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From: Julian Tenney
Date: Thu, Apr 17 2025 10:17AM
Subject: Re: University Resources
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I would say no, but it probably depends. If it's just general access to a third party resource, then the accessibility is not the University's responsibility. However that doesn't mean that the University shouldn't review the accessibility of that resource and i) highlight any issues to users, or ii) raise those issues with the third party.

It might be more complicated if access to the resource is an essential part of a users job. The problem here is define 'essential'.

The EAA is relevant here, with the onus falling on the third party. It's also more complicated because something like pubmed will contain resources in turn provided by multiple third parties, who may have varying standards / policies when it comes to accessibility.

So in my opinion it's a good question because of the 'what ifs' but in my work at University of Nottingham I do not think we are responsible for pubmed's accessibility.

Julian

From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Brian Lovely via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
Sent: 17 April 2025 16:53
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Cc: Brian Lovely < = EMAIL ADDRESS REMOVED = >
Subject: [WebAIM] University Resources

I'm a little out of my zone here, so I hope I can word this question correctly. If a university provides access to outside resources, for example JSTOR or PubMed, is the university responsible for the accessibility of those resources?

Thank you,
Brian Lovely

This message and any attachment are intended solely for the addressee and may contain confidential information. If you have received this message in error, please contact the sender and delete the email and attachment. Any views or opinions expressed by the author of this email do not necessarily reflect the views of the University of Nottingham. Email communications with the University of Nottingham may be monitored where permitted by law.

From: Philip Kiff
Date: Thu, Apr 17 2025 3:00PM
Subject: Re: Reference/Note tags
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Thanks for the detailed response, Duff, confirming much, and clarifying
and qualifying elsewhere. That's very helpful for folks like me who are
trying to pin down some of the finer details of the standards and their
implementations in various software and technology.

You make a good point about the difference between web pages and PDFs:

> Unlike web pages, PDF files persist....Web pages can be fixed for
> everyone by a tweak and a reload. By contrast, PDF is often
> "delivered" rather than "served", so if it’s inaccessible on-delivery
> it’s generally inaccessible for every downstream user, forever.
>
In that context, I would note that the current widespread reliance on
automated accessibility testing for PDFs tends to produce PDFs that will
pass the PAC Tool or CommonLook Validator tests, without actually fully
meeting all the PDF/UA standards. Many PDFs are adjusted to pass these
testing tools, even where the testing tools may be not quite accurate.
Eventually, then, when software and screen readers are in place that
process all these tags more fully, we will have a lot of PDFs that
didn't ever really quite pass PDF/UA, but which only much later start to
present annoying issues for users.

Though the tests are getting better all the time, too.

Oh also, a quick correction: on re-reading my post, I noticed that I'd
mistaken the name of the new footnote/endnote reference tag in PDF 2.0.
I wrote "a new RefNote tag is introduced in PDF 2.0". Not sure where I
got that name! It should be FENote instead. I haven't actually used the
new FENote tag/structure element yet, but look forward to implementing
it in PDF 2.0 compliant files, and am very hopeful it will eventually
result in footnotes and endnotes that can be easily read and navigated
by all users.

Phil.

On 2025-04-15 3:06 p.m., Duff Johnson via WebAIM-Forum wrote:
> In lists, <LbL> elements distinguish the list item’s label from the <LBody> (the content of the LI). <Lbl> was more broadly (but poorly) defined in PDF 1.x. This situation was addressed in PDF 2.0, but implementations are only now beginning to arrive.
>
> [snip]
>
> We can only hope that, over time, assets such as the PDF Association's Techniques for Accessible PDF will help to elevate common understanding.
>
> Duff.

From: Zjef Herwig | HStalks
Date: Sat, Apr 19 2025 10:59PM
Subject: Re: University Resources
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Hey Brian,

I’m not familiar with every detail, but in US law universities aren’t required to make all their materials accessible—mostly because it’s expensive. Even digitizing modern resources can be a big lift, let alone a 12th‑century manuscript. With the sheer volume of items they hold, it would be financially crippling to do it all.

That said, if a professor uses something in their course or a student needs a resource for their studies, the university must provide an accessible version. The idea is that students with disabilities should have equivalent access to any materials, whether they’re in‑house or external.

Best regards,
 
Zjef Herwig

From: Xander Andrews
Date: Thu, Apr 17 2025 1:36PM
Subject: Re: University Resources
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Not a lawyer, or providing legal advice here in any way, but I would point out that a federal jury ruled in Payan v. LACCD that LA City College failed to meet its legal obligations to two blind students, and inaccessible library resources were listed as part of that failure. We may not be responsible for fixing the accessibility issues of a product, but we could be held responsible for using/licensing inaccessible products.

Many University Libraries have been pushing vendors to improve the accessibility of their products during contract renewal negotiations. The University of Washington Libraries tested all of our E-resources<https://lib.uw.edu/services/accessibility/e-resource-testing/#p> in 2022, to evaluate if they meet basic keyboard navigation. Higher level testing is being done by the Library Accessibility Alliance<https://www.libraryaccessibility.org/testing>.
[http://s3-us-west-2.amazonaws.com/uw-s3-cdn/wp-content/uploads/sites/10/2019/06/21094817/Univ-of-Washington_Memorial-Way.jpg]<https://lib.uw.edu/services/accessibility/e-resource-testing/#p>
Library E-Resource Accessibility Testing – UW Libraries<https://lib.uw.edu/services/accessibility/e-resource-testing/#p>
UW Libraries' testing efforts to ensure E-resources procured for use at the Libraries are accessible to individuals with disabilities.
lib.uw.edu



Xander Andrews, MCRP

Disability Resources for Students

Assistant Director, Academic Services



011 Mary Gates Hall

Box 352808

Seattle, WA 98195-2808

206-616-9757



From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of Brandon Keith Biggs via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
Sent: Thursday, April 17, 2025 10:02 AM
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Cc: Brandon Keith Biggs < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] University Resources

Hello,
U.S. universities will often offer to properly tag or convert papers to
Word that a student requests. There's a 2-week turn-around, and sometimes
math content, for example, is not done correctly, but it's very nice to
have the university who will be willing to make a complex file usable on
request.
For less complex PDFs, I recommend:
https://urldefense.com/v3/__https://papertohtml.org/__;!!K-Hz7m0Vt54!k7vvAxRXZ6r4iheOvZeMO8OWLhM3TqYOXj902TK3-zrGuDmwNlXp427W_O9upWb1DvINcs8D21kImr0IG-5Nfp1guw$
Thanks,

Brandon Keith Biggs <https://urldefense.com/v3/__http://brandonkeithbiggs.com/__;!!K-Hz7m0Vt54!k7vvAxRXZ6r4iheOvZeMO8OWLhM3TqYOXj902TK3-zrGuDmwNlXp427W_O9upWb1DvINcs8D21kImr0IG-48r6CSlQ$ >


On Thu, Apr 17, 2025 at 9:24 AM Julian Tenney via WebAIM-Forum <
= EMAIL ADDRESS REMOVED = > wrote:

> I would say no, but it probably depends. If it's just general access to a
> third party resource, then the accessibility is not the University's
> responsibility. However that doesn't mean that the University shouldn't
> review the accessibility of that resource and i) highlight any issues to
> users, or ii) raise those issues with the third party.
>
> It might be more complicated if access to the resource is an essential
> part of a users job. The problem here is define 'essential'.
>
> The EAA is relevant here, with the onus falling on the third party. It's
> also more complicated because something like pubmed will contain resources
> in turn provided by multiple third parties, who may have varying standards
> / policies when it comes to accessibility.
>
> So in my opinion it's a good question because of the 'what ifs' but in my
> work at University of Nottingham I do not think we are responsible for
> pubmed's accessibility.
>
> Julian
>
> > From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > on behalf of
> Brian Lovely via WebAIM-Forum < = EMAIL ADDRESS REMOVED = >
> Sent: 17 April 2025 16:53
> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> Cc: Brian Lovely < = EMAIL ADDRESS REMOVED = >
> Subject: [WebAIM] University Resources
>
> I'm a little out of my zone here, so I hope I can word this question
> correctly. If a university provides access to outside resources, for
> example JSTOR or PubMed, is the university responsible for the
> accessibility of those resources?
>
> Thank you,
> Brian Lovely
>
> This message and any attachment are intended solely for the addressee and
> may contain confidential information. If you have received this message in
> error, please contact the sender and delete the email and attachment. Any
> views or opinions expressed by the author of this email do not necessarily
> reflect the views of the University of Nottingham. Email communications
> with the University of Nottingham may be monitored where permitted by law.
>
>

From: Mosley, Leigh
Date: Mon, Apr 21 2025 6:43AM
Subject: Re: University Resources
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Hi all,

I can only speak for the US, but in terms of legal requirements, under the updated ADA Title II, all institutions receiving funding from states and local governments (such as public universities) are required to ensure that all the web content and mobile apps that they provide for use meet WCAG 2.1 AA. Notably for university libraries, this includes third-party content if there is are "contractual, licensing, or other arrangements" with that publicly-funded entity. (https://www.federalregister.gov/d/2024-07758/p-586) Deadlines for compliance vary by size of jurisdiction, either 4/24/2026 or 4/24/2027. Presumably the option to create a defense by claiming fundamental alteration or undue burden still exists, but no one is sure yet how or if that would work.

Leigh Mosley, MA, MLS, CPWA
Accessibility Coordinator
University of Tennessee Libraries
1015 Volunteer Boulevard
Knoxville, TN 37996-1000
865-974-0011
= EMAIL ADDRESS REMOVED =