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From: Birkir R. Gunnarsson
Date: Fri, Apr 20 2012 9:26PM
Subject: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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Hi

I was doing a review of the WCAG, because I am commenting on an
Icelandic adoption and description of the standard. And I came across
something I did not notice before.
SC criterian 2.4.6 (use descriptive headings and lables) is only level
AA, not level A.
Out of curious, does anyone know why this is?
It seems a lot more fundamental to accessibility than a lot of the
level A criteria I have come across, and it seems a bit out of
character with the rest of the guidelines.
Anyone got a historical or technical perspective on why this happened?
Thanks
-B

From: Duff Johnson
Date: Sat, Apr 21 2012 11:25AM
Subject: Re: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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Birkir,

> I was doing a review of the WCAG, because I am commenting on an
> Icelandic adoption and description of the standard. And I came across
> something I did not notice before.
> SC criterian 2.4.6 (use descriptive headings and lables) is only level
> AA, not level A.

It's interesting that you ask this question - the subject is very much on my mind at this time.

2.4.6 is a content, not a technical prescription. It's an instruction on how to write, not how to semantically encode text. Level A appears generally reserved for "programmatically discernible" items (whether or not that's a good thing is another question).

I agree with you that 2.4.6 "feels" Level A, not AA. The way I prefer to read it goes like this:

"In cases where content is subdivided into logically distinct sections, then section headings/labels (if any) shall be "clear and descriptive" in order to meet the objectives implied by the Guideline."

Of course, as a practical matter, since almost all content does include headings, 2.4.6 is effectively Level A - at least in my mind.

What this raises, however, is the question of how it's possible to be "clear and descriptive" in headings without logic in the "structure" (an SC 1.3.1 Level A concept, hint hint) of headings.

For this reason, I don't understand why (or even how) 2.4.10 is broken out from 2.4.6.

Gosh, normative standards should be clearer than this! :-)

> Out of curious, does anyone know why this is?
> It seems a lot more fundamental to accessibility than a lot of the
> level A criteria I have come across, and it seems a bit out of
> character with the rest of the guidelines.
> Anyone got a historical or technical perspective on why this happened?

I wasn't there, so I can't help on the history. The technical context seems like HTML, in which structure and style are frequently mixed and in which long, deeply structured content is rare, and so, less considered.

I can, however, offer some context from the world of PDF.

In PDF logical structure there is no such question over "headings". In PDF, logical structure elements are unconnected with the appearance of content. If you use only 1 heading in a document and prefer an "H3 style" for it, no problem - but LOGICALLY that heading _is_ an H1 because ipso facto there's "no such thing" as an "H3 all by itself".

In PDF, subdivision headings are the primary and most effective means of content-based navigation for AT users. In part this is because heading structure elements in PDF are ONLY used for subdivisions of content - they have no other function (i.e., headings are not "importance" as they do in HTML 4).

Of course, not everyone authors their PDFs this way, but that's an education, not a technical problem.

One of the great advantages of PDF/UA is that conforming implementations will guide users towards better authoring practices simply because PDF/UA insists, normatively, on logical heading structures when headings are present.

Best regards,

Duff Johnson

President, NetCentric US
ISO 32000 Intl. Project Co-Leader, US Chair
ISO 14289 US Chair
PDF Association Vice-Chair

Office: +1 617 401 8140
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From: Gunderson, Jon R
Date: Mon, Apr 23 2012 12:22PM
Subject: Re: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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>
>For this reason, I don't understand why (or even how) 2.4.10 is broken
>out from 2.4.6.

1.3.1 Requires the use of headers if there are things in the "document"
that visually look like headers.

So 2.4.6 only comes into play when nothing in the "document" looks
visually like a heading.

Just learned this a few weeks ago at a WCAG 2.0 techniques group meeting.

So 1.3.1 has a lot of conditional requirements.

Also in relationship to 2.4.6 in general people are unlikely to put into a
document headings that are not meaningful these days.

Jon Gunderson


>

From: Duff Johnson
Date: Mon, Apr 23 2012 12:47PM
Subject: Re: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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On Apr 23, 2012, at 2:22 PM, Gunderson, Jon R wrote:

>> For this reason, I don't understand why (or even how) 2.4.10 is broken
>> out from 2.4.6.
>
> 1.3.1 Requires the use of headers if there are things in the "document"
> that visually look like headers.

Does it require the use of "headers" or of "heading levels".

If "heading levels" are used in the document (and with HTML, it's pretty clear-cut if heading levels are used!), what rule(s) apply for 1.3.1, if any?

> So 2.4.6 only comes into play when nothing in the "document" looks
> visually like a heading.

…but if something DOES "visually" seem like a heading (and this could be via style OR text (i.e., section enumeration) then 2.4.6 applies?

Ok, I can buy that. If 1.3.1 doesn't apply, 2.4.6 can't; fine.

But - if 1.3.1 IS violated, 2.4.6 is probably also violated - ?

> Just learned this a few weeks ago at a WCAG 2.0 techniques group meeting.
>
> So 1.3.1 has a lot of conditional requirements.

Indeed.

> Also in relationship to 2.4.6 in general people are unlikely to put into a
> document headings that are not meaningful these days.

"Meaningful" is at issue. HTML 4 defines "heading" one way. HTML 5 defines it in a different way. PDF, in yet another.

The Techniques provided to address this question are all HTML-centric, and HTML 4.0-centric at that.

Here's my latest article on the subject: I'd love to know how I'm getting this wrong, if I am:

http://www.commonlook.com/The-Definition-of-Heading

Duff.

From: Spence, Jason (MGS)
Date: Mon, Apr 23 2012 2:53PM
Subject: Re: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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From: Spence, Jason (MGS)
Date: Mon, Apr 23 2012 2:54PM
Subject: Re: Recall: Why is WCAG 2.0 criterian 2.4.6. only leve AA?
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Spence, Jason (MGS) would like to recall the message, "[WebAIM] Why is WCAG 2.0 criterian 2.4.6. only leve AA?".