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From: Bryce.Fields@kyvu.org
Date: Thu, Sep 04 2003 9:08AM
Subject: Section 508 Standards Compliance and Scripts
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I come to the community seeking enlightenment (especially if there are any
of you out there w/ a legal background).
Kentucky Virtual University is currently reviewing Section 508 standards
compliance of several distance education course management systems (CMS).
While doing so, I ran across this explanation of why a system is in
compliance with the part of Section 508 that governs scripting:
"[Software Package X] uses only minimal dynamic scripting for content
presentation. It does use script to conditionally write some content to a
page. Content rendered in this manner is written to the screen before the
page loads, and can't be distinguished from standard content."
It is pretty clear in the context of the paragraph this was taken from that
they are referring to client-side JavaScript and not a server side solution.
Correct me if I'm wrong (and it's been known to happen), but isn't
JavaScript interpreted AS the page loads (at least in the case that they are
describing)? How can scripting write content to the page BEFORE it loads?
This statement makes no sense to me.
KYVU currently uses a CMS that makes a similar claim about its product
("content written to the screen before the page loads"). Disabling
JavaScript while using that platform makes course material inaccessible.
All an end user receives is a one sentence message stating that the page
won't work w/ JavaScript disabled, and no other means to access the course
is provided. How can this be considered compliance w/ 508???
I just want to make sure I'm not missing anything. And TIA for all
comments. (And to anyone who also subscribes to the Webdesign-L discussion
list, I apologize for the cross-posting).

Bryce Fields
Web Developer
Kentucky Virtual University
http://www.kyvu.org/ <http://www.kyvu.org/>;

1-877-740-4357
1-502-573-1555 ext 288

"Do or do not. There is no try." -- Yoda


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From: Paul Bohman
Date: Thu, Sep 04 2003 10:00AM
Subject: RE: Section 508 Standards Compliance and Scripts
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Bryce Fields wrote:
"[if a product claims that it] 'uses only minimal dynamic scripting for
content presentation...[and that the content] is written to the screen
before the page loads, and can't be distinguished from standard content.'
... How can this be considered compliance w/ 508???"

My response:

Here is what Section 508 actually states, with regard to client-side
scripting:

"When pages utilize scripting languages to display content, or to create
interface elements, the information provided by the script shall be
identified with functional text that can be read by assistive technology."

According to Section 508, then, client-side scripting is not automatically
"bad." As long as the scripts can be "read by assistive technology," it is
fully in compliance with Section 508.

Of course, this requirement is sufficiently vague to allow for all kinds of
confusion (for example, do *all* kinds and *all* brands of assistive
technologies have to be able to access the scripts?) But since we can't
change the way it's worded, we have to look at how to implement it as best
we can.

The developers of the product you're concerned about actually understand
Section 508 and JavaScript quite well, from what you've quoted of their
compliance claims. Here's the logic behind what they're saying:

- The first premise is that the most prevalent "assistive technology" that
is potentially affected by inaccessible JavaScript is the screen reader, so
they're concerned about making content accessible to screen readers. NOTE:
There are also screen enlargers, keyboard emulators, and many other kinds of
assistive technologies, but screen readers are the biggest concern here. You
could argue that keyboard accessibility is also a big concern with
JavaScript, which is true, but the keyboard is not generally considered an
assistive technology. So if we take the most literal and most practical
interpretation of Section 508, we're most concerned about making JavaScript
accessible to screen readers.

- The second premise is that the major brands of screen reader (i.e. JAWS
and Window Eyes) support some types of JavaScript. In the case of content
being written to the page "before" the page loads, both screen readers
support this functionality. NOTE: They vendor's choice of wording leaves
some room for debate. It's probably more accurate to say that the JavaScript
writes content to the page *AS* the page is being written, but the end
result is essentially the same: By the time the page is finished loading,
the JavaScript is finished. The script has written its content to the page
and no additional JavaScript is necessary. The screen readers will read this
text as if it were written with plain old HTML (without JavaScript).

- The conclusion is that they can use certain types of JavaScript without
violating Section 508:

IF
JavaScript must be accessible to screen readers (IN ORDER TO comply with
Section 508)
AND IF
certain types of JavaScript are accessible to screen readers
THEN
We can use those certain types of JavaScript and still comply with Section
508.

So, from both a legal and technical perspective, I'd say that they are on
firm ground. But what if someone has JavaScript turned off? Or what if
someone is using an assistive technology that doesn't support that kind of
JavaScript? If either of these conditions exist, then the content will be
inaccessible. No question about it. However, if someone has turned off
JavaScript, then the user has chosen to turn it off. It is a matter of
personal preference. The user chose to make all JavaScript content
inaccessible. In the case of assistive technologies that do not support
JavaScript, the vendor could argue that this too was the user's choice,
since more robust assistive technologies are available. Of course,
considering the price of full-featured screen readers, it may be that the
user can't afford the more robust product, but this is something beyond the
vendor's control. From their perspective, they've done what Section 508
requires, even though a small minority of users will still find the content
inaccessible.

This whole scenario is an example of how Section 508 is not the full picture
of what is required to make content truly accessible to all audiences. There
are limitations in the law.

At the same time, I would argue that the concept of making content "truly
accessible to all audiences" is an unachievable goal on the conceptual
level. No matter how hard you try, you can always come up with rare
exceptions that ruin your hopes of perfect accessibility. We should try our
best to approach that goal. Definitely. But there are still real limits as
to what is actually possible.

Paul Bohman
Technology Coordinator
WebAIM (Web Accessibility in Mind)
www.webaim.org
Center for Persons with Disabilities
www.cpd.usu.edu
Utah State University
www.usu.edu



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From: Joel Ward
Date: Thu, Sep 04 2003 10:05AM
Subject: Re: Section 508 Standards Compliance and Scripts
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> All an end user receives is a one sentence message stating that the page
> won't work w/ JavaScript disabled, and no other means to access the course
> is provided. How can this be considered compliance w/ 508???
> I just want to make sure I'm not missing anything. And TIA for all
> comments. (And to anyone who also subscribes to the Webdesign-L
discussion
> list, I apologize for the cross-posting).

In my experience, to be Section 508 compliant you may be able to require
that Javascript be enabled. Like Jon said, that may be Officially 508
Compliant but not fully accessible to all users.

It depends on your audience and what you really want the site to accomplish.
If you are a public site, requiring Javascript is a bad idea because there's
more of a chance you will have users with scripting turned off. If you are
an internal site, you may be able to get away with it because your
institution has all browsers Javascript-enabled.

In the Spirit of the Law, it's best to make your site compatible with users
that have scripting turned off. However, you can probably argue it is
compliant even if it does require Javascript.






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From: Christopher Phillips
Date: Tue, Sep 16 2003 11:10AM
Subject: Accessible Calendar/ CMS?
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A couple of questions...

I am looking for an accessible web-based group calendar program where
users can submit events and view events submitted by others. PHP/MySQL
preferred, but we're flexible.

Also, I am looking for an accessible open source CMS and have been
referred to xaraya and plone- does anyone have any experience with
either of these or know of any other alternatives?

Lastly, I have had private discussions with some of you on this list
regarding the development of an accessible message board. For those of
you who are interested it looks like phpbb will likely have an
accessible, fully xhtml/css compliant style (template). If you're
interested you can read more about it here:
http://www.accessifyforum.com/viewtopic.php?t=249

Thanks much,
Christopher Phillips
Institute for Community Inclusion
www.communityinclusion.org


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