The Disability Rights Commission - Formal Investigation in Web Accessibility
Will recommendations arising from this investigation promote the advancement of web accessibility?
by Pat Byrne 04/24/04
A formal investigation by the Disability Rights Commission (DRC): 'The Web: Access and Inclusion for Disabled People' [1], conducted by the Human Computer interaction Design at City University, London, April, 2004, reveals the extent of web accessibility problems in the UK.
One thousand publicly accessible websites were tested to check their technical compliance with the Web Content Accessibility Guidelines 1.0 World Wide Web Consortium's Web Initiative Accessibility (W3C WAI) Standards [2]. The investigation also involved disabled people, with different impairments, and accessibility experts in evaluating the usability and practical accessibility of the sites.
To examine reasons for any shortcomings identified the views of organisations likely to commission websites and website developers were also sought.
Despite it being widely accepted that, by law, websites in the UK are required to be accessible under the Disability Discrimination Act (Part 3) [3] findings from the DRC investigation showed that legal obligations are not, for the main part, being fulfilled:
0f the 1000 websites tested, 81% failed to achieve the minimum (Priority 1 or Level A standard) of W3C WAI Web Content Accessibility Guidelines. [4]
Only 2 of the 1000 sites tested met WAI's Priority 2 or Level AA standard - which states:
'A Web content developer should satisfy this checkpoint. Otherwise, one or more groups will find it difficult to access information in the document. Satisfying this checkpoint will remove significant barriers to accessing Web documents'.
None of the sites tested achieved Priority 3 or Level AAA - the highest level of compliance within the WAI guidelines.
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Thus not surprisingly the evaluation of a representative 10% sites identified a number of accessibility and usability problems.
Compliance with WAI guidelines does not in itself ensure that sites are 'practically accessible and usable by disabled people.' The report states that as many as 45% of the problems encountered by disabled users did not violate any of the W3C WAI Checkpoints.
The investigation concluded that problems relating to web accessibility and usability can only be resolved by including disabled users directly in the design and evaluation of websites.
Recommendations
The study produced a number of detailed findings and provided recommendations. For example:
- Increased training and awareness raising
- Improved access to the latest versions of assistive technology and products, by disabled people, and training in their use
- Provision of clearer web accessibility guidelines
- Development web accessibility policy and procedures
- The development, by the Government, of best practice guidance
- Promotion of a formal accreditation process for website developers and a register of accredited website developers
- Inclusion of disabled people, with various impairments, in the design and development process from an early stage
In drawing comparisons between the results of automated testing and user evaluations the study showed that 'automated tests alone do not predict the experience of disabled people when using websites.' The report suggests that website designers have an inadequate understanding of the needs of disabled users and also with regard to the creation of accessible websites. Thus concluding that designers alone cannot be expected to recognise and remedy problems relating to web accessibility and suggest that these can only be resolved by including disabled users directly in the design and evaluation of websites.
Government Best Practice Guidelines
The DRC report recommends that as a minimum the Government, should develop best practice guidelines, ensuring that such guidance:
- prescribes a process for the development of accessible websites which involves disabled users throughout the development cycle, from initial design through to final usability testing
- provides for the maintenance of websites with regular internal and external checking for accessibility
- promotes a formal accreditation process for website developers, and a register of accredited website developers who have been appropriately trained and who abide by the guidance
- promotes a certification scheme, comprising an accessibility kite mark, so that website commissioners can demonstrate that their website has been developed in accordance with guidance.
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p>Recommendations were also made with regard to policy development; stating that web commissioners should formulate written policies ensuring that: as a minimum
disabled people, with a range of sensory, cognitive and mobility impairments are involved from early on in the process of website design and development
The need for human judgement
The study highlights the need for qualitative decision making and the involvement of website accessibility professionals. Recommendations include: support for website developers in manually checking issues requiring human judgement.
The need for expertise and human judgement in evaluating web accessibility has been discussed elsewhere and Witt & McDermott [5]have argued that the creation of accessible solutions is very much an art, pointing to the levels of interpretation and subjective judgements required as a result of the range of standards and guidelines. Commenting on 'Bobby' [6]one of the most commonly used diagnostic tools, Witt and McDermott [7]argue that its effective use is dependent upon the ability of the web developer to interpret the final report. Maurice Franceschi [8] has recently highlighted specific problems in using these tools and shared his solutions.
There is considerable agreement that there is need for human judgement with regard to the development of accessible and usable websites. David Sloan [9] in his article 'Creating accessible e-learning content' points out that 'manual intervention will always be required', he suggests that although a resource may be technically validated as accessible, significant problems may remain.
Therefore, it is essential that the usability and practical accessibility problems disabled people, with various impairments, experience when using the Internet, be identified. Additionally, knowledge and skills are required in order to design and develop accessible and usable websites. Problems creating barriers to usability and accessibility for disabled people need to be understood and solutions applied. There are various ways that websites can be assessed for accessibility and usability.
Assessing websites for accessibility and usability
When assessing websites for accessibility, Sloan advocates using a range of approaches [10], including:
- checking tools
- testing in different browsing environments, including non-graphic browsers such as Lynx
- using the resource with assistive the technologies including screen readers and speech browsers or screen magnifiers
- manually checking resources by asking questions such as:
can the resource be used without a mouse?
can the users adjust text size and style?
does the site remain readable when style information is removed? - evaluating the resource with disabled people
He advocates the use of the W3Cs Authoring Tool Accessibility Guidelines (ATAG)[11] , which provides a checklist of features with which authoring tools should comply to ensure that content produced is as accessible as possible. Sloan also points out that 'some issues will only become apparent when observing a disabled person use the resource'. [12]
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p>A similar approach to ensuring web sites are accessible is recommended by W3C WAI, who suggest that:
No single evaluation tool yet provides comprehensive information or captures all problems with regard to the accessibility of a site; therefore evaluation involves a combination of approaches. [13]
Benefits of involving disabled people in providing feedback are highlighted with regard to accessibility and usability.
Expert and novice users with disabilities will provide valuable feedback about accessibility or usability problems and their severity.[14]
Notwithstanding, the recognised value of th involvement of disabled people within the process of developing accessible and usable websites, some problems could arise with regard to the very prescriptive recommendations arising from the DRC investigation. The report states that web developers as a minimum should involve disabled people with various impairments throughout the design and development process. Such course of action may require to be carefully considered.
It may be that in some establishments it could be comparatively easy to involve disabled people, with a range of impairments, in website development and evaluation. For example:
- Within large educational institutions with an equal opportunities policy, an awareness of web accessibility issues; and a legal requirement to make 'reasonable adjustments' for disabled students with a range of impairments, and where students are regularly entering new programmes.
- In large organisations, where staff employed may have a range of impairments; and where there are plentiful resources
However, this recommendation may prove more difficult to fulfil for web developers, who are self-employed or work with a small organisation with fewer resources.
It is a concept which throws up a number of issues including:
- the logistics of identifying and recruiting disabled people with a range of impairments:
- the perception that such evaluators are a resource?
would they be seen as altruistic volunteers or would they be paid workers or consultants?
would their usefulness cease or would it increase when they become 'experts', with perhaps more informed responses?
Moreover, it cannot be assumed that all disabled people, with the same impairment, experience the same difficulties, nor will they necessarily encounter the same barriers when accessing the WWW. Like all users they will also have personal preferences and subjective opinions. Writing in relation to the DRC's formal investigation, David Sloan examines some of these issues raised; he points to the advantages of involving disabled users in the process of designing and developing accessible websites and suggests that perhaps they should be viewed as 'customers rather than "accessibility" testers. [15]
It may be that some clarification is required with regard to this recommendation, particularly, with regard to web commissioners' policy development and the production of Government guidelines. Whilst theoretically, the inclusion of disabled people, with a range of impairments, in the development of websites could be very beneficial, it will not always be practical and in some cases impossible. The notion that such a requirement is always, or is 'as a minimum' essential could slow down the production of accessible and usable websites. This would be the case if the recommendations relating to Government Guidance and Policy Development have to be interpreted as meaning that all web designers, whether, accessibility/usability experts, or otherwise, must always, for every website they create, work within guidance or policy stipulating that disabled people with a range of impairments are involved at every stage of the process as such criteria could prove difficult to meet.
The identification of experts in the field of web accessibility should prove somewhat simpler, and presumably many of these people will have worked extensively with disabled people; they may themselves have impairments, have worked closely with organisations representing disabled groups, produced guidelines, informative articles, raised awareness and significantly contributed to the advancement of web accessibility in various ways. Many of them will be knowledgeable with regard to the needs of individuals with various impairments accessing the WWW. However, they will not necessarily be involving disabled people throughout the design process of every website they develop.
Sloan [16] has demonstrated an in depth understanding of the requirements of people with different impairments and like other experts in this field can go beyond the identification of barriers to web accessibility, as experienced by particular groups, to offering solutions.
The DRC study emphasises the need for expertise, and advocates the promotion of accredited web developers with genuine expertise in the field of accessibility. Many of these can be found within the Guild of Accessible Web Designers.
An association of organisations and accessible web designers and developers - it is designed to both promote and protect standards - not technical standards - but accessible web design standards. [17]
The Guild already includes within its membership many internationally recognised experts in the field, committed to promoting mutual support and learning with regard to web accessibility.
Currently there exist organisations where there is a high level of expertise in the field of web accessibility; also committed disability officers, aware of, and keen to, comply with legislation and promote the needs of disabled staff, customers, potential clients and students. Furthermore, there may also exist the opportunity to include disabled people, as valued stakeholders, in the web design and development process. However, problems can arise with regard to: (a) who controls the project and (b) whether they view web accessibility as important.
It could be argued that one of the main issues holding back the advancement of web accessibility is highlighted in the report, where it is stated that:
'The recurrent barriers to achieving accessibility'... 'appear to be a combination of unsupported assumptions about what it takes to achieve an accessible website and of ignorance about how to tackle access issues even when the will to do so is already present'.
In examining university web policies in the USA, Paul Ryan Bohman points out that ' Most university policies fall short of achieving their purpose; highlighting the key problem as the failure to define technical standard within universities' web accessibility policies. [18]
Government guidelines with regard to policy could be usefully applied here. The investigation highlighted the fact that only 2 of the 1000 sites tested achieved Level AA - the study also reveals that in particular usability and practical accessibility issues were encountered by blind people. Checkpoints relating to this standard, unless addressed, will always mean that blind people, also people with other impairments, will encounter barriers to access. Recommendations in the study, with regard to policy, ask only that policies explain what standard of accessibility is to be achieved and to bear in mind the WAI view that unless Level AA is the standard used then one or more impairments groups will find it difficult to gain access to its content.
It would appear from the findings in the investigation that a stronger recommendation could be made and that at a minimum policies should identify Level AA as the standard to be adopted, otherwise, blind users may continue to constitute 'the most disenfranchised group'.
It could be argued that, where web design and developers have a high level of skill in the development of accessible websites, and a thorough knowledge of the barriers encountered by people with different impairments, the involvement of disabled people, would be less critical, albeit still valuable if available.
The Policy of the DRC has been to seek improvement and the investigation has identified five websites,[19] which were deemed to be the most accessible and usable, rather than identify the worse sites. However, Bert Massie of the DRC, has stated that in the future, where response to web accessibility is inadequate then the Commission will 'be vigorous in the use of our enforcement powers'. Sanctions may be taken against owners of inaccessible websites and support will be provided for test cases being brought by individual disabled people. Offenders may also be named and shamed.
Enforcement, bringing legal action and adverse publicity, could drive forward the uptake of accessible and usable web design practice and ensure that Disability Discrimination legislation is upheld so that disabled people are not disadvantaged when accessing the Internet. This first web accessibility investigation by the DRC has been significant in raising awareness regarding the issue of web accessibility; highlighting the dearth of accessible and usable websites; identifying problems relating to the design and development of accessible websites, which place disabled people at a disadvantage. It has also made some very useful recommendations including the need for an accredited body, however, some recommendations such as: as a minimum involving disabled people, with a range of impairments, at all stages of the web design and development process, may prove impractical and even impossible. An opportunity may also have been lost to recommend much more emphatically the need for a minimum standard at Level AA, because:
'A Web content developer should satisfy this checkpoint. Otherwise, one or more groups will find it difficult to access information in the document. Satisfying this checkpoint will remove significant barriers to accessing Web documents'.[20]
Pat Byrne, 24th April, 2004.
References:
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http://www.drc-gb.org/publicationsandreports/report.asp
http://www.w3.org/TR/WCAG10/#def-checkpoint
http://www.disability.gov.uk/dda/#part2b
http://www.w3.org/TR/WCAG10/#priorities
(cited in 'Access All Areas', Phipps, Sutherland and Seale.)
http://www.techdis.ac.uk/accessallareas/AAA.pdf
http://bobby.watchfire.com/bobby/html/en/index.jsp
href="http://www.techdis.ac.uk/accessallareas/AAA.pdf
http://www.mcu.org.uk
http://www.techdis.ac.uk/accessallareas/AAA.pdf
http://www.w3.org/WAI/eval/
http://www.w3.org/TR/WCAG10/
http://www.dmag.org.uk/resources/design_articles/testingwortheffort.asp
http://www.techdis.ac.uk/accessallareas/AAA.pdf
http://www.gawds.org
(A pilot study and preliminary findings)
. Webaim Web Accessibility in Mind.
December 20, 2003
http://www.webaim.org/coordination/articles/policies-pilot
date downloaded 22nd December, 2003.
http://www.theregister.com/2004/04/15/drc_names_notshames/
date downloaded 22nd April, 2004.