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PDF with multiple References to same Note

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From: Alan Zaitchik
Date: Jun 22, 2018 7:16AM

Any suggestions on the best practice for the following case?

I have a 2 page PDF where there are multiple references in multiple paragraphs to the same footnote. Visually all the footnotes are collected at the end of the document. The references are on both pages of the document.

The relevant standard for accessibility is the new HHS standard, but I cannot place the Note tag after the Reference tags in the reading order -- and I cannot place each after the paragraphs in which the Reference tag occurs since there are multiple such Reference tags for the same Note tag!

From https://www.hhs.gov/web/section-508/making-files-accessible/pdf-required/index.html -- "Move the footnote text in the tag structure to either directly after the reference number, or directly after the paragraph that contains the reference number."

I have no access to the original InDesign document, and I cannot edit the PDF (e.g. by creating multiple instances of the same footnotes) without destroying its appearance.

What is the least annoying way to handle this for screen reader users?

(1) Keep it the way it is.
(2) Move (in the tag tree) each note tag to directly after the first reference to it.
(3) Move (in the tag tree) each note tag to directly after the paragraph containing the first reference to it.
(4) Something else?

Thanks for suggestions!

Alan