What I Would Like From The BS8878 Accessibility Code of Practice

I recently expressed reservations about the approaches being taken in the BS 8878 draft code of practice on Building Accessible Experiences for Disabled People. But I do feel that such a Code of Practice is desirable.  However rather than the current approach which places the main emphasis on conformance with WCAG, together with an inappropriate reliance on UAAG tools (which organisations providing Web sites have no control over) and a reliance on use of ATAG-conformant tools (which ignores the complexity of workflows, the increasing diversity of file formats and the growth in importance of user-generate content) I feel the Code of Practice should provide a framework for a user-focussed approach to accessibility, which provides a content for use of good practices for developing widely accessible Web sites, such as WCAG guidelines, usability guidelines, etc.

The BS 8878 draft code of practice already includes much valuable advice, especially on the need to engage users with disabilities in both the design and testing phases of Web site development and on the need for organisations to provide accessibility policies. These sections should be provided at the start of the document and not relegated towards the end, as they currently are.

Once the need to include people with disabilities in the planning and development stages and the need for organisations to explicitly state their accessibility policies, only then should the code of practice include implementation details. And rather than repeat the advice included in WCAG, I feel the document should require that such recommendations should only be used if they are proven to work in their intended context of use and they can be implemented and maintained with reasonable levels of expenditure of resources.

And finally I feel that the code of practice should seek to be future-proofed, and recognise that technical innovations are likely to take place which may enhance accessibility of services although infringing guidelines developed in the past.