Forum Guide to Ensuring Equal Access to Education Website

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Forum Guide to Ensuring Equal Access to Education WebsitesH a

Forum Guide to Ensuring EqualAccess to Education Websites

Introduction to Electronic Information Accessibility Standard


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Forum Guide to Ensuring EqualAccess to Education WebsitesIntroduction to Electronic Information Accessibility Standards


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ii HForum Guide to Ensuring Equal Access to Education Websites

National Cooperative Education Statistics System

The National Center or Education Statistics (NCES) established the National Cooperative Education Statistics System(Cooperative System) to assist in producing and maintaining comparable and uniorm inormation and data on earlychildhood, elementary, and secondary education. These data are intended to be useul or policymaking at the ederal,state, and local levels.

The National Forum on Education Statistics (the Forum) is an entity o the Cooperative System and, among its otheractivities, proposes principles o good practice to assist state and local education agencies in meeting this purpose. TheCooperative System and the Forum are supported in these endeavors by resources rom NCES.

Publications o the Forum do not undergo the same ormal review required or products o NCES. The inormationand opinions published here are those o the Forum and do not necessarily represent the policy or views o the U.S.Department o Education or NCES.

July 2011

This publication and other publications o the National Forum on Education Statistics may be ound at the websites listed

below.

The NCES Home Page address is http://nces.ed.gov.The NCES Publications and Products address is http://nces.ed.gov/pubsearch .The Forums Home Page address is http://nces.ed.gov/orum .

This publication was prepared in part under Contract No. ED-06-CO-0056 with the Council o Chie State SchoolOcers. Mention o trade names, commercial products, or organizations does not imply endorsement by the U.S.Government.

Suggested CitationNational Forum on Education Statistics. (2011). Forum Guide to Ensuring Equal Access to Education Websites: An

Introduction to Electronic Inormation Accessibility Standards(NFES 2011807). U.S. Department o Education.Washington, DC: National Center or Education Statistics.

For ordering inormation on this report, write:ED Pubs, U.S. Department o EducationP.O. Box 22207Alexandria, VA 22304

Or call toll ree 1-877-4-ED-PUBS, or order online at http://www.edpubs.gov.

Technical ContactGhedam Bairu

(202) [email protected]
http://nces.ed.gov/http://nces.ed.gov/pubsearchhttp://nces.ed.gov/forummailto:[email protected]:[email protected]://nces.ed.gov/forumhttp://nces.ed.gov/pubsearchhttp://nces.ed.gov/


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Forum Guide to Ensuring Equal Access to Education WebsitesH iii

Working Group MembersA volunteer working group o the National Forum on Education Statistics produced this document. It was developedthrough the National Cooperative Education Statistics System and unded by the National Center or Education Statistics(NCES) o the U.S. Department o Education.

Chair

Lee Rabbitt, Newport Public Schools (Rhode Island)

MembersJim Addy, Iowa Department o Education

Sheila Corey, Alaska Department o Education and Early Development

Kathleen Gosa, Kansas State Department o Education

Rachael Traub, Massachusetts Department o Education

Raymond Woten, Virginia Department o Education

ConsultantTom Szuba, Quality Inormation Partners

Project OcerGhedam Bairu, National Center or Education Statistics

AcknowledgmentsThe members o the Section 508 Accessibility Working Group o the National Forum on Education Statistics would liketo thank everyone who reviewed drats o this document or otherwise contributed to its development. This includes theForum Steering Committee, the Technology Committee, and members o the National Forum on Education Statistics.


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iv HForum Guide to Ensuring Equal Access to Education Websites

Foreword

The National Forum on Education Statistics (the Forum) is pleased to release the Forum Guide to Ensuring Equal Access toEducation Websites: An Introduction to Electronic Inormation Accessibility Standards. One goal o the Forum is to improvethe quality o education data gathered or use by policymakers and program decisionmakers. An approach to urtheringthis goal has been to pool the collective experiences o Forum members to produce best practice guides in areas o high

interest to those who collect, maintain, and use data about elementary and secondary education. Presenting educationdata in a manner that complies with both the letter and spirit o ederal Section 508 accessibility laws is one o those highinterest areas.

This guide is designed or use by inormation technology administrators, data specialists, and program sta responsibleor the content in data reports, as well as education leaders (e.g., administrators who prioritize tasks or technical anddata sta), and other stakeholders who have an interest in seeing that our schools, school districts, and state educationagencies operate in an eective and equitable manner or all constituents, regardless o disability status. It is intendedto raise awareness in nontechnical audiences and suggest best practices or complying with Section 508 goals at anoperational level in schools, school districts, and state education agencies. It is not intended to recreate technical resourcesthat already exist to acilitate Section 508 compliance.

This document refects the judgment o experienced education data managers and inormation technology specialists.While there is no mandate to ollow these principles, the authors hope that the contents will prove a useul reerence toothers in their work.

In Tis GuideChapter 1 raises awareness about how people with disabilities access electronic inormation, introduces the ederal Section508 accessibility law, and challenges education leaders to make their electronic resources accessible to all constituentsregardless o disability status (i.e., to comply with the law).Chapter 2 describes the technical capabilities required by Section 508 and international guidelines or achieving

accessibility, although it does not present detailed technical guidance.

Chapter 3 recommends practical strategies or planning to improve accessibility and comply with Section 508 standardsin an education organization.

Appendix A provides additional inormation about reerences cited in this document and other resources related toimproving accessibility.

Appendix B presents a set o Section 508 compliance leadership indicators rom the U.S. General Services Administration.

Appendix C presents a list o commonly asked questions (and answers) regarding Section 508.

Appendix D shares Web Content Accessibility Guidelines (WCAG) 1.0 checkpoints that explain how developers canoperationalize the Section 508 guidelines.


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Forum Guide to Ensuring Equal Access to Education WebsitesH v

Te National Cooperative Education Statistics SystemThe work o the Forum is a key aspect o the National Cooperative Education Statistics System (Cooperative System).The Cooperative System was established to produce and maintain, with the cooperation o the states, comparable anduniorm educational inormation and data that are useul or policymaking at the ederal, state, and local levels. To assistin meeting this goal, the National Center or Education Statistics (NCES), within the U.S. Department o Education,established the Forum to improve the collection, reporting, and use o elementary and secondary education statistics. The

Forum deals with issues in education data policy, sponsors innovations in data collection and reporting, and providestechnical assistance to improve state and local data systems.

Development o Forum ProductsMembers o the Forum establish task orces to develop best practice guides in data-related areas o interest to ederal,state, and local education agencies. They are assisted in this work by NCES, but the content comes rom the collectiveexperience o the state and school district task orce members who review all products iteratively throughout thedevelopment process. Documents prepared, reviewed, and approved by task orce members undergo a ormal publicreview. This public review consists o ocus groups with representatives o the products intended audience, review sessionsat relevant regional or national conerences, or technical reviews by acknowledged experts in the eld. In addition, alldrat documents are posted on the Forum website prior to publication so that any interested individuals or organizationscan provide eedback. Ater the task orce oversees the integration o public review comments and reviews the document anal time, publications are subject to examination by members o the Forum standing committee sponsoring the project.Finally, the entire Forum (approximately 120 members) reviews and ormally votes to approve all documents prior topublication. NCES provides nal review and approval prior to publication.


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Forum Guide to Ensuring Equal Access to Education WebsitesH vii

able o Contents

National Cooperative Education Statistics System ii

Working Group Members iii

Acknowledgments iii

Foreword iv

In Tis Guide iv

Te National Cooperative Education Statistics System v

Development o Forum Products v

Chapter 1 Why Should I Care About Accessibility? 1

Introduction 1

Section 508 Summary 2

Benets o Section 508 Compliance 3

A Challenge to Education Leaders 3

Examples o Good and Bad Electronic Resources (Section 508 Compliance) 4

Chapter 2 What Do I Need to Know to Comply With Section 508 Accessibility Standards? 7

Understanding Accessibility Law, Guidelines, and Development Standards 7

Section 508 o the Rehabilitation Act (29 USC 794d), as Amended by the Workorce Investment Act o 1998 8

Subpart Bechnical Standards 8119421 Sotware applications and operating systems 8119422 Web-based intranet and internet inormation and applications 11

Web Content Accessibility Guidelines 10 15

Web Content Accessibility Guidelines 20 16

Chapter 3 How Do I Implement Section 508 Accessibility Standards? 17Introduction 17

Conducting a Sel-Audit 17

Establishing Perormance Goals 18

Developing a Project Plan 18

raining Staf 19

Dedicating Adequate Resources 20

Making Accessibility a Part o Routine Operations 20

Appendix A Forum/NCES Resources & Selected State Laws and Policies Governing Accessible echnologies 21

Web Resources Reerenced in Tis Document 21Forum/NCES Resources 22

Selected State Laws and Policies Governing Accessible echnologies 24

Appendix B Section 508 Leadership Indicators rom the US General Services Administration 27

Appendix C Commonly Asked Questions About Section 508 29

Appendix D Web Content Accessibility Guidelines 10 31


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viii HForum Guide to Ensuring Equal Access to Education Websites

List o ablesTable 2-1. WCAG 1.0 Checkpoints or Section 508 1194.22 ...................................................................15

List o Figures

Figure 1-1. Simulation o a ctional education report. ..................................................................................4Figure 1-2. People with visual impairments sometimes use a screen magnier to enlarge text and images .....5

Figure 1-3. Websites without appropriate alt tags leave blind readers with little inormationto interpret meaning. ..................................................................................................................6

Figure 2-1. Sotware/operating systems Provision (a) requires that all product unctions be executablevia a keyboard alternative to manipulating a mouse. ...................................................................9

Figure 2-2. Sotware/operating systems Provision (i) requires that alternatives to color accompanyall color coding. .....................................................................................................................10

Figure 2-3. Web-based Inormation Provision (a) requires that an appropriate text equivalent beprovided or all images. ............................................................................................................12

Figure 2-4. Web-based Inormation Provision () requires that image link maps be readable by userswithout additional exchange with the server. ............................................................................13


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Forum Guide to Ensuring Equal Access to Education WebsitesH 1

Chapter 1 Why Should I CareAbout Accessibility?

IntroductionSchools, districts, state education agencies, and the U.S. Department o Education all routinely collect and report dataelectronically, most oten via websites and online applications accessed through the Internet. Education data are sharedwith both educators and the public in the orm o static and dynamic web pages, PDF les, query and search engineoutput, build-your-own table tools linked to secure databases, and other easily exchanged electronic ormats. As we enterthe second decade o the 21st century, parents, educators, administrators, and community members oten look rst to theInternet to nd the inormation they need about their schools and students. Because the Internet is no longer a secondarysource o inormation, these are not casual visits. School and district websites are undamental, and even vital, sources oinormation to the education enterprise.But what i you were to search online or your local schools activity

calendar and saw a blank page, or perhaps only an indecipherable stringo nonsensical characters? This is eectively what happens to scoreso web users with visual disabilities when trying to access many ormso education data and resources. Similarly, some parents and studentsmight hope to retrieve a podcast o the school superintendents back-to-school address, only to nd that a hearing impairment prevents orlimits access to the recording o the spoken message. And still othercommunity members may nd it impossible to navigate a website becauseo a physical condition that prevents them rom maneuvering a mouse toclick here and access new inormation.

According to the 2000 U.S. Census, nearly 20 percent o the populationin the United States has some type o disability.1 While this numbermay seem unexpectedly high to many people, it is supported by the act that ully 7 percent o the male population in theUnited States (approximately 10 million men) cannot distinguish red rom green or see red and green dierently rommost people (the most common orm o color blindness).2 Nonetheless, countless websites and paper publications colorcode data in a well meaning but misguided eort to improve understanding.

Other types o disabilities aect students, parents, school sta, and community members as well, including motorimpairments, cognitive/developmental issues, hearing impairments, visual epilepsy, and other conditions. Even peoplewho are not classied with traditional disabilities can nd themselves disabled with respect to accessing inormationonline. This includes people dealing with common age-related impediments, such as loss o vision, hearing, or motordexterity (e.g., rom degenerative conditions commonly associated with the aging process, such as arthritis).

Many people with disabilities participate in the education system because they or their children have something to gainrom becoming educatedand something to contribute as members o society. Ensuring that all stakeholders can accessinormation about educational organizations, processes, and perormance is air, necessary, and empowering. Providingthis access, however, requires electronic and inormation technologies (EITs), such as websites, to be designed in a mannerthat adequately accommodates the capabilities o assistive technologies (screen readers, braille printers, screen enlargers,

1 Census 2000 counted 49.7 million people with some type o long lasting condition or disability. They represented19.3 percent o the 257.2 million people whowere aged 5 and older in the civi lian noninstitut ionalized population (i.e., not in the militar y or otherwise institutionalized). Source : Disabilit y Status : 2000(Census 2000 Brie). Accessed September 2010 at http://www.census.gov/prod/2003pubs/c2kbr-17.pd.2 Color Blindness: More Prevalent Among Males. Howard Hughes Medical Institute (2006). Accessed September 2010 at http://www.hhmi.org/senses/b130.html.

Challenge: Try to navigate your school

districts website without using your

mouse. I the experience proves utile,

youll better understand what it is like

or a viewer who cannot operate a

hand-held pointing device, such as

a mouse and youll know that the

website does not comply with ederal

(and many state) laws requiring equal

access to electronic inormation or

people with disabilities.
http://www.census.gov/prod/2003pubs/c2kbr-17.pdfhttp://www.census.gov/prod/2003pubs/c2kbr-17.pdfhttp://www.hhmi.org/senses/b130.htmlhttp://www.hhmi.org/senses/b130.htmlhttp://www.hhmi.org/senses/b130.htmlhttp://www.census.gov/prod/2003pubs/c2kbr-17.pdf


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Making sure that all stakeholders

can access information about

educational organizations, processes,

and performance is fair, necessary,

and empowering. Doing so not only

improves access for people with

disabilities, but also helps people who

are aging or otherwise technologically

challenged. It also helps to clarify

and improve an organizations overall

communications.

text-to-voice translators, and various keyboard and mouse modifcations).Interestingly, ensuring that websites and other electronic inormationare accessible by these devices not only aids people with disabilities, butalso people using older computers and operating systems (who mightargue that they are technologically challenged). It also motivates aneducation organization to more comprehensively consider its strategiesand templates or improving and clariying communications in general.

Section 508 SummaryIn 1998, the U.S. Congress amended the Workorce RehabilitationAct o 19733 to require ederal agencies to make their EIT accessible topeople with disabilities. By defnition, inaccessible technology reersto the electronic display or presentation o inormation that interereswith any individuals ability to obtain and use inormation quickly and

easily. Section 508 (as amended) requires ederal departments and agencies that develop, procure, maintain, or use EITs toensure that ederal employees and members o the public with disabilities have access to, and use o, inormation and datacomparable to that o employees and members o the public without disabilities. Most states have similar laws, regulations,or policies designed to ensure that people with disabilities have equal access to public inormation (see appendix A).

Section 508 standards reer to a set o airly technicalspecifcations and perormance requirements or developing,reporting, and sharing electronic inormation, tools, andresources that promote Section 508 compliance. Otentimes,these standards are presented as a series o checklist items ortechnical developers (see chapter 2). Standards are sometimesorganized by the type o EIT being addressed, such as sotwareapplications and operating systems; web-based inormation orapplications; telecommunication products; video and multimediaproducts; sel-contained, closed products (e.g., inormationkiosks, calculators, and ax machines); and desktop and portable

computers. Although all o these technologies are important in thefeld o education, this document ocuses on those more relevantto accessing, using, and reporting education data, such as

sotware applications and operating systems, includingpurchased or developed operating systems and applicationsotware programs, or any products that contain sotwareas an integral component o their unctionality; and

web-based inormation or applications, includingpurchased or contracted websites, and encompassing theinormation content as well as any associated applications,plug-ins, or web-based interaces or other technologies

and devices (such as telecommunications).

Document Purpose & Audience

While there are several highly technical

resources related to Section 508 accessibility

standards (see appendix B), this document

focuses, instead, on raising awareness in

nontechnical audiences and offers best

practices for complying with Section 508 goals

at an administrative levelthat is, guidance for

planning to adopt and implement Section 508standards in schools, school districts, and state

education agencies.

This document is written for information

technology administrators, data and program

specialists responsible for the content in data

reports, education leaders (e.g., administrators

who prioritize tasks for technical and data

staff), and other stakeholders who have an

interest in seeing that our schools, school

districts, and state education agencies operatein an effective and equitable manner for all

constituents, regardless of disability status.

3 Section 508 o the Rehabilitation Act (29 U.S.C. 794d), as amended by the Workorce Investment Act o 1998 (P.L. 105-220), August 7, 1998. Visithttp://www.section508.gov/or more inormation.

2 HForum Guide to Ensuring Equal Access to Education Websites
http://www.section508.gov/index.cfm?FuseAction=Content&ID=14http://www.section508.gov/index.cfm?FuseAction=Content&ID=14http://www.section508.gov/index.cfm?FuseAction=Content&ID=14


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Benets o Section 508 ComplianceThere are many benets to an education organization that complies with Section508 Accessibility Guidelines. In addition to adhering to existing ederal (and state)laws, presenting inormation in a manner that can be used by all people, regardlesso disability status, is the right thing to do. More tangible benets o taking aproactive and systematic approach to presenting electronic inormation in a Section

508-compliant manner include

promoting the use o cleaner code and other improvements to sitedevelopment;

developing web pages that are easier to print or otherwise exchange;

encouraging consistency across websites that may have grown beyondmanagement control over time, including an opportunity to reestablisha standard look and eel to the organizations website and electronicresources through development standards, common rameworks, and templates (e.g., cascading style sheets);

identiying (and removing) redundant inormation and orphaned web pages ollowing site review;

expanding access via additional platorms (e.g., handhelds and multiple browsers);

improving usability or all stakeholders; and

establishing or enorcing proactive data governance within the organization.

Section 508 is shorthand

or a ederal law that

requires ederal agencies,

and organizations receiving

ederal unds, to make their

electronic and inormation

technology accessible to

people with disabilities.

Most states have

comparable laws,

regulations, or policies.

A Challenge to Education LeadersUnortunately, many schools, districts, and even state educationagencies do not yet comply with many components o the Section 508Accessibility Guidelines.4 In some cases, sta members are not awareo their responsibilities as mandated by Section 508. In other instances,perceived technical challenges interere with compliance. And in manyorganizations, the sheer volume o work required to update websites (andother electronic resources) overwhelms planners to the point o makingSection 508 compliance appearto be impractical.

4A 2009 asse ssment o Texas school distr icts ound that only 12.89 percent (144 o 1,117 districts) had websites that were compliant with Section 508 Accessibil ityGuidelines as determined by the WatchFire Bobby Sotware, an online scanning tool commonly used to evaluate website accessibility. Source: May, S. and Zhu, Q.(2009). A Web Accessibility Assessment on the Texas Public School System. Universal Access in the Inormation Society. Accessed September 2010 at http://www.springerlink.com/content/705q6n485445650m/?p=c6a3c70b20446892003b3b174900d&pi=0 .

In addition to complying with ederal

(and many state) laws, presenting

inormation in a manner that can

be used by all people, regardless o

disability status, is the right thing to do.

Presenting electronic inormation in a manner that is accessibleto people with disabilities does not automatically happen. Doingso requires raising awareness in technical sta, administrators,and policymakers (the purpose o this document); appropriatetechnological design and application (see chapter 2 and appendix A);and a commitment to proactively manage inormation technologyby assigning sta and nancial resources to update existing websitesand EITs. As such, it is unlikely that progress toward compliance will

occur unless education leaders actively support Section 508 goals as animportant organizational priority (see appendix B). School leaders canestablish policies and procedures that make accessibility an expectationin the organization or, alternatively, they can accept or even encouragea status quo in which many o their data users may be unable to access

inormation in a manner that is understandable to them. The tools to accomplish the job are available as long as there iscommitment to doing so.

This document is intended to raise

awareness in nontechnical audiences and

oer best practices or complying with

Section 508 goals at an administrative

level in schools, school districts, and state

education agencies. It is not intended to

recreate technical resources that alreadyexist to acilitate Section 508 compliance

(see appendix A).
http://www.springerlink.com/content/705q6n485445650m/?p=c6fa3c70b20f446892003fb3b174900d&pi=0http://www.springerlink.com/content/705q6n485445650m/?p=c6fa3c70b20f446892003fb3b174900d&pi=0http://www.springerlink.com/content/705q6n485445650m/?p=c6fa3c70b20f446892003fb3b174900d&pi=0http://www.springerlink.com/content/705q6n485445650m/?p=c6fa3c70b20f446892003fb3b174900d&pi=0http://www.springerlink.com/content/705q6n485445650m/?p=c6fa3c70b20f446892003fb3b174900d&pi=0


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Examples o Good and Bad Electronic Resources (Section 508 Compliance)Figures 1-1, 1-2, and 1-3 illustrate how the presentation o inormation can aect its accessibility to people withdisabilities. These examples display an inaccessible resource juxtaposed to an accessible version o the same content,enabling readers to see what it is like to try to read this inormation with a disability.

Figure 1-1. Simulation o a fctional education report that relies on common red-green color codes toconvey meaning, as viewed (through a simulation tool) by a person with red-green colorblindness. Note the diminished dierence the color coded scheme conveys (image A versusimage B) to a person who is red-green color blind. The simulation tool was accessed throughthe Vischeck website at http://www.vischeck.com/vischeck/.

Original Image (A) Red-Green Colorblind(Deuteranope) Simulation (B)

2008 District-Wide AYP Report

KEY

2008 District-Wide AYP Report

KEY

Schools Making AYP in Green PrintSchools Not Making AYP in Red Print

Schools Making AYP in Green PrintSchools Not Making AYP in Red Print

1 Anderson Elementary

2 Babcock Middle School

3 Cheevers Elementary

4 County High School

5 Dodge Elementary

6 Eccand Elementary

7 Farmer Elementary

8 Groves Middle School

9 Highland Elementary10 Jones Academy

11 Kilgore Middle School

12 Lambert Elementary

13 Milo Elementary

14 North County High School

15 Oswald Elementary

1 Anderson Elementary

2 Babcock Middle School

3 Cheevers Elementary

4 County High School

5 Dodge Elementary

6 Eccand Elementary

7 Farmer Elementary

8 Groves Middle School

9 Highland Elementary10 Jones Academy

11 Kilgore Middle School

12 Lambert Elementary

13 Milo Elementary

14 North County High School

15 Oswald Elementary
http://www.vischeck.com/vischeck/http://www.vischeck.com/vischeck/


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Figure 1-2. People with visual impairments sometimes use a screen magnifer to enlarge text and images.Although enlarging text may help them see characters more clearly, it also reduces the amounto inormation that can be viewed at one time on a monitor screen. The upper image (A)illustrates how magniying characters may detract rom meaning when the column and rowheadings in the lower image (B) extend beyond the viewing rame.

(A) C D E7 460,731 462,287 0.34%

8 1,617,250 1,799,630 11.28%

9 57,758 58,052 0.51%

10 1,138,438 1,233,356 8.34%

11 7.98 7.96 -0.25%

127:40 7:35 -1.09%

(B)Category February 2010 March 2010 % Change

Total Number o Pages Viewed 12,900,477 14,330,913 11.09%

Average Number o Pages Viewed Per Day 460,731 462,287 0.34%

Total Number o Visits 1,617,250 1,799,630 11.28%

Average Number o Visits Per Day 57,758 58,052 0.51%

Total Number o Visitors 1,138,438 1,233,356 8.34%

Average Number o Pages Viewed Per

Visit

7.98 7.96 -0.25%

Average Visit Duration (In Minutes andSeconds)

7:40 7:35 -1.09%

Median Visit Duration (In Minutes andSeconds)

1:28 1:25 -3.41%

Most Active Day o the Week (Visits) Tuesday (274,734) Monday (342,148) 24.54%

Busiest Hour o a Day (Visits) 14:0015:00(110,557)

14:0015:00(120,802)

9.27%


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Home

Link 1

Link 2

Link 3

Link 4

Link 5

Link 6

Link 7

Link 8

ABC

logo

ABC School District

PTA End of Year Party

ABC High School

August 6 - 12, 2010

Register

Now!

Virtual

Tour

(A) What sighted viewers see.

Home

Link 1

Link 2

Link 3

Link 4

Link 5

Link 6

Link 7

Link 8

ABC School District

PTA End of Year Party, August 6 - 12, 2010

Register Now Take Virtual TourABC S choolDistrict logoReturn to

Home Page

Front of ABC High School(B) What blind viewers see when alt

tags are available.

ABC School District

(C) What blind viewers see when alt

tags are not available.

Figure 1-3. Websites without appropriate alt tags leave blind readers with little inormation to interpret meaning.(A) How a website is seen by a person who is not blind. (B) How a website with appropriate alt tagsmight be seen by a reader who is blind. (C) How a website without appropriate alt tags might beseen by a blind person. Screen readers will not help convey website content without unctioningdescriptive text equivalents like alt tags.


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Chapter 2 What Do I Need to Knowto Comply With Section 508

Accessibility Standards?Understanding Accessibility Law, Guidelines, andDevelopment StandardsAs described in chapter 1, Section 508 o the Rehabilitation Act o 1973 was amended and signed into law in 1998(Workorce Reinvestment Act) as a set o mandated standards that supplanted nonbinding guidelines rom 1986. Inother words, optional suggestions or helping disabled people to accessinormation were transormed into mandated Section 508 implementationguidelines that now have the orce o ederal law. Many states have similar

laws, regulations, and policies.

To help organizations implement Section 508 mandates, voluntary bestpractices or improving the accessibility o electronic inormation (andcomplying with Section 508 law) have been developed by two leaders in theeld: the United States Access Board and the World Wide Web Consortium(W3C) Web Accessibility Initiative (WAI).

The United States Access Board is an independent ederal agencydevoted to improving accessibility or people with disabilities.5Created in 1973 to ensure access to ederally unded acilities, theBoard is now a leading source o inormation on accessible design.

As such, it develops and maintains design criteria or the built environment, transit vehicles, telecommunicationsequipment, and EITs. In 1998, the Board established the Electronic and Inormation Technology Access AdvisoryCommittee (EITAAC), which was composed o representativesrom government, industry, and disability advocacy groups orthe purpose o developing accessibility standards.

The W3C (World Wide Web Consortium) is an internationalcommunity in which member organizations, a ull-time sta,and the public work together to develop web standards.6 Acentral goal o the W3C is to promote web accessibility so thatpeople with disabilities can perceive, understand, navigate,interact with, and contribute to the World Wide Web. W3C

hopes to contribute to this goal through the establishment othe WAI (Web Accessibility Initiative), which has developedseveral sets o voluntary standards that support both thespecic mandates o Section 508, as well as more broadlyconstructed eorts to improve accessibility on the Web.The WAI developed Web Content Accessibility Guidelines(WCAG) or web developers (including content authors and

5 For more inormation about the United States Access Board, visit http://www.access-board.gov/index.htm.6 For more inormation about the World Wide Web Consortium and its Web Accessibility Initiative, visit http://www.w3.org/and http://www.w3.org/WAI/.

Challenge: Try to read a moderately

complex spreadsheet on yourhandheld data device (e.g., an

iPhone or Blackberry). Did you track

the column and row ormatting or

each cell? Could you identiy trends

and patterns in the data? Might this

be what it is like or a person who

needs to use a screen magnier to

read data?

Section 508 standards are mandated by

ederal law.

WCAG standards are not required

by ederal law but, instead, help

organizations become more compliant

with Section 508 through the adoption

and implementation o WCAG standards.

Some state accessibility laws integrate

both Section 508 guidance and

numerous WCAG practicesgiving

WCAG the orce o law in those states.
http://www.access-board.gov/index.htmhttp://www.access-board.gov/index.htmhttp://www.w3.org/http://www.w3.org/http://www.w3.org/WAI/http://www.w3.org/WAI/http://www.w3.org/WAI/http://www.w3.org/http://www.access-board.gov/index.htm


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site designers) in 1999 (WCAG 1.0). Version 2.0 (WCAG 2.0) was released in 2008 to apply to a broader andmore advanced world o technology.

This chapter summarizes the legally mandated Section 508 Accessibility Guidelines as well as practical, but voluntary,WCAG standards and recommendations that support attaining the Section 508 requirements. Additional inormationabout Section 508 concepts and implementation can be ound in appendix C (Commonly Asked Questions AboutSection 508).

Section 508 o the Rehabilitation Act (29 USC 794d), asAmended by the Workorce Investment Act o 1998

Subpart Bechnical Standards7

Section 1194.21 (sotware applications and operating systems) addresses purchased or developed operatingsystems and application sotware programs, or any products that contain sotware as an integral componento their unctionality.

1194.21 Sotware applications and operating systems8

Provision (a) LanguageWhen sotware is designed to run on a system that has a keyboard, productunctions shall be executable rom a keyboard where the unction itsel or the result o perorming aunction can be discerned textually.

InterpretationThis provision is intended to permit people who cannot manipulate a mouse to still engagein all unctions in an application by means o a keyboard. Similarly, the provision would be helpul to a userwith a visual impairment that prevents them rom pointing a mouse (even i they can use it) to a specic

place to, or example, select a drawing tool or pick a color rom a digital pallet. To comply with this provision,developers need to enable all application unctions to be triggered via keyboard shortcuts that are identiablewith a text label (see gure 2-1).

Provision (b) LanguageApplications shall not disrupt or disable activated eatures o other products thatare identied as accessibility eatures, where those eatures are developed and documented accordingto industry standards. Applications also shall not disrupt or disable activated eatures o any operatingsystem that are identied as accessibility eatures where the application programming interace or thoseaccessibility eatures has been documented by the manuacturer o the operating system and is availableto the product developer.

InterpretationMany sotware applications and operating systems enable users to customize accessibility

eatures (e.g., changing color schemes or adjusting sound requencies). This provision prohibits applicationsrom automatically disabling such eatures that have been activated by a user prior to running the application.

7 For more inormation about how to interpret and respond to Section 508 requirements, visit the United States Access Boards resource Guide to the Section 508Standards or Electronic and Inormation Technology at http://www.access-board.gov/sec508/guide/. Useul inormation is also available in the orm o a side-by-side comparison o WCAG and Section 508 at http://www.jimthatcher.com/sidebyside.htm#WCAG .8 These provisions o Section 508 deal specically with sotware applications and operating systems but, because o variation in programming languages, ocus onconcepts and unctionalities rather than explicit coding instructions. For additional technical guidance, visit http://www.access-board.gov/sec508/guide/1194.21.htm.
http://www.access-board.gov/sec508/guide/http://www.access-board.gov/sec508/guide/http://www.jimthatcher.com/sidebyside.htm#WCAGhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.jimthatcher.com/sidebyside.htm#WCAGhttp://www.access-board.gov/sec508/guide/


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Figure 2-1. Sotware/operating systems Provision (a) requires that all product unctions be executable via akeyboard alternative to manipulating a mouse.

Provision (c) LanguageA well-dened on-screen indication o the current ocus shall be provided that movesamong interactive interace elements as the input ocus changes. The ocus shall be programmatically

exposed so that assistive technology can track ocus and ocus changes.

InterpretationThe position on a screen where an action takes place is reerred to as the ocus. Forexample, when a user selects a button, that button becomes the ocus. This provision requires that anapplications ocus be identiable to assistive technology (such as a screen view enlarger) through its code, sothat a user o assistive technologies can identiy, and thereore ollow, the point o ocus as it changes whilerunning an application.

Provision (d) LanguageSucient inormation about a user interace element, including the identity,operation and state o the element, shall be available to assistive technology. When an image represents aprogram element, the inormation conveyed by the image must also be available in text.

InterpretationThis provision requires that all orms o visually displayed tools, such as a checkbox, menu,

toolbar, scroll bar, and similar items, have both descriptive and statustext associated with them. In otherwords, a button that toggles an element on or o (such as items on a tool bar) needs to not only describe theelement (e.g., page ruler), but also its status or state (e.g., toggled o).

Provision (e) LanguageWhen bitmap images are used to identiy controls, status indicators, or otherprogrammatic elements, the meaning assigned to those images shall be consistent throughout anapplications perormance.

InterpretationSome applications assign meaning to images. For example, a right-pointing arrow in thebottom right corner o a page may mean advance to the next screen. This provision requires that themeaning o such an image (which should have a text description according to Provision (d) above) should


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10HForum Guide to Ensuring Equal Access to Education Websites

not change within an application. In other words, the right-pointing arrow should not have a text descriptionon the rst page that says advance to the next screen but then change in meaning to select this item on asubsequent page.

Provision () LanguageTextual inormation shall be provided through operating system unctions ordisplaying text. The minimum inormation that shall be made available is text content, text input caretlocation, and text attributes.

InterpretationA computers operating system is responsible or controlling its basic unctions, such asreceiving input rom a keyboard or mouse, displaying inormation on a monitor, and storing data on a harddrive. Most sotware applications incorporate standard protocols used by the operating system or invokingthese core unctions. This provision prohibits applications rom using uniquely derived instructions beyondstandard operating system protocols or handling these key taskswhich potentially would not be operableby assistive technologies that are designed to be compatible with common operating systems.

Provision (g) LanguageApplications shall not override user selected contrast and color selections and otherindividual display attributes.

InterpretationPeople with disabilities oten adjust monitor display (color, contrast, ratios, etc.) to meettheir viewing needs. This provision prohibits applications rom automatically overriding user-selected display

settings.

Provision (h) LanguageWhen animation is displayed, the inormation shall be displayable in at least onenon-animated presentation mode at the option o the user.

InterpretationAnimation (motion) can present a challenge to certain types o assistive technology devices.As such, this provision requires that an alternative orm o presenting inormation be available wheneveranimation is used to convey meaning in an application (e.g., such as an animated character guiding a userthrough the help section).

Provision (i) LanguageColor coding shall not be used as the only means o conveying inormation,indicating an action, prompting a response, or distinguishing a visual element.

InterpretationWhile this provision does notprohibit the use o color, it does require at leastone alternative method o conveying any meaningassociated with the use o color. For example,i a green light is to be clicked to advance apresentation slide and a red light to go backward,the application should identiy the advance and goback unctions in some way other than just color. Inthis example, text that describes the unctions wouldsuce (see gure 2-2).

Provision (j) LanguageWhen a product permits a user

to adjust color and contrast settings, a variety o colorselections capable o producing a range o contrastlevels shall be provided.

InterpretationThis provision only applies toapplications that allow users to adjust screen colors.Any such application should also enable users toadjust contrast settings in order to accommodateindividual viewing needs.

Figure 2-2. Sotware/operating systemsProvision (i) requiresthat alternatives to coloraccompany all color coding.

go

back

advance

slide


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Provision (k) LanguageSotware shall not use fashing or blinking text, objects, or other elements having afash or blink requency greater than 2 Hz and lower than 55 Hz.

InterpretationThis provision is critical to accommodating the needs o viewers with photosensitive epilepsy.These users can have seizures triggered by displays that ficker, fash, or blink, particularly in requenciesgreater than 2 Hz and lower than 55 Hz, which are, thereore, prohibited.

Provision (l) LanguageWhen electronic orms are used, the orm shall allow people using assistive

technology to access the inormation, eld elements, and unctionality required or completion andsubmission o the orm, including all directions and cues.

InterpretationThis provision requires that keyboard alternatives enable users to navigate a orm and thattext labels accompany eld elements in close proximity. In other words, labels should correspond directlywith orm input requirements (e.g., the student name label should be tagged directly to its input eld ratherthan just somewhere on the same page so that a screen reader can clearly identiy the relationship between theeld and the tag). Moreover, users should be able to move rom one orm element to another by means o thekeyboard (e.g., unction keys) in addition to the use o a mouse.

1194.22 Web-based intranet and internet inormation and applications9, 10

Section 1194.22 (web-based intranet and internet inormation or applications) addresses purchased or contractedwebsites, and encompasses content as well as associated applications, plug-ins, or web-based interaces or otherproducts (such as telecommunications devices).

Provision (a) LanguageA text equivalent or every non-text element shallbe provided (e.g., via alt, longdesc, or in element content).

InterpretationText equivalent reers to the use o words (i.e., text)attached to any nontextual eature, such as an image or audio clip,to describe the purpose and/or unction o an image. Note that thetext may describe the image (e.g., an image o school supplies), but

should describe the unctionality o the image (e.g., a picture o schoolsupplies that serves as a link to the school supply store at http://www.ctionalschool/supplies). Developers must use some common sensewhen applying alt textneither too little nor too much inormation isuseul (see gure 2-3). This provision is intended to permit people whocannot manipulate a mouse to still employ all unctions in an applicationby means o a keyboard. Similarly, implementing this provision wouldhelp a user with a visual impairment that prevents them rom pointing amouse (even i they can use it) to a specic place to, or example, selecta drawing tool or pick a color rom a digital pallet. To comply with thisprovision, developers need to enable the triggering o all application unctions via keyboard shortcuts that areidentiable with a text label (see gure 2-1).

9 These provisions o Section 508 apply specically to the development o websites and web pages. A site is considered to comply with Section 508 i it meets thestandards established in Provisions (a) through (p). Some provisions may not be required i they are determined to impose an undue burden on the organization.By law, an undue burden is dened as signicant diculty or expense. In determining whether an action would result in an undue burden, an agency is directedto consider all agency resources available to the program or component or which the product is being developed, procured, maintained, or used. For more guidance,visit http://www.access-board.gov/sec508/guide/1194.22.htm.10 See appendix D or a priority-level checklist o WCAG 1.0 checkpoints that explain how developers can operationalize the Section 508 guidelines.

Because the unctional

limitations o disabled

users do not change, there

is considerable overlap

between Section 508

provisions applicable to

sotware applications

and operating systems

(1194.21) and web-

based intranet and

internet inormation and

applications (1194.22).
http://www.fictionalschool/supplieshttp://www.fictionalschool/supplieshttp://www.fictionalschool/supplieshttp://www.access-board.gov/sec508/guide/1194.22.htmhttp://www.access-board.gov/sec508/guide/1194.22.htmhttp://www.access-board.gov/sec508/guide/1194.22.htmhttp://www.fictionalschool/supplieshttp://www.fictionalschool/supplies


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Provision (b) LanguageEquivalent alternatives or any multimedia presentation shall be synchronized withthe presentation.

InterpretationSynchronizing reers to the pace o the presentation o alternative representations omultimedia content. In other words, i a video clip includes audio, the timing o the captioning (i.e., theequivalent alternative) should match the pace o the audio so that someone reading a caption would see thetext at an appropriate time to understand the video.LanguageWeb pages shall be designed so that allinormation conveyed with color is also available without color, or example rom context or markup.

InterpretationWhile this provision does not prohibit the use o color, it does require at least one alternativemethod o conveying any meaning associated with the use o color. For example, i a green light is to beclicked to advance a presentation slide and a red light to go backward, the application should identiy theadvance and go back unctions in some way other than just color. In this example, text that describes theunctions would suce (see gure 2-2).

Figure 2-3. Web-based Inormation Provision (a) requires that an appropriate text equivalent be provided orall images. Appropriate does not mean detailed but, rather, that the text equivalent adequatelydescribes the image content and unctionality (i any).

Not enough information. Too much unnecessary information. An appropriate text-equivalent of

the image.

(A) Image.

(B) Head and shoulder image o a

tricolored (white, brown, and black)dog wearing a black color.

(C) Image o a dogs ace.

Provision (c) LanguageDocuments shall be organized so they are readable without requiring an associatedstyle sheet.

InterpretationA style sheet denes the color, ont, text alignment, size, spacing, borders, etc. so as toestablish the appearance and ormatting o a web page. Some people with disabilities create their own stylesheets to help accommodate their specic needs (e.g., a user with low vision may increase ont size on thepages they view). This provision prohibits developers rom designing web pages that override style sheetspreviously dened by viewers.

Provision (d) LanguageRedundant text links shall be provided or each active region o a server-side imagemap.

InterpretationThis very technical provision simply requires that any image used as a map to link to anotherweb page must include a URL that a web viewer can read without additional communication with the webserver, which would be an additional burden or a disabled user because it delays the fow o inormation (seegure 2-4).


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Provision (e) LanguageClient-sideimage maps shall be providedinstead o server-side image mapsexcept where the regions cannot bedened with an available geometricshape.

InterpretationThis technical

provision requires that user-readable tags accompanynongeometric shapes that serveas maps by including alt tagsinside any area tag in any image.

Provision () LanguageRow andcolumn headers shall be identiedor data tables.

InterpretationThis provision,which requires that any rows

and columns in a data tableinclude labeled headers, is simply

Figure 2-4. Web-based Inormation Provision (e) requires thatimage link maps be readable by users withoutadditional exchange with the server. In thisexample, the mouse arrow highlights a dierentURL depending on which part o the image isbeing pointed to by the viewer.

www.fctionalteacherino.edu

www.fctionalstudentino.edu

a necessary step to presenting any tabular data. In other words, identiying row and column header labels isnecessary or any user including, but not limited to, people with disabilities.

Provision (g) LanguageMarkup shall be used to associate data cells and header cells or data tables thathave two or more logical levels o row or column headers.

InterpretationThis provision extends guidance in Provision (g) above based on the added need in largetables to label individual cells with both their column and row headings. Imagine, or example, a screenreader listing data or each cell in a table with 10 columns and 20 rows. This provision mandates that thecolumn and row heading labels accompany each cell so that the user is not expected to recall each row andcolumn heading based on headings listed once by the screen reader at the beginning o the table.

Provision (h) LanguageFrames shall be titled with text that acilitates rame identication and navigation.

InterpretationFrames are design tools that allow a web page to be divided into separately managed, andeectively independent, parts. While the visual appearance o rames may be seamless to sighted users(allowing or content in dierent rames to be visually linked), linking content across rames oten isdicult or many types o assistive technology tools, such as screen readers. For example, a navigation bar isoten separated rom web content by means o rames. Providing titles with text that clearly distinguishes anavigation rame rom a content rame helps users navigate the page more reasonably.

Provision (i) LanguagePages shall be designed to avoid causing the screen to ficker with a requencygreater than 2 Hz and lower than 55 Hz.

InterpretationThis provision is critical to accommodate the needs o viewers with photosensitive epilepsy,who can have seizures triggered by displays that ficker, fash, or blink, particularly in requencies greater than2 Hz and lower than 55 Hz, which are, thereore, prohibited.

Provision (j) LanguageA text-only page, with equivalent inormation or unctionality, shall be provided tomake a web site comply with the provisions o this part, when compliance cannot be accomplished in anyother way. The content o the text-only page shall be updated whenever the primary page changes.

InterpretationRunning parallel websites or people with and without disabilities is not recommendedin this document. However, in instances in which a web page cannot otherwise be designed to comply


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with Section 508 guidelines, this provision requires an alternative, text-only presentation o the page withequivalent inormation and unctionality. In order to preserve the integrity o the text-only alternative, itshould be updated whenever the primary page is changed.

Provision (k) LanguageWhen pages utilize scripting languages to display content, or to create interaceelements, the inormation provided by the script shall be identied with unctional text that can be readby assistive technology.

InterpretationThis provision requires that meaningul content be included in code in a manner that can beread by assistive technologies. Application and site developers should amiliarize themselves with the manyacceptable technical ways o placing unctional text within script and complying with this provision.

Provision (l) LanguageWhen a web page requires that an applet, plug-in or other application be presenton the client system to interpret page content, the page must provide a link to a plug-in or applet thatcomplies with 1194.21(a) through (l).

InterpretationThis provision requires that any proprietary application or transmitting or displayingcontent (e.g., Adobe Acrobats Portable Document Format Viewer, or PDF Viewer) be included as a link thatis readable by assistive technology tools. Providing this inormation is necessary or any user including, butnot limited to, people with disabilities. This provision simply ensures that the links are readable by assistive

technology tools.

Provision (m) LanguageWhen electronic orms are designed to be completed on-line, the orm shall allowpeople using assistive technology to access the inormation, eld elements, and unctionality required orcompletion and submission o the orm, including all directions and cues.

InterpretationThis provision requires that text labels be accessible near the eld elements they are intendedto describe. In other words, labels should correspond directly with orm input requirements (e.g., the studentname label should be tagged directly to its input eld rather than just somewhere on the page, so that ascreen reader can clearly identiy the relationship between the eld and the tag).

Provision (n) LanguageA method shall be provided that permits users to skip repetitive navigation links.

InterpretationThe content on many web pages does not begin until ater a pages heading and navigationalinormation. This provision requires that page design include a mechanism that permits viewers to skip thisrepetitive inormation and go directly to content. Such a capability is especially important or someone usinga screen reader, which would require that the entire navigation bar be read on each page prior to accessingcontent.

Provision (o) LanguageWhen a timed response is required, the user shall be alerted and given sucienttime to indicate more time is required.

InterpretationSome web applications are designed to time out when a response is not received in acertain amount o time. While this practice may support certain security-related purposes, people usingassistive technologies may sometimes need more time than other viewers to access, assimilate, and respond toweb content and prompts. This provision requires that a viewer be given an option (by means o a prompt) torequest additional time when necessary to enter a response.


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Web Content Accessibility Guidelines 1011

The WCAG 1.0 includes general principles o accessible web design that support and extend Section 508 web-basedintranet and internet inormation and applications standards described above (1194.22). WCAG 1.0 also includescheckpoints or each principle that explain how developers can operationalize Section 508 guidelines. Table 2-1 describeshow WCAG 1.0 recommendations align with Section 508 web standards. See appendix D or more inormation,including a WCAG 1.0 checklist (by priority level).

Table 2-1. WCAG 1.0 Checkpoints or Section 508 1194.22Web-Based Intranet and Internet Inormationand Applications Standards

Section 508Web Standard(1194.22 Web)

Related Web Content Accessibility Guidelines (Version 1.0)

Web Provision (a) Checkpoint 1.1Provide a text equivalent or every nontext element (e.g., via alt,longdesc, or in element content). This includes images, graphical representations o text(including symbols), image map regions, animations (e.g., animated GIFs), applets andprogrammatic objects, ASCII art, rames, scripts, images used as list bullets, spacers,graphical buttons, sounds (played with or without user interaction), stand-alone audio les,audio tracks o video, and video.

Web Provision (b) Checkpoint 1.4For any time-based multimedia presentation (e.g., a movie or animation),synchronize equivalent alternatives (e.g., captions or auditory descriptions o the visualtrack) with the presentation.

Web Provision (c) Checkpoint 2.1Ensure that all inormation conveyed with color is also available withoutcolor; or instance, rom context or markup.

Web Provision (d) Checkpoint 6.1Organize documents so that they may be read without style sheets. Forexample, when an HTML document is rendered without associated style sheets, it must stillbe possible to read the document.

Web Provision (e) Checkpoint 1.2Provide redundant text links or each active region o a server-side imagemap.

Web Provision () Checkpoint 9.1Provide client-side image maps instead o server-side image maps exceptwhere the regions cannot be dened with an available geometric shape.

Web Provision (g) Checkpoint 5.1For data tables, identiy row and column headers.

Web Provision (h) Checkpoint 5.2For data tables that have two or more logical levels o row or columnheaders, use markup to associate data cells and header cells.

Web Provision (i) Checkpoint 12.1Title each rame to acilitate rame identication and navigation.

Web Provision (j) Checkpoint 7.1Until user agents allow users to control fickering, avoid causing the screento ficker.

Web Provision (k) Checkpoint 11.4I, ater best eorts, you cannot create an accessible page, provide a linkto an alternative page that uses W3C technologies, is accessible, has equivalent inormation(or unctionality), and is updated as o ten as the inaccessible (original) page.

Note: Provisions (l), (m), (n), (o), and (p) do not align with WCAG 1.0.

11 For more inormation about the WCAG 1.0 recommendations, visit http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/.
http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/


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Web Content Accessibility Guidelines 2012

Organizations that have ully operationalized the basic standards established in WCAG 1.0 may wish to considerimplementing the WCAG 2.0 released in October 2008. WCAG 2.0 standards were introduced in an eort toincorporate a wider range o technologies that had become available since the 1999 publication o the WCAG 1.0recommendations. In many respects, WCAG 2.0 standards are not technology specic, but instead ocus on soundapproaches to presenting inormation on the web in an appropriate manner. As such, the 12 WCAG 2.0 recommendations

are organized into 4 principles: perceivable, operable, understandable, and robust.13

1. PerceivableInormation and user interace components must be presentable to users in ways they can perceive,meaning that the inormation being presented cannot be invisible to all o a users senses. This principle is urtherdemonstrated in the ollowing examples.

1.1 Text alternatives: Provide text alternatives or any nontext content so that it can be changed into other ormsthat people need, such as large print, braille, speech, symbols, or simpler language.

1.2 Time-based media: Provide alternatives or time-based media, including captions and alternatives or audioand video content.

1.3 Adaptable: Create content that can be presented in dierent ways (e.g., simpler layout) without losinginormation or structure; in other words, all content should be accessible through the use o assistivetechnologies.

1.4 Distinguishable: Use sucient contrast to make it easier or users to see and hear content, includingseparating the oreground rom the background.

2. OperableUser interace components and navigation must be operable, meaning that users must be able tooperate the interace and that the interace cannot require interaction that a user cannot perorm.

2.1 Keyboard accessible: Make all unctionality available rom a keyboard; that is, all unctionality should bekeyboard accessible.

2.2 Enough time: Provide users enough time to read and use content.

2.3 Seizures: Do not design content in a way that is known to cause seizures.

2.4 Navigable: Provide ways to help users navigate, nd content, and determine where they are; in other words,actively provide tools that help users to navigate and nd content.

3. UnderstandableInormation and the operation o user interace must be understandable, meaning that theinormation and the operation o the user interace cannot be beyond their understanding.

3.1 Readable: Make text readable and understandable.

3.2 Predictable: Make content appear and operate in predictable ways.

3.3 Input assistance: Help users avoid and correct mistakes.

4. RobustContent must be robust enough so that it can be interpreted reliably by a wide variety o user agents,including assistive technologies, meaning that users must be able to access the content as technologies advance

and evolve.4.1 Compatible: Maximize compatibility with current and uture user agents, including assistive technologies.

These guidelines are divided into testable success criteria. When evaluating a website or accessibility, or planning anaccessibility strategy, these success criteria can be assessed to make sure that WCAG 2.0 principles have been achieved(i.e., that they conorm with WCAG 2.0). A reerence guide to techniques or meeting all WCAG 2.0 recommendationsis available online at http://www.w3.org/WAI/WCAG20/quickre/ .

12 For more inormation about how the WCAG 2.0 recommendations dier rom WCAG 1.0, visit http://www.w3.org/WAI/WCAG20/rom10/di.php .13 These descriptions o the our WCAG 2.0 principles are urther discussed at http://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-ourprincs-head.
http://www.w3.org/WAI/WCAG20/quickref/http://www.w3.org/WAI/WCAG20/quickref/http://www.w3.org/WAI/WCAG20/from10/diff.phphttp://www.w3.org/WAI/WCAG20/from10/diff.phphttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-fourprincs-headhttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-fourprincs-headhttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-fourprincs-headhttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-fourprincs-headhttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.html#introduction-fourprincs-headhttp://www.w3.org/WAI/WCAG20/from10/diff.phphttp://www.w3.org/WAI/WCAG20/quickref/


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Chapter 3 How Do I Implement Section508 Accessibility Standards?

IntroductionImproving accessibility requires more eort than expertise. In act, most othe conceptual standards and the vast majority o the technical procedures ormaking EIT compliant with Section 508 standards are relatively straightorwardto implement. The greatest obstacles to success are a lack o commitment andperseverance.

Ensuring organizational commitment to Section 508 compliance is, in manyways, more easily achieved than it is or many technology initiatives. Unlikeinvesting in new computer systems, databases, or decision support systems, moststakeholders agree that improving the accessibility o EITs is always the right

thing to dothus, the question in many peoples minds is not whether to improve accessibility, but how, and how much,to improve accessibility.

Buy-in rom the policymakers and administrators who manage an organization is o utmost importance. These peopleestablish the day-to-day procedures and practices that support the organizations long-term priorities. I they agreethat accessibility is an organizational priority, the technical and content sta they manage will most likely be able toimprove the accessibility o the organizations EITs. I, on the other hand, educational leaders believe that accessibilityis unimportant (probably unlikely), unrealistic, or unachievable (a more likely scenario), then documents like this oneand resources such as those described in appendix A may help to convince them o both the merit and practicality ocommitting the organization to Section 508 compliance.

Conducting a Sel-AuditWith respect to Section 508 compliance, a sel-audit is anexamination o an organizations EITs to assess and/or veriy theaccessibility o these resources to people with disabilities. As describedin chapter 2, resources rom the ederal government (such as theUnited States Access Board) and other organizations (such as theW3C) can be used to identiy a checklist o items or evaluatingSection 508 compliance o EITs.

The product o a sel-audit is an inventory o the organizationsEITs accompanied by measures o compliance. While, in theory, apage-by-page audit o a website or a le-by-le audit o spreadsheets

is necessary to ully veriy compliance, an audit that provides anaccurate picture based on a air sample o these resources is advisableduring the early stages o planning. For example, a sel-audit mayreveal the ollowing:

O the 2,000 pages on our website, we reviewed 80 pages rom 6 dierent program areas to fnd that 20 othose pages (25 percent) were WCAG 1.0-compliant. No pages were compliant with WCAG 2.0.

While this inormation is not exhaustive, it does indicate that the organizations website is largely not compliant withSection 508and it provides enough inormation to develop a plan or improving accessibility. Note that a statistically

Challenge: Download a ree screen

reader (e.g., at http://www.screenreader.

net/ or http://www.nvda-project.org/)

on a test workstation and try to access

the inormation on a newspaper website.

Was it easy to pick the article you wanted

to read? Could you comprehend the

inormation? How much or little did it slow

you down? Does the experience change

your perspective on the need to improve

the accessibility o electronic resources?

The concepts outlined in this

chapter ocus on the stepsthatare particularly critical or, or

unique to, planning to introduce

Section 508 upgrades in an

education setting.
http://www.screenreader.net/http://www.screenreader.net/http://www.nvda-project.org/http://www.nvda-project.org/http://www.screenreader.net/http://www.screenreader.net/


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deensible approach to sampling web pages is not necessary to collect this useul inormation as long as common sense isused to sample a air representation o the website.

Establishing Perormance GoalsAlthough the results o a sel-audit are not required or settingperormance goals, audit ndings provide a reality check withrespect to the amount o work required to become Section508-compliant. Continuing with the example o working toimprove the compliance o an organizations 2,000 page website,planners next need to set goals or achieving compliance. Intheory, o course, 100 percent o a website should be Section508-compliant, but it is likely that interim goals that greatlyimprove the accessibility o the site are more realistic. Whenestablishing goals, good managers oten break larger tasks intosmaller, more manageable, modules that serve as test cases or thelarger eort and, perhaps more importantly, are accomplishable. Forexample, a reasonable and practical set o goals might be presentedas the ollowing:

Although the organization endeavors to make its entirewebsite Section 508-compliant, we will commit to improvingaccessibility over time in the ollowing manner. Eectiveimmediately, all new or updated web pages will comply withthe WCAG 1.0 checklist. Within 6 months, 90 percent o the200 most-viewed existing pages will comply with the WCAG1.0 checklist. Within 1 year, the most-visited 50 percent o ourweb pages will comply with the WCAG 1.0 checklist.

Developing a Project Plan

A thorough and realistic project plan is critical to eciently and eectively improving accessibility in an educationorganization. Good plans oten

start with something basic that sta members are likely to understand (e.g., the challenge that color codes presentto people who are color blind) rather than a component that may be important, but does not speak clearly to theirneeds or experiences (e.g., technical xes or clariying code);

build in evaluation time or a eedback loop that supports the iterative nature o developing, testing, andimplementing new initiativesas sta become more experienced with approaches and techniques or improvingaccessibility, they will grow in condence and require less time to implement subsequent improvements; and

stress extensibility, in which modules are expanded or customized ater initial implementation has beensuccessulonce stakeholders have retrotted a ew simple web pages, they can then address particularly popularpages prior to undertaking eorts to improve the entire website.

A project implementation plan should present work in discrete, manageable tasks. For example, retrotting an entire stateeducation agency website to become Section 508-compliant is a very big jobpotentially too big to be accomplished ina single step. Instead, more manageable tasks might be identied and prioritized, such as improving the accessibility o asmaller set o particularly popular web pages. Another approach might be to divide a large systemwide job into subtasksbased on data categories: public pages, student pages, student assessment, sta pages, etc. Activities in the implementationplan should be assigned, carried out, monitored, and completed in discrete units that can be comprehended, initiated, andaccomplished by members o the implementation team.

Mission-Critical Applications for Education

Institutions

Access to some EITs is more critical than

others. Areas in which EIT accessibility is

likely o greater importance include:

Inormation intended or routine studentand parent use

Inormation intended or broad public

dissemination

Inormation necessary or sta to

accomplish operations undamentalto the organizations core mission and

physical security.

Section 508 compliance is o paramount

importance to these mission-critical areas.


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A compliance schedule is an important part o any implementation plan, but a schedule is only eective when itsgoals and deadlines are realistic. I the goals are unattainable and deadlines are missed, subsequent deadlines lose theircredibility. Thus, a key issue that oten arises throughout the course o many large projects is schedule slippage.Organizational commitment to achieving Section 508 compliance gives project leaders condence to use theirmanagement skills to overcome deadline issues because they know that the project is important and that ailure will benoticed by the organizations leadership team.

raining StafAlthough many people, including those in the role o inormationtechnology specialists, appear to lack awareness o the requirementso Section 508 accessibility standards, the technical steps needed toimprove accessibility are not daunting. As such, training eorts canocus on the ollowing two overarching priorities:

1) improving awareness and explaining the rationale oraccessibility standards, and

2) pointing technical sta to existing resources that explicitlydescribe techniques or improving accessibility.

Because some o the techniques or improving accessibility are technicalin nature (i.e., or web developers) and others are content related (i.e., orprogram or data sta who prepare content or websites), it oten makessense to customize training or these two distinctly dierent groups osta.

Introducing the concept o Section 508 complianceTraining programs should be designed so that those unamiliarwith Section 508 standards will not be overwhelmed with technical details, while those stakeholders who bring someamiliarity with accessibility issues will not be bored. One strategy or providing this type o customized training programis to adopt a modular approach, with each module building upon content rom the previous session. Stakeholders canbegin training activities at the level that is most appropriate or their knowledge and experience. The initial trainingmodule might, or example, introduce the concept o accessibility and the goals o the Section 508 (and related state)laws without delving too deeply into technical details and terminology. A subsequent module might address moreormal terminology and model either technical- or content-related practices or improving accessibility, depending onthe audience type. A nal module would then describe the organizations preerred practices and long-term strategy orimproving accessibility and achieving compliance.

Including meaningul real examples to illustrate training pointsPeople who participate in training activities generallylearn better when they are exposed to concepts and techniques that can be readily applied to their everyday jobs. Trainingbecomes meaningul when it is clearly applicable to the duties o the participants. Good trainers oten illustrate pointsthrough the use o real-lie examples that are directly related to the duties o session participants.

Customizing training to match audience needsNot all stakeholders need to improve accessibility in the same way. For

example, web developers generally are responsible or the technical details o web page construction. Program sta, onthe other hand, oten ocus on what inormation belongs on a web page and how it should be presented. Customizingtraining content to meet unctional needs, while minimizing the presentation o less relevant inormation, makes trainingeorts more ecient and eective.

Maintaining appropriate governance structuresAs with other data governance and quality control initiatives, all partso the organization need to comply with Section 508 guidance. Independent entities, such as athletic departments orschool board committees, should not be able to develop external sites when they are really a part o the organization andshould be accountable or meeting standards.

It is unlikely that sta will understand

how to help an education organization

become Section 508-compliant unless

they

become aware o the law, practicalrecommendations, and relatedexpectations;

accept personal responsibility or

improving accessibility; andlearn how to become compliantthrough technical training.


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Dedicating Adequate ResourcesIn spite o the eort that goes into a sel-audit and project plan, it is airly simple to set goals and create plans. Achievinggoals according to plan, on the other hand, demands more work.

The policymakers and administrators who establish and managethe day-to-day procedures and practices guiding the organization

need to ormally task individual sta members or teams with theresponsibility o ensuring that web pages and other EITs complywith Section 508 to refect the organizations goals on this ront.Ater appropriate training (see above), individual programmers willneed to retrot the existing website based on managements priorities(e.g., improving accessibility on high priority pages in a targeted andmodular manner). In organizations with large websites or that areunder substantial time pressure (e.g., when acing a compliance-related

lawsuit), accomplishing compliance goals will likely require more resources than in smaller organizations that are in aposition to proactively transition to Section 508 compliance at a less aggressive pace.

New concepts, such as improving EIT

accessibility, become institutionalized by

establishing clear expectations;

delivering high-quality training; and

holding sta accountable in aconsistent and routine manner.

Making Accessibility a Part o Routine OperationsBecause many education organizations nd themselves with relatively extensive websites that are not yet Section508-compliant, senior leaders will likely nd themselves in retrot mode as they endeavor to improve accessibility.Once websites achieve reasonable accessibility goals (e.g., 100 percent o new or updated web pages and 90 percent othe 200 currently most-viewed pages are in compliance with the WCAG 1.0 checklist), leaders need to consider howto institutionalize Section 508 accessibility expectations. Maintaining website/EIT compliance requires eective statraining and ongoing accountability.

The reason education organizations share data with students, sta, parents, and community members is because theinormation is judged to be o value to the recipients. Ensuring that all stakeholders have adequate access to inormationabout educational organizations, processes, and perormance is air, necessary, and empowering. Doing so not onlyimproves access or people with disabilities, but also helps people who are aging or otherwise technologically challenged. It

also is the right thing to do.


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Appendix A Forum/NCES Resources& Selected State Laws and

Policies Governing Accessibleechnologies

Web Resources Reerenced in Tis Document

http://www.section508.gov/Section 508 o the Rehabilitation Act (29 U.S.C. 794d), as amended by theWorkorce Investment Act o 1998 (P.L. 105-220), August 7, 1998.

http://www.access-board.gov/index.htm The United States Access Board, a ederal agency committed to

accessible design.http://www.w3.org/The World Wide Web Consortium (W3C).

http://www.w3.org/WAI/The Web Accessibility Initiative (WAI).

http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/An introduction to Web ContentAccessibility Guidelines (WCAG) 1.0 recommendations.

http://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.htmlAn introduction to WCAG 2.0recommendations.

http://www.jimthatcher.com/index.htmA useul website or anyone looking to better understand theimplications o website accessibility.

http://www.w3.org/WAI/WCAG20/rom10/di.phpInormation about how the WCAG 2.0recommendations dier rom WCAG 1.0.

http://www.w3.org/WAI/WCAG20/quickre/ A quick reerence to WCAG 2.0 recommendations (successcriteria) and techniques.

http://www.access-board.gov/sec508/guide/A Guide to the Section 508 Standards or Electronic andInormation Technology.

http://www.access-board.gov/sec508/guide/1194.22.htm Provisions o Section 508 dealing specically withweb-based intranet and internet inormation and applications.

http://www.access-board.gov/sec508/guide/1194.21.htmProvisions o Section 508 dealing specically withsotware applications and operating systems.

http://www.vischeck.com/vischeck/A simulation tool or showing users what images and websites look like tosomeone who is color blind.

http://www.screenreader.net/ A ree screen reader to support blind and visually impaired computer users.

http://www.nvda-project.org/A ree and open source screen reader or the Microsot Windows operatingsystem.

http://www.census.gov/prod/2003pubs/c2kbr-17.pdDisability Status: 2000 (Census 2000 Brie). U.S. CensusBureau, accessed September 2010.
http://www.section508.gov/index.cfm?FuseAction=Content&ID=14http://www.section508.gov/index.cfm?FuseAction=Content&ID=14http://www.access-board.gov/index.htmhttp://www.access-board.gov/index.htmhttp://www.w3.org/http://www.w3.org/http://www.w3.org/WAI/http://www.w3.org/WAI/http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/http://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.htmlhttp://www.w3.org/TR/UNDERSTANDING-WCAG20/intro.htmlhttp://www.jimthatcher.com/index.htmhttp://www.w3.org/WAI/WCAG20/from10/diff.phphttp://www.w3.org/WAI/WCAG20/from10/diff.phphttp://www.w3.org/WAI/WCAG20/quickref/http://www.w3.org/WAI/WCAG20/quickref/http://www.access-board.gov/sec508/guide/http://www.access-board.gov/sec508/guide/http://www.access-board.gov/sec508/guide/1194.22.htmhttp://www.access-board.gov/sec508/guide/1194.22.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.access-board.gov/sec508/guide/1194.21.htmhttp://www.vischeck.com/vischeck/http://www.vischeck.com/vischeck/http://www.screenreader.net/http://www.screenreader.net/http://www.nvda-project.org/http://www.nvda-project.org/http://www.census.gov/prod/2003pubs/c2kbr-17.pdfhttp://www.census.gov/prod/2003pubs/c2kbr-17.pdfhttp://www.census.g

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