Tuesday Jul 24, 2007

University of Toronto white paper "Accessibility Issues with OOXML"

Jutta Treviranus, Director of the Adaptive Technology Resource Centre and Dr. Stephen A. Hockema, faculty member of Information Studies - both at the University of Toronto - have just published the white paper "Accessibility Issues with OOXML". This paper describes some of the accessibility challenges that people with disabilities face with office documents and office formats generally, and then notes the accessibility issues that they have found in OOXML. Treviranus & Hockema note in the overview of the paper:

It should be noted at the outset that this paper is not meant to serve as a substitute for a thorough accessibility review undertaken by a diverse team of disability experts, with inclusion and active participation of persons with disabilities. Rather, with this cursory glance we hope to demonstrate the urgent need for such a review.

Even though they state that their work is a "cursory glance", rather than a "thorough accessibility review", their paper notes a number of specific technical issues, some of which come from their inspection of the ~6,000 page OOXML specification (and others from the Microsoft white paper "Accessibility of Ecma Office Open XML File Formats").

Here is the two paragraph introduction to their paper:

1. Introduction

Office Open XML (OOXML) is an electronic document file format based on XML originally developed by Microsoft Corporation to their proprietary Microsoft Office suite as an alternative for previous proprietary document formats. In December, 2006, the organization Ecma International published a standard (ECMA-376) based upon this format. Ecma International then submitted this standard to the International Standard Organization's JTC-1 committee for fast-track consideration of its adoption as an international standard. As of July, 2007, that process is ongoing.

If the ISO adopts OOXML as a standard, this will have significant implications, as many national, regional and municipal governments mandate the use of a standard format in public schools and for all official government documents and records. In an increasingly electronic and on-line document world, the accessibility of this format has clear implications for members of disadvantaged or minority communities and persons with disabilities, as access to educational materials, government services, records, opportunities, participation and representation is at stake. Hence, accessibility should be a crucial prerequisite for standardization and adoption. With this in mind, this paper undertakes a preliminary analysis of the OOXML format with respect to its accessibility, with emphasis on accessibility to persons with disabilities. We will demonstrate that the OOXML format fails to adequately support accessibility of documents.

And here is the one paragraph conclusion of their paper:

5. Conclusions

There are grave issues with respect to the accessibility of Office Open XML as a format and potential standard that should preclude its adoption at present. It may be the case that OOXML can be improved to ameliorate some of the more specific technical concerns, but it is most likely too late for the higher-level issues, especially those inherent in the process by which OOXML was developed. We suggest that energy would be better spent in the ongoing effort to improve the existing ISO ODF standard (with which OOXML would overlap and compete if it is adopted). In any event, decisions with respect to standardized document formats should be made in consultation with members of disability communities, disabilities experts and developers of assistive technologies, with universal accessibility as a core requirement as opposed to an ad hoc afterthought.

There is quite a lot more in between introduction & conclusion, but I fear I wouldn't do it justice trying to summarize here. I encourage you to read the original yourself!

Saturday Jul 14, 2007

Continuing the conversation with Gray Knowlton, Group Product Manager for Microsoft Office

Gray, I want to thank you again for taking the time to continue this conversation through your latest blog comment. I know that others reading these blog postings appreciate it as well - several folks have told me that they find the discussion useful and illuminating. I appreciate your candor, and I feel that with this reply you have answered all of my questions. Thank you.

Also, I very much appreciate your comments about the importance of being supportive of the energy and enthusiasm and contributions of folks new to the field. I've said so privately, but let me reiterate publicly: Reed, I apologize if anything I have said has made you feel uncomfortable, was unwelcome, felt harsh or critical. The IT accessibility effort needs the energy and enthusiasm and contributions of folks new to the field - folks like you and many others I have had the pleasure of meeting. In no way do I want to discourage your work.

Gray - you have graciously invited me to contribute to the Ecma OOXML accessibility effort, and I'm glad that you have found at least some of the questions I've raised thus far to be useful contributions. I'm sorry, but alas I must decline your invitation to particulate in a more formal way. I am quite busy with other work - with contributions to ODF accessibility, and contributing to the development of open source and free access solutions (and the growing community of users/developers around that). I am also deeply involved in the Section 508/255 Refresh activity, where I have the distinct pleasure of working on with, among others, several dedicated folks from Microsoft's accessibility team. Then of course there is my "day job" at Sun...

I'm glad to hear that you plan to take my questions and criticisms constructively, with the aim of improving OOXML accessibility. Accessibility work is never done; perfect accessibility remains an elusive goal that we all of us must continue to strive toward. It does feel a little odd, though, for a Microsoft representative to invite contributions to the Ecma OOXML work from an OASIS ODF subcommittee co-chair whose company is not an Ecma member. Microsoft, an OASIS member, declined to participate in the OASIS work on ODF. In fact, I note that this is the second time it has been suggested that I contribute accessibility expertise to a new Microsoft standards effort, when there is an already existing standards effort in that area that Microsoft refuses to join.

Separate from my lack of standing in Ecma, and in addition to being rather busy at the moment, there is another reason that I am not motivated to become further involved with Microsoft OOXML accessibility. I have several times before tried to contribute to Microsoft accessibility efforts, and each time before been disappointed. In 1995 - shortly after Microsoft reacted to a major blow-up in the disability community in Massachusetts over a different CIO's decision to standardize on the (then inaccessible) Windows 95 desktop - I attended a 3-day Microsoft accessibility summit. At that summit I spoke passionately and at length about the things I felt Microsoft needed to do to truly address accessibility concerns in their OS and applications and tools. Later, in 1995/1996, I accepted a Microsoft invitation to Redmond for a couple of days of meetings and presentations to Microsoft OS engineers to help develop an accessibility architecture for Windows. In both cases, I came away feeling that my remarks and energy fell on mostly deaf ears. The suggestions I made in the 3-day summit were little acted on. The accessibility framework I attempted to contribute to became MSAA - a tremendous disappointment to me and others who had hoped for a comprehensive accessibility framework that would eliminate the need for all of the reverse engineering & special casing work that AT products still have to do today in Microsoft Windows. So please forgive the skepticism that I bring to these discussions; they are informed by a decade-long history I have with Microsoft on accessibility.

Shifting gears, there are a few things that you said in your comments yesterday that I'd like to respond to. In replying to one of my questions (also quoted below), you said (with emphasis added):

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.

I'm sorry, but I must strongly disagree with the notion that ODF v1.0 had "no accessibility support". Please note that I have never suggested OOXML had no support for accessibility. Rather, I believe there are important questions as to how complete and sufficient that support is. But you and Microsoft have just now made that claim about ODF v1.0. I'm sorry Gray, but to me this is just a continuation of Microsoft attacks and disinformation about ODF that began in Massachusetts nearly two years ago. Especially coming from someone who says he has no accessibility background and expertise, it truly calls into question your assertion from your most recent reply, where you said: "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."

As I noted at the beginning of discussions around ODF accessibility in 2005, ODF v1.0 was "based on standard web technologies like SMIL for audio and multimedia, and SVG for vector graphics, which have and continue to be vetted by the World Wide Web Accessibility Initiative processes". I further noted that "we also know that two of the existing applications that currently read/write ODF can export Tagged PDF files in support of PDF accessibility, and Adobe has already conducted some tests to verify that accessibility across that translation is preserved (and thus must exist in the original ODF file)." While I didn't say so at the time, please note that, like OOXML, ODF v1.0 was derived from an earlier file format which had many years of expert accessibility attention paid to the application that creates files in that format. This is precisely why, after a thorough evaluation of the ODF v1.0 format for accessibility, the OASIS ODF Accessibility subcommittee only found 9 accessibility issues to correct.

In your comment yesterday, you also wrote: "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." Accessibility has become a theme, a subtext in the larger debates around acceptance of ODF or OOXML by various bodies and governments and customers; in the debates about the suitability of ODF or OOXML for use in various places. As the market for office suites runs to the tens of billions of dollars a year, it comes as no surprise that some folks who are partisans to one format or the the other may seek any advantage they can to further their favored format. As I noted in November of 2005, it was Microsoft who brought accessibility into these debates, by attacking ODF on accessibility grounds.

I said in my first posting about your report, "Since the start of the discussions around office document accessibility nearly two years ago...I have seen NO clear and technical discussion of the accessibility of the Microsoft OXML format. Rather, in meetings I've been part of, Microsoft representatives have simply stated that since Microsoft Office is accessible... it is automatically the case that the underlying file format fully supports everything needed for accessibility." Your report represents the first actual review of OOXML accessibility after nearly two years of office document accessibility debate, and so therefore it is naturally the subject of a lot of interest and scrutiny.

Bottom line: when it comes to the acceptance of OOXML - in standards bodies or governments - I think there are three related things going on with respect to accessibility:

  1. The accessibility of office documents has appropriately become a significant issue - in Massachusetts and worldwide. In response, Sun, IBM, the Royal National Institute for the Blind, the Institute for Community Inclusion, Design Science, and several individual disability experts and users with disabilities did a tremendous job analyzing the ODF v1.0 spec for accessibility. The resulting contributions to ODF v1.1 led us to say that "we believe that ODF will meet or exceed the accessibility support provided in all other office file formats as well as that specified in the W3C Web Content Accessibility Guidelines 1.0". The Commonwealth of Massachusetts made it clear to Sun and IBM that they would not accept ODF v1.0, but instead insisted that the OASIS standards body make ODF v1.1 - with the results of our accessibility improvements - an OASIS standard before they would move forward with the plans set forth in ETRM v3.5 to deploy OpenDocument Format for their office documents. Given the issues that your project has highlighted in OOXML, the fact that there are unanswered accessibility questions (such as those I have highlighted with respect to DAISY and Braille conversion), and the fact that there has been no authoritative accessibility review of OOXML to date; I think it is reasonable to ask why the Commonwealth of Massachusetts should add OOXML to their set of acceptable document standards? If the Commonwealth insisted that ODF 1.0 wasn't acceptable - that only the standardized output of an accessibility peer-review of experts and technical individuals/users with disabilities would meet their needs - then shouldn't any other proposed format have to meet the same standard? Shouldn't Massachusetts insist that Ecma standardize on an OOXML v1.1 with accessibility improvements before OOXML can be deployed? Why should another document format receive less scrutiny? Why should another document format be held to a lesser standard?

  2. As was done in Massachusetts in 1994/1995 with the threatened embargo of Microsoft products due to the lack of Windows 95 accessibility, disability advocates in Massachusetts have raised the consciousness of folks throughout the world; this time around the importance of office document accessibility. They have made it clear that the needs of people with disabilities should be thought of and addressed in advance of a standard being accepted. They have made it clear that people with disabilities should be part of the standardization and review process (the adage "nothing about us without us"). They have, in essence, raised the bar on accessibility. I've seen recognition and appreciation of this in Denmark, and Belgium, and France, and England - everywhere that I have traveled and met with disability group and government document accessibility standardization folks. In each of these places, the folks adopting ODF have made it clear that they plan to use ODF v1.1 instead of ISO/IEC 26300 (ODF v1.0). They all want the version resulting from the accessibility peer-review. Yes, ISO standardization of ODF is important to them; many European organizations place an important emphasis on ISO standards. But the ISO imprimatur of ODF wasn't sufficient for the folks I met with; they required the results of our accessibility work before they would use it. For those governments and customers who care about accessibility, this higher bar is entirely appropriate and should be used.

  3. At some point the standards bodies themselves will come (are coming; perhaps have already come) to recognize the importance of accessibility concerns as a pre-requisite for standardization. As I noted previously, a principle established by the European Council eAccessibility Resolution of February 2003 is that people with disabilities should be empowered "to take more control over the development of the mechanisms for delivering eAccessibility", and "by support for their increased participation in standardisation bodies and technical committees". One can argue whether it would be fair if ISO - or more appropriately, the countries who vote on ISO standardization - were to raise the bar on accessibility for one office document standard (e.g. OOXML) after approving an earlier standard without such an accessibility bar (e.g. ODF v1.0). In fact, I've heard Microsoft representatives make that very argument. But that bar should appropriately be raised; and when it is raised it will require more of those that come after than those that came before. This is ever the case when we raise the bar on something, and insist that things be changed - whether it is recognition that slavery is wrong, or that women should have the right to vote, or that "separate but equal" isn't at all equal, or that affordable access to technology and government documents is a basic right of citizens in the Information Society. It would be a poor argument indeed that U.S. presidential candidates in 1920 shouldn't have to take into consideration womens' votes since in 1916 Woodrow Wilson didn't have to worry about them. And please remember, there are more document formats & format revisions in the ISO queue. Do we make the comparison argument indefinitely? When ODF v1.2 (or whatever) comes to ISO for standardization, a raised bar should of course apply to it. Likewise to any new PDF standards. And if Microsoft's XPS "XML Paper Specification" goes through Ecma and on to ISO, a raised bar should apply to XPS as well.

So to conclude this current exchange... thank you again for taking the time to illuminate the work your team has undertaken thus far on OOXML accessibility. Thank you for making it clear that you feel that a more complete accessibility evaluation of OOXML is needed, and that you intend your white paper to be the start of that work. I look forward to hearing more from you, your team, and an OpenXML Developer effort to thoughtfully and thoroughly analyze the accessibility of OOXML.

I make no apology for increasing accessibility requirements, nor for my advocacy of them. Next week at the 5th public meeting of the Telecommunications and Electronic and Information Technology Advisory Committee, I will continue the work of raising the bar on accessibility - working with my counterparts at places like Adobe, IBM, Microsoft, and others in industry; with expert users from the disability community including the American Council of the Blind, the American Foundation for the Blind, Communications Service for the Deaf, the National Federation of the Blind, Paralyzed Veterans of America, and other notable organizations; and with disability experts from U.S. Universities, from independent consulting firms, and from the international community. Raising the bar on accessibility and building architectures to make technology more accessibility is what I do. It is what I have been doing for the last 15 years.

People with disabilities - especially folks with severe disabilities like blindness and total hearing loss and severe physical impairments - face some truly severe barriers in technology. It is morally incumbent upon the people developing technology - like the two of us - to work diligently to remove those barriers. I'm sure you will agree that we must continually raise the bar on accessibility ; continually challenge ourselves to do an increasingly better job ensuring that everyone has the fullest possible access to and use of the products, technologies, and standards that we create. When it comes to technology for people with disabilities, we should not accept any backsliding on what is possible. Nor on what is acceptable.


Peter Korn


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