Talking with Microsoft's Gray Knowlton about MSOXML accessibility

Late last week, Gray Knowlton wrote a lengthy blog comment, sharing some of this thoughts about my review of the Microsoft white paper "Accessibility of Ecma Office Open XML File Formats" that Gray posted to the OpenXML Developer website. Given the importance of the office document accessibility, and the attention that ODF and MSOXML are getting with respect to accessibility, I wanted to continue the conversation directly in my blog (vs. buried in a comment to his comment). The rest of this is written directly to Gray...

First, Gray, thank you for talking the time to have this discussion - and thank you for correcting my misspelling of your name (oops!). You mentioned that you undertook this review "in part to educate a few individuals who claimed that “Open XML does not support accessibility”" but that "it was not intended to be a definitive guide to accessibility of Open XML". Can you tell me, has Microsoft - or anyone else - done a thorough review of MSOXML accessibility? Education, and "correction" of "significant misunderstandings" is one thing; a thoughtful and thorough accessibility review is another. Is this white paper the former, or the latter? If as you say it is the former, what about that thoughtful and thorough accessibility review?

Gray, at the start of your blog comment you say "I’m not sure that the “who did this?” question matters as much as your post seems to indicate", and you spend several paragraphs describing your (non-accessibility) background at Microsoft and Adobe. You also noted the name Reed Shaffner, as "a member of my team specifically focused on the accessibility of the Microsoft Office system", though you don't mention whether he was involved in writing this white paper (by the way, is this Reed Shaffner the author of these two blog posts? the new hire from Duke University who last year was a college senior and who presented a paper Linking Pgm allozyme and nucleotide variation in blue mussels at a Colorado Evolution conference?).

The reason I raise the question of authorship of the white paper is to better ascertain the level of accessibility expertise involved in the review. MSOXML has gone through the ECMA standards process, and is up for vote and adoption by the International Standards Organization, and is being evaluated by many countries and U.S. States for use and standardization in their organizations. Knowing whether a thoughtful and thorough accessibility evaluation was done on MSOXML has an impact on folks in many of these places.

Elsewhere in your comments, regarding my question about the use of WCAG 1.0, you note: "We are aware that the WCAG1.0 guidelines might not be the most appropriate of benchmarks today, but there are few finalised alternatives. I do work with our accessibility team on evaluating Open XML against the developing standards, and as I am sure you are aware we are active participants in these processes; however it would not be appropriate at this point to publish anything until those efforts are completed." I understand that issue, but then why do you use the XML Accessibility guidelines, which are only in draft form? It doesn't seem consistent to me...

And speaking of questions, I hope that we can continue this conversation, and that you might address the other questions I raised in my review. To quickly summarize them:

Blog question #2 (unaddressed):When and how will the accessibility failings cited in the paper be fixed?

In your evaluation, you note that MSOXML fails to support WCAG 1.0 checkpoints 4.2, 5.2, 9.4, 10.2, 12.1, 12.2, and 12.4, and that MSOXML only partially supports checkpoints WCAG 1.0 checkpoints 6.4, 8.1, 9.1, and 11.1. Some of these have quite significant impacts on folks with disabilities, including especially those who use assistive technologies to access office documents. For example, WCAG 1.0 Checkpoint 9.4 requires that you have a logical TAB order through all of the links, form controls, and objects within a document. Without this, keyboard only users won't be able to get to and manipulate all document content; screen reader users may miss some sections of content altogether. Another example: WCAG 1.0 Checkpoint 12.4 requires that all labels be explicitly associated with the objects they are labeling. Without this, blind folks using screen readers have a lot of trouble figuring out what a control is when they TAB so it - imaging hearing "edit field; edit field; edit field" as you TAB through a form, instead of "name edit field; address edit field; city edit field".

Blog question #4 (unaddressed): How does MSOXML meet accessibility needs outside of WCAG 1.0 & the W3C XML Accessibility draft? How well does MSOXML support translating into DAISY and Braille?

Perhaps your comment "The scope of the original project was not intended to provide the more significant contribution to the accessibility community you describe in your post" answers this, but it wasn't clear to me from your reply, and I don't want to make poor assumptions (misspelling your name is bad enough!). Does Microsoft know how well MSOXML supports the requirements of DAISY book creation? How well is supports the creation of Braille publications? How well it meets other accessibility needs? Does Microsoft have any experienced accessibility people looking at MSOXML, evaluating against accessibility needs independent of W3C accessibility specs?

Blog question #5 (unaddressed): Is there a difference between the phrases "supported" and "fully supported" in the white paper? When the white paper says that a provision is only "partially supported", what is missing?

Since you use "supported" in some places, and "fully supported" in others, it strongly implies there is a difference. Is there? Is merely "supported" less than full support? And when you note that MSOXML only "partially supports" an accessibility checkpoint, you don't say what is missing. Could you please elaborate on that missing support?

Blog question #6 (unaddressed): Why is the white paper so lacking in clear "supports" statements about the XML Accessibility guidelines?

The style change from the white paper text about WCAG 1.0 vs. XML Accessibility checkpoints almost suggests two different authors. But whatever the reason for it, it leaves a reader like me unable to form a clear picture of how MSOXML stacks up against the XML Accessibility checkpoints.

Separate from these questions - which I hope to read your answers to soon - I want to touch again on this comment of yours: "the scope of the original project was not intended to provide the more significant contribution to the accessibility community you describe in your post, but I posted this project to OpenXMLDeveloper.org specifically for this reason. I do hope this project can become the contribution that you and others have expressed interest in evaluating." Many people - me among them - are not in a position to review a 6,000+ page specification. Microsoft has been working on accessibility for at least the past 20 years, and is the author of that that massive specification. Shouldn't Microsoft have its experienced accessibility experts working on this, rather than hoping that others work on it for you?

On a different topic, I'm curious about your comment regarding my P.S. about an accessibility problem I noted in the PDF edition of the white paper. You said: "I am somewhat embarrassed to have not used the tools in Acrobat for making PDF documents more accessible. I did create a Tagged PDF, as you noted, but I haven’t installed Acrobat on my new hardware yet, so I did not have the ability to edit the PDF to correct this easily." Did you use Word 2007 to create the white paper, and the Export to PDF function to create the PDF? In other words, is this the result of a bug in the accessibility functionality of Word 2007's PDF export feature (as you say that you need Adobe Acrobat to "edit the PDF to correct this easily")?

Finally, fair is fair. You asked me a question:

Speaking of PDF, would you mind please pointing out the list of W3C recommendations supported by PDF/X-1a, PDF/X-3 and PDF/A? It’s been a few years, but I don’t recall the use of XForms, SVG or MathML in these specifications. These are all ISO standards today, so I’m curious to compare this with the ODF example you cited in your post.

First, let me forward you to Andrew Kirkpatrick of Adobe, who writes the Adobe Accessibility Blog, and who along with me and 40 other folks is a member of the Telecommunications and Electronic and Information Technology Advisory Committee providing recommendations for updates of accessibility standards issued under section 508 of the Rehabilitation Act and guidelines under Section 255 of the Telecommunications Act. Perhaps you met Andrew during your time at Adobe? In any case, Andrew and Adobe are the experts on PDF accessibility, not me and Sun...

That said, please let me observe that PDF/X-1a (also known as ISO 15930-1:2001) and PDF/X-3 (also known as ISO 15930-3:2002) are "graphic technology standards" for use in "prepress digital data exchange". They are subsets of the full PDF standard. They are not for editable office documents; rather they are for the final step in a print document's life prior to being sent to the printer (whether that document started out life as a spreadsheet or a glossy 4-color magazine advertisement). Mathematical equation editing happens upstream - in places like office documents or other formats dedicated to preserving all of the semantic meaning of the equation. Likewise the gathering of form data.

Anyway, where I believe it makes sense to ask these questions is with PDF/A-1 (also known as ISO 19005-1:2005). This is a "document management" standard, which is described as an "electronic document file format for long-term preservation". It is here (rather than while in transit to a printer) that the preservation of accessibility information is important, and where our accessibility attentions make sense. I haven't yet read that standard, so I can't speak to what W3C specifications it does or does not incorporate. As I find out more, I'll post the answers here.

Comments:

Peter,

minor correction: "thank you for TALKING the time" should be "... TAKING ...". ;-)

Bigger point: It took me a long time to work out what might be inaccessible about these document formats - they're available on the web (or by asking MS) after all. It only slowly became clear that you're talking about how usable they are by disabled people.

I stongly dislike it when people use an over-arching abstract word (without establishing a context) to mean something very specific, and expect the whole world to accept the resulting diminution of the English language. I doubt I'm alone here. Whether it's "unilateralist" to mean "a proponent of unilateral nuclear disarmament" or "abstention" to mean "abstention from some (unspecified) degree of sex", or "intellectual property" to mean "bogus patents", or here "accessibility" to mean "usablity by the disabled", YUCK!

We're not talking about whether the disabled can get to these formats (are they wide enough for a wheelchair?) but whether they can _use_ them - "accessibility" is thus the wrong word. So could you stick to plain English, please?

How about instead saying ".... whether ... can be used by the disabled ..." near the top of an article, and then using "usab{le,ility}" from then on?

Thanks in advance!

--
Alan Mackenzie (Ittersbach, Germany).

Posted by Alan Mackenzie on July 12, 2007 at 02:07 AM PDT #

Allthough you have a lot of critique I found the document created for developers on OOXML very enlightening as before a lot of people were claiming that ooxml did not support accesibility whilst ODF does. Is there a simular document by Sun that shows how the current ISO ODF standard compares to these accessibility standards ? so we can compare ?

Posted by Jeffrey on July 12, 2007 at 07:35 AM PDT #

Jeffrey, You'll be pleased to find documents relating to the OASIS accessiblity assessment of ODF 1.0 here, http://www.oasis-open.org/committees/tc_home.php?wg_abbrev=office#access-eval The ODF spec is published, so you can easily compare it to WCAG 1.0 if you were really interested in that. Regards,

Posted by John Drinkwater on July 12, 2007 at 10:10 AM PDT #

Hi Peter, I'm trying to post a (lengthy) response to your post, and I'm getting "Your comment was marked as spam and will not be displayed." -- can you help? Gray

Posted by Gray Knowlton on July 13, 2007 at 08:17 AM PDT #

Hi Peter,

I’m taking a break at the Microsoft World Wide Partner Conference in Denver. I’ve had a lot of great discussions about people using Open XML in their solutions; there are a lot of possibilities for folks to explore. It is great to see the interest level in the formats, and great to see real traction for this new standard.

I really hope you can see me as different from Ecma; I am not part of TC-45, I didn’t edit or review the specification drafts; in creating the reports, I was merely attempting to answer a question. I do hope this project can help illustrate what support already exists, and what might need improvement.

My work is different than the OASIS sub-committee in that I’m not really inventing something that wasn’t there, I’m only seeking to clarify what was part of Open XML from the beginning. Certainly there may be improvements to Open XML that will help, and I hope my project will contribute to that improvement. I would hope you would also approach the Open XML accessibility issues as an area where we can continue to see improvement even beyond the initial ISO submission. This would be consistent with your expectation of ODF, and I am definitely hoping for your continued contribution in this project as well.

I’ll happily continue to engage with you on the topic as long as we’re both helping to contribute to accessibility, rather than the Open XML vs. ODF Debate; that’s not something I’m interested in participating in. I'm sure you can see that I follow it closely, but I haven't participated because I would rather focus on what people are doing with the software instead.

I really hate to respond to your questions this way, but I'm going to quote your paragraphis as you did mine. I'm sure this is getting hard to ready by this point, but here goes.

"...but that "it was not intended to be a definitive guide to accessibility of Open XML". Can you tell me, has Microsoft - or anyone else - done a thorough review of MSOXML accessibility?"

This is a question that is probably best posed to the specification editors; I am not one of those. My review of this topic was only in response to a direct question. I do hope this project can provide meaningful input to Ecma, however.

"..."Education, and "correction" of "significant misunderstandings" is one thing; a thoughtful and thorough accessibility review is another. Is this white paper the former, or the latter? If as you say it is the former, what about that thoughtful and thorough accessibility review?"

I completely agree. As I indicated in my earlier comment, the current state of this project is definitely the former. The outcome implied by the latter is my reason for submitting the project to OpenXMLDeveloper.org. I do hope that through contribution in the community, this can be accomplished.

"...Gray, at the start of your blog comment you say "I’m not sure that the “who did this?” question matters as much as your post seems to indicate", and you spend several paragraphs describing your (non-accessibility) background at Microsoft and Adobe. You also noted the name Reed Shaffner, as "a member of my team specifically focused on the accessibility of the Microsoft Office system", though you don't mention whether he was involved in writing this white paper (by the way, is this Reed Shaffner the author of these two blog posts? the new hire from Duke University who last year was a college senior and who presented a paper Linking Pgm allozyme and nucleotide variation in blue mussels at a Colorado Evolution conference?)..."

Reed is absolutely committed to improving our support for assistive technologies, and for users with assistive technology needs, like you. I’m sure you will agree that the more people involved in this discussion the better… particularly people with his level of enthusiasm and vigor for the topic. Reed is one of many people at Microsoft who care deeply about the accessibility community, and as you know from your participation in various groups, there is great depth of knowledge and experience that we contribute to the conversation. We have a vibrant internal working group that strives to improve our products. Reed is a part of this overall effort within the company. I would encourage you to be supportive of those who are new to the technology area, rather than discouraging their contribution by attempting to highlight their level of inexperience.

"...The reason I raise the question of authorship of the white paper is to better ascertain the level of accessibility expertise involved in the review..."

This is a question that I intended to address directly in my prior comment on your blog (sorry for that.) To be as plain as possible, I am not an expert in accessibility technology. This project was led by me in response to a comment, and is intended to take a public guideline and apply Open XML to it. I would encourage you to engage with Ecma committee members to discuss accessibility of the Ecma spec, as they will likely have a different take on the issue than I do. If you joined Ecma TC-45, in fact, it would allow you to provide even more insight.

"...Elsewhere in your comments, regarding my question about the use of WCAG 1.0, you note: "We are aware that the WCAG1.0 guidelines might not be the most appropriate of benchmarks today, but there are few finalised alternatives. I do work with our accessibility team on evaluating Open XML against the developing standards, and as I am sure you are aware we are active participants in these processes; however it would not be appropriate at this point to publish anything until those efforts are completed." I understand that issue, but then why do you use the XML Accessibility guidelines, which are only in draft form? It doesn't seem consistent to me..."

Again, you are correct, and I’ll reiterate the intended goal of donating the project to OpenXMLDeveloper.org; I intend to arrive at the more thorough review you indicate, whether or not Ecma did, will do, or has planned. I chose those guidelines because they seemed somewhat reasonable, but in the WCAG 1.0 review, I found that many of the requirements (like image maps) aren’t totally relevant to documents; it’s why I added the XML guidelines as well, and also why the review was not thorough or fully completed. I had sufficiently demonstrated the point prior to completing this review, and (as you noted) there are other guidelines that are probably better for this evaluation, so the work was not completed prior to the migration to OpenXMLDeveloper.org.

I took great care in my reply and on the project itself to clearly label the work as “preliminary draft” – this is not finished material, there are changes that will be made to the existing findings, and new research will be done. I don’t think you should view this as something to take to a national body meeting and criticize Ecma 376 – this project will probably not withstand that level of scrutiny at this stage.

Blog question #2 (unaddressed):When and how will the accessibility failings cited in the paper be fixed?

Putting aside the "failings" comment, changes to the spec are entiredly dependent on Ecma, just like you cannot personally re-write ODF. After a more thorough review is completed, this project will be submitted to them for consideration in the future. This is similar to (but slightly different than) ODF 1.0, which has no accessibilty support, but does have an engaged committee to improve support in future versions.

Blog question #4 (unaddressed): How does MSOXML meet accessibility needs outside of WCAG 1.0 & the W3C XML Accessibility draft? How well does MSOXML support translating into DAISY and Braille?

This is a great takeaway from your first post; short answer: I don’t know, but we do plan to incorporate this evaluation into future efforts. This is precisely why I took the time to reply to you directly via your blog. I do hope you can continue to provide this type of input, it is very much appreciated. I also hope that TC45 members will follow along with this project and take any findings into account for future versions of the spec.

Does Microsoft have any experienced accessibility people looking at MSOXML, evaluating against accessibility needs independent of W3C accessibility specs?

Yes.

It's worth noting that "MSOXML" refers to something that doesn't exist. I'm happy with Ecma 376, DIS29500, EOOXML (if you have to) or plainly "Open XML Formats." I'm sure you'd correct me if I referred to ODF as "Open Office XML Document Format," (which unilke the realtionship that the acronym "MSOXML" implies,) was actually the original name for ODF in OASIS.

Blog question #5 (unaddressed): Is there a difference between the phrases "supported" and "fully supported" in the white paper? When the white paper says that a provision is only "partially supported", what is missing?

By asking to clarify “missing” support, I’d take your comment to mean that you’re looking to find problems rather than understand the specification and how it contributes to the accessibility community. I sense that this post is an attempt to use this report against Open XML in the future; for example, to have information you can use in an ISO committee meeting to criticize the specification. Since I don’t really consider this a political exercise, I’m not that interested in answering your question. But the language difference is duly noted, and will be corrected and specifics appropriately clarified.

Blog question #6 (unaddressed): Why is the white paper so lacking in clear "supports" statements about the XML Accessibility guidelines?

I hope that I clarified this earlier, but if not, I’ll just say that having sufficiently corrected the perception of the original commenter, it wasn’t necessary to go too much further on the research I had started. But I do agree that understanding these guidelines is useful. I’ll take this as good input for future research; I do hope to have a definitive answer at some point, but it wasn't done for the sake of excluding information.

Shouldn't Microsoft have its experienced accessibility experts working on this, rather than hoping that others work on it for you?

This is odd because I see comments a lot that say "Microsoft did this on their own and therefore Open XML should not be considered as a standard." Setting aside the apparent contradition in these two comments, I'll just say that the posting on OpenXMLDeveloper.org is precisely intended to drive a community-based consensus on Open XML accessibility. To answer your question, the Microsoft Office team spends a great deal of time reviewing accessibility support as well as participating in the broader accessibility community.

While Microsoft wrote the initial submission to Ecma which was 2,000 pages, it was Ecma TC45 that then worked on the spec and improved to by adding an additional 4,000 pages of information to improve interoperability of the spec. As you know, Microsoft spends a lot of energy in the accessibility community, sitting next to you in standards committees, promoting support for accessibility within our products and so on. That knowledge is consistently passed onto the Office product team and is evident in the great accessibility support that you see in Microsoft Office. This knowledge was also used when initially designing the Open XML spec, and only improved more once it was passed onto Ecma. It is reasonable to expect this will continue to improve this over time, just as the ODF specification did \*after\* they finished taking 1.0 through ISO.

In other words, is this the result of a bug in the accessibility functionality of Word 2007's PDF export feature (as you say that you need Adobe Acrobat to "edit the PDF to correct this easily")?

I did use the Office tool to export the document, although I can’t comment on why this specific issue happened. I can investigate further, but this is hard to do on a trade show floor :). You may be right, and I will check.

That said, please let me observe that PDF/X-1a (also known as ISO 15930-1:2001) and PDF/X-3 (also known as ISO 15930-3:2002) are "graphic technology standards" for use in "prepress digital data exchange"

I asked you this question because you raised the topic of SVG and XForms. You are quite correct that PDF/x family of standards is intended to improve the efficiency and reliability of pre-press document exchange. Vector graphics are a significant part of this exchange, and the ISO standard identified does not support SVG… in other words, the standard whose sole purpose is to improve predictability and reliability within print production workflows does not include SVG as a means for describing vector graphics. Since vector graphics are included in virtually every document exchanged in a pre-press environment, ratifying an ISO standard to enable this exchange that does not use a W3C Recommendation would seem contrary to your opinion on the re-use of standards. It seems that there is a strong precedent within ISO that does not agree with your point of view here.

It doesn’t mean SVG is good or bad, it only means that existing ISO specifications were ratified with support for different technology.

As SVG relates to accessibility, the National Center for Assistive Media has offered a strong position as well:

“SVG is a language for describing two-dimensional graphics in XML. SVG includes markup for text equivalents, but there is nearly non-existent support for SVG in assistive technology.” - http://ncam.wgbh.org/richmedia/mediatypes/SVG.php

I am not criticizing SVG here, but what I am saying is that unanimous consensus does not exist to say that all vector graphics should be described using SVG.

Anyway, where I believe it makes sense to ask these questions is with PDF/A-1 (also known as ISO 19005-1:2005). This is a “document management” standard, which is described as an “electronic document file format for long-term preservation”. It is here (rather than while in transit to a printer) that the preservation of accessibility information is important, and where our accessibility attentions make sense. I haven’t yet read that standard, so I can’t speak to what W3C specifications it does or does not incorporate. As I find out more, I’ll post the answers here.

I can help. I believe that XForms are not supported, nor is SVG. Andrew is welcome to comment as well if I’m not correct.

I do want to make it clear that I’m not criticizing either W3C recommendation (or any standard for that matter), it seems they have uses within technologies that some deem important. I’m not placing any value on supporting or not supporting standards within other standards (Open XML, for example, directly references the Dublin Core namespace), but what I am saying is that there are precedents within existing ISO standards where existing recommendations from the W3C were not supported.

It calls into question the validity of statements that would have you believe that this is “required” of proposed standards, particularly in ISO, where SVG and XForms have not been reviewed.

But all poking aside, Peter, I really do hope that we can have a constructive dialog on Open XML as it pertains to accessibility. As I stated earlier, I’m really not excited about the political debate. Again, I absolutely welcome your contribution, and I do value your input very much. Please look forward to updated information on the project soon. Please also look forward to contributions that reflect your input as well.

Regards,
Gray Knowlton,
Group Product Manager,
Microsoft Office

Posted by Gray on July 13, 2007 at 08:19 AM PDT #

Gary: Why wasn't ECMA able to produce a bug free ooxml standard? Why doesn't Microsoft license its patents under the same clear terms SUN Microsystem does? Why did they provoke the developer community with 6000 pages lacking substance? Why is the specification incomplete? What did Microsoft do to respond to criticism? It is very easy for Microsoft to resolve most of the problems. Yet, Microsoft does not. Microsoft plays the very same tricks it played with competition authorities and that makes professionals upset.

I thought the public criticism was over the top but then I read the documents myself. An OOXML ISO standard would be a disaster because the job isn't finished. Do you think it is good for your professional career to give birth to an ISO standard of the present quality? OOXML is dead in its fast-tracks. Microsoft could well succeed to turn it into an ISO standard but who would respect ISO standardisation anymore?

Posted by Bert on July 14, 2007 at 12:19 PM PDT #

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