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.
The authors
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."
Accessibility policies
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.
Help is also given with selecting a Content Management System –
e.g. does the CMS application write any code such as JavaScript
that would undermine accessibility?
User testing
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."
Benefits
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."
Ordering
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.
Tel: 020 8996 9001
Fax: 020 8996 7001
