Thursday Sep 05, 2013

"Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT)" was formally published today as a W3C Working Group Note

After an intense 16 months, the Web Content Accessibility Guidelines Working Group has published the Working Group Note "Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT)".

I want to thank my co-editors Michael Cooper and Andi Snow-Weaver; co-authors Loïc Martínez Normand, Mike Pluke, Andi Snow-Weaver, and Gregg Vanderheiden; and all of the active and engaged participants in the WCAG2ICT Task Force and the reviewing and approving participants in the WCAG Working Group for all that they have done to draft, review, and publish this Working Group Note in record time. I also want to specifically thank Andrew Kirkpatrick and Joshue O Connor, the new co-chairs of the WCAG Working Group for their 11th hour work to get this document published this week.

Even though this document was only published today, it has already had a tremendous impact on regulatory efforts in Europe and the United States. Previous drafts of WCAG2ICT from last July and from last December formed the basis of the European procurement standards effort Mandate 376 and specifically the draft technical standard EN 301 549. Similarly in the United States, the U.S. Access Board decided to use the Web Content Accessibility Guidelines 2.0 as the basis the refresh of Section 508 ICT accessibility standards as they are applied to non-web documents and software (as set forth in their 2011 Draft Rule).

I'm certain I speak for all members of the WCAG2ICT Task Force and the WCAG Working Group when I say that we look forward to the completed Mandate 376 and Section 508 refresh work, and hope that our Working Group Note will have proven helpful in the efforts to develop effective, meaningful, and globally harmonized accessibility standards for ICT procurement.

Monday Dec 17, 2012

Applying WCAG 2.0 to Non-Web ICT: second draft published from WCAG2ICT Task Force - for public review

Last Thursday the W3C published an updated Working Draft of Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies. As I noted last July when the first draft was published, the motivation for this guidance comes from the Section 508 refresh draft, and also the European Mandate 376 draft, both of which seek to apply the WCAG 2.0 level A and AA Success Criteria to non-web ICT documents and software.

This second Working Draft represents a major step forward in harmonization with the December 5th, 2012 Mandate 376 draft documents, including specifically Draft EN 301549 "European accessibility requirements for public procurement of ICT products and services". This work greatly increases the likelihood of harmonization between the European and American technical standards for accessibility, for web sites and web applications, non-web documents, and non-web software.

As I noted last October at the European Policy Centre event: "The Accessibility Act – Ensuring access to goods and services across the EU", and again last month at the follow-up EPC event: "Accessibility - From European challenge to global opportunity", "There isn't a 'German Macular Degernation', a 'French Cerebral Palsy', an 'American Autism Spectrum Disorder'. Disabilities are part of the human condition. They’re not unique to any one country or geography – just like ICT. Even the built environment – phones, trains and cars – is the same worldwide. The definition of ‘accessible’ should be global – and the solutions should be too. Harmonization should be global, and not just EU-wide. It doesn’t make sense for the EU to have a different definition to the US or Japan." With these latest drafts from the W3C and Mandate 376 team, we've moved a major step forward toward that goal of a global "definition of 'accessible' ICT."

I strongly encourage all interested parties to read the Call for Review, and to submit comments during the current review period, which runs through 15 February 2013. Comments should be sent to public-wcag2ict-comments-AT-w3.org. I want to thank my colleagues on the WCAG2ICT Task Force for the incredible time and energy and expertise they brought to this work - including particularly my co-authors Judy Brewer, Loïc Martínez Normand, Mike Pluke, Andi Snow-Weaver, and Gregg Vanderheiden; and the document editors Michael Cooper, and Andi Snow-Weaver.

Friday Jul 27, 2012

Applying WCAG 2.0 to Non-Web ICT: first draft published from WCAG2ICT Task Force - for public review

Last December the U.S. Access Board published the second Advanced Notice of Proposed Rulemaking for refreshing the Section 508 Accessibility Standards which describe the accessibility support that should be in Information and Communication Technologies that are purchased by U.S. federal agencies [many U.S. States and Universities also apply these standards to their ICT purchases; and in Europe the emerging Mandate 376 effort seeks to do the same for European government purchases].

One particularly interesting thing in this second draft is the idea of applying the Web Content Accessibility Guidelines version 2.0 (AA level) to non-web platforms and applications. This is set forth in provision E207.2 WCAG Conformance which states: "User interface components and content of platforms and applications shall conform to Level A and Level AA Success Criteria and Conformance Requirements specified for web pages in WCAG 2.0 (incorporated by reference in Chapter 1)." In explaining this decision, the Access Board noted that: "WCAG is written to be technology neutral. While oriented towards web pages which are defined as being delivered using HTTP, it is straightforward to apply the WCAG 2.0 Success Criteria and Conformance Requirements to user interface components and content of platforms and applications."

Many of public comments to the Access Board praised the significant use of WCAG 2.0 throughout this draft, and appreciated the potential to simplify the standard, but raised concerns that for a number of the WCAG 2.0 Success Criteria it wasn't so straightforward to do this. The April 2012 M376 draft followed the Access Board's lead in using WCAG 2.0 but noted a number of places where they felt it didn't apply to non-web ICT.

To better clarify this use of WCAG 2.0, Oracle joined with a number of our colleagues working in industry, disability advocacy, U.S. and European accessibility standards bodies, and U.S. Federal agencies - all with deep accessibility technology expertise as well as WCAG 2.0 knowledge - to develop guidance in applying WCAG to non-web ICT as part of a new W3C WAI Task Force: "WCAG2ICT".

After a couple months of very intense work, earlier today we published our first public draft for comments of Applying WCAG 2.0 to Non-Web Information and Communications Technologies. I strongly encourage all interested parties to review this draft, and submit comments during the current review period, which runs through 7 September 2012 (details in the Status of This Document section).

I also want to thank the participants of the WCAG2ICT Task Force for the incredible time and energy and expertise they brought to this work - including particularly my co-authors Judy Brewer, Loïc Martínez Normand, Mike Pluke, Andi Snow-Weaver, and Gregg Vanderheiden; and the document editors Shadi Abou-Zahra, Michael Cooper, and Andi Snow-Weaver.

Tuesday Mar 13, 2012

The Section 508 refresh moves forward - Oracle comments to the ANPRM

Last December the U.S. Access Board published their second Advanced Notice of Proposed Rulemaking ("2011 ANPRM") - a second draft of the new accessibility regulations for Federal procurement of Information and Communication Technologies (ICT). Comments on this draft were due March 7th.

The draft rules generated over 70 public comments, addressing various aspects of the new rules. I coordinated Oracle's public comments on the 2011 ANPRM, and also spoke at the public hearing they held at the CSUN conference two weeks ago.

I have had the pleasure of being closely involved in the Section 508 refresh process from the beginning, as part of the advisory committee to the Access Board which produced an advisory report to help the Board create their refreshed rules. I am very much looking forward to the next steps in this process, and particularly to the final rule, which should be a major step forward.

Thursday Jun 24, 2010

The next step in the Section 508/255 Refresh, and Oracle's public comments

Background

When Congress amended the Federal Rehabilitation Act in 1997, it directed the U.S. Access Board to create a set of Accessibility Standards that would apply to Electronic and Information Technology (E&IT) procured by the U.S. Federal Government (known as the "Section 508 standards"). It further directed the Access Board to periodically refresh these standards.

Likewise when Congress passed the Telecommunications Act of 1996, it directed the U.S. Access Board to develop a set of guidelines for telecommunications accessibility (known as "Section 255 guidelines"). It likewise further directed the Access Board to periodically refresh these guidelines.

In 2006 the Access Board convened the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) to advise them on a converged set of accessibility provisions to apply to both Federal Procurement (Section 508) and telecommunications more broadly (Section 255). In April, 2008 TEITAC delivered their final report, containing their recommendations for a common set of accessibility provisions to cover both E&IT, and telecommunications products.

The ANPRM

Last March, the Access Board announced the availability of an Advanced Notice of Proposed Rulemaking - an early preview of the their proposed accessibility provisions to cover E&IT and telecommunications (now together also called simply Information Communications Technology or ICT).

This past Monday, the 90-day comment period closed, with more than 150 public comments submitted to regulations.gov. Among those are the public comments from Oracle, primarily authored by myself and Accessibility Program Director Peter Wallack (with contributions gathered from numerous Oracle engineering teams).

To broadly summarize the key Oracle comments (including those from the public hearing in March):

  • The proposed standards significant advance the framework for accessible ICT procurement.

  • Harmonizing with WCAG 2.0 AA is very welcome (and we have specific suggestions to tweek how that is done in the proposed provisions).

  • Recognition of the "dance of three" - platform responsibilities, application responsibilities, and assistive technology responsibilities - is welcome and very important (and we have specific suggestions to tweek how that is accomplished).

  • Formal requirements for tools used to author electronic documents are important (with more specific "tweek" suggestions).

  • Care must be taken with provisions around movie playback and VoIP software. The provisions should not transform general purpose computers that incidentally have such features (e.g. a server with a DVD drive on it, or downloaded Skype software added after the fact) inadvertently into "movie players" and "telephones", which are required to have a "CC" button on them or otherwise meet hardware requirements relating to "telephones".

  • 508 general exception §1194.3(f) - the so-called "back office exception" - shouldn't be completely removed. A narrowly tailored exception that would both require all "remote-able" user interfaces to be accessible while allowing physical interaction needed solely for maintenance, repair, or occasional monitoring to be excepted from compliance is important. The design of data centers essentially requires full use of the 8+ feet of height of server racks, necessitating that some switches and other physical controls be out of reach of someone in a wheelchair.

  • The Access Board's recognition that some ICT may receive "patches" to fix bugs or clean up functionality shouldn't trigger a reappraisal of accessibility provisions is welcome. Numerous Oracle customers have stable editions of our products and platforms (e.g. Solaris 8) in production systems that they will continue to maintain for many years into the future - as they have already done for more than a decade. It is important to recognize that the "expected life" of major ICT products can be decades.

Next steps

Now that the Access Board has closed the comment period, it will carefully read and review the thousands of pages of comments they have received. After their thorough analysis of them, they will issued a revised set of proposed provisions - a formal Notice of Proposed Rulemaking. And after another public comment period (and likely another thousand or so pages of comments), a second review and finally issuance of their Final Rule. And soon after that, ICT products procured by the U.S. Federal government (and the many States and Universities that likewise apply 508) - not to mention telecommunications under the jurisdiction of the FCC - will need to meet the updated accessibility provisions.

And while that is some time into the future - already ICT companies are delivering products into the market that meet many of the newly proposed provisions. For example, AOL already has real-time-text support in AOL Instant Messenger. Numerous software video playback products support and decode closed captions. The Java and GNOME platforms (including Solaris and other GNU/Linux environments) - along with the Apple Macintosh and iPhone/iPad, and the RIM Blackberry family of phones - define a rich set of Accessibility Services that are supported by many thousands of applications and which enable assistive technologies to provide access without any need for reverse engineering. And a growing number of websites are already making use of WCAG 2.0 and the emerging WAI-ARIA specification for Rich Internet Application accessibility.

So even though the refresh effort is far from complete, it is already having a profound influence on what is being developed and shipped today!

Sunday Apr 06, 2008

Presentation of the TEITAC report to the U.S. Access Board

Last Thursday, April 3rd, the Telecommunications and Electronic and Information Technology Advisory Committee (or TEITAC for short) presented their final report to the United States Access Board. It was the culmination of more than 18 months of very hard work by a very talented group of 41 representatives and their alternates who were representing their respective companies, disability organizations, government agencies, and countries.

As one of the, shall we say "more vigorous", members of TEITAC, I find myself with a whole constellation of emotions having reached this important milestone and the formal conclusion of my TEITAC duties. I am incredibly proud of the report we produced. We tackled many very challenging issues, and reached consensus on a large subset of them. The process was intellectually stimulating - and at times wearing - but always very engaging and valuable. I got to work with a number of folks I have long respected, and I got to meet and work with many new-to-me folks who brought a tremendous amount of energy and thought to the process. I look forward to continuing to work both sets of colleagues in the years to come.

While the 41 folks reached consensus on the majority of the issues, there were about a dozen "minority reports" that were contributed from members - underscoring the importance of language that did reach consensus, as well as arguing alternately for or against language that is included but which did not reach consensus. These "minority reports" are uniformly thoughtful, and also worth reading. Reports were contributed from: ATIA; from Adobe; from CITA and The Telecommunications Industry Association; from IBM; from the Information Technology industry Council; from Microsoft; from the National Association of State Chief Information Officers and Association of Assistive Technology Act Programs; from Panasonic; from Sun Microsystems; from the Trace R&D Center; and from the Web Accessibility Initiative of the W3C.

The next step in the process is for the U.S. Access Board to digest this volume of material, and produce their own draft set of provisions, and to produce a regulatory assessment of what such a draft would entail. These will then be molded into their Notice of Proposed Rulemaking. Published in the Federal Register, these proposed rules will be open to public comment for a period of some weeks. After reviewing comments, the U.S. Access Board will issue their Final Rule, which will specify the standards for accessibility under which procurement of Electronic and Information Technology by the U.S. Federal Government shall take place. They shall also specify the guidelines for accessibility that apply to telecommunications products shall be subject to in the United States. Like many folks, I eagerly await the first formal indications of the Access Boards thoughts, which may expect to first appear on the refresh website.

Wednesday Feb 27, 2008

In the 'TEITAC' home stretch!

With an odd mixture of joy, relief, and maybe a little bit of sadness (but mostly relief), I read that "The Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) will deliver its report to the Board on April 3, 2008" in this web news release on the webiste of the U.S. Access Board. This release notes that:

The Committee’s report will be the basis for the Board’s first update of the Section 508 standards since their original publication in 2000. The Board will review the Committee recommendations and issue an update proposal which will be available for public comment.

Along with my Sun colleague (and TEITAC Editorial Working Group member) Michele Budris, and colleagues from 40 other companies organizations, I have been working on the Update of the Section 508 Standards and the Telecommunications Act Guidelines since the first meeting in October 2006. During 26 days of face to face plenary meetings, 38 hours of teleconference plenary meetings, regular weekly meetings among 8 subcommittees (which were open to public participation) - not to mention meetings of more than a dozen ad-hoc task groups) - we have largely reached consensus on the draft of our recommendations that we will be delivering to the Access Board in early April. That meeting will be held at the Grand Hayatt in downtown Washington DC, followed by what is rumored to be a black tie reception. But before we all get to dress up, we have to finish the final stretch (a last 14 hours of meetings).

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Peter Korn

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