E-mail List Archives
Thread: PDF forms
Number of posts in this thread: 10 (In chronological order)
From: McDonald, Jennifer
Date: Tue, Aug 16 2011 2:27PM
Subject: PDF forms
No previous message | Next message →
I'm trying to prioritize my PDF accessibility updates and I'm wondering
if anyone know of any requirement (Section 508) to add form fields to
PDF files that serve a purpose to print and mail. We are currently
tagging and making other updates to forms that previously contained no
form fields. We would like to add those later to aid people in filling
out the form before printing, but adding those fields is just not in
scope at the moment.
Thanks for any info!
Jeni
--------------------------------------------------------------------------------
The information contained in this communication may be confidential, is intended
only for the use of the recipient(s) named above, and may be legally
privileged. If the reader of this message is not the intended recipient, you
are hereby notified that any dissemination, distribution, or copying of this
communication, or any of its contents, is strictly prohibited. If you have
received this communication in error, please notify the sender immediately and
destroy or delete the original message and any copy of it from your computer
system. If you have any questions concerning this message, please contact the
sender.
================================================================================
From: Karlen Communications
Date: Tue, Aug 16 2011 2:42PM
Subject: Re: PDF forms
← Previous message | Next message →
Even if a form is to be printed and mailed, adding form controls means that someone with learning, cognitive or visual disabilities can independently fill out the form, print it and send it in.
Form controls in Section 508 are covered in provision N.
Recommend to clients faced with legacy content to work on what is currently being used be customers/ clients, begin creating new content to the standards, and make legacy content accessible as it is needed.
Cheers, Karen
Out of Office, Sent from my iPad
On 2011-08-16, at 4:27 PM, "McDonald, Jennifer" < = EMAIL ADDRESS REMOVED = > wrote:
> I'm trying to prioritize my PDF accessibility updates and I'm wondering
> if anyone know of any requirement (Section 508) to add form fields to
> PDF files that serve a purpose to print and mail. We are currently
> tagging and making other updates to forms that previously contained no
> form fields. We would like to add those later to aid people in filling
> out the form before printing, but adding those fields is just not in
> scope at the moment.
>
> Thanks for any info!
>
> Jeni
>
> --------------------------------------------------------------------------------
> The information contained in this communication may be confidential, is intended
> only for the use of the recipient(s) named above, and may be legally
> privileged. If the reader of this message is not the intended recipient, you
> are hereby notified that any dissemination, distribution, or copying of this
> communication, or any of its contents, is strictly prohibited. If you have
> received this communication in error, please notify the sender immediately and
> destroy or delete the original message and any copy of it from your computer
> system. If you have any questions concerning this message, please contact the
> sender.
> ===============================================================================>
From: Bourne, Sarah (ITD)
Date: Tue, Aug 16 2011 2:51PM
Subject: Re: PDF forms
← Previous message | Next message →
Jeni,
Although the intent is to "print and mail", is another, accessible process available? If not, then the form should probably be tagged. Even if a person needs assistance with the printing and mailing part, they should be to at least know what the form is asking for so they can request assistance from someone with an adequate trust level.
And even that may not be considered to be enough by itself. In Massachusetts, the Disability Policy Consortium filed a suit against the MA Executive Office of Health and Human Services and its MassHealth program in the US District Court over exactly this issue. If I'm reading the documents correctly, it was for violation of ADA, Title II, and Section 504, rather than 508, because those are the ones applicable to state (and local) government. (See article "Disabled sue state agency for forms" from the July 27, 2011, Boston Globe: http://articles.boston.com/2011-07-27/news/29821350_1_disabled-residents-americans-with-disabilities-act-plaintiffs ) I'm not a lawyer, so I don't know enough to advise you on how this would translate to federal agencies.
sb
Sarah E. Bourne
Director of Assistive Technology &
Mass.Gov Chief Technology Strategist
Information Technology Division
Commonwealth of Massachusetts
1 Ashburton Pl. rm 1601 Boston MA 02108
617-626-4502 fax 617-626-4516
http://twitter.com/sarahebourne
= EMAIL ADDRESS REMOVED =
http://www.mass.gov/itd
-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of McDonald, Jennifer
Sent: Tuesday, August 16, 2011 4:28 PM
To: WebAIM Discussion List
Subject: [WebAIM] PDF forms
I'm trying to prioritize my PDF accessibility updates and I'm wondering if anyone know of any requirement (Section 508) to add form fields to PDF files that serve a purpose to print and mail. We are currently tagging and making other updates to forms that previously contained no form fields. We would like to add those later to aid people in filling out the form before printing, but adding those fields is just not in scope at the moment.
Thanks for any info!
Jeni
--------------------------------------------------------------------------------
The information contained in this communication may be confidential, is intended only for the use of the recipient(s) named above, and may be legally privileged. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication, or any of its contents, is strictly prohibited. If you have received this communication in error, please notify the sender immediately and destroy or delete the original message and any copy of it from your computer system. If you have any questions concerning this message, please contact the sender.
================================================================================
From: Ryan E. Benson
Date: Wed, Aug 17 2011 6:33PM
Subject: Re: PDF forms
← Previous message | Next message →
If the intent of the form is to fill out and print - to be the most
accessible you should make the form fillable via whatever program they
use. I don't know of anything in Section 508 that says if the pdf is a
form it must have fields. However if the PDF does have fields, they
must be accessible.
--
Ryan E. Benson
On Tue, Aug 16, 2011 at 4:27 PM, McDonald, Jennifer < = EMAIL ADDRESS REMOVED = > wrote:
> I'm trying to prioritize my PDF accessibility updates and I'm wondering
> if anyone know of any requirement (Section 508) to add form fields to
> PDF files that serve a purpose to print and mail. We are currently
> tagging and making other updates to forms that previously contained no
> form fields. We would like to add those later to aid people in filling
> out the form before printing, but adding those fields is just not in
> scope at the moment.
>
> Thanks for any info!
>
> Jeni
>
> --------------------------------------------------------------------------------
> The information contained in this communication may be confidential, is intended
> only for the use of the recipient(s) named above, and may be legally
> privileged. If the reader of this message is not the intended recipient, you
> are hereby notified that any dissemination, distribution, or copying of this
> communication, or any of its contents, is strictly prohibited. If you have
> received this communication in error, please notify the sender immediately and
> destroy or delete the original message and any copy of it from your computer
> system. If you have any questions concerning this message, please contact the
> sender.
> ===============================================================================>
From: Duff Johnson
Date: Wed, Aug 17 2011 9:00PM
Subject: Re: PDF forms
← Previous message | Next message →
On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
> If the intent of the form is to fill out and print - to be the most
> accessible you should make the form fillable via whatever program they
> use.
Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
> I don't know of anything in Section 508 that says if the pdf is a
> form it must have fields.
From:
http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
---------
Subpart B - Technical Standards
SubSection 1194.21 Software applications and operating systems.
(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
----------
This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
> However if the PDF does have fields, they
> must be accessible.
Absolutely - once you have a fillable form (see above), the form elements must be accessible.
Duff Johnson
p +1.617.283.4226
e = EMAIL ADDRESS REMOVED =
t http://www.twitter.com/duffjohnson
w http://www.duff-johnson.com
From: Ryan E. Benson
Date: Wed, Aug 17 2011 9:24PM
Subject: Re: PDF forms
← Previous message | Next message →
Nice Duff, I didn't connect .21 to PDFs/documents - but that is totally valid.
--
Ryan E. Benson
On Wed, Aug 17, 2011 at 11:01 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
> On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
>
>> If the intent of the form is to fill out and print - to be the most
>> accessible you should make the form fillable via whatever program they
>> use.
>
> Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
>
> In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
>
> In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
>
>> I don't know of anything in Section 508 that says if the pdf is a
>> form it must have fields.
>
> From:
>
> http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
>
> ---------
> Subpart B - Technical Standards
> SubSection 1194.21 Software applications and operating systems.
>
> (l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
> ----------
>
> This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
>
> If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
>
> I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
>
>> However if the PDF does have fields, they
>> must be accessible.
>
> Absolutely - once you have a fillable form (see above), the form elements must be accessible.
>
> Duff Johnson
>
> p +1.617.283.4226
> e = EMAIL ADDRESS REMOVED =
> t http://www.twitter.com/duffjohnson
> w http://www.duff-johnson.com
>
>
From: Andrew Kirkpatrick
Date: Wed, Aug 17 2011 9:45PM
Subject: Re: PDF forms
← Previous message | Next message →
Uh... 22n?
Thanks,
AWK
Andrew Kirkpatrick
Group Product Manager, Accessibility
Adobe Systems
= EMAIL ADDRESS REMOVED =
http://twitter.com/awkawk
http://blogs.adobe.com/accessibility
-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Duff Johnson
Sent: Wednesday, August 17, 2011 11:02 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] PDF forms
On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
> If the intent of the form is to fill out and print - to be the most
> accessible you should make the form fillable via whatever program they
> use.
Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
> I don't know of anything in Section 508 that says if the pdf is a form
> it must have fields.
From:
http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
---------
Subpart B - Technical Standards
SubSection 1194.21 Software applications and operating systems.
(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
----------
This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
> However if the PDF does have fields, they must be accessible.
Absolutely - once you have a fillable form (see above), the form elements must be accessible.
Duff Johnson
p +1.617.283.4226
e = EMAIL ADDRESS REMOVED =
t http://www.twitter.com/duffjohnson
w http://www.duff-johnson.com
From: Duff Johnson
Date: Wed, Aug 17 2011 9:51PM
Subject: Re: PDF forms
← Previous message | Next message →
Andrew,
The first clause of .22(n) is weasel-wordage that can (and has) been used (by some) to leave PDF forms tagged (yes), but unfillable.
That's why I prefer a ref. to .21(l) in this case.
...go back to the Tequila, ya snark! ;-)
Duff.
On Aug 17, 2011, at 11:42 PM, Andrew Kirkpatrick wrote:
> Uh... 22n?
>
> Thanks,
> AWK
>
> Andrew Kirkpatrick
> Group Product Manager, Accessibility
> Adobe Systems
>
> = EMAIL ADDRESS REMOVED =
> http://twitter.com/awkawk
> http://blogs.adobe.com/accessibility
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Duff Johnson
> Sent: Wednesday, August 17, 2011 11:02 PM
> To: WebAIM Discussion List
> Subject: Re: [WebAIM] PDF forms
>
> On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
>
>> If the intent of the form is to fill out and print - to be the most
>> accessible you should make the form fillable via whatever program they
>> use.
>
> Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
>
> In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
>
> In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
>
>> I don't know of anything in Section 508 that says if the pdf is a form
>> it must have fields.
>
> From:
>
> http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
>
> ---------
> Subpart B - Technical Standards
> SubSection 1194.21 Software applications and operating systems.
>
> (l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
> ----------
>
> This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
>
> If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
>
> I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
>
>> However if the PDF does have fields, they must be accessible.
>
> Absolutely - once you have a fillable form (see above), the form elements must be accessible.
>
> Duff Johnson
>
> p +1.617.283.4226
> e = EMAIL ADDRESS REMOVED =
> t http://www.twitter.com/duffjohnson
> w http://www.duff-johnson.com
>
>
From: Andrew Kirkpatrick
Date: Wed, Aug 17 2011 9:57PM
Subject: Re: PDF forms
← Previous message | Next message →
Sorry, that was a bit snarky and sent before complete. Suffice it to say, I believe that 1194.22n also applies to PDF forms, in some cases more so than anything in 1194.21. I'm checking email on vacation and probably should just go back to the vacation!
Thanks,
AWK
Andrew Kirkpatrick
Group Product Manager, Accessibility
Adobe Systems
= EMAIL ADDRESS REMOVED =
http://twitter.com/awkawk
http://blogs.adobe.com/accessibility
-----Original Message-----
From: Andrew Kirkpatrick
Sent: Wednesday, August 17, 2011 11:43 PM
To: 'WebAIM Discussion List'
Subject: RE: [WebAIM] PDF forms
Uh... 22n?
Thanks,
AWK
Andrew Kirkpatrick
Group Product Manager, Accessibility
Adobe Systems
= EMAIL ADDRESS REMOVED =
http://twitter.com/awkawk
http://blogs.adobe.com/accessibility
-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Duff Johnson
Sent: Wednesday, August 17, 2011 11:02 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] PDF forms
On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
> If the intent of the form is to fill out and print - to be the most
> accessible you should make the form fillable via whatever program they
> use.
Just as a documents are for reading (an unstated but nonetheless very real presumption in Section 508), forms are for "filling". Ipso facto, forms must be fillable by users who must use AT.
In the case of a form in PDF format, that would indicate that form-fields are required in order for the form to comply. A form in (for example) TIF format would not be acceptable, because it cannot be made fillable by an AT user, and thus, cannot comply.
In any event, so far, I think of this approach as the strictly-correct model for forms. I'm curious to know if it gets up anyone's nose, or conversely, seems obvious... (and I may have bothered this list on this same question before).
> I don't know of anything in Section 508 that says if the pdf is a form
> it must have fields.
From:
http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
---------
Subpart B - Technical Standards
SubSection 1194.21 Software applications and operating systems.
(l) When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
----------
This text (while appearing - unaccountably - in the "software applications" section), seems pretty clear to me that if you deliver an "electronic form" for "use" it has to be fillable. There's no provision for intention, so claiming intent to deliver "only" a "fill with a quill" form doesn't address the requirement.
If end-users are expected to "fill" the form at all, it should be a AT-usable fillable form.
I think the regulation is clear, and the answer is: PDF forms (because they are "electronic forms") must be fillable to qualify for Section 508 conformance. Any dissent on that?? (I really want to know).
> However if the PDF does have fields, they must be accessible.
Absolutely - once you have a fillable form (see above), the form elements must be accessible.
Duff Johnson
p +1.617.283.4226
e = EMAIL ADDRESS REMOVED =
t http://www.twitter.com/duffjohnson
w http://www.duff-johnson.com
From: McDonald, Jennifer
Date: Thu, Aug 18 2011 9:15AM
Subject: Re: PDF forms
← Previous message | No next message
Thanks everyone. This is the sort of conversation I needed.
Jeni
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Duff Johnson
Sent: Wednesday, August 17, 2011 10:02 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] PDF forms
On Aug 17, 2011, at 8:33 PM, Ryan E. Benson wrote:
> If the intent of the form is to fill out and print - to be the most
> accessible you should make the form fillable via whatever program they
> use.
Just as a documents are for reading (an unstated but nonetheless very
real presumption in Section 508), forms are for "filling". Ipso facto,
forms must be fillable by users who must use AT.
In the case of a form in PDF format, that would indicate that
form-fields are required in order for the form to comply. A form in (for
example) TIF format would not be acceptable, because it cannot be made
fillable by an AT user, and thus, cannot comply.
In any event, so far, I think of this approach as the strictly-correct
model for forms. I'm curious to know if it gets up anyone's nose, or
conversely, seems obvious... (and I may have bothered this list on this
same question before).
> I don't know of anything in Section 508 that says if the pdf is a form
> it must have fields.
From:
http://www.section508.gov/index.cfm?fuseAction=stdsdoc#Software
---------
Subpart B - Technical Standards
SubSection 1194.21 Software applications and operating systems.
(l) When electronic forms are used, the form shall allow people using
assistive technology to access the information, field elements, and
functionality required for completion and submission of the form,
including all directions and cues.
----------
This text (while appearing - unaccountably - in the "software
applications" section), seems pretty clear to me that if you deliver an
"electronic form" for "use" it has to be fillable. There's no provision
for intention, so claiming intent to deliver "only" a "fill with a
quill" form doesn't address the requirement.
If end-users are expected to "fill" the form at all, it should be a
AT-usable fillable form.
I think the regulation is clear, and the answer is: PDF forms (because
they are "electronic forms") must be fillable to qualify for Section 508
conformance. Any dissent on that?? (I really want to know).
> However if the PDF does have fields, they must be accessible.
Absolutely - once you have a fillable form (see above), the form
elements must be accessible.
Duff Johnson
p +1.617.283.4226
e = EMAIL ADDRESS REMOVED =
t http://www.twitter.com/duffjohnson
w http://www.duff-johnson.com