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Re: How is PDF accessibility evaluated?

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From: Karlen Communications
Date: Feb 7, 2015 4:04AM

I am going to reluctantly wade into the fray and then back out of it.

I am, and those of us on the various PDF/UA committees for our countries are advocating for the adoption of PDF/UA into legislation and genral "this is what an accessible PDF is" standard. I am on the Canadian committee and have been for many years. I also use adaptive technology.

I look at inclusion from a global perspective and the Incheon Strategy to Make the Right Real in the Asia Pacific Region which is a strategy to implement the Convention on the Rights of People with Disabilities states that for digital content international standards are to be implemented. This is quite progressive and allows for the immediate adoption and implementation of standards as they are developed.

In terms of the Access Board "standards" or guidelines or best practices, I have some serious concerns about the direction they are headed or it looks like they are implementing. I was at a webinar this past week and was gobsmacked to hear them recommend as a standard/guideline/best practice/requirement that tables be used for design layout in Word, that text boxes be used in Word instead of formatted styles and that the null attribute be used for decorative images in Word documents.

One person did ask if the null attribute worked the same way in Word as it did in HTML and the response was telling in terms of an understanding of how standards/guidelines/requirements are being perceived and even knowledge about accessible document design in general. The answer from the people who created this training and guidance/requirements was that it didn't work in Word but it was a WCAG requirement/technique so it was included in their new standard/guidelines/requirements.

I used the slash to separate the terms standard/guidelines/requirements/best practice because during the 90 minute webinar these terms were used interchangeably and I still don't know if these are going to be what the Access Board and Department of Education as well as federal agencies are going to mandate be put in place and accepted.

This training/requirements/guidelines/standards/best practices were developed by a small group and the focus seems to be on those using screen readers and not really paying attention to what we know is and isn't accessible or even good document design. There is also no mechanism for anyone outside of the committee that created these standards/guidelines/ requirements/best practices to comment or help them reshape their documentation.

I am a Microsoft MVP for Word and a Microsoft Accessibility MVP. I know that work has been done to make text boxes in Word more accessible and although progress has been made, access is still hit and miss in terms of the adaptive technology. It also appears that the material developed by/for the Access Board and Department of Education is not thinking of backward compatibility even to Word 2007. The example they gave for using tables for design layout is actually a good example of where Tab Stops should be used to optimize the content for accessibility.

...and the next webinar and set of standards/guidelines/requirements/best practices are on accessible PDF!!!!!!

As someone who has been working in this field for over a decade, has written books on creating and working with accessible PDF, Word and PowerPoint as well as general accessible document design and done a lot of training and workshops at conferences, and someone who depends on adaptive technology to access digital content, I am really concerned that adoption of these standards/guidelines/requirements/best practices are going to create more inaccessible content that will need remediation before it is accessible.

Going back to the PDF part of this discussion. PDF/UA gives us the tool to answer the question "what do you mean by or want in an accessible PDF? We can now say, it has to be PDF/UA compliant. We don't really care how you get there, but this is where you need to end up.

To add more fuel to the discussion, here is a link to an interview I've done in advance of my PDF/UA session at CSUN.
http://www.accessiq.org/news/features/2015/02/accessible-pdfs-and-the-potential-of-pdfua

Backing out of the fray now and skulking in the background. Nice to hear from you Loretta!

Cheers, Karen


-----Original Message-----
From: <EMAIL REMOVED> [mailto: <EMAIL REMOVED> ] On Behalf Of Loretta Guarino Reid
Sent: February 6, 2015 8:05 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] How is PDF accessibility evaluated?

On Fri, Feb 6, 2015 at 4:58 PM, Chagnon | PubCom < <EMAIL REMOVED> > wrote:

> Susan wrote: "So I shouldn't be using the WCAG guidelines (and I
> thought the W3 was a standards board) at all?"
>
> WAI is the standards board for accessibility, under the larger W3C
> organization.
> WCAG are the guidelines developed by the WAI.
>
> It's not that you shouldn't be using the WCAG guidelines for PDFs,
> it's more that they were written specifically for website/HTML
> information and many of guidelines don't fit well with PDFs .
> Remember, when they were initially developed around 2000 (if I recall
> the dates correctly), they addressed only website information. Office
> documents and PDFs weren't then
> -- and still aren't today -- specifically addressed.
>

​WCAG2 was published in December 2008 and is intentionally format-independent. It is not HTML specific. PDF techniques are included in the WCAG2 techniques because PDF can also be web content. PDF was included in the process as the WCAG2 success criteria were being written.


> Four terms to understand in this discussion:
> -- Guidelines, as in "WCAG" means a broad overview of what's trying to
> be achieved. Sometimes those guidelines apply, sometimes they don't,
> depending upon the material, file format, content, usage, etc. Quoting
> from the WCAG website, "The 12 guidelines provide the basic goals that
> authors should work toward in order to make content more accessible to
> users with different disabilities. The guidelines are not testable,
> but provide the framework and overall objectives to help authors
> understand the success criteria and better implement the techniques."
> Note the phrase, guidelines are not testable.
> -- A standard is a hard and fixed requirement. It's measureable and
> the content either passes or fails. (Or wins a court case or not, or
> the owner is fined or not, etc.)
> -- A success criteria or checkpoint is a way to test whether a
> guideline has been met.
> -- And a technique is a suggestion as to how the
> guidelines/standards/success criteria can be met by those who create
> the content.
>
> So yes, you should still refer to WCAG, but in regards to PDFs, WAI
> has only given us suggestions and methods, not standards or even guidelines.
> It's one person's way of doing things (or maybe it was put together by
> a small group). There are many other "techniques" you could use to
> achieve the same results.
>
> On the other hand, the PDF UA is an ISO standard; ISO = the
> International Standards Organization. These are defined standards and
> thus give us something to assess PDFs, haul people's butts into court,
> etc. But the PDF US standards have to become more widely accepted and
> formally adopted by governments and other institutions before they can
> be applied, and I believe that's what Duff and his crew are working on. Well, I hope they are.
>
> In reviewing WCAG itself, more than half of the guidelines don't apply
> at all to PDFs for one reason or another, but mostly because we just
> can do some of those tasks in PDFs. Or in Word documents, for that matter.
>
> One more quirk in all this:
> -- W3C sets the standards for HTML, so they can write any standards
> and guidelines they want to cover websites.
> -- But Acrobat PDF is controlled by Adobe, MS Word et al by Microsoft.
> So an outsider like the W3C can't tell these 2 corporations what to do
> with their software and proprietary formats. It's a detente situation:
> all the players have to come to mutual agreement on these things.
> Luckily, both Adobe and Microsoft have been fairly decent on this, not
> perfect, but better than most software companies. Ask anyone how
> accessible Oracle's software is!
>
> --Bevi Chagnon
>
>
> -----Original Message-----
> From: <EMAIL REMOVED> [mailto:
> <EMAIL REMOVED> ] On Behalf Of Susan Grossman
> Sent: Friday, February 6, 2015 5:19 PM
> To: WebAIM Discussion List
> Subject: Re: [WebAIM] How is PDF accessibility evaluated?
>
> So I shouldn't be using the WCAG guidelines (and I thought the W3 was
> a standards board) at all?
>
> On Fri, Feb 6, 2015 at 1:32 PM, Chagnon | PubCom < <EMAIL REMOVED> >
> wrote:
>
> > Duff is correct; WCAG has only techniques & methods for making
> > accessible PDFs. They are not standards nor guidelines. Far from it!
> >
> > Because they are not standards, they cannot be used, for example, to
> > assess whether a PDF is in fact accessible. Governments can't
> > formally adopt them into law as they have WCAG itself. You can't
> > file a complaint using techniques to back up your claim because
> > techniques can't hold up in court. So think of what WCAG has
> > published as only suggestions on how to make an accessible PDF.
> >
> > For better guidance on standards for PDFs, see the PDF/UA Competence
> > Center's website at
> > http://www.pdfa.org/competence-centers/pdfua-competence-center/
> > You'll learn about the ISO 14289 standard for Universally Accessible
> > PDFs ... a real standard.
> >
> > And you'll also Duff's smiling mug gracing the website's banner
> > <grin>
> >
> > --Bevi Chagnon
> >
> > — — —
> > Bevi Chagnon | www.PubCom.com
> > Consultants, Trainers, Designers, and Developers For publishing
> > technologies
> > | Acrobat PDF | Digital Media | XML and Automated Workflows GPO |
> > | Print | Desktop Publishing | Sec. 508 Accessibility | EPUBs
> > — — —
> >
> > -----Original Message-----
> > > WCAG 2.0 has standards for PDF's located here:
> > > http://www.w3.org/TR/WCAG20-TECHS/pdf.html
> >
> > From: <EMAIL REMOVED> [mailto:
> > <EMAIL REMOVED> ] On Behalf Of Duff Johnson
> > Clarification: these are Techniques, not Standards… a non-trivial
> > distinction.
>
>
> > > list messages to <EMAIL REMOVED>
>