A hole in section 508

Section 508 of the Rehabilitation Act is the law in the US that enures that US Government organisations will only buy ICT products that are accessible.

When asked about accessibility, vendors will often say their products conform to section 508 and will point to the relevant document called a Voluntary Product Accessibility Templates (VPAT). Which will say if the product is accessible and any areas that are not fully accessible.

The problem is that the VPAT only considers the accessibility of the product and not the accessibility of any outputs of the product. This means that website development tools, Content Management tools, document creation tools or any other tool that produces output that may be viewed electronically can conform to section 508 but none of their outputs do.

It is obviously important that people with disabilities should be able to use the tools. However, overall, there will be many more people with disabilities who may wish to view the outputs than will use the tools. I would suggest that the question ‘does the tool produce accessible output?’ is in fact more important than the question ‘Is the tool accessible?’.

The vendors of tools, and the creators of Section 508, would argue that creation of accessible output is the responsibility of the user of the tool not of the tool itself. Although it is true that tools cannot ensure that the output is accessible I am convinced that they can help the user.

Tools can be categorised in terms of the help they provide in producing accessible outputs:

• The output cannot be made accessible whatever the user does.
• The output can be made accessible but the user is not given any specific help.
• The user is given help by, for example: pre-built templates that are accessible, or prompts for information required for accessibility.
• The tool includes testing for accessibility that can be triggered before the user saves new outputs.

I think it would be a great move forward for accessibility if Section 508, or similar regulations, included a section where the vendor could categorise the tool into one of these four categories.

In the meantime I would suggest that vendors who are truly committed to accessibility provide this information in addition to the VPAT.