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Re: Lists without labels in PDFs

for

From: chagnon@pubcom.com
Date: Sep 13, 2018 1:53PM

IIRC from memory, PDF/UA-1 does not require the LBL tag on list items. Only
the LBody tag.

PDF/UA-1 and WCAG 2.0 are the current federal requirements under Sec. 508.
Any newer standards are not yet "the law."

But agencies like HHS can always require documents to exceed the law.
Whether that's the right action for them to take is debatable, especially
since we have neither a standard that requires it nor the software tools to
build it.

At this time, we recommend for HHS documents that have a
non-bulleted/non-numbered list, tag them with just <P> tags and an
appropriate heading tag before each section, if you think that will aid in
comprehension.

Other agencies, who haven't put the cart before the horse like HHS has, are
compliant using the standard list tag structure without an LBL subtag.

The best solution needs to be:

-- That the ISO PDF/UA committee address non-bulleted and non-numbered lists
in a forthcoming standard. Not all lists have bullets or numbers!

-- That software authoring tools such as MS Word and Adobe InDesign allow
authors to style lists as lists but without numbers or bullets or LBL tags.

-- And, of course, that assistive technologies correctly interpret this new
tagged format.

Let's just say that all of that is "in development."

--Bevi Chagnon
- - -
Bevi Chagnon, founder/CEO | <EMAIL REMOVED>
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PubCom: Technologists for Accessible Design + Publishing
consulting . training . development . design . sec. 508 services
Upcoming classes at www.PubCom.com/classes
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Latest blog-newsletter - Accessibility Tips at www.PubCom.com/blog

-----Original Message-----
From: WebAIM-Forum < <EMAIL REMOVED> > On Behalf Of Alan
Zaitchik
Sent: Thursday, September 13, 2018 3:37 PM
To: <EMAIL REMOVED>
Subject: [WebAIM] Lists without labels in PDFs

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

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