Most of us recognize the ubiquitous disabled access sign for parking spaces (the side view of a person in a wheelchair, also known as the "handicapped parking symbol" to the politically incorrect among us). Its real name is the International Symbol of Access (ISA), and for those of you just returning from your long vacation on Mars, you can find the modern version of the ISA, along with other access symbols, at the Graphic Artists Guild.
Why the interest in this important but not particularly computer-oriented symbol? Because it directly relates to the topic: the 1998 Amendment to Section 508 of the Rehabilitation Act (29 U.S.C. 794d) of 1973, or simply Section 508 for short. You can think of this amendment as sort of a disabled access sign for the Internet. The act requires that all Electronic and Information Technology (EIT) purchased by or designed for federal agencies be designed to allow comparable access to information for all persons--both with disabilities and without.
It's pretty simple when you read it like that, but in practice it can become quite complex. It places some very interesting restrictions on what you can and cannot do. In this article, I will address the following:
1. What is Section 508?
2. How does it affect Web application design?
3. Does it apply to you?
What Is Section 508?
Section 508 came about as an amendment to the Rehabilitation Act of 1973 and on a grander scale is an outgrowth of Title VII of the Civil Rights Act of 1964. This thing has serious roots.
It contains what is essentially a rewording of the Web Content Accessibility Guidelines first published by the World Wide Web Consortium (W3C) back in 1999 and updated to Version 2.0 in 2003.
Section 508 is larger than that, however--it addresses the general accessibility of federal information, both by federal employees and by regular old citizens like you and me. In essence, it requires that any information that can be accessed by a person without a disability must also be accessible to a person with a disability. At first glance, this might seem pretty straightforward, but with Web applications, it requires a lot of planning (or rewriting!). Just look at the raging debate revolving around Netscape support; the accessibility problem is more complex than that.
For example, consider access for the vision impaired. When I started the research for this article, I was thinking perhaps a special magnifying screen or a speech interface. As it turns out, I had no clue. Speech output is fine for reading a page, but how does a person both blind and deaf interact with the browser? Do you install Braille interfaces (yes, there are Braille displays) on every device? How about a person with no fine motor control? What exactly does "accessible" mean? Well, here is just one subsection of the Section 508 accessibility guidelines. This is subsection 1194.31, which outlines the Functional Performance Criteria of EIT:
(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.
(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.
(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.
(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.
(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.
All of a sudden it starts to get challenging, doesn't it? Paragraph (f) just shot down any double-clicking I might have been thinking about. And that's just one subsection. There are others, just as challenging. I find one paragraph in subsection 1194.25 particularly intriguing:
(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
I always wondered what you were going to do with a fingerprint scanner when dealing with someone without a finger. And I suppose retina scans are useless for someone with advanced cataracts. Section 508 describes how to deal with all those situations.
Section 508 is publicly available, like any federal regulation. The final standard goes to great lengths not only to address the issues, but to discuss the reasoning behind each part of the document and even the estimated costs and benefits. You can read the HTML version or the text version or download a PDF version. It's just a trifle--only twenty or thirty thousand words (as a point of reference, this article is about a tenth of that). It covers everything from self-contained devices to desktop PC cabling. If you want to know what the government means when it says "accessible" (and why) in regard to electronic and information technology, this is the place to go. And don't worry, I'll have a bunch of links at the end of this column to help you get all the information you need on any aspect of Section 508.
How Does Section 508 Affect Web Application Design?
Interestingly enough, Section 508 affects Web application design in remarkably specific ways. I have read government documents dealing with computers and software in which it was clear that the writers didn't know much about their subject, and this seemed to be the rule rather than the exception. So I was astonished to find that the Section 508 provisions were written clearly and (for government documents) concisely. I especially like the fact that the writers went out of their way to explain why they did certain things--in some cases with pictures, just in case you didn't get the point. The link takes you to the description of the figure shown in Figure 1 (which also just happens to be Figure 1 from the standard).
Figure 1: The Section 508 standard includes figures to aid in comprehension.
In a similar vein, subsection 1194.31, the part of the standard dealing with Web applications, is very clear. There are 16 separate requirements, (a) through (p), which clearly describe the layout and content of "Web-based Internet and Intranet Information and Applications." While a bit wordy, the name is in fact a pretty apt description of all of the basic types of browser-based systems we use today. (You will recognize, though, that the authors didn't really take cell phones and PDAs into account in this--it will be interesting to see how those are handled, undoubtedly as a "self-contained device.")
As it turns out, I actually was partially right in my original assessment: The primary requirements in this section have to do with "assistive technology," which typically means text-to-speech devices for the visually impaired. I'd like to examine a couple of the requirements:
(a) A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).
This one is fairly easy, although most of us don't do it for every graphic image on the page. But it wouldn't be that hard to implement. This is probably one of the least intrusive statements, with the possible exception of paragraph (j), which disallows flickering at rates between 2 and 55 Hz.
(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.
At first glance, this isn't so bad, but there is one place where we often use color to denote information: links. My new Web site has rollover "buttons" (which are actually done entirely in HTML using style sheets) for links in which the text changes color when you hover over the button. I specifically took out the underlining on the hover because I didn't like the way it looked. Take a look at Figure 3. These buttons fail paragraph (c) because the only notification to the user is a change in color.
Figure 3: These standard and rollover "buttons" from my Web site do not conform to Section 508 standards.
(g) Row and column headers shall be identified for data tables.
I particularly enjoyed reading this one, although it does make for a lot of work for some situations. If your tables have headings at the row and/or column level, this section requires that you use the SCOPE attribute to identify the information as such. It is not enough simply to use TH (table heading) tags rather than TD (table data) tags, because in some cases even a TD tag can serve as a heading. Instead, you are directed to use the SCOPE attribute, as shown in Figure 4. When you look at the figure, you might be as amused as I was to see that the example used in a federal document included the names Betty, Wilma, and Fred. Only in America would the Flintstones find their way into Federal guidelines.
Figure 4: The scope attribute is used to identify the heading information for cells in a table.
(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with 1194.21(a) through (l).
This one has the possibility of being the most expensive to implement because most assistive technology today can read HTML but has no way to handle text generated by applets (or other plug-ins). So, anything that shows up in an applet is, by definition, inaccessible. For example, IBM's entire InfoCenter is unusable by someone attempting to access it via assistive devices, because the navigation bar is just one big applet.
(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
Coming a close second in cost to implement might be the requirements of this particular paragraph. Very few of us use the attributes identified in this paragraph, even though they've been available for a long time. Figure 5 shows those attributes at work: The ID attribute identifies a field, while the FOR attribute of the LABEL tag identifies a piece of text as being the label for that field.
Figure 5: Here's a FORM with properly applied LABEL attributes.
So How Bad Is It?
I've discussed only five of the 16 paragraphs. There are others that are nearly as bad. If you want to know the real impact of these provisions on your applications, you should take the time to review the entire document. It really depends on what you did on your site. And, of course, there are ways around everything--for example, the standards allow for sites to have text-only versions, provided they are kept up-to-date with the non-text version. That may be enough for you. It's double maintenance, but for mostly static sites, it's not a bad option.
On the other hand, for Web sites and applications that need lots of ongoing maintenance, double development might prove to be too costly, especially if you do your work by hand. And if you use a tool to generate some or all of your interface, you need something like a "Section 508" switch that forces the tool to generate code that is Section 508-compliant.
Do the Guidelines Apply to You?
Here's the real question! Chances are that today, the guidelines do not yet apply to you or your company. Unless you are selling software or services to a federal agency, you don't have to implement Section 508 guidelines. But that doesn't mean that you shouldn't be thinking about them.
Remember, federal agencies are usually just the initial place where accessibility mandates appear. First the federal agencies, then the rest of the country. If the past is any guideline, I have to believe that someday these particular guidelines will be extended to the general public, probably first through state and local governments. So, if you're doing business with courts or school systems, my guess is that at some point these accessibility guidelines will affect you as well.
But Should They?
And the even greater question is "should they"? If you think about it, the Internet is one of the great equalizers, at least among those with access. In America, most people have telephone lines, and as PCs drop in price, that means that Internet access is becoming more and more available.
Think of someone blind, living alone, unable to do many of the things we take for granted, like reading the paper or watching television. And even with wonderful organizations like The Lighthouse for the Blind, the selection of information is restricted. Until now, for the visually impaired, the world has been in many ways a place where only limited information was available.
But if the Internet were to become truly accessible, suddenly the whole world would open up through the wonders of assistive technology. And this same argument holds true for those whose lives are made more difficult by various other physical challenges, such as hearing impairment or motor skill deficit. In many ways, the Internet holds out hope for people of all backgrounds to become more connected, and that's always a positive goal.
While it may not be economically feasible for everybody to make their sites completely accessible, I hope that you will at least consider the issue from now on as you are designing your pages. Just think to yourself, "How does my site look to a blind person?"
Here's a list of links where you can find out more about Section 508 and about accessibility in general.
The Access Board
The Access Board's Section 508 page
Americans with Disabilities Act Home Page
The National Institute on Deafness and Other Communication Disorders
Comparison of WCAG and Section 508
Web Content Accessibility Guidelines
A personal favorite: WCAG in Haiku
Southeast Disability and Business Technical Assistance Center
Lighthouse International (The Lighthouse for the Blind)
Gallaudet Rersearch Institute