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The lowdown on PAS 78

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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 here.

Copyright © 2006, OUT-LAW.com

OUT-LAW.COM is part of international law firm Pinsent Masons.

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