Web Accessibility System Change: The Myths, Realities, and What We Can Learn From Two Large Scale Efforts

By: Cyndi Rowland and Heather Mariger

As Web accessibility garners increased importance and attention, there is greater emphasis on making system wide, rather than individual, changes in our efforts to create a more accessible world. This is accomplished through policy setting and implementation that places the importance of Web accessibility alongside other Web considerations (Kubarek, Mitrano, Rowland, & Trerise, 2006; Rowland, 2004).

In the early years of Web accessibility, individual developers made the commitment to create accessible Web content. When it became evident that leaving accessibility up to individual developers was not efficient, entire systems began making Web accessibility a priority and a policy. Since then, in the U.S., many educational institutions (Anderson, n.d.; Cochran, 2006a, 2006b; Petersen, 2005; WebAIM, 2005), states (ITTATC, n.d.), and the Federal government (U.S. Access Board, 2000) have implemented policies that require accessibility of the Web for individuals with disabilities in line with accepted standards. Abroad, many countries are also making this same change by implementing laws and policies to guarantee access to digital content for individuals with disabilities (WebAIM, n.d.). Some, including the United Kingdom, extend the requirement for Web accessibility into private industry. This is analogous to the applicability of accessibility in the built environment for businesses under the American's with Disabilities Act. The European Commission, the executive body of the European Union, has a strategic plan "i2010" that will, among other things, address the accessibility of the digital economy and promises to drive the inclusion of individuals with disabilities throughout society (European Commission, n.d.). The United Nations is launching ratification efforts for the Convention on the Rights of Persons with Disabilities that specifically includes accessibility of information and communication technologies (United Nations, n.d.). To date, there are 70 member states that have signed in support of the Convention.

Although the presence of a policy alone does not guarantee accessible Web content (Bohman, 2004; Walsh, 2007), thoughtful implementation planning supports the execution of the policy (Rowland, 2007). Because of this, it was thought that the NCDAE readership might be interested in a synopsis of how other large-scale efforts were conceived and implemented.  With this in mind we thought it useful to select two different large accessibility initiatives and briefly describe them. Each is described with respect to key components of system change efforts. Although the outcomes associated with the components are unknown, they represent current thinking and recommended practice.

The intent of this article is to provide information on important components of two efforts including (a) a description of their policy, (b) the accessibility standard they use, (c) how the efforts are funded, (d) how change was implemented over time, (e) the training and supports offered, (f) any monitoring plans, and (g) any planned consequences. It is hoped that understanding these efforts may aide others in their planning or execution of Web accessibility policy.

We selected one large-scale system change in the U.S., and one abroad. Before the U.S. federal government's change to the Section 508 requirement in 2001, the highest profile large-scale effort came from the California Community Colleges (Chancellor's Office, California Community Colleges, 1999). The State of California is again in the midst of another large-scale accessibility effort in their system of higher education. In January of 2006, the California State University system launched the planning phase of its Accessible Technology Initiative (California State University, n.d.). January of 2007 marked the beginning of their implementation efforts. Although they are just beginning, we will briefly describe what is happening in California. Our second selection is the United Kingdom's Disability Discrimination Authority (DDA). Passed in 1995, the provisions for accessible Web content were in effect May of 2002; although the Act itself does not mention Web accessibility, the supporting documents are rich with examples that make it clear that digital accessibility was the intent of Parliament. Thus, the UK has had nearly 5 years of implementation.

The following are brief descriptions of the accessibility-change efforts for these large systems:

The California State University

See http://www.calstate.edu/accessibility/ for complete information

Description of the policy

The Accessible Technology Initiative was created to help the California State University (CSU) system carry out the requirements for accessible technology as expressed in the January 2005 Executive Order 926; the CSU Board of Trustees Policy on Disability Support and Accommodations.

"It is the policy of the CSU to make information technology resources and services accessible to all CSU students, faculty, staff and the general public regardless of disability"

Each of the 23 campuses in the CSU system are responsible for planning and implementation. The ATI is comprised of three priorities, each with separate timelines.

• Priority One covers Web Accessibility
• Priority Two covers Instructional Materials Accessibility
• Priority Three covers Electronic Information and Technology Procurement

The accessibility standard

The Accessible Technology Initiative uses the Section 508 requirements as the technical standard to achieve. This was selected because the State of California (California Government Code 11135) applies this standard to the CSU system.
It should be noted that all of the Section 508 regulations for electronic and information technology are in effect in the CSU system. Thus, the accessibility of items such as faxes, printers, computers, and kiosks, are as important as accessibility of Web and instructional materials.

Funding the changes

Since the responsibility of each campus is stressed throughout the available documents, it is assumed that each campus must accomplish this system-change from their budgets. For each of the three major priorities, the Chancellor's Office has noted the presence of CSU-wide resources (e.g., an enterprise level evaluation tool, faculty toolkit, guidelines for captioning, template for procurement). Moreover there are documented instances of CSU faculty who have received grants to improve accessibility efforts. These projects then make their resources available to the CSU system (e.g., EnACT grants support faculty development)

Implementation over time

The first year (i.e., 2006) was considered a planning year for the CSU. Beyond 2006, the implementation for each priority is on its own timeline. These timelines set forth the plan of implementation for the Accessible Technology Initiative:

1. Web Accessibility
   1. January 2007:
      1. Each campus must have adopted campus-wide accessibility policies that set forth the implementation plan with required items such as timelines, milestones, monitoring, remediation, and accountability processes
      2. Evaluation and repair of the top 20 most accessed Web pages
   2. March 2007: New and updated websites that conform to the standard
   3. May 2007: Completion of campus self-evaluation of Web content and applications as part of their overall transition plan.
   4. June 2007: Submit both the Self-Evaluation & Technology Access Transition Plan to the Office of the Chancellor
   5. May 2008: Accessibility for all Web content, including legacy content
   6. June 2008 and 2009: Submit assessment and progress reports to the Office of the Chancellor
2. Instructional Materials Accessibility
   1. June 2007: Each campus must have a plan in place to support the practices of faculty & staff as they create accessible instructional content in a timely manner. This plan must be submitted to the Office of the Chancellor
   2. July 2007: Accessible design will be part of new courses that use technology. Old courses will be made accessible if redesigned or if a student with a disability requires access.
   3. June 2008 and 2009: Submit assessment and progress reports to the Office of the Chancellor
   4. July 2009: All technology-enabled courses (i.e., old and new) will have accessibility built into the content authoring process
3. Electronic and Information Technology Procurement
   1. January 2007: Campus policy developed and promulgated. Pilot procurement process has begun
   2. June 2007: Submit a progress report on accessible procurement to the Office of the Chancellor
   3. July 2007: Fully implement accessible procurement process with the exception of credit card purchases
   4. March 2008:  Implementation now includes credit card purchases
   5. June 2008 and 2009: Submit assessment and progress reports to the Office of the Chancellor

Training and supports

It is assumed that each campus will identify and then follow their own plan to provide training and support to staff and faculty for the conversion to accessibility. A central Website provides an amazing array of accessibilty resources and instructional materials that can be used at local campuses.

Monitoring plans

It is clear in the documentation that yearly monitoring is a requirement of the CSU system-change effort. Moreover, the assessment and progress reports must be submitted to the Office of the Chancellor setting forth the clear expectation that monitoring will occur.

Planned consequences

One would hope that a planned consequence of conforming to the CSU policy would be acknowledgement of the effort or kudos to any campus accomplishing the policy. However, no statement was found in the CSU documentation to support such a notion. It is clear that the reporting requirements, by the stated timelines, will be used to determine if individual campuses are achieving good outcomes with the policy. What is not known is the consequence of any campus that fails to make progress as outlined in their individual campus plans.

The United Kingdom

Please see the Resources section below

Description of the policy

The UK Parliament enacted the Disability Discrimination Act (DDA) in 1995. However, it does not actually mention web accessibility. Technically, web accessibility falls under Section III (the requirement to make "reasonable adjustments" for persons with disabilities). Although the DDA does not specify Web accessibility, the supporting materials (i.e., the Code of Practice), specifically mentions it. The publication of the standards document for this policy was March 2006.

The accessibility standard

The DDA published their standard for Web accessibility in a Publicly Available Specification (PAS) 78. In it, the technical standards to which Websites will adhere are those from the Web Content Accessibility Guidelines (WCAG) of the World Wide Web Consortium. At the time of the PAS, the WCAG was in version 1.0. There is no specification regarding priority levels.

Funding the changes

Compliance (and paying for said compliance) is the responsibility of the individual organization.

Implementation over time

The DDA was enacted in three stages:

• December 1996 - it is unlawful to discriminate against persons with disabilities
• October 1999 - Service providers and employers must make "reasonable adjustments" for persons with disabilities - This is when web accessibility was technically to come into effect
• October 2004 - The small employer exemption was removed. Service providers must also make "reasonable adjustments" to the physical features of their premises for persons with disabilities.

The Code of Practice was published in May of 2002. The PAS 78 came into effect March of 2006

Training and supports

In the PAS 78 there are many groups specifically noted as providing training and or support for Web accessibility in the UK. Here are some of those mentioned there:
The W3C and Website Accessibility Initiative (WAI)
http://www.w3.org/wai/
The WAI provides much detailed support for the DDA's Web accessibility. They also have checklists of the standard to be used (e.g., see
http://www.w3.org/TR/WAI-WEBCONTENT/full-checklist.html)

The Royal National Institute for the Blind (RNIB)
http://www.rnib.org.uk/xpedio/groups/public/documents/code/InternetHome.hcsp
The RNIB offers a website with resources and recommendations on Web accessibility. Predictably this advice focuses mainly on accessibility for those with visual impairments.

Royal National Institute for Deaf People (RNID)
http://www.rnid.org.uk/
The RNID works to represent those who are deaf or hard of hearing. They provide tips for captioning and rich media.

AbilityNet
http://www.abilitynet.org.uk/ Provides training technical assistance and awareness with many of their services at no cost for employers.

British Dyslexia Association
http://www.bda-dyslexia.org.uk
This group aims to influence government and other institutions to promote a dyslexia friendly society.

Disability Rights Commission (DRC)
http://www.drc-gb.org/
The DRC works to eliminate discrimination based on disability status. They were established by an Act of Parliament

Mencap
http://www.mencap.org.uk
 This charity group works to promote individuals with learning disabilities. It includes their opportunities on the Web.

Scope
http://www.scope.org.uk/
This group focuses on those with Cerebral Palsy and provides insight into access needs from a motor perspective.

Monitoring plans

In 2004, the (Disability Rights Commission) DRC published a formal report on an investigation into the accessibility and usability of 1000 websites. Only one in five met even the most basic accessibility requirements.

Planned consequences

A website that is in breach of accessibility can be sued. The Royal National Institute for the Blind (RNIB) has threatened legal action against at least two large UK companies who changed their websites in order to avoid legal action.

In the wake of their formal report, the DDA issued a warning that organizations will face legal action the possibility of paying out unlimited compensation if they fail to make their websites accessible for people with disabilities.

Recently, an American company with no physical presence in the UK was cited as being in violation of the DDA.

Resources on Web accessibility in the UK

• http://www.webcredible.co.uk/user-friendly-resources/web-accessibility/uk-website-legal-requirements.shtml
• http://www.dmag.org.uk/resources/legal/dda.asp
• http://www.rnib.org.uk/xpedio/groups/public/documents/PublicWebsite/public_legalcase.hcsp
• http://www.wwwcoder.com/main/parentid/472/site/4610/266/default.aspx
• http://alistapart.com/articles/accessuk/
• http://www.userfocus.co.uk/articles/drc_report.html

What does it all mean?
The global nature of the internet underscores the importance of ensuring that our own websites comply with the most stringent of standards around the world. While there is still much work to be done before true web accessibility (on any scale) is available for all persons, including those with disabilities, the large scale efforts of entities such as California State University and the United Kingdom are helping to forge a path. Through their efforts, we can learn what we can do (and what not to do) to improve our own systems and to contribute to making the web accessible for all…

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