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Re: CommonLook failures and HHS requirements

for

From: Chagnon | PubCom
Date: Dec 21, 2017 10:44PM

You're running into an industry problem.

There is no authoritative, defined "do this / don't do that" standard for those who create accessible PDFs.

The PDF/UA standard (ISO 14289-1:2012, https://www.iso.org/standard/54564.html) is a technical specification for how a PDF is to be produced by software. It really doesn't say anything much about how content creators (you, me, and HHS) should make a PDF accessible.

For example, no standard states how many H1 tags can be in a document (and some of us argue whether any standard should ever state how many should be allowed in a document). Or how many words/characters should be in Alt-text. Or what items should have Alt-text at all, such as whether it's needed on descriptive hyperlinks.

The end result of this industry shortcoming; everyone gets to make up their own requirements of what makes a PDF accessible. HHS (Health and Human Services) has theirs. CommonLook and other industry tool makers have theirs. My firm has ours. WCAG has its version. And I'm sure every single remediator on this list has their own version, too.

Your comments on the five issues you stated below are valid. RE: Number 5 about embedding fonts, I strongly urge you to always embed fonts (with subsetting) so that all characters are recognized and presented to the user accurately. Otherwise a screen reader, for example, will miss a math symbol.

But the bottom line for your post is that HHS calls the shots as to what they want to see in a PDF. You signed a contract to meet their PDF standards for accessibility. Reread every word of the contract. Make it happen.

A federal government agency can legally hold your company's feet to the fire to meet the specified requirements in the contract. Your opinion has little bearing on the contract's requirements. The time to question the requirements was during the bid cycle, not after the contract was awarded.

In federal government contracting, we contractors must produce what it required by the contract or the agency can take legal action and essentially ban us from future federal contracts. In my professional opinion (I am not a lawyer but teach classes on government contracting), your company should consider the feedback you received from HHS as a "cure" letter; that is, you have not met the contract's requirements and they are formally telling you to fix the deliverable or be in violation of the contract. If you don't understand this, please consult a lawyer who is knowledgeable about federal government contracting.

We can debate later if some agencies have gone overboard on some of their requirements. Right now, you have to bring your deliverables into compliance with the contract.

Hope this helps,
--Bevi Chagnon

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Bevi Chagnon
www.PubCom.com | Technologists for Accessible Design and Publishing
print – digital – web – documents – pdfs – epubs
consulting – training – development – design – sec. 508 services
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Bevi Chagnon is a US delegate (ANSI) to the ISO for PDF and PDF/UA standards