testing is
but one aspect of accessibility evaluation on the 183 Report Cards you
have issues at http://webaccessibility.cita.illinois.edu/data/schools/ so
that we have a more accurate and truthful report to properly discuss at
our institutions.

> I can't think of a more basic accessibility feature than using a label
> element or title attribute to label a form control.
> The lack of form control labeling was my biggest conclusion from the
> pages tested and my biggest worry is how to address this issue.

Yet nowhere in your evaluations or reporting is this fact highlighted. Why
is this?

> I think everyone agrees that form control labeling is a part of WCAG
> 1.0, WCAG 2.0, Section 508 requirements and almost any other web
> accessibility standard developed.
> If higher education can't even label simple form controls correctly,
> how are they ever going to make Dynamic HTML widgets accessible?

How about by focusing on real accessibility issues and not forcing
everyone to 'pass' the FAE ranking exercise by insisting that every table
cell have either a header or ID (when @scope is often more than enough),
or that "The text content of each h1 element should match all or part of
the title content"? Engaging in real dialog rather than perpetuating
boogie-man scare tactics and tick-box evaluations that leave higher
education institutions worrying about their 'ranking' rather than truly
meeting the needs of disabled students within their student body.

===========================John Foliot

NOTE: These are my personal opinions, and in no way reflect the opinion of
Stanford University (with whom I am under contract), T-Base Communications
(my employer), my associates or other professional affiliates with whom I
do business with.

Co-chair - W3C HTML5 Accessibility Task Force (Media)