Complying with New York State’s New Web Accessibility Policy

Debi Orton, IT ManagerNYS Governor’s Office of Employee Relations

What we’ll cover…• Applicable and related Federal laws• History of NYS accessibility policy• Standards and Guidelines• Overview of current landscape: new laws,

standards and guidelines

Americans with Disabilities Act (ADA) – 1990: Title I

– Title I: Employment• Covers employers with >= 15 employees• Requires equal opportunity to full range of

employment-related opportunities available to others• Prohibits discrimination in recruitment, hiring,

promotion, training, pay, social activities, etc. • Requires reasonable accommodation for people with

disabilities, absent undue hardship

ADA: Title II– Title II: State and Local Government Activities• Regardless of size or receipt of Federal funding• Requires that people with disabilities have equal

opportunity to benefit from programs, services, activities (e.g., public education, employment, trasnportation, recreation, health care, social services, courts, voting and town meetings)• Covers architectural barriers, fundamental alteration

ADA: Title III– Title III: Public Accommodations• Covers businesses and nonprofit service providers that

are “public accommodations” (private entities who own, lease, lease to, or operate facilities such as restaurants, retail stores, hotels, movie theaters, private schools, convention centers, doctors’ offices, homeless shelters, transportation depots, funeral homes, zoos, day care centers, sports stadiums, etc.)• Prohibits exclusion, segregation, and unequal

treatment

ADA: Title IV

– Title IV: Telecommunications Relay Services• Covers telephone and television access to people with

hearing and speech disabilities• Establishes telecommunications relay services 24/7• Requires closed captioning of Federally funded public

service announcements

Telecommunications Act – 1934 & 1996

– Requires manufacturers of telecommunications equipment and providers of telecommunications services to ensure that equipment and services are usable people with disabilities

Other Applicable Federal Laws• Fair Housing Act• Air Carrier Access Act• Voting Accessibility for the Elderly and

Handicapped Act• National Voter Registration Act• Civil Rights of Institutionalized Persons Act• Architectural Barriers Act

Individuals with Disabilities Education Act (IDEA)

– Requires public schools to provide a free, appropriate public education in the least restrictive environment appropriate to their individual needs

Rehabilitation Act of 1973

– Section 501: Affirmative action and nondiscrimination in agencies of the Executive Branch

– Section 503: Requires affirmative action and prohibits employment discrimination by contractors and subcontractors with contracts for more than $10K.

Rehabilitation Act of 1973

– Section 504: “No qualified individual with a disability in the United States shall be excluded from, denied the benefits of, or be subjected to discrimination under” any program or activity that receives Federal financial assistance or is conducted by any Executive agency or the USPS

Rehabilitation Act of 1973

– Section 508: Establishes requirements for electronic and information technologies developed, maintained, procured or used by the Federal government• Must be accessible to people with disabilities, including

employees and members of the general public• NYS Policy adopts two parts of Section 508 explicitly

and a third implicitly

Web Standards• Established and maintained by the World

Wide Web Consortium (W3C)– Markup languages• HTML• XHTML• XML

– Presentation language : CSS– Accessibility Standards : WCAG, ATAG, UAAG,

ARIA

Accessibility Standards• Two major accessibility standards:– Section 508 – World Wide Web Consortium (W3C) • Web Accessibility Initiative (WAI)

– Web Content Accessibility Guidelines (WCAG)» 1.0 – May, 1999» 2.0 – December, 2008» 2.0 “last call” issued in May, 2004

NYS Accessibility Policy• First policy published in 1996 – required

reasonable accommodation for IT• Second policy published in 1999 – required

conformance to WCAG 1.0 level A• June, 2004: Hybrid standard adopted,

amalgam of Section 508 and WCAG 1.0 – Separated into policy document and standard

document

NYS Validation Tool• 2008 – NYS Forum developed customized

testing tool; provided tool free to state agencies and contractors working for state entities for one year

• 2009 – CIO/OFT picked up tool for another year

• 2010 – No NYS validation tool available

NYS Accessibility Policy

• Hybrid reviewed and adjusted every two years• 2010 – Policy changed to adopt Section 508

section 1194.22 (web standards, aligned with WCAG 1.0) and 1194.31 (functional testing)

• 1194.22 requires web content to meet provisions of 1194.21 (software applications and operating systems)

NYS Accessibility Policy• Covers all “state entities” identified in

Executive Order 117• Covers all Internet, intranet, extranet sites

and web applications• Covers all content on state entities’ web sites

Section 508, §1194.22• § 1194.22 Web-based intranet and internet

information and applications.– (a) A text equivalent for every non-text element shall

be provided (e.g., via "alt", "longdesc", or in element content).

– (b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Section 508, §1194.22

– (c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

– (d) Documents shall be organized so they are readable without requiring an associated style sheet.

– (e) Redundant text links shall be provided for each active region of a server-side image map.

Section 508, §1194.22

– (f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

– (g) Row and column headers shall be identified for data tables.

– (h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

Section 508, §1194.22– (i) Frames shall be titled with text that facilitates

frame identification and navigation.– (j) Pages shall be designed to avoid causing the screen

to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

– (k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

Section 508, §1194.22– (l) When pages utilize scripting languages to

display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

– (m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

Section 508, §1194.22– (n) When electronic forms are designed to be completed

on-line, 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.

– (o) A method shall be provided that permits users to skip repetitive navigation links.

– (p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Reference to §1194.21

• § 1194.21 Software applications and operating systems.

• Deals with the convergence of applications and web sites

• Applies to NYS sites by virtue of §1194.22(m)

Section 508, §1194.31

• § 1194.31 Functional performance criteria.– (a) At least one mode of operation and

information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

Section 508, §1194.31

– (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.

Section 508, §1194.31– (c) At least one mode of operation and

information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

– (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.

Section 508, §1194.31– (e) At least one mode of operation and

information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.

– (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

NYS Policy Requirements

• New content must conform immediately• Any content developed by contractor must

conform• Provides language to include in any

procurement involving web content• Policy requires annual validation and

reporting to CIO/OFT

How People With Disabilities Use the Web

• People who are blind access the web via:– Screen reading software – Refreshable Braille displays– CANNOT use pointing devices

• People with low vision may use those tools or:– Screen magnification software – External (larger) displays

Blindness / Low Vision

• Visual acuity also a factor for:– People using mobile devices– People using older equipment (smaller monitors,

lower resolutions)

• Visuals need to be described using “alt text”• Videos or presentations containing instruction

needs to be audibly described

Blindness / Low Vision

• Cataracts

• Glaucoma

Low Vision

• Macular Degeneration

• Retinopathy

Low Vision

• Difficult to magnify graphical text without distortion

Magnified graphical text

Color Blindness

Map of Hurricane Isabel (with color)

• Map of Hurricane Isabel (simulating red/green color blindness)

Color Blindness

• Subway maps

Color Blindness

• Video or presentation content with audio must be captioned

• Elearning content cannot rely on audio cues• People whose computers do not support

sound• Can be an issue for mobile device users

Deafness / Hearing Impairment

• Cannot use mouse for navigation• Interaction through keyboard only• May have difficulty with timed responses

Mobility Impairments

• Images are helpful for many with cognitive impairments

• Avoid “Wall o’ Text”• Use headlines and bullets• Attention to “fog index”

Cognitive Impairments

Principles of Accessibility• Users may require assistive technology to

effectively use technology or browse web• Provide information in more than one format• Navigation and layout should be consistent,

predictable• Alternate text should describe visual content’s

purpose [not necessarily a literal description of the content]

Testing for Accessibility

• Three basic ways to evaluate– Automated testing– Manual review – Functional testing

Automated Testing

• Automated testing tools don’t usually fix errors

• The best tools link error reports to the standard being violated

• Web developers will need a fairly comprehensive understanding of HTML and CSS

Automated Testing

• Many free, but limited [e.g., can only test a page at a time]

• Many for-fee tools customizable and can do batch testing

• Most can select either of the two major accessibility standards (Section 508 or WCAG)

• Automated testing not all that’s needed

Manual Evaluation• Look at alternate text for images• Turn off images and styles• Turn off scripting• Use keyboard to navigate• Data table markup• Look at use of color• Proprietary formats

Functional Testing• Have a user of assistive technology test site

while you watch• Test with “one of each”• User with visual impairments• User with hearing impairments (if sound on site)• User with cognitive impairments• Etc.

The Short-Term Future – Web Standards

• HTML & CSS Changing– HTML5 – some backward compatibility, but would

deprecate some accessibility features available in HTML 4

– CSS3 – little impact on accessibility– ARIA – Might be used to mitigate some of the

accessibility problems currently existing in HTML5

The Short-Term Future – Accessibility Standards

• WCAG 2.0– Now a recommendation– Support and implementation materials available

on the W3C site, WebAIM, etc.

The Short-Term Future – U. S. Law

• Section 508 about to undergo “refresh” – move to harmonize with WCAG 2.0

• ADA is being modified to cover the web, both public sector sites and private sector sites that function as “places of public accommodation”

• ADA changes also suggest harmonization with WCAG 2.0

The Short-Term Future – NYS Law

• Assembly bill in the last session required NYS to comply with Section 508 in toto

• Working with sponsor to include supports• Outcome will depend upon election

Resources – W3C• W3C site: http://w3.org– HTML & CSS:

http://www.w3.org/standards/webdesign/htmlcss– Scripting and AJAX support:

http://www.w3.org/standards/webdesign/script– Accessibility:

http://www.w3.org/standards/webdesign/accessibility

– Mobile Web: http://www.w3.org/standards/webdesign/mobilweb

Resources – W3C• List of web accessibility evaluation tools:

http://www.w3.org/WAI/ER/tools/• Developing a Web Accessibility Business Case for

Your Organization: http://www.w3.org/WAI/bcase/resources.html

• Developing Organizational Policies on Web Accessibility: http://www.w3.org/WAI/impl/pol

Resources – U. S. Government

• Section 508 : http://www.section508.gov/• Section 508 draft changes:

http://www.access-board.gov/508.htm• Americans with Disabilities Act:

http://www.ada.gov/

Resources – NYS Government

• Office of the Chief Information Officer/Office for Technology: http://oft.state.ny.us/Policy/indexa.htm– Select the policy on Accessibility – download in

Word or PDF format

• NYS Forum: http://nysforum.org/accessibility/resources/

Other Resources

• WebAIM: http://webaim.org/• National Center for Accessible Media (NCAM):

http://ncam.wgbh.org/

Questions?