1. 1 ​ Updating your Section 508 testing process to address the new WCAG 2 standards of the refresh Jonathan Avila Chief Accessibility Officer SSB BART Group

2. 2 Agenda Standards Approach Comparison Resources

3. 3 WCAG 2 Level A and AA Section 508 “Refresh” incorporates WCAG 2 A/AA by reference –A is minimum level of accessibility –AA conformance requires Level A and AA be met. WCAG is set of technology neutral success criteria (SC) WCAG SC are testable statements – unchangeable –E.g. Provide text alternatives for any non-text content… WCAG 2 Level A and AA) is the standard for web, documents, and software –May choose to use PDF/UA for PDF documents –Additional “refresh” standards for authoring tools, software, platforms, hardware, etc.

4. 4 Additional WCAG Documents Success criteria are understood through non-normative techniques and understanding documents that can change –As technologies change new ways to implement are available Apply to software (desktop or mobile) through lens of Guidance for applying WCAG to non-web ICT document WCAG Conformance requirements –Compliance levels –Full pages –Complete process –Accessibility supported –Non-interference

5. 5 Gaps in WCAG 2 WCAG 2 became recommendation in 2008 Some gaps for touch and small screen size –Touch target size –Gesture access with AT running –Single touch access –Touch up events Mobile Accessibility Task Force (MATF) & other TFs at W3C proposing to fill the gaps in WCAG 2.1+ Section 508 would have to be updated again to include WCAG 2.1+ –Because it’s included by reference it would be straightforward

6. 6 Overall Approach Update checklist (document, web, software) –Most agencies have their own checklist breaking down what the standards mean –Many checklists already incorporated some WCAG 2 SC –Some agencies apply current software standards to web while others do not –Simplifies approach as same standards are applied across documents, web, and software –Checklist may be used in procurement process

7. 7 Guidance on Understanding SC Techniques non-normative documents –Sufficient techniques Techniques that are known to meet the SC and are accessibility supported –Include PDF, HTML, CSS, Silverlight, Flash etc. –Sufficient techniques are not required –Approx. 206 general techniques –Approx. 97 HTML techniques –Common failure techniques Documented failures of the success criteria Approx. 93 documented failures

8. 8 Overall Approach (cont.) Read the understanding WCAG documents –Describe intent of each SC and thought process of working group –SC names may be misleading so don’t presume applicability E.g. SC 2.4.6 Headings and Labels Look to Federal Baseline Tests and interagency collaboration –CIO Council Accessibility Community of Practice Address how Functional Performance Criteria are addressed –Only apply when standard can’t be met or there is no relevant technical criteria applicable

9. 9 Testing Update test steps for checklists based on sufficient and failure techniques –Expected results –Known passes and failures Reconfigure testing tools –Nearly all automated tools already test for WCAG 2 Level A and AA –Continuous integration tools –Unit testing tools Choose new manual testing tools –E.g. Contrast checker

10. 10 Metrics Current Section 508 –16 web standards –12 software (Some duplicates, some not applicable to web) 6 different but applicable to web 3 not applicable to web 3 duplicates of web standards –22 effective combined standards WCAG 2 A and AA SC –38 success criteria Comparison –16+ new requirements – essentially double 1194.22

11. 11 Standards in current Section 508 not in/different from WCAG 2 Section 508 1194.22 WebWCAG 2 Level A/AAComments Twice per second flashing limit – no exception for size. Allows for flashing in the range from 56-59 times per seconds WCAG’s is 3 times per second and also allows for small areas to contain flashing content. Practically equivalent Require that documents are readable without associated style sheets Only requires that content is in a meaningful sequence More flexibility Requires that embedded and linked non-HTML media provide a link to an accessible plug-in Indicates that the technology relied upon for conformance are accessibility supported. Most agencies will likely still be providing links to plug-ins – if not on every page on some general page

12. 12 Items in current Section 508 not in WCAG 2 (cont.) Section 508 1194.22 WebWCAG 2 Level A/AAComments Requires that alternative pages are not used unless cannot be made accessible WCAG allows for alternative pages to be used but has no bar to determine when or when they are not allowed Unclear how strictly this was followed previously. Could be addressed by agency requirements. In our experience most US Federal agencies require that link text is meaningful when taken out of context even though it’s not explicitly in Section 508. WCAG AA allows for it to be understood in context. Out of context is a WCAG AAA requirement. Some agencies will likely want to address this in their checklists.

13. 13 WCAG and Current Section 508 Comparison

14. 14 Text Alternatives and Time-Based Media WCAG SCComparisonWhat’s New 1.1.1 Non-text Content [A] Essentially sameClarifies not just images but non-text content 1.2.x Time-based mediaEssentially sameDefines details of what captions must include.

15. 15 Adaptable WCAG SCComparisonWhat’s New 1.3.1 Information and Relationships [A] Includes 1194.22 (g)(h)tables (l) scripts and (n) forms Also addresses structure like headings, lists, emphasis, etc. 1.3.2 Meaningful Sequence [A] Effectively addressed by 1194.22(d) readable without associated styles Decouples and specifically addresses reading order 1.3.3 Sensory Characteristics [A] New but often covered by 1194.22(n) forms Instructions can’t reference sensory characteristics

16. 16 Distinguishable WCAG SCComparisonWhat’s New 1.4.1 Use of Color [A]Essentially the same 1194.22(c) 1.4.2 Audio Control [A] NewMust be a way to stop, pause, mute, or adjust volume with audio that plays automatically 1.4.3 Contrast (Minimum) [AA] NewRequires specific contrast between foreground & background of text/images of text 1.4.4 Resize Text [AA]NewContent needs to remains readable and functional with browser zoom 1.4.5 Images of Text [AA No web equiv. 1194.21(f) for software When technology permits use text instead of images of text

17. 17 Keyboard Accessibility WCAG SCComparisonWhat’s New 2.1.1 Keyboard [A] New to web before de facto required already Essentially same as 1194.21(a) software Clarifies the requirement by emphasizing the method of input, rather than the nature of the output. 2.1.2 No Keyboard Trap [A] NewProhibits the keyboard from being trapped

18. 18 Enough Time and Seizure Prevention WCAG SCComparisonWhat’s New 2.2.1 Timing Adjustable [A] Essentially the same as 1194.22(p) 2.2.2 Pause, Stop, Hide [A] Similar to 1194.21(h) Animation Addresses control rather than animations as text. 2.3.1 Three Flashes or Below Threshold [A] Essentially sameLessened requirements for size and allows 3 times per second

19. 19 Navigable WCAG SCComparisonWhat’s New 2.4.1 Bypass Blocks [A]Essentially same as 1194.22(o) Uses the phrase “blocks of content that are repeated” instead of just “repetitive navigation links”. Potentially allows methods other than skip links like headings 2.4.2 Page Title [A] New, similar to frame requirement 1194.22(i) Titles must describe topic or purpose of page 2.4.3 Focus Order [A]NewRequires meaningful sequence of focus order

20. 20 Navigable (continued) WCAG SCComparisonWhat’s New 2.4.4 Link Purpose (In Context) [A] NewLink text must describe topic or purpose link when take into account context. Already common in many agencies 2.4.5 Multiple Ways [AA]NewPages except those in set must be reachable in more than one way. 2.4.6 Headings and Labels [AA] NewHeadings and labels are descriptive 2.4.7 Focus Visible [AA]New to web but covered under software 1194.22(c) Keyboard focus must be is visually apparent when using the keyboard to navigate

21. 21 Readable (Language) WCAG SCComparisonWhat’s New 3.1.1 Language of Page [A] NewThe default language of content is exposed to assistive technology 3.1.2 Language of Parts [AA] NewChanges in language must be exposed to assistive technology

22. 22 Predictable WCAG SCComparisonWhat’s New 3.2.1 On Focus [A] New but portions implicitly covered under 1194.22(n) UI components must not initiate a change of context when focused. 3.2.2 On Input [A]New but portions implicitly covered under 1194.22(n) Changing the setting of UI components does not automatically cause a change of context 3.2.3 Consistent Navigation [AA] NewRepeated navigational items must occur in the same order across pages. 3.2.4 Consistent Identification [AA] New to web, images covered in software by 1194.21(e) Components must have the same functionality are identified consistently

23. 23 Input Assistance WCAG SCComparisonWhat’s New 3.3.1 Error Identification [A] Implicitly covered by 1194.22(n) Forms although errors not mentioned Automatically detected input errors are identified and described in text to the user 3.3.2 Labels or Instructions [A] Implicitly covered by 1194.22(n) Forms although not specifically called out. Requires visual labels or instructions when content requires user input

24. 24 Input Assistance (continued) WCAG SCComparisonWhat’s New 3.3.3 Error Suggestion [AA] NewMust provide suggestions for correction when input errors are automatically detected and suggestions are available 3.3.4 Error Prevention (Legal, Financial, Data) [AA] NewWhen legal, financial, or test data is present, data can be changed or deleted the changes or deletions can be reversed, verified, or confirmed

25. 25 Compatibility WCAG SCComparisonWhat’s New 4.1.1 Parsing [A] NewSpecific significant HTML/XHTML validation and parsing errors in code are avoided 4.1.2 Name, Role, Value [A] Partially covered until 1194.22(l) scripts for web and 1194.21(d) Identity for software Sufficient information (including identity, operation, and state) about user interface components is available to assistive technology

26. 26 Resources Web Content Accessibility Guidelines (WCAG) 2.0 –https://www.w3.org/TR/WCAG20/https://www.w3.org/TR/WCAG20/ Guidance on applying WCAG to Non-Web ICT –https://www.w3.org/TR/wcag2ict/https://www.w3.org/TR/wcag2ict/ Comparison Table of WCAG 2.0 to Existing 508 Standards –https://www.access-board.gov/guidelines-and- standards/communications-and-it/about-the-ict- refresh/background/comparison-table-of-wcag2-to-existing-508- standardshttps://www.access-board.gov/guidelines-and- standards/communications-and-it/about-the-ict- refresh/background/comparison-table-of-wcag2-to-existing-508- standards Understanding WCAG 2.0 –https://www.w3.org/TR/UNDERSTANDING-WCAG20/Overview.htmlhttps://www.w3.org/TR/UNDERSTANDING-WCAG20/Overview.html Techniques for WCAG 2.0 –https://www.w3.org/TR/WCAG20-TECHS/Overview.html#contentshttps://www.w3.org/TR/WCAG20-TECHS/Overview.html#contents