PDF/UA and Section 508. Karen McCall Karlen Communications Copyright 2015

Transcription

1 PDF/UA and Section 508 Karen McCall Karlen Communications Copyright 2015

2 What NPRM Section 508 Says 1 Page 12 talks about alternate formats: The proposed guidelines also would require documentation in electronic formats including Web-based self-service support and electronic documents to conform to all Level A and AA Success Criteria in WCAG 2.0 or ISO (PDF/UA-1). Page 38 talking about comparable access. Phrasing becomes equal access. So, for example, if a federal agency posts a PDF version of a recent settlement agreement on its website as part of a press release, that document would need to comply with PDF/UA-1.

3 What NPRM Section 508 Says 2 Also on page 38: The proposed rule would address these deficiencies in the existing 508 Standards by clearly delineating the scope of covered electronic content, as well as specifying concrete, testable, technical requirements to ensure the accessibility of such content. The Board proposes that all covered electronic content would be required to conform to WCAG 2.0 Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages or, where applicable, ISO (PDF/UA-1).

4 What NPRM Section 508 Says 3 Page 39 talking about non-public facing content: Proposed E205.3 would require an agency s non-public facing electronic content to meet the accessibility requirements in the proposed rule (i.e., WCAG 2.0 Level A and Level AA Success Criteria or PDF/UA-1) when such content (a) constitutes agency official business, and (b) falls within one or more of eight categories of communication. Coverage would extend to all forms of content constituting official communications by agencies, including Web pages, postings on social media, s, and electronic documents. The Board believes that this approach strikes an appropriate balance in ensuring the accessibility of essential electronic content for persons with disabilities, while also tempering agency compliance obligation

5 What NPRM Section 508 Says 4 Page 64, E102.6 ISO: This is an international standard for accessible portable document format (PDF) files. PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation, and validation of PDF content to ensure accessibility for people with disabilities who use assistive technology such as screen readers, screen magnifiers, joysticks and other assistive technologies to navigate and read content. This proposed standard is new to both the 508 Standards and the 255 Guidelines. It is offered as an option to WCAG 2.0 for accessible PDFs.

6 What NPRM Section 508 Says 5 Page 68 revises the definition of ICT: Using a common term that is applicable to both the 508 Standards and 255 Guidelines supports one of the central goals of this rulemaking namely, development of a single set of comprehensive requirements for two substantive areas that are inseparable from regulatory and policy perspectives. Additionally, to address confusion regarding application of the existing 508 Standards to electronic documents, the proposed ICT definition expressly clarifies that electronic content such as Web pages and PDFs falls within the definition of ICT. Lastly, this newly defined term provides an updated set of illustrative examples that better reflect today s technologies.

7 What NPRM Section 508 Says 6 Page 74, public facing content: In turn, proposed E205 requires conformance to the Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 or ISO (PDF/UA-1), both of which are incorporated by reference in 508 Chapter 1 and 255 Chapter 1. Exception for non-public maintained by the National Archives and Records Administration (NARA.

8 What NPRM Section 508 Says 7 Page 75, public facing content: This section proposes that all public-facing content must meet the accessibility requirements in E205.4, which, in turn, requires conformance to WCAG 2.0 Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages or, where applicable, ISO (PDF/UA-1). Content regardless of form or format including draft electronic documents would be covered under this proposed section when public facing.

9 What NPRM Section 508 Says 8 Continuing page 75: This section proposes that an agency s non-public facing content be required to meet the accessibility requirements in E205.4 (i.e., WCAG 2.0 Level A and Level AA Success Criteria or PDF/UA-1) when such content (a) constitutes agency official business, and (b) falls within one or more of eight categories of communication. The eight proposed categories are: (1) emergency notifications; (2) initial or final decisions adjudicating administrative claims or proceedings; (3) internal or external program or policy announcements; (4) notices of benefits, program eligibility, employment opportunities or personnel actions; (5) formal acknowledgements or receipts; (6) questionnaires or surveys; (7) templates or forms; and (8) educational or training materials.

10 What NPRM Section 508 Says 9 Page 76, draft content: Draft content would, however, fall within the ambit of proposed E205.3 (and, therefore, be required to conform to WCAG 2.0 or PDF/UA-1) when an agency intends a draft to be final in the sense that it is being formally disseminated or published for input or comment by its intended audience. draft policy memorandum by to the office of human resources for review, neither the nor draft memorandum would be covered However, if instead, the agency task force had completed its draft policy on telecommuting and circulated the draft policy as an attachment sent to all agency employees soliciting their input and comments, then both the and attached draft policy memorandum regardless of format (e.g., word processing document, PDF) would be covered by this section and, accordingly, need to satisfy the accessibility requirements in E205.4.

11 What NPRM Section 508 Says 10 Page 84, C203.1 General The section proposes to require content integral to the use of covered ICT to conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 or ISO (PDF/UA- 1), both of which are incorporated by reference in 255 Chapter 1.

12 What NPRM Section 508 Says 11 Page 123, General: These proposals for accessible support documentation are derived from and of the existing 508 Standards and 255 Guidelines respectively, but the requirement that electronic documentation comply with WCAG 2.0 or PDF/UA-1 would be new to both the standards and the guidelines.

13 What NPRM Section 508 Says 12 Page 124, Electronic Support Documentation: This section proposes to require documentation in electronic formats including Web-based self-service support and electronic documents to conform to all Level A and AA Success Criteria and Conformance Requirements in WCAG 2.0 or ISO (PDF/UA-1), which are each incorporated by reference in 508 Chapter 1 and 255 Chapter 1.

14 What NPRM Section 508 Says 13 Page 135: Question 38. The proposed rule would, among other things, require federal agency websites and electronic content to conform to WCAG 2.0 or PDF/UA-1. Do federal agencies believe that the Preliminary RIA adequately captures their potential costs to comply with these requirements? If not, how might the analysis be improved? Are there significant cost elements missing from the Preliminary RIA? Please be as specific as possible.

15 What NPRM Section 508 Says 14 Page 145, support documents: These four proposed information collection requirements are generally similar to those under existing 255 Guidelines , which were previously reviewed and approved by the Office of Management and Budget (OMB) in accordance with the PRA (OMB Control Number ), though compliance with WCAG 2.0 (or PDF/UA-1) is new. The newly proposed information collection is the requirement that telecommunications equipment manufacturers ensure that any electronic documentation (such as web-based self-service support or PDF user guides) provided to end users must meet specified accessibility standards (602.3).

16 What NPRM Section 508 Says 15 Page 146, Section 602.3: : Section 602.3: The estimated response time assumes that development of accessible electronic support documentation will take 300 hours for each new product. This estimate, in turn, is based on the assumption that each product will have, on average, 200 pages of electronic documentation, and that each page will require 1.5 hours of formatting and editing to comply with WCAG 2.0 or PDF/UA-1, as applicable.

17 What NPRM Section 508 Says 16 Page 149, overview of ISO PDF related standards: PDF/UA-1 provides a technical, interoperable standard for the authoring, remediation and validation of PDF content to ensure accessibility for people with disabilities who use assistive technology, such as screen readers, screen magnifiers, joysticks and other technologies used to navigate and read electronic content.

18 What NPRM Section 508 Says 17 Page 165, E205.4 Accessibility Standards. : Content shall conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1) or, where applicable, ISO (PDF/UA-1) (incorporated by reference in Chapter 1).

19 What NPRM Section 508 Says 18 Page 176, C203 Electronic Content : C203.1 General. Regardless of the medium or the method of transmission and storage, electronic content integral to the use of ICT shall conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0 (incorporated by reference in Chapter 1) or ISO (PDF/UA-1) (incorporated by reference in Chapter 1).

20 Just when you thought it was clear! Page 176, continued: Advisory C203.1 General. WCAG is written to be technology neutral. While oriented towards web pages which are defined as being delivered using HTTP, the WCAG 2.0 Success Criteria and Conformance Requirements can be applied to all electronic content. Guidance can be found at Page 203 reaffirms support document accessibility to WCAG or PDF/UA.

21 PDF/UA What is it and how do we implement it?

22 PDF/UA Combines the three components of accessing PDF documents into a technical specification: The PDF document itself must be accessible to PDF/UA. The viewer/reader must be accessible to PDF/UA. The adaptive technology must be able to access the document contents and the viewer/reader to PDF/UA. If any one of these components is missing, there is no PDF/UA compliance. Can have a document identifier stating that the document is PDF/UA compliant which might help in identifying where barriers are.

23 What PDF/UA Means to Us There is a consistency of experience and expectation when a PDF document is opened. Greater access to educational material, employment based material including employment forms, and any PDF document. We need to understand the results of the technical specifications and when asked what do you mean by an accessible PDF we must answer PDF/UA compliance.

24 Elements of a PDF/UA Compliant Document For our purposes in advocacy: The document must have Tags. The Tags must be correct for the type of content. Tags must be in a logical reading order (which might not be the order in which content appears on the page, i.e., brochures). Headings as navigational structures must be sequential and you can t skip a level. Bookmarks mirror Headings. Alt text for images. Decorative images are Artifacts. There is a core language for the document and Multilanguage documents have language attributes on Tags for the changes in language..

25 Authors and Publishers The document author or publisher determines the format of publication. It can be epub, HTML and/or PDF. No matter which format content is published in, it must be accessible to international and/or country specific legislation. One format isn t better for those of us with disabilities than another. We have to stop the skirmishes over what is best for them and focus on ensuring any format of content is accessible to international standards. As people with disabilities we have the right to choose which format that is available to us we want to access/read.

26 Choice! One of the premises of accessible document design and access to content is that the end-user is able to choose how they view and interact with content. This concept has been around since 2001 or earlier. Toward that goal, if someone accesses a PDF, epub or HTML document, they should have the tools to convert that document to the format of their choice. Choice can be based on device, weather, built or open space environment, or the need to have content explained or presented in a different format to facilitate understanding. Print content now has choice: print, audiobook or e-text and Amazon has a link so you can start reading e-text and switch to an Audible took without losing your place.

27 Alternate Text Production Centres How much time would be saved if Students didn t have to buy 2 copies of a text? Students could access digital text at the point of purchase? IF a student required alternate format, the PDF that arrived could easily be converted to the other format using File, Save As? Students could keep their digital books for reference and not have to return it at the end of a semester. We could empower students by giving them the tools to convert to a preferred format. We don t have to create differently accessible content. If we do have to create differently accessible content, why create accessible content in the first place?

28 Blended Model of Remediation Not all PDF documents have to be accessible by midnight. There are services that facilitate an on-demand compliant remediation of PDF documents. There are services that do high volume remediation of PDF to compliance. There are tools to do it yourself. Need to take a look at how many PDF have to be PDF/UA compliant, what are staffing and financial resources and how to meet goals and compliance. Use staff and outsourcing in combination.

29 Incheon Strategy Incheon Strategy to Make the Right Real which is the Asia and Pacific Region strategy to implement the Convention on the Rights of People with Disabilities. Goal 3: Enhance access to the physical environment, public transportation, knowledge, information and communication One of the problems with specifying a version of a standard is that by the time legislation is passed, a new version has been published. We are in the process of finalizing PDF/UA 2 and begin working on PDF/UA 3. I would also think that WCAG 3 is being worked on. 34. Proportion of accessible and usable public documents and websites that meet internationally recognized accessibility standards.

30 Resources For more reading on PDF/UA and Section 508

31 Resources for PDF NPRF of Section 508 Refresh: PDF Association PDF/UA Reference Suite: PDF/UA Technical Implementation Guide (AIIM): Publications/Standards/Committees/PDFUA/Technical-Implementation-Guide PDF/UA Flyer from the PDF Association sample PDF/UA compliant document:

32 Adobe Accessibility Resources et al Adobe Accessibility Resources for PDF: Matterhorn Protocol for PDF/UA: PAC (PDF Accessibility Checker) 2.0: PDF Techniques for Web Content:

33 Accessible Document Design There are tagged PDF tutorials on the Karlen Communications website, Handouts page: Adding Accessible Images to Documents. Customizing a Table of Contents. Adding Accessible Placeholders to PowerPoint presentations. Conference Handout 2015 (summary of Word, PowerPoint and PDF ). Importing and Exporting Styles in Word. Creating and Customizing an Index. Tables and Columns in Word (Don t use Text Boxes). Text Boxes and Accessibility.

34 Contact! Karen McCall, M.Ed. Karlen Communications Canadian delegate to PDF/UA Microsoft MVP for Word ( ) Microsoft Accessibility MVP (established 2014)