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Evaluating web accessibility best practices

Presented by Jude Robinson and Hollie Kay

8 December 2021

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Contents

Introduction
What you can expect from a VPAT
What to look out for
Other ways of judging accessibility
Top tips

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Introduction

Committing to accessibility

Why do we need to address accessibility?

26% of US adults experience some form of disability (Source: CDC, 2018)
The pandemic has accelerated the move to blended learning
More and more library content is being made available online

So how is the law relevant to accessibility?

The Americans with Disabilities Act (ADA) of 1990 prohibits discrimination against individuals with disabilities in all areas of public life
Other legislation or regulation exists at State and City level
The Rehabilitation Act of 1973 applies to any program that receives federal financial support, updated in 1998 with Section 508 to cover IT and Communication Technology (ICT)

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Why do we need to address accessibility?

The Centers for Disease Control and Prevention published figures in 2018 that estimate that 26% of US adults experience some form of disability. That’s a lot of students, faculty, and researchers in your institution who will need or benefit, from accessible content.

Centers for Disease Control and Prevention, 2018

As librarians you’ll be very aware of the challenges that the pandemic brought in terms of making content accessible when students couldn’t physically come to the library. Blended learning was already on the agenda, and the last few years have forced a rapid shift towards it. As public spaces open up again, the integration of online technology and traditional classroom-based teaching and learning will stay relevant.

Conversely, some disabled people who previously may have been able to avoid digital barriers are now forced into using digital methods of access because face 2 face interactions are potentially dangerous for their health.

And as well as enabling online learning, libraries have been increasing digital content in recent years for a number of reasons, including reducing the need for archive space and the possibilities of 1 digital copy being read by multiple users at the same time.

So how is the law relevant to accessibility?

First of all, an important caveat - I Am Not A Lawyer and none of this should be interpreted as legal advice. Please seek advice from your in-house lawyers on all legal issues.

In the US, the law that covers accessibility is the ADA, which prohibits discrimination against individuals with disabilities in all areas of public life. The purpose of the law is to make sure that people with disabilities have the same rights and opportunities as everyone else. For technology and web accessibility we’re mostly talking about ADA Title III, which prohibits discrimination on the basis of disability in places of public accommodations.

Other legislation can build on the ADA, or be relevant to web accessibility. Some examples include: New York State Human Rights Law; the New York State Civil Rights Law; the New York City Human Rights Law, and the Unruh Civil Rights Act California.

The Rehabilitation Act of 1973 also prohibits discrimination on the basis of disability and applies to any program that receives federal financial support. In 1998, Section 508 was added to the Rehabilitation Act, incorporating standards for the accessibility of “information and communication technology.” That can be anything from websites to documents, printers, desktop, and mobile software.

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Introduction

In practice

What does this mean for librarians?

Section 508 requires federal institutions to select the product that best meets accessibility requirements; ICT software must provide comparable access to people with disabilities as it does for those without
The ADA is for everyone - it can require that a tool or website be accessible, but there are no specific guidelines that explain how

A standardised report for identifying product accessibility

A template exists to help suppliers document their obligations under Section 508.
Suppliers use this - known as a VPAT® - to document their conformance level.

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What does this mean for librarians?

Section 508 says that Information Communication Technology (ICT) that is developed, procured, maintained, or used by federal entities needs to provide comparable access to all service users whether they have a disability or not. The enforceable part of Section 508 is primarily focused on procurement - federal entities are required to select the product that best meets accessibility requirements.

For example, say you work in a federal entity and you’re buying some printers. You’ve narrowed down your search to three printers that meet your business needs. Section 508 says that you should look at the accessibility level of each of them and pick the one that’s most accessible. In practice, Section 508 requires the people who are making acquisitions to have a method of comparing different products fairly.

The Section 508 regulations only apply to federal entities, but section 508 can be - and is - used by many organisations to aid compliance with the ADA as well.

The ADA is much more broadly applicable and covers more ground. It doesn’t explicitly address web accessibility, but a number of US courts have ruled that commercial websites are "places of public accommodation" and so subject to the ADA.

A standardised report for identifying product accessibility

Luckily the Information Technology Industry Council designed a format to help buyers and sellers of ICT products identify conformance with Section 508 Standards (and by extension compliance with the ADA).

Suppliers may use this format - known as a Voluntary Product Accessibility Template (or VPAT®) to produce a conformance report.

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What you can expect from a VPAT

Scope, definitions, applicable standards, product details

A VPAT®, or Voluntary Product Accessibility Template, is a template for providing a comprehensive statement of a supplier product’s conformance with accessibility standards around the world:

W3C/WAI WCAG 2.0 and/or WCAG 2.1
Section 508 of the Rehabilitation Act (US)
EN 301 549 of the Web Accessibility Directive (Directive EU 2016/2102).

Conformance level terms in VPAT version 2.x

Supports, Partially Supports, Does Not Support, Not Applicable, Not Evaluated

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A completed VPAT is called an “Accessibility Conformance Report”, or ACR. In practice, organisations nearly always just use “VPAT” when referring to the report, so we’ll be doing that.

Here’s a sample of our own VPAT for the Nature.com website. Looking at a VPAT you should expect to encounter a few pieces of explanatory information:

The VPAT template edition and version: we use the International Edition, which includes all available standards. Other suppliers might use the individual “Revised Section 508”, “EN 301 549” or “WCAG” editions instead. The VPAT® registered service mark is shown, and the latest version, currently 2.4.
Name of product: including version of the product being reviewed (if applicable - products aren’t necessarily always versioned).
Report date: specifying when the report was last published or updated.
Product description: a brief explanation of the product.
Contact information: which is where follow-up questions can be sent.
Notes: includes any further information about the product or the report (this may be left blank)
Evaluation methods Used: these describe the tools and strategies that a supplier has used to evaluate the accessibility of their product. You may see Assistive Technologies like screen readers (e.g. JAWS or NVDA) or voice input software (e.g. Dragon). You may also see a range of accessibility testing tools (e.g Pa11y, axe, WAVE, Tenon, SortSite, among others). Some suppliers might describe a specific manual evaluation method (e.g. WCAG-EM, Trusted Tester).
Application Standards/Guidelines: the Standards/Guidelines that are covered in the report - e.g. WCAG 2.0 A and AA. There must be at least one standard/guidelines or combination of the three that are applicable to the product being assessed. This table does not tell you if the product meets that standard/guideline, only whether or not the product has been assessed against it..

The Applicable Standards table is followed by a section (not shown) that defines the Terms used - Supports, Partially Supports, Does not Support, Not Applicable, Not Evaluated. Then you’ll see the Accessibility Conformance Report (ACR) tables, shown on the next slide

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What you can expect from a VPAT

The Accessibility Conformance Report

The accessibility standard/guidelines are listed and graded within the tables

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A different VPAT shown on this slide. We borrowed an example VPAT from the accessibility consultancy Deque (it’s shorter than ours!).

These tables are the meat of the VPAT - they tell you how the supplier has assessed their product against each criterion in the included standards.

You might see notes above the tables that are applicable to the product or to the report (for example versioning information, additional product description, information about what the document does or does not cover, or other things the supplier thinks are relevant). This may be left blank.

Under the notes is a table of three columns: Criteria, Conformance Level, and Remarks and Explanations. There are multiple rows in this column, one for each criterion in each standard.

Criteria

The criteria column contains references to the standard that’s being described. This screen shows the first few criteria of the WCAG standard, but you may see criteria from Section 508 instead (or in addition), or from the comparative EU regulation, EN 301 549, if the supplier sells their product in Europe as well as the US.

Conformance level

The supplier states whether or not their product conforms to each criterion. This is a single value for the entire product - a supplier can’t claim “Supports” if most of their product conforms, but they have a few pages or features where it doesn’t.

Remarks and Explanations

This is where the supplier justifies the Conformance Level they’ve selected. The point of this column is not to contain an itemised list of every defect, but a supplier is expected to be honest and specific about examples where their product falls short.

Too little information means that you can’t make an informed decision about the product, and too much information can obscure the degree of conformance by overwhelming the reader with data. It should be concise.

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What to look out for...

The warning signs!

The (potentially) suspicious VPAT

Out of date template or mismatched formatting
Document hasn’t been updated for a long time
Everything marked as “Supported” - 100% conformance is unlikely
Contains marketing language
No useful detail in Remarks and Explanations column
Missing content in cells
Suspicious “Not Applicable” Conformance Level claims
Only automated testing (or no testing at all!) listed in “Evaluation Methods”

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It’s possible to get some clues about a suppliers understanding and commitment to accessibility through their VPAT (if they have one).

There are some warning signs you can look out for. None of them are absolute guarantees that the content is inaccessible, but if you do see these, the supplier may warrant a closer look.

Out of date template or mismatched formatting

If the document has no version information, it could be Version 1, which was superseded in 2017.

A document that claims to be Version 2.x needs to use the matching terminology (i.e. v1 uses “Supports”, and “Supports with exceptions”; v2.x series uses “Supported”, “Partially Supported”)

Document hasn’t been updated for a long time

Especially in the case of fast moving software like websites, you’d expect the VPAT to change fairly regularly.

No updates for >12 months can be a sign of a lack of necessary process.

That said, they’re time consuming to prepare and need specialist knowledge, so many suppliers do full reviews of their VPATs on a yearly basis.

Ironically: everything passes! That can be a warning sign - 100% conformance is extremely hard to achieve.

Contains marketing language

A VPAT is not the place for advertising how amazing and cost-effective a product is. It’s meant to be a warts-and-all statement of facts.

No useful detail in Remarks and Explanations column, for example:

Remarks column left blank
Remarks column just says “yes” or “no” without elaboration
Remarks text simply repeats the text of the associated WCAG criterion

Missing content in cells

Each cell should have content. If a product meets a requirement, there must be a description on how this is achieved. If a product does not meet a requirement or only partially meets a requirement then this must also be described in detail.

Suspicious “Not Applicable” Conformance Level claims

Some VPATs say “Not Applicable” instead of “Does Not Support.” Only when a product does not have a feature can the specification “Not Applicable” be used. For example, if a VPAT for a video player specified “Not Applicable” for the Captions requirement, then that would be a red flag.

Only automated testing (or no testing at all!) listed in “Evaluation Methods”

Automated testing tools can only test approximately 30% of all possible accessibility errors. If the supplier’s methodology consists only of automated testing, or if the kind of testing they’ve used isn’t described at all, then the accessibility conformance can’t be accurately judged.

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What to look out for...

Good signs

A good VPAT

Produced by someone who specialises in accessibility
Clearly states the scope of the report, and the testing methods and tools that were used to produce it
Remarks and explanations are concise but thorough, and reflect real components
Honest disclosure of defects
Publicly available

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There are some signs you can look out for that indicate that the supplier takes accessibility seriously. None of these are absolute guarantees that the content is accessible, but if you do see these, you may gain some reassurance.

Produced by someone who specialises in accessibility

Ideally the VPAT will be produced by someone who didn’t have a hand in actually making the software. People generally don’t intentionally create faulty software, if they mark their own homework, they’re less likely to catch their own mistakes. Some companies commission external accessibility companies to produce their VPATs for them. Others use their own in-house experts.

Honest disclosure of defects

No product will be perfect so seeing these defects clearly listed may indicate that a thorough audit has been completed, and that the supplier understands the topic.

Publicly available

Is it a standard document, available to everyone, that you can get to easily from the supplier’s website? E.g. Springer Nature publishes its VPATs in the public source code repository Github, where a full change history is maintained. We link to those documents in our accessibility statements.

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Other ways of judging accessibility

Going beyond the VPAT

Do they have people responsible for accessibility?
Do they have someone or a team sorely responsible for accessibility?
How senior are these people?
For how long have they been addressing accessibility?
Who on product teams is responsible for accessibility?
Is the supplier a member of The Valuable 500 or similar organizations dedicated to improving accessibility?

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A bad VPAT doesn’t necessarily mean a bad product. Producing a VPAT is a skill that needs to be learned, and since the Section 508 Refresh (2017), a lot of suppliers are learning how to write these documents for the first time. Some are not based in the US and may not have encountered Section 508 requirements before. They could be serious about accessibility, they could have a reasonably accessible product, but are new to documenting their conformance in this format.

Because VPATs are voluntary, not every supplier will have one for a given product. Some suppliers will scramble to produce one if you ask them for it, and VPATs produced in a hurry will probably not be very good.

Or you could find yourself with multiple suppliers who all have good VPATs, and you need to choose between them.

The intention of the VPAT is for it to be an aid in assessing a product’s accessibility. It’s not the only method you can use, you can go beyond comparing VPATs and ask questions about the supplier’s organisation too. Here are some questions for suppliers that might be useful.

Do they have people responsible for accessibility?

Do they have someone or a team solely responsible for accessibility?

How senior are these people?

For how long have they been addressing accessibility?

Who on product teams is responsible for accessibility? Accessibility should be everyone’s responsibility. Suppliers should bake accessibility into their organisations.

Is the supplier a member of The Valuable 500 or similar organizations dedicated to improving accessibility?

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Top Tips

Quick takeaways

Check the VPAT uses the latest template and that the document is actively maintained
Honest description of existing defects is a good sign
Where you see gaps or warning signs of a bad VPAT ask your supplier for clarification
Ask your suppliers questions about their commitment to accessibility
View accessibility as an ongoing task

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Finally we get to the top tips

Check the VPAT uses the latest template and that the document is actively maintained

An actively maintained document is a sign that the product is being regularly reviewed. Some suppliers do this every 12 months (Springer Nature included).

Honest description of existing defects is a good sign

Most suppliers will not achieve 100% conformance. The larger and more complex the product, the less likely they are to be able to honestly make that claim. It’s reasonable to ask them if/when they plan to remediate the defects that they’ve described!

Where you see gaps or warning signs of a bad VPAT ask your supplier for clarification

It could be a sign that there are problems with the product, OR just that the supplier is inexperienced with the VPAT document format

Ask your suppliers questions about their commitment to accessibility

If you feel you need more information, don’t be afraid to ask your supplier some of the questions I just highlighted.

Do suppliers view accessibility as an ongoing task

Software especially is never finished - bug fixes and new features are rolled out all the time. Remediations are often incremental. Having “a project to fix accessibility” is an anti-pattern.

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Thank you

bit.ly/evaluate-access

Contact details

Jude Robinson

Global Head of Frontend Development

jude.robinson@springernature.com

Hollie Kay

Senior Frontend Developer

hollie.kay@springernature.com

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