BS 8878: “Accessibility has been stuck in a rut of technical guidelines”

Launch of the BS 8878 Web accessibility Code of practice

Yesterday I listened to a Webinar entitled “BS 8878 Explained” which was given the day after the official launch of the “BS 8878 Web accessibility. Code of practice“. The Code of Practice can be purchased for £100 from the BSI shop :-( Once I realised this was the case I tried to  keep a note of the main points which were being made during the Webinar.  Unfortunately the PowerPoint slides which were used do not seem to have been published, so there may be mistakes in the notes I have taken.  It is unfortunate that the launch of this important new code of practice was not supported by the availability of accompanying support materials – uploading the slides to PowerPoint and providing a URL on the title slide would have been simple to do. Perhaps the reasons for not doing this are to maximise consultancy opportunities although, since I have learnt that a recording of the Webinar has been made available, I’m inclined to think that this was just an oversight. Note that I learnt about the availability of the recording of the Webinar from the TwapperKeeper archive of all #bs8878 tweets – and note that an archive of tweets for the 7-8 December 2010 is also available, which may be useful if you want to view the discussions which took place during the Webinar.

Back in June I wrote a post about a draft version of BS 8878 in which I concluded:

the Code of Practice correctly acknowledges the complexities in seeking to enhance accessibility of Web products for people with disabilities.  It was also good to see the references to ‘inclusive design’ rather than the ‘universal design’ which, I feel, leads people to believe that a single universal solution is possible or, indeed desirable.

Many thanks to the people who have produced this document which gets my support.

Although I haven’t read the final published version the Webinar  seems to confirm that a pragmatic and user-focussed approach to Web accessibility has been taken to the production of the code of practice. A summary of my notes from the Webinar is given below and some general comments are given at the end of this post. I should also add that the Access8878 Web site provides a summary of the Code of Practice which is available for free and that Deborah Edwards-Onoro has also published a summary of the Webinar.

Notes from the Webinar

During the Webinar Robin Christoperson and Jon Gooday Elliot Martin gave an introduction to this new BS Code of Practice and provided a case study of how Lloyds TSB have gone about addressing accessibility issues.

The key points I noted during the talk are given below:

• BS 8878 is user-focussed.
• BS 8878 covers ‘Web products’ and not just Web sites (including email used over the Web; Flash;  mobile; …).  However the code of practice doesn’t cover software.
• BS 8878 is a code of practice  which gives guidance (could, should, …) rather than detailed technical specifications.
• It can be possible to comply with BS 8878 if you implement recommendations. It should be noted that this includes documentation of various processes and decisions.
• BS 8878 is applicable to all types of organisations.
• “Accessibility has been stuck in a rut of technical guidelines and a low level focus” i.e. with those working in Web team taking a  checklist approach to accessibility. BS 8878 endorses a more strategic and high level approach. It has been described as provided a more holistic approach.

Following a Lloyd TSB Case Study of how they have addressed accessibility issues the structure of the BS 8878 document was described.

The documents explains why an  accessibility policy is needed, with examples of such policies accessibility statements being provided in annexes to the document.

Advice is given on making ‘justifiable decisions’, which aim to make you think and understand the implications of actions and  ensuring that decisions are documented.

Section 7 of the document covers WCAG guidelines, inclusive design (which wasn’t covered in previous BS 78, the previous code of practice on Web accessibility) and provision of personalised Web sites (e.g. Wen sites for BSL users; style switchers; etc).

Section 8 covers testing processes, to ensure accessibility issues are addressed in the testing processes.  The Annexes provide more detailed examples.

A significant change in the document following changes to DDA legislation (which has been replaced by the Equality Act) which covers liability. Since the legislation applies only to services hosted in the UK there will be need to take care when making use of services provided by 3rd party providers. [It was unclear as to whether this meant that since 3rd party services would be exempt from UK legislation there would be no liability, or the UK organisation using the service would have to accept liability.]

The heart of document is a 16 step plan:

Step 1: Define the purpose.

Step 2: Define the target audience.

Step 3: Analyse the needs of the target audience (note this wasn’t covered in PAS 78)

Step 4: Note any platform or technology preferences

Step 5: Define the relationship the product will have with its target audience

Step 6: Define the user goals and tasks

Step 7: Consider the degree of user experience the web product will aim to provide

Step 8: Consider inclusive design & user-personalised approaches to accessibility

Step 9: Choose the delivery platform to support

Step 10: Choose the target browsers, operating systems & assistive technologies to support

Step 11: Choose whether to create or procure the Web product.

Step 12: Define the web technologies to be used in the Web product

Step 13: Use Web guidelines to direct accessibility web production  This step covers use of WCAG guidelines.

Step 14: Assure the web products accessibility through production (i.e. at all stages)

Step 15: Communicate the web product’s accessibility decisions at launch

Step 16: Plan to assure accessibility in all post-launch updates to the product

Note that BS 887 is a very new document. The editorial team welcome feedback on  experiences of using the approaches described in the document which can be fed into next version, which should be published in 2 years time.

Observations

“BS 8878 is user-focussed“:  this was the most pleasing aspect of the Webinar. I have argued in the past that Web accessibility has been regarded as a feature of a resource, with the user often being invisible. It is good to see that the balance has been re-addressed.

“Accessibility has been stuck in a rut of technical guidelines and a low level focus“:  another comments I would agree with.  I was pleased to see that Step 13: “Use Web guidelines to direct accessibility web production” is correctly regarded as just one small part of a much more sophisticated approach to addressing Web accessibility challenges.

The more process-driven approach to Web accessibility reflects the ideas which have been described in a series of papers on Web accessibility which a group of accessibility researchers and practitioners have published over the past six years or so.  In particular the BS 8878 Code of Practice implements the suggestions that:

If current approaches in the specification of accessible Web sites are flawed, what alternative approaches should be taken? The authors’ experience suggests that there is not a single specification, or set of them, that can be prescribed for accessibility. The approach that appeals to the more experienced mind is one that operates on a repertoire of techniques, policies and specifications that are worked upon freshly in each new situation. The results of this expert approach cannot be mandated as the relevant expertise cannot be distilled but the practice of consideration, and exploration can be mandated. The authors are inclined to the view that it is more the processes undertaken by authors or not, that are responsible for many accessibility problems. This suggests a process-oriented approach to accessibility rather than one based on strict technical adherence to technical specifications.

which were described in a paper on “One world, one web … but great diversity” which was presented at the W4A 2008 conference in Beijing, China.

The 16 step approach also provides a pragmatic approach to addressing the challenging areas of Web accessibility, such as the accessibility of research publications hosted in institutional repositories or the accessibility of amplified events.  At this year’s W4A 2010 conference in a paper on “Developing Countries; Developing Experiences: Approaches to Accessibility for the Real World” we proposed the following approaches:

Reasonable Measures: Rather than regarding WCAG conformance as a mandatory requirement, WCAG should be regarded as guidelines, which may be ignored if their use conflicts with other requirements – so long as steps are taken to address the potential exclusion that may result. It should be noted that UK legislation that requires use of ‘reasonable measures’ to ensure that users with disabilities are not discriminated against unfairly, provides a legislative context for this approach. A policy based on ‘seeking to make use of WCAG’ will provide the flexibility needed. This would not be possible with a policy which states that all resources must conform to WCAG.

Justification of Costs: ‘Reasonable measures’ should include identification of costs of conforming with accessibility guidelines. There should be consideration of the trade-off between financial savings and usability issues. For example the attraction of promoting open source, free assistive technology in developing countries may be tempered by the challenges of moving users away from familiar, currently-used commercial alternatives – which may in reality have been illegally obtained at low cost.

Provision of Alternatives: If it is too costly or difficult to conform with accessibility guidelines, the provision of alternatives that are as equivalent as possible may be an appropriate solution. As described in[10] the alternative need not be Web-based.

Just-in-time Accessibility: A requirement that all resources conform to WCAG is a ‘just-in-case’ solution. This may be an appropriate resource for widely accessed informational resources, but may be inappropriate if resources are expected to be little used. There may be advantages in delaying provision of accessibility solutions to allow development of technologies which can enable more cost-effective solutions to be devised.

Advocacy, Education and Training: Those involved in supporting content providers and other stakeholders should ensure that education and training on best practices is provided, together with advocacy on the needs for such best practices.

Sharing and Learning: With an emphasis on a community-based approach to the development of appropriate solutions it is important that best practices are widely shared.

Engagement of Users with Disabilities: The need to ensure that disabled people are included in the design and development of Web solutions must be emphasised.

Focus on ‘Accessibility’ rather than ‘Web Accessibility’: The benefits of Web/IT solutions to real world accessibility difficulties needs to be considered. As described above, amplified events can address difficulties in travel and access, even though the technologies used may not conform with accessibility guidelines.

When time permits it would be interesting to see how the holistic approaches to Web accessibility which we have developed (and described in our papers) maps to the approaches described in the BS 8878 Code of Practice.

To conclude, I’d like to give my thanks to the contributors to the BS 8878 Code of Practice who are helping to ensure that Accessibility is no longer “stuck in a rut of technical guidelines“.

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Note (added on 2 April 2012). I have been informed that the official slides on BS 8878 from its launch, together with other free information including, case studies of organisations using BS 8878, detailed blogs on its use by SMEs, tools and training for applying the Standard and news on its progress towards an International Standard, can be found on the Hassell Inclusion web site.