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Re: PDF forms

for

From: Ryan E. Benson
Date: Aug 17, 2011 9:24PM

Nice Duff, I didn't connect .21 to PDFs/documents - but that is totally valid.

--
Ryan E. Benson



On Wed, Aug 17, 2011 at 11:01 PM, Duff Johnson < <EMAIL REMOVED> > wrote:
> On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
>
>> If the intent of the form is to fill out and print - to be the most
>> accessible you should make the form fillable via whatever program they
>> use.
>
> Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
>
> In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
>
> In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
>
>> I don't know of anything in Section 508 that says if the pdf is a
>> form it must have fields.
>
> From:
>
> http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
>
> ---------
> Subpart B - Technical Standards
> SubSection 1194.21  Software applications and operating systems.
>
> (l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
> ----------
>
> This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
>
> If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
>
> I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
>
>> However if the PDF does have fields, they
>> must be accessible.
>
> Absolutely - once you have a fillable form (see above), the form elements must be accessible.
>
> Duff Johnson
>
> p  +1.617.283.4226
> e   <EMAIL REMOVED>
> t  http://www.twitter.com/duffjohnson
> w  http://www.duff-johnson.com
>
>