Internet Newsletter for Lawyers
September/October 2004, by Delia Venables

Accessibility in Practice
Antony Nicholls

Last month's newsletter featured an article by David Gilroy Is your website accessible? in which he discussed the Disability Discrimination Act (1995) and how it relates to services provided via websites. With the Act coming into full force in October 2004 and as a firm that specialises in Employment Law we recently took steps to address the issue of "accessibility".

In the absence of any concrete do's and don'ts to ensure and demonstrate accessibility in the UK, we have to borrow good practice from the Worldwide Web Consortium (W3C) and their Web Content Accessibility Guidelines (WCAG) at www.w3.org/WAI. The WCAG does not have any legal standing in the UK but is perhaps the closest thing we have to a minimum standard for web accessibility and applying these standards enables us to demonstrate that we are taking "reasonable" steps to ensure access to our services by disabled people.

Do We Start Over or Recycle?

Like most firms, we have put a lot of time and resource into our website, opting in our case for a "Flash" site which portrayed a strong visual image. Design became paramount and usability and accessibility whilst a big consideration perhaps regrettably took a backseat.

After consulting much material on the Internet relating to the DDA and the W3C guidelines we decided that we had two options open to us: either to start again from scratch or to "Retrofit" our site to achieve compliance with the standards. (To "Retrofit" the site means to modify the present pages in order to make them compliant rather than creating accessible content from the beginning).

We wanted to preserve some if not all of the investment we had made previously and therefore decided on the "Retrofit" route. Hopefully, this would also retain some of the good features we had achieved in the original site.

Validation of Conformance

In order to work towards an accessible website and in order to demonstrate that we have made a commitment to making our services available to disabled people, we decided to adopt the WCAG 1.0 framework. (These are currently under review and there is a draft of new ones, known as WCAG 2.0, available on the WC3 website but the new ones are not yet in force).

The W3C site publishes some useful tips on how to validate your site against its guidelines:

1. Use an automated accessibility and browser validation tool. (However, note that software tools do not address all accessibility issues, such as the meaningfulness of link text, the applicability of a text equivalent, etc.)

2. Validate syntax (e.g. HTML, XML, etc.).

3. Validate style sheets (e.g. CSS).

4. Use a text-only browser or emulator.

5. Use multiple graphic browsers, with:
- sounds and graphics loaded
- graphics not loaded
- sounds not loaded
- no mouse
- frames, scripts, style sheets, and applets not loaded.

6. Use several browsers, old and new.

7. Use a self-voicing browser, a screen reader, magnification software, a small display, etc.

8. Use spell and grammar checkers. A person reading a page with a speech synthesizer may not be able to decipher the synthesizer's best guess for a word with a spelling error. Eliminating grammar problems increases comprehension.

9. Review the document for clarity and simplicity. Readability statistics, such as those generated by some word processors can be useful indicators of clarity and simplicity. Better still, ask an experienced (human) editor to review the written content. Human editors can also identify potentially sensitive cultural issues that might arise due to language or icon usage.

10. Invite people with disabilities to review documents. Expert and novice users with disabilities will provide valuable feedback about accessibility or usability problems and their severity.

Testing Tools

There are a number of automated testing tools available which provide reports on how a website complies with the WCAG 1.0 guidelines. For a list of these tools consult www.w3.org/WAI/ER/existingtools.html and for a review, consult www.dimi.uniud.it/~giorgio/papers/hfweb00.html.

When testing a site it is important to note that automated tools can not check everything and subsequently can not guarantee compliance. In fact they will often generate "false positives", i.e. they will identify an issue that does not exist.

We opted to use the BOBBY accessibility testing tool at bobby.watchfire.com. The Bobby site allows one page per site to be tested for free. Alternatively you can purchase the product and it will assess the whole site and produce a complete picture of how each page scores against the WCAG 1.0 checkpoints.

At first glance, the Bobby report can appear overwhelming and depending on how your pages are structured can be completely confusing. It consists of three sections Priority 1 Accessibility, Priority 2 Accessibility and Priority 3 Accessibility. Each of these sections corresponds to the respective WCAG 1.0 priority levels. Within each of these sections you will find issues identified which Bobby can check automatically against the guidelines (denoted by a policeman's hat icon) and also a number of items that cannot be checked automatically and require manual examination. These are presented in the User Checks subsection of the priority level and are denoted by a question mark icon.

Our Experiences

The first time we ran the Bobby tools against our site, many shortfalls were identified. Through a reiterative process, we eventually eliminated all the key accessibility shortfalls and we were left with the remaining user checks. The user checks as mentioned earlier are items which the Bobby tool cannot automatically test; many of these are not relevant to the page being tested and many are standard clauses which will be included in any test on any web page. Determining the website's accessibility particularly against the user checks will always be subjective, and will require human analysis. Therefore we considered the report from the tool as a guide only and proceeded to decide whether the reported issues were relevant and needed to be fixed.

During testing we found numerous "false positives" which we eliminated and, since all our pages have a similar structure, we could effectively get one page to comply and then use this page as a template for the remaining pages.

The testing left us with a small subset of issues which we actioned and subsequently achieved Bobby AAA compliance which translates to compliance with WCAG 1.0 priorities 1,2 and 3.

Speech Enabling

Further to testing with Bobby and manual analysis against the WCAG 1.0 guidelines, we have also opted to "speech enable" our site using a screen reader called Browsealoud at www.browsealoud.com. You need to purchase a license from Browsealoud, after which you can publish a link on your site to the browsealoud reader download area. Visitors to your site simply download the software and install it following which the full text of the site is available as a spoken word.

Browsealoud can also produce statistics for you on how many downloads have originated from your site and therefore give you an indication of how often the tool is being used and an inference of how many disabled visitors have viewed your site.

Hopefully through adopting the WCAG 1.0 guidelines as a benchmark we have demonstrated a commitment to ensuring that disabled people have access to our services and that we have taken reasonable steps to achieve website accessibility.

We plan to continue monitoring developments arising from the DDA and to review the site accordingly. We are also planning an overhaul of our Intranet and Extranet, again using WCAG 1.0 as a framework.

Antony Nicholls is IT Director of Lees Lloyd Whitley, www.llw.co.uk. Lees Lloyd Whitley are a national practice, with offices in the North West of England and London. The firm undertakes both Private Client and Commercial work.
Email asn@llw.co.uk.

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