PAS 78: Guide to good practice in commissioning accessible websites is the result of a year's collaboration among the DRC, RNIB, BBC, Tesco, IBM, the W3C and many others.
Following the guidance could help any organisation to demonstrate compliance with the UK's Disability Discrimination Act, which requires websites to be accessible and usable for disabled people.
The need for PAS 78
The 56-page document, available for £30, sets out the steps that an organisation should follow to ensure that any new web development accommodates the widest possible audience. It assists with the formation of an accessibility policy and the procurement of developers. It stresses the importance of user testing and maintenance of accessibility levels.
The Disability Rights Commission (DRC) approached BSI last year, following its own accessibility review of 1,000 UK websites which found 81% of sites failing on automated tests to reach even a minimum standard. Its report on that guidance identified a need for best practice guidance for accessible website development and ongoing maintenance.
DRC Commissioner Michael Burton explained the problem at yesterday's launch event in London. "Website commissioners saw [accessibility] as a technical issue for developers," he said, "but developers had an uninformed tick-box approach to the guidelines. So we established an accountability framework."
The guidelines to which he refers are the Web Content Accessibility Guidelines (WCAG), drawn up by the World Wide Web Consortium's Web Accessibility Initiative. WCAG 1.0, published in 1999, defined accessibility in terms of Levels A, AA and AAA. It remains the benchmark for website accessibility. But the DRC saw a need for something else, something that board rooms could understand.
Burton approached BSI, which recommended a Publicly Available Specification. A PAS is not a full British Standard but it is developed using a similar process. It can be introduced more quickly because it doesn't require full consensus among experts. The end result is guidance, not a standard, and it is subject to review in less than two years. But a PAS can become a standard over time, depending on how it is accepted.
Julie Howell, the Royal National Institute of the Blind's Digital Policy Development Manager, was commissioned by the BSI as the Technical Writer for the PAS Project. Howell wrote the first draft and submitted that to a Steering Group – with representatives from the DRC, AbilityNet, the BBC, the Cabinet Office, IBM, Tesco.com, University College London and the Usability Professionals’ Association. In addition, more than 120 representatives from across the new media, digital and related industries were invited to join a Review Panel to comment on the draft. More than 900 comments were received, running to 188 pages.
Howell, who has been with the RNIB for 12 years, said she became involved with PAS 78 because it presented an opportunity to improve the lives of disabled people. "Commissioners have to step up to their duty," she said.
She was keen to stress that PAS 78 is not in conflict with the WAI guidelines which are under the directorship of Judy Brewer. "The WAI was involved from the earliest stage," she said. Addressing an audience of experts in the field yesterday she added, "I hope it contains very little that's new for you."
Giles Colborne, president of the UK Chapter of the Usability Professionals' Association, said the most important part of PAS 78, in his view, is its call for an accessibility policy within an organisation. He described the policy as "a roadmap to making and keeping a site accessible."
PAS 78 explains that the policy should set accessibility targets and should be referenced in tender and contract documents. Colborne suggests that it might be anything from one to 10 pages in length. A summary should appear on the website itself.
PAS 78 says the policy should reference the W3C guidelines and the specifications that the website upholds. It should include "a description of the disabled users to be consulted during the development of the website" and an explanation of the core tasks that users should be able to achieve on the site – e.g. buy a book – and the criteria for determining success.
Where an area or element of the website is unlikely to be accessible to people with particular impairments, an explanation should be provided of any repairs to be made and the timescale; how disabled people can find alternative access to the information; or why it is considered reasonable for the area to remain inaccessible.
Full contact details should also be made available as part of the policy. The website summary should also provide contact details for requesting further information about the accessibility policy and provision for users to lodge complaints or suggestions with the website commissioner.
Sites should be usable and accessible on "a reasonable range" of web browsers and operating systems, it says.
Level A, AA or AAA?
PAS 78 states that measurable success criteria should include "conformance criteria, e.g. all pages must conform to WCAG 'AA'". But this is given as an example. The guidance stops short of mandating that all sites should achieve WCAG Level AA.
Yet on the subject of adding new pages and making changes to existing pages, it notes: "Small changes, such as adding a new graphic, or writing a new paragraph should, as a minimum, be tested for conformance to WCAG 'AA'.
OUT-LAW put this to Julie Howell.
"The reason we put AA in is Judy Brewer usually recommends it as the standard that a site should achieve," said Howell. "But it is mentioned as an example. It isn't the purpose of the PAS to dictate which Level of WCAG web developers should aspire to."
Howell explained: "The PAS encourages developers to decide that for themselves and to provide their rationale in their web accessibility policy. However, we would remind web developers that the higher the Level, the greater the number of disabled people who will be able to use the site."
Brewer advised against PAS 78 making reference to a particular version of WCAG. The current version is 1.0; but WCAG version 2.0 has been expected for a long time and its publication date is still unknown. "Judy said we should be version neutral," said Howell.
As for the reference to new pages or changes to existing pages, Howell explained: "We have said that anything new should conform to AA. But we did stop short of saying that all pages should be AA. The higher the level achieved, the more people will be able to use a site. So if you're adding new pages and only aim for Level A, you're missing a trick."
Choosing a website developer
PAS 78 acknowledges that there is currently no nationally recognised system of accreditation for website developers who claim to create accessible websites. So commissioners are encouraged to perform their own reference checks of previous work and they should expect a practical knowledge of PAS 78.
Questions for suppliers are suggested, e.g. Describe how your solution will meet the accessibility targets as outlined within our accessibility policy; describe how your design process follows ISO 13407 Human-centred design processes for interactive systems; describe how you will validate early designs with users, including disabled users.
PAS 78 states that "large changes that affect important tasks within the interface, i.e. how a user logs onto a site or buys a product, should undergo user testing."
When commissioning a site, a test plan should be developed by website commissioners that enables the accessibility targets to be achieved and performance measured. The document explains the importance of user testing, not just automated testing, and the methods (reference is made to an existing British and International Standard, Human-centred design processes for interactive systems.
A large sample size is encouraged and the suggested user profiles include, among others, users with mild, medium and severe vision impairment; users with mild, medium and sever motor difficulties; users with medium dyslexia; and users with mild to medium learning or cognitive disabilities.
We put it to Howell that most organisations cannot afford such comprehensive testing. Howell accepted this. "We're not saying you have to test your site against all these users. Testing with a few is better than testing with none." She said that blind internet users find most of the problems experienced by other disabled user groups – "So testing with one blind person is better than none."
There is also a recruitment problem. PAS 78 says website commissioners "may contact a recruitment agency to recruit users who exactly match the required criteria." But finding such an agency may not be easy.
"At present there are few testing agencies that offer easy and direct access to a pool of web sites testers that are disabled," said Howell. "PAS 78 presents a golden business opportunity in this regard. Entrepreneurs might choose to establish such services in response to the advice set out in PAS 78. However, RNIB reminds disabled people who claim welfare benefits that they need to check how any paid consultancy work affects their welfare entitlements."
Judy Brewer, Director of the WAI, commented: "PAS 78 will benefit UK business and customers and reinforce implementation of W3C/WAI guidelines."
The DRC pointed out that making a more accessible website also widens the reach of your audience, tapping into the massive spending power of disabled people, it improves search engine listings and also facilitates the easy transfer of this content to other media such as interactive TV or mobile phones.
But it also assists legal compliance.
Struan Robertson, editor of OUT-LAW.COM, commented: "The DRC's endorsement of PAS 78 is significant and it could be used in court to illustrate whether a business has complied with the Disability Discrimination Act. A failure to follow it could be damaging to an organisation's case; but compliance would be evidence of steps being taken to fulfil the legal duty."
To order a copy of PAS 78, contact BSI Customer Services quoting marketing reference code PAS78-U. The document is available in various alternative formats: Braille, easy read, accessible PDF, large print, audio, DAISY and Welsh.
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