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Re: H1 to H4 titles sub titles....


From: Hoffman, Allen
Date: May 3, 2011 12:42PM

No technical standard in current Section 508 requires use of headings, nor does it specify incremental consistent usage in any way. In addition, you might be able to clearly demonstrate a functional performance failure under specific circumstances regarding randomized heading usage, but in my view this would be limited to a specific situation and would involve extreme time impact on some users with disabilities. Equivalent facilitation allows for multiple ways to meet a technical standard, e.g. if tables are required to have headings, and you implement the whole thing in .css and such is navigable and understandable in the same fashion as mark-up would be, equivalent facilitation would be successful. The WCAG 2 format of the current 508 skip-nav is more broad, and requires ability to bypass blocks of text, which at the end of the day really does require, at least in one method, use of headings, and for sanity's sake consistently applied usage.

Allen Hoffman

-----Original Message-----
From: Sailesh Panchang [mailto: <EMAIL REMOVED> ]
Sent: Tuesday, May 03, 2011 10:08 AM
To: WebAIM Discussion List
Subject: Re: [WebAIM] H1 to H4 titles sub titles....


My statement was in the context of Web pages that have "headings"
(stylized text / images).
Equivalent facilitation will require compliance with 1194.31 (a) then.
The Technical Standards, Functional Performance criteria are sub parts
of the part 1194 of which equivalent facilitation too being an
essential component of this part.
And to comply with S508 a product must comply with all applicable
provisions and not just tech. standards. So the statement "Nothing in
this part ..." includes 1194.5 and 1194.31 and 1194.22.
Right... I am addressing the issue of headings for S508 broadly here.
My first email discussed the significance of not skipping levels.

On 5/2/11, Jukka K. Korpela < <EMAIL REMOVED> > wrote:
> Sailesh Panchang wrote:
>> I will argue that h-markup is required to comply with S508 functional
>> performance criteria.
> The issue was not whether heading markup is used or not. Moreover,
> argumentation based on free and loose interpretation of Section 508 rules is
> questionable. Rules that specify whether something is legal or not are to be
> interpreted rigorously: only things explicitly forbidden are to be treated
> as illegal - any borderline cases are to be interpreted in favor of the
> accused.
>> 1194.31 (a) At least one mode of operation and information retrieval
>> that does not require user vision shall be provided,
> On web pages, with due provisions like alt texts, the criterion is fulfilled
> fairly automatically.
>> In effect, compliance with the performance criteria of �1194.31
>> is the test for Equivalent Facilitation.
> Equivalent Facilitation is not one of the criteria. Instead, it is used to
> label this principle:
> "Nothing in this part is intended to prevent the use of designs or
> technologies as alternatives to those prescribed in this part provided they
> result in substantially equivalent or greater access to and use of a product
> for people with disabilities"
> This _allows_ designs and technologies, instead of imposing restrictions.
>> So if h-tags are added to the doc, they should be as per specs:
>> consistent and correctly nested.
> There is no specification that forbids an h4 following an h1. The specs at
> most mention it as a good design principle not to skip heading levels. No
> requirement. And even if there were a requirement in some HTML or WAI spec,
> that would not make it part of Section 508 conformance.
> Yucca