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From: Alan Zaitchik
Date: Thu, Sep 13 2018 1:37PM
Subject: Lists without labels in PDFs
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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

From: chagnon
Date: Thu, Sep 13 2018 1:53PM
Subject: Re: Lists without labels in PDFs
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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 ADDRESS REMOVED =
- - -
PubCom: Technologists for Accessible Design + Publishing
consulting . training . development . design . sec. 508 services
Upcoming classes at www.PubCom.com/classes
- - -
Latest blog-newsletter - Accessibility Tips at www.PubCom.com/blog

From: Duff Johnson
Date: Thu, Sep 13 2018 2:06PM
Subject: Re: Lists without labels in PDFs
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> IIRC from memory, PDF/UA-1 does not require the LBL tag on list items. Only
> the LBody tag.

PDF/UA-1 only requires <Lbl> tags if there a label is present.

If the list-items do not include labels, there's nothing to tag with <Lbl>, so such elements are not required.

> 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!

As above, this is already addressed in PDF/UA-1. If there's no label, there's nothing to tag with a <Lbl> element.

> -- 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.

Yes. There is no substitute for actually implementing the specification.

Duff.

From: Philip Kiff
Date: Thu, Sep 13 2018 2:30PM
Subject: Re: Lists without labels in PDFs
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On 2018-09-13 3:37 PM, Alan Zaitchik wrote:
> 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?

Neither JAWS nor NVDA need to have list label <Lbl> tags present to read
a list smoothly in a PDF. When reading "line-by-line" using cursor keys,
JAWS inserts a pause between each <Lbl> and <LBody> tag requiring a new
keypress each time. In a list with no <Lbl> tags present, it just pauses
between one <LBody> and the next. If I recall correctly, NVDA handles
this better by reading the <Lbl> content without pausing in most cases,
thereby saving the user from having to keep clicking on the cursor at
each appearance of a bullet.

Phil.

--
Philip Kiff
D4K Communications

From: Ryan E. Benson
Date: Thu, Sep 13 2018 3:22PM
Subject: Re: Lists without labels in PDFs
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Hi I can address this in a few days from a hhs view. I am located in NC, so
I can address after the hurricane.

Ryan E. Benson

On Thu, Sep 13, 2018, 15:37 Alan Zaitchik < = EMAIL ADDRESS REMOVED = > wrote:

> 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
>
> > > > >