European Standards on ICT Accessibility : report on phase I

An Open Conference on the results from Phase 1 of Standards Mandate 376: Public Procurement of accessible ICT in Europe took place 3-4 June 2008 in Brussels. It brought together many of the great and the good in the accessibility world including vendors, consultants, public bodies, standards groups, trade bodies, academia, and me, from European and international organisations. The audience came to listen and comment on the final draft outputs from phase 1 and the intent of phase 2.
To understand the conference you need to know a little of the background. In December 2005 the EU Commission issued a mandate M/376 with the main objectives:

To harmonise and facilitate the public procurement of accessible ICT products and services by identifying a set of functional European accessibility requirements.
To provide a mechanism through which the public procurers have access to an electronic toolkit, enabling them to make use of these harmonised requirements in the procurement process.

The mandate is being carried out in two phases:

Phase I – Inventory of European and international accessibility requirements and assessment of suitable testing and conformity schemes
Phase II – Standardisation activities.

The intention of the Mandate is to provide a similar framework in Europe that section 508 provides in the USA. In fact as section 508 is being revised at present and the W3C Web Accessibility Initiative (WAI) is close to publishing version 2 of their guidelines (WCAG 2 and ATAG 2) there is a real hope and intent that these three initiatives will create an aligned and compatible set of requirements that can be used worldwide.

The conference reviewed the drafts of two documents produced for part 1.

The first “Human Factors (HF); European accessibility requirements for public procurement of products and services in the ICT domain (European Commission Mandate M 376, Phase 1) ETSI DTR 102 612 V 0.0.40 (2008-05-19)” , to quote its full name, can be found at http://portal.etsi.org/stfs/STF_HomePages/STF333/STF333.asp .

This Technical Report provides:

An inventory of ICT products and services that are usually bought by public procurers,
A listing of existing functional accessibility requirements in EU and EFTA Member States and internationally,
The identification of gaps where no accessibility requirements exist and suggestions for developing missing or additional requirements,
A list of existing national, European and international standards and technical specifications which might comply with functional accessibility requirements and
Proposes standardization work for the development of requirements and award criteria that still do not exist or that are not yet standardized.

All the requirement and standards are cross referenced .

The document runs to over 200 pages and is intended as a reference document for phase 2.

I also believe that it is an important document, in its own right, for anyone looking at accessibility, as it provides and excellent catalogue of relevant standards and specifications. In its electronic version it could be used for example to quickly find information about standards on ‘captioning’ or ‘touch screens’.

The process of the mandate requires that this becomes a completed document so that there is a stable base for part 2 of the mandate. However, I believe that the information in this document should be turned into an on-line resource that could easily be accessed and easily explored. Further there is a need for this information to be continuously update as new requirements, standard and specification become available. This type of updating cannot wait for a formal revision of the document which might not happen for 3-5 years.

The second document: ‘CEN/BT WG 185 Project Team Final Draft Report: European accessibility requirements for public procurement of products and services in the ICT domain (European Commission Mandate M 376, Phase 1)’ can be found at http://www.econformance.eu/euconformancereport.html . The document is ‘an analysis of conformity assessment schemes of products meeting accessibility requirements’.

The document addresses the issue of how a procurer can ensure that a product is and will be accessible, or more specifically that the product fulfils defined accessibility requirements (product in this document covers: hardware, software, services and processed material). It is just under a hundred pages.

It describes the conformity assessment process which is applicable to any assessment, not just accessibility. It has four stages:

Selection: deciding what information needs to be collected.
Determination: collecting the required information.
Review and attestation: deciding if the requirements have been met.
Surveillance: if required, reviews the continuing conformance over time.

It discusses:

The various parties who can perform the assessments: first party: the vendor, second party: the procurer, third party: an independent body.
The criteria types to be used during the assessment.
Comparisons of a variety of existing assessment processes including: AENOR (from Spain), VPAT (from USA) and Segala (from Ireland) all of which have very different characteristics. The process of comparison will not doubt help inform the discussion during the second part of the mandate.

One specific area that came up in the discussions of this document was the pros and cons of first and third party attestations. Not surprisingly the vendors tended to prefer first party and the procurers tended to want third party.

The problem with first party is how much they can be trusted, vendors will tend not to say ‘we do not conform’.

The problems with third party are that it will add cost but more importantly who will be accountable if the attestation is found to be false.

The other problem, particularly with accessibility, is that it can only really be assessed at the time of use not at the time of procurement; for example if a vendor provides an application package which then needs to be configured and modified the raw package may be deemed to be accessible but the delivered solution may not.

My feeling is that the standards need to provide a good way for vendors to attest and then this could be baked into the purchase contract. This would probably be based on the existing section 508 Voluntary Product Accessibility Template (VPAT); one change to the VPAT should be the removal of ‘voluntary’ from the title as it gives the wrong message to the procurer as it sounds as if the vendor can decide what information to include. If it is baked into the contract then it is no longer ‘voluntary’.

I think there is more benefit of third party assessments of the final deliverable. A standards based international assessment process with independent reporting and complaints processes could be very valuable for the procuring organisations and their ultimate end-users. The RNIB See-it-right scheme and Segala’s TrustMark are particular examples of the direction this should take.

The second stage of the mandate will be critically important . It has the possibility of creating a procurement process that will benefit all parties and advance access-for-all significantly. It also has the possibility of creating a bureaucratic nightmare that the vendors will refuse to cooperate with and will not benefit the procurers or the ultimate end-users.

It is therefore extremely important that all the relevant stakeholders actively participate in the next phase. If you are a vendor of an ICT product (hardware, software, services or processed material) then you should have a member of staff who follows and comments on the proceedings. This also goes for major procurers (particularly, but not exclusively, in the public sector) as well as activist for specific disability groups.

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