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Lists without labels in PDFs

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From: Alan Zaitchik
Date: Sep 13, 2018 1:37PM

I have a feeling this subject has been broached before, but I cannot find it.

I am working on PDFs that must conform to the (new) HHS requirements for accessibility. Some documents have lists (e.g. a page of References) whose list items do not have labels. There is in fact nothing in the text which I might cajoled or force into that role of label. These clearly are lists, but tagging them as such generates a violation of the HHS requirement that every list item must have a label. (That requirement was not changed in the new HHS requirements.)

I could forget about the list structure altogether and tag each item as a <P>, but these are semantically lists, and I imagine a screen reader user would welcome hearing something like "References heading level 2, list of 10 items" or its ilk, even if the screen reader burped on the fact that no list labels are present. Would (recent) releases of Jaws and NVDA handle this acceptably?

Any suggestions? Should I ignore the "technical foul" and generate list items without labels? Should I give up on lists and just create paragraphs? Something else?

I would like to ask for the client's blessing only after hearing from you worthy experts!

Thanks,

A