BSI s BS 8878:2010 Web Accessibility Code of Practice

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1 BCS, The Chartered Institute for IT Consultation Response to: BSI s BS 8878:2010 Web Accessibility Code of Practice BCS The Chartered Institute for IT First Floor, Block D North Star House North Star Avenue Swindon SN2 1FA

2 This page is left deliberately blank. Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 2 of 7

3 BCS, the Chartered Institute for IT The Institute promotes wider social and economic progress through the advancement of information technology science and practice. We bring together industry, academics, practitioners and government to share knowledge, promote new thinking, inform the design of new curricula, shape public policy and inform the public. As the professional membership and accreditation body for IT, we serve over 70,000 members including practitioners, businesses, academics and students, in the UK and internationally. We deliver a range of professional development tools for practitioners and employees. A leading IT qualification body, we offer a range of widely recognised professional and end-user qualifications. Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 3 of 7

4 We have consulted our members and their recommendations and comments are as follows: Recommendations: 1. Draft BS 8878, like PAS 78:2006 depends on the user already being committed to accessibility. Those using this document will need to convince business colleagues, suppliers and clients of the importance of incorporating accessibility into current web design processes. The current content tone makes accessibility sound restrictive and unnecessarily cumbersome. Suggestion: The whole tone of the document needs to reflect that accessibility is all about good website design and good business. 2. Whilst the draft is of benefit where it defines good business processes for ensuring accessible websites are developed and maintained, technical definitions or advice are unnecessarily duplicated. Definitions of web accessibility are confused and overly technical eg things over IP instead of cached/local HTML files). Suggestion: Technical definitions and advice are covered in the WCAG 1 guidelines and in extensive online resources and where applicable, references should be made to them rather than duplicate their content. It is also recommended that web accessibility is defined simply as making sure that things in a web browser work, or refer to the W3C 2 definitions in the WCAG. Advice on WCAG1 and WCAG2, being different, would also be helpful. 3. Section 1 Scope - The revision of a document that helps people understand and embed accessibility is to be welcomed. The successful application of Equality Act 2010 or Disability Discrimination Act 1998 (DDA) depends on a wide range of people in the commercial sector being able to understand what is needed. Suggestion: For the listed audiences to understand the impact of this Code of Practice more prominence needs to be given to how it will be employed within the law and its status when prosecutions are brought under DDA. 4. Section 4 General principles - Draft BS 8878 should be supporting good web project management practice at every level of implementation. It currently appears to ignore this. Suggestion: To revise Section 4 so that it refers to and ties the Code of Practice and accessibility into the accepted web project management format used in the industry. Place Steps 1 to 15, paragraphs to into an annex. 1 Web Content Accessibility Guidelines 2 World Wide Web Consortium Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 4 of 7

5 5. Section 4 - All web products need a business case. It is at this point that the degree of accessibility needs to be planned for. It s also good practice as it defines the boundaries and helps identify problems early on in a project so they can be dealt with. Suggestion: Section 4 should focus on creating a business case while incorporating accessibility and paragraphs 4.4 and An annex to section 4 should provide a simple checklist of ideas for identifying soft or unquantifiable benefits related to accessibility for the business case. It should emphasise that getting sign-off of a business case that includes accessibility is an important step in getting active support for a project from senior management. 6. Section Step 2 where a reference is made to excluding users based on age, we have inferred that this means it s okay to exclude people under 18 from sites carrying pornography. Suggestion: This should be made explicit, otherwise you are implying that it is acceptable to have a site that has poor usability for old people. 7. Section Step 9 it is not immediately obvious why a desktop computer should be the base platform for accessibility. If you are creating a website for iphone users or television users this would not make any sense. It would not be acceptable to make a television web browser that is inaccessible unless you access it using a desktop computer. 8. Section Step 14 linking to the Accessibility statement on every page is unhelpful. More links mean more complexity. Corporate accessibility statements are not useful. 9. Government and local government websites have vastly improved accessibility over the past ten years because the sector carried out an extensive campaign to incorporate accessibility standards. A detailed set of intelligible, properly presented and interpreted guidelines (based on W3C web guidelines including WCAG) was prepared to guide government staff and was supported by other documentation and training. As a manual, it was too big, but the principle was a good one i.e. government managers recognised that they could not tell staff how to manage accessible websites until they understood accessibility. Suggestion: The draft Code to take a lead in promoting W3C and other relevant web guidelines in a format that is accessible to non-technical business people. 10. Section 6 takes up a lot of space telling people how to conduct a user-centred project, a topic which is widely addressed in related Project Management standards and publications. At this stage of the draft Code it appears incredibly burdensome when it s actually a process most people will recognise - it's just been rewritten here to emphasise accessibility. Suggestion: To revise Section 6 so that it refers to and ties the draft Code and accessibility into the accepted web project management format used in the industry. The detail should go in an annex. Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 5 of 7

6 11. The content of the current annex section is helpful and extended use would avoid the body text of the draft Code from becoming too cumbersome. Suggestion: Use the annex section to provide the basis for a manual that could be further expanded on the accompanying website. 12. The draft Code does not refer to web guidelines until section 7. Most people doing a website project have to juggle with this right from the start if they are trying to convert others to accessibility standards. It is one of the few recognised standards. Although accessibility levels A/ AA/ AAA are mentioned, an explanation of the pros and cons of each level is not found. This is a very useful notation because most non-technical managers, senior staff, Internet users have heard of it. Suggestion: Include explanation about accessibility levels A/ AA/ AAA so people know and understand how they might be used and why the content of these levels changes from time to time. 13. Section 7.2 Gathering requirements from disabled users disabled users are not all the same. Some are highly-skilled and have the latest expensive access equipment and tend to work for assessment companies that tell you if your website is accessible. Most disabled users however, have cognitive and/or age-related impairments, multiple disabilities and old software. Suggestion: Your testing panel should reflect the above differences. 14. Section Summary of accessibility testing methods where reference is made to validating HTML for correctness. Validation will make the new WAI-ARIA standards hard to deploy as they cannot be used with HTML4 which is the code for 99% of websites. Suggestion: This should be clearly marked as a secondary concern to accessibility and usability. 15. Section Testing with assistive technologies With reference to the second bullet point, testing with a screen magnifier is probably of little utility unless you are doing multimedia delivery. With reference to the third bullet point, web browsers on different platforms have completely different assistive technology interfaces. For example, Firefox on Windows supports MSAA, Firefox on Linux supports AT-SPI. This means that you cannot just test the browser on one operating system. 16. Accessibility for business users is about improving their service to a segment of their market they have hitherto ignored or failed. Managers have to be aware of the law relevant to their work. At times it seems the draft Code is promoting an over cautious attitude to avoiding falling foul of the law rather than promoting a way of helping people to improve a service. This is seen clearly in Annex N d). Suggestion: If a statement is needed about responsibility for legal issues, then a 'catch all' statement for those using the draft Code would be better. Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 6 of 7

7 17. Accessibility needs embedding into people as well as products. Implementing accessibility is all about good website design management and business practices for accessibility becoming part of good business. For some businesses this may involve a change in direction. At the very least it will need communicating to everyone in the business. Suggestion: Add new sections about Communicating with everyone in the business and the need to consider refocusing business direction. In summary, we would stress that accessibility cannot be separated from usability. Design and implementation processes must involve users with a range of disabilities to assess how easily users without expert IT skills can obtain the products or information which the website is intended to deliver. For example a site which claims conformity with current accessibility guidelines for disabled persons that has a screen reader which takes a user with visual impairment a disproportionally long time to work through the information on its web page is in practice unusable. An important aspect of the draft Code is that it should highlight the need for greater interaction and improved understanding between web designers and developers of assistive software and hardware which are one of the main objectives of BCS, The Chartered Institute s Inclusion Policy Panel and Assistive Technology Specialist Group. Ian Ryder Deputy Chief Executive BCS, the Chartered Institute for IT Consultation Response to BSI on BS8878 Web Accessibility Code of Practice Page 7 of 7

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