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Re: PDF forms

for

From: McDonald, Jennifer
Date: Aug 18, 2011 9:15AM


Thanks everyone. This is the sort of conversation I needed.

Jeni

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Duff Johnson
Sent: Wednesday, August 17, 2011 10:02 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] PDF forms

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

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