Is PDF accessible in Australia?
More than two years ago I wrote about WCAG 2.0 and Accessibility Supported, and my fear that, “the concept of ‘accessibility supported’ is not fully understood”. I believe that this “could put at risk the whole move to improve the accessibility of the web.” I am concerned that mixed-messages relating to the status of PDF as a “web content technology” is still causing problems within Australia at least.
Now this would all be fine and dandy if developers were able to clearly identify which web content technologies, when used appropriately, are sufficiently supported by assistive (adaptive) technologies to be considered “accessibility supported” within the meaning of WCAG 2.0. However, when WCAG 2.0 was released in December 2008, the WCAG Working Group and the W3C effectively side-stepped this question, and more than three years later they continue to do so.
“The Working Group, therefore, limited itself to defining what constituted support and defers the judgment of how much, how many, or which AT must support a technology to the community and to entities closer to each situation that set requirements for an organization, purchase, community, etc.”
In Australia, this effectively means handing the decision over to the government regulators, most importantly the Australian Human Rights Commission and the Australian Government Information Management Office (AGIMO).
“The Commission’s advice, current October 2010, is therefore that PDF cannot be regarded as a sufficiently accessible format to provide a user experience for a person with a disability that is equivalent to that available to a person without a disability, and which is also equivalent to that obtained from using the document marked up in traditional HTML.”
The websites of all government agencies in Australia are required to transition to WCAG 2.0, Level AA compliance, by the end of 2014. The Australian Government Information Management Office (AGIMO) is managing this transition through the National Transition Strategy (NTS), and the Government Web Guide provides an overview of what is required in terms of accessibility and which web content technologies can be used:
“Web technologies that claim accessibility support must prove WCAG 2.0 conformance through the use of WCAG 2.0 sufficient techniques…
Agencies are reminded that it is still a requirement to publish an alternative to all PDF documents (preferably in HTML). … Agencies must abide by the Australian Human Rights Commission’s Disability Discrimination Act Advisory Notes in order to mitigate risk of disability discrimination complaint.”
Australian Government Web Guide: Accessibility (April 2011)
While I didn’t fully agree with excluding PDF, that all seemed reasonably clear until January this year when AGIMO posted an article on their blog about the Release of WCAG 2.0 Techniques for PDF. The main article is short, comprising an outline of the situation and various resources. However, in the comments, various people ask if this means that PDF (when used appropriately) can now be considered “accessibility supported”, to the extent that it is no longer necessary to provide multiple accessible formats. In answering this question, Jacqui van Teulingen, the Director of AGIMO wrote in part:
“As stated, the PDF Sufficient Techniques are now available, so technically an agency can rely on PDF by using the WCAG 2.0 PDF Sufficient Techniques and all applicable General Techniques, and will be considered to be complying with the NTS.”
Release of WCAG 2.0 Techniques for PDF (January 2012)
On the face of it, this comment seems to be at odds with the directive in the Australian Government Web Guide and the advice provided in the Human Rights Commission Advisory Note relating to web content accessibility. And, I suspect, once again there are developers, particularly those working on sites for government agencies, left wondering, or maybe even wandering…
We need clarity
This issue is not just about the use of PDF, but rather the process in Australia for determining those “web content technologies” that are considered acceptable and those that are not. I find it really hard to understand how Flash can be declared acceptable but PDF unacceptable, when both can cause significant accessibility problems when used inappropriately. Surely, it should not be a question of what technology is used, but how it is used.
When it comes “accessibility supported”, rather than precluding some web content technologies and not others, I believe the authorities should rely on the existence of Sufficient Techniques for each relevant Success Criteria as the main determinant of whether the use of a particular technology is accessible. That means, for example, if a web document has an image, there is a technique that allows an accessible alternative for that image, and if there are headings, then there is a technique that will allow them to be presented by different user agents, including commonly used assistive technologies.
I think the Australian authorities should consider the approach to the issue of “accessibility supported” (WCAG Conformance Requirement 4) as outlined in the Government of Canada Standard on Web Accessibility:
“Conformance requirement 4 (Only Accessibility-Supported Ways of Using Technologies) defines the ways of using technologies that can be relied upon to satisfy the success criteria. It can only be met by use of the following technologies:
- XHTML 1.0 or later excluding deprecated elements and attributes,
- HTML 4.01 excluding deprecated elements and attributes,
- HTML5 or later excluding obsolete features, or
- Technologies with sufficient techniques (specific to each technology) to meet all applicable success criteria.”
Government of Canada Standard on Web Accessibility (1 August 2011)
I believe it is time the Australian Government Information Management Office and the Human Rights Commission fully embrace both the spirit and the recommendations of WCAG 2.0. The accessibility of websites should be determined by how well they satisfy the five WCAG 2.0 Conformance Requirements regardless of the web content technology used.