When is an accessible PDF accessible?

I recently wrote a blog: Standards must be accessible, in which I complained that a standards document on accessible documents was not itself accessible. Adobe had promised to create an accessible version which they have duly done. I have been sent a copy of the document but, as I write, this document has not been put up on the website so you are going to have to believe some of the comments below.

I ran it against the Adobe accessibility test and it came up clean so why is the document still not really accessible? The problem is that the Adobe test ensures that it has sufficient tags to enable a screen reader to navigate around the document and read all the text. However, there are two other types of problems that may make the document inaccessible:

• The layout and format of the document—for example very small fonts.
• How the reader software deals with reflow and Read Aloud.

Let us look at some examples in the Adobe version of the document. This list is based on comments made by the British Dyslexia Association and my own experience:

• Acronyms are used without spelling them out first. There is a lists of abbreviations in the appendix but at least the first use should be spelt out with the acronym in brackets.
• The document is mainly 9 point and 100 characters per line, recommendations are that body text should be at least 12 points and a maximum of 70 characters per line.
• The Adobe Reader has the facility to reflow text. This allows the user to choose the size of the text and the width of the line. It should mean the user can scroll down the document without having to scroll right and left. This does not work properly with the latest version of the reader on my Mac. I have made Adobe aware of this issue and I hope that it will get resolved soon.
• The Read Aloud function does not recognise headers as separate sections of text. When it is reading a page it reads a heading and the following text without a pause. Surely it could and should pause at the end of a heading?
• The reflow and Read Aloud also have a problem with the table of contents. The printed page layout is in the order: heading number, heading title, and page number as you would expect. But when you switch to reflow or Read Aloud the order changes to: heading number, page number and heading title. This order makes no sense especially as there is no pause between the heading title and the next heading number. It should read heading number, heading title, page number and a pause.
• Footnote numbers are small superscripts above the relevant word. Given that the body text is only 9 point the superscript is even smaller. It would be better if the footnote numbers were in square brackets and therefore the same size as the rest of the text.
• In the electronic version, clicking on the superscript takes you to the footnote, so being small is not necessarily a problem. What would be really nice is being able to click on the footnote and be returned to the relevant position in the text, as this would make it much easier for people with some form of reading difficulty, or vision impairment, to get back to the right place.
• Another oddity of the footnotes is that Read Aloud reads them before reading the content of the page, which is confusing.
• The printed version is fully justified (the right hand side is straight) but the Dyslexia association and many other organisation consider that left justified text is easier to read. Reflow is always left justified so one solution is to use reflow.
• Bookmarks are an excellent way to navigate around a document so it is a shame that the latest version of the document does not include bookmarks for the various headings. Some people may argue that the table of contents works as an alternative for bookmarks; but I have tried both and being able to see and jump to the bookmarks from anywhere in the document is much more useful than having to page back to the table of contents.
• Given my preference for bookmarks it would be great if Read Aloud could also read the bookmarks.

I am sure that this is not a complete list of the accessibility issues with the particular document and I would appreciate comments from my readers suggesting other similar issues with pdf documents. But this list is long enough to show that there is still a problem. It appear to me that there is a need for:

• A set of guidelines on formatting documents including types of fonts, text sizes, use of justification and spacing between lines and paragraphs.
• A set of guidelines relating to the set up of accessible pdf documents such as the use of bookmarks and initial views.
• Some improvement to the Adobe Reader so that it provides a engaging experience for all users. This might be provided by a third party.

It would be really useful if pressure for these changes came from the standards organisations including CEN.