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Thread: Remediation Delayed
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From: Peter Shikli
Date: Sun, Jun 30 2019 11:09AM
Subject: Remediation Delayed
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This question is a mix of technical and legal related to accessibility.
We have more than one government agency client that has web pages and
PDF documents that can be properly remediated to WCAG 2.0 level AA, but
with links or attachments that are many, poor-quality image scans of
documents whose source has long since disappeared. Because our holding
company builds backend website applications, we could offer these
agencies the following solution:
1) The main web page or PDF goes online accessible.
2) The web page links or PDF attachments are replaced by a short,
accessible form to request either the current, inaccessible images or
their remediated versions.
   a) In the first case, the inaccessible images are displayed
immediately.
   b) In the second case, the remediation request is dropped into a
work order between the agency and my company.
3) In the case of remediation (2.b above), the images are OCR'd,
remediated, and posted online to replace the above request form. And the
requester is advised with an email containing a link to the subject web
page or PDF that is then completely accessible.
Our analysts have broken into two camps. The one I call "Purists" say
providing option 2.a above violates WCAG because it leads to
inaccessible content. The other "Pragmatic" camp takes the position
that WCAG allows for inaccessible content as long as an identical
accessible version is available, in this case, a few days after the
request. The "Pragmatists" also raise considerations of the client's
budget and capacity, but I would like to ask the community to weigh in
without those factors.
Does the above approach comply to the spirit and words of WCAG and the W3C?
Cheers,
Peter Shikli
Access2online
From: Ryan E. Benson
Date: Sun, Jun 30 2019 4:01PM
Subject: Re: Remediation Delayed
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If the agencies in question are federal, I would request a formal sit down
with the Section 508 coordinator. I haven't read your plans yet, but if the
agency is federal you really need the 508 coordinator's blessing before
moving on whatever plan. This will need an exception granted, which in most
agencies, only the coordinator can approve.
Next, given that the sources are gone, I am guessing the are older files,
some people want files up to share with people, others must have them up
for legal reasons. After covering what it would take to get that 10-50 year
old file accessible, is no longer that necessary.
If the content is required to be online, we either make the owner put a
notice on an entry page that says saying the files are not accessible, and
if you need an accessible version, please contact {POC for the Program},
or we may add an additional requirement of having the Program develop a
schedule to make everything accessible. I have approved some that were a
few months, and one that were 5 years. it comes down to the specifics of
the situation.
--
Ryan E. Benson
On Sun, Jun 30, 2019 at 1:20 PM Peter Shikli < = EMAIL ADDRESS REMOVED = > wrote:
> This question is a mix of technical and legal related to accessibility.
>
> We have more than one government agency client that has web pages and
> PDF documents that can be properly remediated to WCAG 2.0 level AA, but
> with links or attachments that are many, poor-quality image scans of
> documents whose source has long since disappeared. Because our holding
> company builds backend website applications, we could offer these
> agencies the following solution:
>
> 1) The main web page or PDF goes online accessible.
>
> 2) The web page links or PDF attachments are replaced by a short,
> accessible form to request either the current, inaccessible images or
> their remediated versions.
> a) In the first case, the inaccessible images are displayed
> immediately.
> b) In the second case, the remediation request is dropped into a
> work order between the agency and my company.
>
> 3) In the case of remediation (2.b above), the images are OCR'd,
> remediated, and posted online to replace the above request form. And the
> requester is advised with an email containing a link to the subject web
> page or PDF that is then completely accessible.
>
> Our analysts have broken into two camps. The one I call "Purists" say
> providing option 2.a above violates WCAG because it leads to
> inaccessible content. The other "Pragmatic" camp takes the position
> that WCAG allows for inaccessible content as long as an identical
> accessible version is available, in this case, a few days after the
> request. The "Pragmatists" also raise considerations of the client's
> budget and capacity, but I would like to ask the community to weigh in
> without those factors.
>
> Does the above approach comply to the spirit and words of WCAG and the W3C?
>
> Cheers,
> Peter Shikli
> Access2online
>
> > > > >
From: Tim Harshbarger
Date: Mon, Jul 01 2019 2:48AM
Subject: Re: Remediation Delayed
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Having the alternative accessible content available at the same time the inaccessible content is available is probably more in keeping with the spirit of WCAG 2.0. Yet, the agencies involved are likely using WCAG 2.0 as part of a process to comply with a law. Most of those laws include some kind of language for a situation like this.
My suggestion would be to discuss the legal obligations and technical requirements with the agencies. One reason for that is they are the ones most likely to be held accountable for any interpretation they make of their legal obligations.
Thanks!
Tim Harshbarger