This is a continuance of the previous piece looking at BS 8878, “Web accessibility — Building accessible experiences for disabled people — Code of Practice”.

Problems

The ‘Accessibility Policy’ section demonstrates that for all the “we can’t be using WCAG 2.0, as it’s not ready”, it appears that this document is not ready itself. We’re asked to see section 7.2 for further information, but section 7.2 doesn’t yet exist. Many sections appear to be blank or incomplete.

Sadly, this seems quite common across the document. It seems to further suggest that the document itself has been rushed — there are places which are left blank, but there’s no information as to whether or not these are intentionally blank — and I would suggest that this document itself needs a further review period once the initial comments have been taken on board.

It also makes it seem a little cheeky that the document doesn’t want to use WCAG 2.0 on the basis that it isn’t ready whilst in itself probably being further from completion… [update: this, and indeed the BSI draft, was written before yesterday's release of WCAG 2.0]

This is continued on throughout further sections. I am invited to leave a comment asking what I think of…

8.1 Gathering requirements from disabled users of a business’ or organization’s websiteBS 8878 (Draft)

…only the problem is, that’s all it says. There’s no information about how you should gather requirements. If this document was intended to be made ready for publication after this initial review period, those behind it need to take a step back and re-assess. There are whole sections which need to be completed, then presented for review, then published. Otherwise when we’ve been asked to review blank content, the BSI cannot say that interested parties have had a chance to review these relevant sections.

This is reflected again in what from the business must be seen as one of the most important parts of the document — the business case for accessibility.

Currently, this says:

AbilityNet is currently preparing a business case for accessibility. It is anticipated that this will be completed during December.BS 8878 (Draft)

If the business case is not ready, this standard is not yet ready for review. Go away, finish it, and come back to us when it’s finished. Then we’ll review it.

[The impression I have now is that there may be another drafting after the initial comment period. I would recommend this, and feel that this would address a number of my concerns: I don't think we've had the chance to comment on everything properly, and therefore I don't think it can be seen as ready even once the current comments have been taken into account]

There’s also stuff in there which seems to suggest the people compiling the Standard have lost all track of time. We are asked:

if you are a public body, have you taken steps to publish a Disability Equality Scheme and Action Plan by December 2006?BS 8878 (Draft)

Well, either you did publish it by December 2006, or you didn’t. To misquote Yoda, there is either published or published not; there is no ‘steps’.

Next, I’m told that if my site is not usable, I am in breach of the DDA. The DDA being — and this is the important point — the Disability Discrimination Act. If my site has poor usability which affects everyone, then it is obviously a pile of poo and I ought to do better but surely I am not actually discriminating against someone in the process?

Disabled People

Again, the standard is sadly lacking.

Some disabled people are able to enjoy the full web experience despite their impairments without any additional assistance or accommodation. Other disabled people need to change some of the settings of their operating system or browser in order to access and use web content, read the screen, others can only read access and use the web content with the aid of access technology. Other people rely more heavily on the ability to alter font sizes and colours to suit their individual needs.BS 8878 (Draft)

And that’s it. According to BS8878, this is How Disabled People Access Web Content. No reference to people with dyslexia; no direct reference to people who can’t use a mouse or various other types of disability.

This is truly appalling: I had expected that this section would provide good in-depth information about different types of disability, about how these people access different sorts of web content, to help give the high-level chappie (or chappess) reading the document a better understanding.

It’s not even as though this information isn’t available. WebAIM have produced excellent articles on visual disability, auditory disability, motor disability, cognitive disability and seizure disorders. These are excellent articles which give you a good understanding of the subject.

Those involved in the BSI document really ought to pull their socks up; this is the sort of content they ought to have produced — and that frankly I expected from them.

Many sections of the document contain useful information — Annex G contains useful information on ‘measuring success’ which might be new to a number of people, but all too frequently the information is partial or missing.

Contracting Web Design

It is not possible to provide a definitive specification for a fully accessible web content which will satisfy the requirements of the DDA. Therefore organizations ought to be sceptical if contracting companies declare that they will create web content that are “DDA?compliant” or “compliant with the law”. Conversely, organizations cannot require a web designer to design a web content that is “DDA?compliant” or “compliant with the law”. BS 8878 (Draft)

As someone before me pointed out, this is of little bloody use to anyone. It’s all very well telling people what they can’t say, but the actual practical benefit would be found in advising people what they should say (or ask for).

It would also seem to directly contradict their earlier statement…

In the absence of county court case law it is not yet possible to make recommendations that guarantee compliance with the DDA…BS 8878 (Draft)

…which strongly carries the implication that once there has been some case law, it will be possible to “provide a definitive specification for a fully accessible web content which will satisfy the requirements of the DDA”.

Summary

It’s a good idea to have a British Standard for accessibility. This, in its present form, is not really it. Parts appear to be missing, and other parts are not covered in enough depth yet.

The BSI and the people behind it must take the feedback from this document, improve and update the document and then return to the public for a further review. Anything less than that has not been made open to public review, simply because of the large portions of the document which are missing.

Back in August 2006, I was scathing of the latest status of WCAG 2.0. As updates were released, I began to change my opinion, as the WAI actually took note of what people had to say and began to improve their document, to the extent that by the time it became a Candidate Recommendation (in April 2008, I think), I was saying that it was now better should be used in preference to WCAG 1.0.

I sincerely hope the people behind this British Standard put in the same level of work that those on the WAI did, because this document is currently where WCAG 2.0 was. You can see what they are trying to do, but it’s not really usable as it stands. I hope in the future to be able to announce that BS 8878 has convinced me it has improved sufficiently for me to recommend it, much as WCAG 2.0 did.

I would also hope that the BSI look at finding a way to improve their emailing. Currently, every time you comment on the draft, they send you an email, telling you that you have commented on the draft, and what that comment was. Now, I know I commented on the draft, after all, it was me that did it, and I don’t really see the point of being sent some thirty-odd emails telling me so. If you want to ensure that people know what their comments are, could you not ‘batch up’ the comments on a daily basis into one emaill per person per day?