Complementing Standards by Demonstrating Commitment and Progress

Posted on Friday, 22 May 2015 by Sarah Horton

By Sarah Horton, David Sloan, and Henny Swan

Note: This is the manuscript version of the paper we presented at the 12th Web for All Conference (W4A 2015). The paper appears in W4A 2015 Proceedings of the 12th Web for All Conference, Copyright © 2015 ACM. The paper won the best paper award in the Communications category. You can also view the presentation slides on Slideshare.


Concern for people is at the core of web accessibility. We want to ensure that all people are able to successfully access and use digital products and services. However, for many organizations, evidence of accessibility typically involves some declaration of standards compliance, and efforts toward accessibility focus on identifying and repairing issues in existing digital resources that fail to meet standards. When approached as a compliance activity, accessibility can seem daunting, if not impossible. Most sites and apps have hundreds, if not thousands, of pages and screens, and are in a state of constant flux, with a constant stream of new content and features. For many organizations, the digital landscape they seek to make accessible was constructed with little thought to accessibility, and contains third-party products and services over which they have little or no control. When “accessibility” means comprehensive and continuous compliance with standards, the positive energy around concern for people and striving for improvement gets spent finding and fixing bugs.

As user experience consultants with an accessibility consultancy, we see first-hand the shortcomings of approaching accessibility as solely a standards compliance activity. Standards have a key role in defining and measuring progress toward accessibility. Standards are a guide for identifying and repairing accessibility issues. But in many cases, standards compliance is a narrow way to define accessibility, particularly with large, distributed systems and environments. In this position paper we propose a way to consider standards within a larger context of accessibility activity, with a particular focus on making progress and removing barriers to a quality user experience in existing digital environments.

The Value of Standards

In our role as consultants we evaluate the accessibility of a variety of digital products and services, including those that help people learn new things, connect with family and friends, manage finances, and purchase everything from bras to bulldozers. We work with organizations that are concerned with making sure people can engage in these activities, including people with disabilities. They know that their success as an enterprise depends on the success of their customers and users, as success builds brand loyalty, which in turn leads loyalty behavior such as repurchase and recommendations (Hassenzahl, 2013; Nielsen & Gilutz).

But improving user experience is typically not the primary driver for engaging with an accessibility consultancy. Organizations are usually concerned with meeting obligations, providing people with disabilities with access to products and services. To that end, they want to learn what modifications and optimizations are required to make their products and services compliant with standards like the Web Content Accessibility Guidelines (WCAG) 2.0 and Section 508 of the Rehabilitation Act. In these cases, technical standards are seen primarily as a means to identify barriers—that is, attributes of an existing product or service that fail to meet standards and success criteria.

We are seeing a gradual shift toward a more proactive approach to accessibility, engaging with organizations that are just beginning work on a new product or significant reworking of an existing product. In these cases we use standards as part of the project specification, defining accessibility attributes of the product from the start and measuring compliance with the standard throughout the design and development process. Standards have an enabling role, serving as a vehicle for integrating accessibility into use cases, wireframes, specifications, and code.

Standards specify accessibility features

Technical standards are helpful for specifying what attributes are needed for something—a product, a building, a website—to be accessible to people with disabilities. They specify attributes like dimensions and auxiliary features that are known to be helpful for and usable by people with disabilities—for example, in an elevator, the minimum door width needed to accommodate someone in a wheelchair or scooter, and raised and braille lettering on buttons and audible feedback, so people who are blind can select a floor and know when they’ve reached it. Architects and builders have solid specifications to follow when building features such as elevators.

When building new digital products, specifications such as WCAG serve as a guide to decision-making. Product designers and developers that follow WCAG specifications can avoid creating accessibility barriers in the products they are building.

Standards help flag accessibility barriers

Standards are helpful for evaluation and benchmarking. With the elevator example, we can inspect an existing elevator to determine whether the dimensions and features are consistent with standards. If the elevator door is too narrow, or the buttons do not have raised letters, then the door is not in compliance with standards.

With digital products, we use standards to measure attributes of existing features. With the help of standards we can determine whether, for example, controls are correctly labeled and are operable using a keyboard.

The Limits of Only Standards

Elevators make a good standards success story because they are well specified and there are solid protocols in place to evaluate, certify, and re-evaluate and certify over time. Of course, elevators do break, and some are more accessible and usable than others. But relative to other features of our shared environment, elevators are pretty straightforward. It is possible to be successful in complying with standards, and ensure elevators are stable and accessible over time (United States Access Board, 2010).

On the other hand, digital products are dynamic, constantly changing, and are far less contained than features like elevators in the physical environment, and assessing their accessibility solely by measuring against standards will produce compliance failures. Also, standard-based assessments do not account for the impact of noncompliance on user experience, or on the completeness of the standard in terms of coverage of issues likely to be experienced by people with disabilities. Both these factors may lead to a standards-conformant website that contains significant barriers for people with disabilities (Power, Freire, Petrie, & Swallow, 2012). And finally, compliance audits tend to lead to remediation activity, which focuses energy and efforts on repairing features that are broken rather than considering a holistic solution to accessibility barriers (Kelly, Sloan, Phipps, Petrie, & Hamilton, 2005).

Digital products are dynamic

The digital environment is in constant flux. Websites are constantly changing and morphing, with new content, features, and updates. A page that meets accessibility standards one minute can fail the next, and a site judged to be accessible could become certifiably inaccessible in an instant, and due to the smallest compliance violation.

Take for example user-contributed content. On a WCAG-conformant “accessible” site, a customer might post a product review containing a non-descriptive “click here” link and upload an image without descriptive text, causing the page to fail two Level A WCAG success criteria: 1.1.1 Non-text Content and 2.4.4 Link Purpose (In Context). With a purely compliance-based definition, these two issues, on a single piece of content provided by a third-party, cause the site to become “not accessible.”

Digital products tend toward sprawl

Most sites and apps have more screens than can be manually evaluated for accessibility. To address this reality, some organizations turn to automated testing tools, using software to evaluate compliance against accessibility standards. This approach has inherent limitations due to a lack of depth of some tests—for example, software can determine whether an image has a text alternative but cannot assess whether the text accurately describes the image. Tools are limited not only in their coverage of accessibility standards but also in their approach to assessing against those checkpoints that can be automatically tested (Vigo, Brown, & Conway, 2013). Some organizations opt to thoroughly evaluate only a sample of a site or app, using tools and manual tests to identify issues on the sample and then extrapolating from the results to identify and repair issues with content and functionality throughout. Due to limits of depth and breadth, neither approach can guarantee that all content and functionality is complaint with standards.

Demonstrating Commitment and Progress

What if, in addition to evaluating products against standards, we focus energy and resources on activities related to creating a culture, practice, and processes that support accessibility? A coordinated accessibility program, with documentation and continual assessment, provides the means to demonstrate commitment and progress toward achieving accessibility. In this way, accessibility moves from a standards-based remediation activity that is characterized by standards failures and technical remediation to an endeavor that is focused on people and good experience, and targets successful progress forward towards an accessible digital environment (Horton & Sloan, 2014).

Here we present different models that could serve as the basis for further thinking and exploration of ways beyond standards compliance that an organization can show evidence of its efforts toward achieving accessibility.

Accessibility has reporting standards

In recent years, digital accessibility standards activity has addressed the importance of coordinated and sustained processes to support the provisioning of accessible digital products and environments. Here we focus on two standards—one from the United States and one from the United Kingdom—that address process and documentation.

The 21st Century Communications and Video Accessibility Act (CVAA) in the United States includes requirements around documenting accessibility efforts and progress toward barrier removal. Section 14.31, Recordkeeping requires manufacturers and service providers to create and maintain records about accessibility efforts, including:

(1) information about the manufacturer’s or service provider’s efforts to consult with individuals with disabilities;

(2) descriptions of the accessibility features of its products and services; and

(3) information about the compatibility of its products and services with peripheral devices or specialized customer premise equipment commonly used by individuals with disabilities to achieve access. (CVAA, 2011)

The recordkeeping requirements go on to specify how organizations must report progress, mandating that an officer of the manufacturer report annually through a compliance certificate to the U.S. Federal Communications Commission (FCC).

British Standards Institute Standard BS 8878 (British Standards Institute, 2010) presents a 16-step process for creating and procuring accessible web products. BS8878 encourages a process of documenting decisions and justification for them throughout the project lifecycle, and recognizes organizations may need to take a pragmatic approach where accessibility aspirations come into conflict with other objectives or are affected by project constraints. Step 15 of BS8878 specifically relates to communication of accessibility decisions at launch, including examples of where accessibility is not optimal, as might be the case in an early launch where some compromises have had to be made (Hassell, 2014).

The approach of documenting and justifying decisions that do not favor accessibility rather than being prohibited from making them should provide organizations with some flexibility to deal with situations where accessibility is not readily achievable.

Models Exist in the Built Environment

Standards for accessibility of public services and facilities are far more mature than digital accessibility standards. In this section we take a high-level look of how the American Disabilities Act (ADA) and the ADA Standards for Accessible Design support progress toward accessible environments, working toward positive and lasting change with long-standing services and facilities constructed without the benefit of accessibility specifications. We argue that this scenario closely matches that of the complex and decentralized digital environments that we commonly evaluate, most of which were constructed without guidance from standards, and now require often substantial and difficult remediation activities to achieve compliance.

The ADA scoping requirements in particular are helpful as a model for shaping obligations to fit their context of application. When specifying requirements for the built environment, the ADA differentiates between the following activities:

  • Building a new facility: When building a new facility, businesses must ensure the new facility is compliant with accessibility standards. For example, a new library building must meet specifications for accessibility.
  • Altering an existing facility: When altering features of an existing facility, businesses must ensure the alterations are compliant with accessibility standards. Additionally, any accessibility barriers present in the “path of travel” to the altered area must be addressed. For example, a library might renovate a wing of its building to house a new media lab. If the drinking fountain en route to the media lab is not compliant, some monies from the project must be reserved to install an accessible drinking fountain.
  • Removing barriers in an existing facility: Businesses must work to remove existing accessibility barriers. These efforts start with evaluating the existing facility and developing and acting on a barrier removal plan. Informing the plan is the notion of “readily achievable,” whereby the barrier removal is “easily accomplishable and able to be carried out without much difficulty or expense.” Readily achievable is measured in context—for example, large and well-resourced businesses are expected to remove more barriers than small businesses. Examples of barrier removal might include installing accessible door handle or installing an entry ramp.

These concepts apply to “places of public accommodations.” The ADA has 12 categories of businesses that provide goods and services to the public, including stores, restaurants, libraries, hotels, hospitals, and more. Organizations in these categories are obligated to take measures to ensure people with disabilities are able to access services and communications (United States Access Board; United States Department of Justice).

Translating these concepts to the digital environment, an organization could assess the public areas of their digital landscape (“places of public accommodations”) and establish a policy and processes to support the following approach:

  • Creating a new digital resource: All new technology development must follow accessibility standards. Any new technology brought into the digital environment, including those from third-party providers, must be accessible.
  • Altering an existing digital resource: When altering an existing website or application, such as adding a new feature, the new feature must be compliant with accessibility standards. For example, a live chat “ask a librarian” feature must meet accessibility standards. Modeling on the “path of travel” concept, there must be a specified effort to bring all pages that include the chat feature and the pages and paths leading to the chat feature into standards compliance.
  • Removing existing barriers: All websites and applications in the environment must be evaluated for accessibility. Existing barriers must be noted, and organizations must make a plan for fixing accessibility issues. Modeling on the “readily achievable” concept, barriers that are easy to accomplish and do not require much difficulty or expense take priority, and remaining issues are regularly revisited to reassess achievability. The impact of issues on accessibility must also be a factor in determining priority.

With this framework in place, organizations can establish an accessibility program, guided by careful and deliberate attention to making progress. In their Checklist for Existing Facilities (Adaptive Environments, 1995) prepared for the National Institute for Disability and Rehabilitation Research, Adaptive Environments Center provides a straightforward and ongoing program for identifying accessibility issues and developing an implementation plan for remediating barriers in a facility.

  • Get organized: Establish a timeframe for evaluating the facility. Invite people with disabilities and people with expertise in accessibility evaluation to assist in identifying barriers and solutions.
  • Obtain floor plans: Gather floor plans to assist in documenting issues in the facility.
  • Conduct the survey: Take notes and record dimensions. Document the experience of the space from different perspectives, including with physical, visual, hearing, and cognitive disabilities.
  • Summarize barriers and solutions: List the barriers identified and consider solutions. Learn about costs and timeframes for modifications.
  • Make decisions and set priorities: Review the summary with stakeholders to decide which solutions to pursue. For those that are not readily achievable, develop a plan for alternative access. Make an implementation plan.
  • Maintain documentation: Keep the survey, notes, and plans up to date.
  • Make changes: Remediate planned changes and update implementation plan to reflect barrier removal activities.
  • Follow up: Revisit the implementation plan and revise when changes become readily achievable.

Taking this planning framework to the digital environment, a similar approach might be along these lines:

  • Get organized: Establish a timeframe for evaluating digital resources. Reach out to people with disabilities, and engage digital accessibility experts to assist with evaluation and solution identification.
  • Obtain resource documentation: Gather together documentation and specifications for the digital resources.
  • Conduct audit: Evaluate the resource against digital accessibility standards.
  • Summarize barriers and solutions: List the barriers identified, assess their impact and how much resource will be required for remediation. Propose solutions.
  • Make decisions and set priorities: Inform stakeholders of issues and work together to decide which issues to address. Make a plan for all other issues, including a plan for addressing access issues that may arise for solutions that are not readily achievable. Create an implementation plan.
  • Maintain documentation: Use the audit to establish a baseline. Update the baseline to reflect changes, including new resources and any redesign and remediation activities.
  • Make changes: Remediate planned changes. Perform retests as needed to respond to remediation activity, and update the audit and implementation plan.
  • Follow up: Revisit the implementation plan and revise when changes become readily achievable.

This approach complements BS8878, which defines steps for complete projects, by focusing on the process of pragmatic and practical remediation of large, complex digital estates, where “throwing away and starting again” is not an option.


We partner with organizations to help meet obligations for providing digital products and services that are accessible to and usable by people with disabilities. We use standards to identify existing barriers. In some cases, repairing barriers is straight-forward—in others, more complex. Achieving and sustaining compliance with technical standards in an environment as complex and dynamic as a large organizational website is not realistic. However, persistent attention to providing accessible digital environments is essential, so we need measures in addition to standards compliance to keep advancing toward accessibility.

We see an important role for process standards related to recordkeeping and reporting to ensure accessibility efforts focus on people and are pointed in the direction of success. We also can learn from standards in the physical environment, and model efforts on progress made in building accessible places of public accommodation. We must be realistic in our expectations, and differentiate between new digital resources and those that are long-standing and difficult to repair. We should also consider the notion of “readily achievable” as a way to focus prioritization and remediation efforts around barriers that are easy and inexpensive to remove and will have the greatest impact.

When partnering with organizations, we begin by establishing a baseline, documenting the current state of accessibility in existing resources. We then embark on a process of improving accessibility, while at the same time establishing a response plan to address any difficulties that might arise from known issues. As we engage with organizations on creating accessibility in practice, we believe activities that show commitment and progress have as much, if not more, lasting value as standards compliance on making progress toward accessible digital environments.


About Sarah Horton

Sarah is TPG's UX Strategy Lead. She joined TPG in April 2013, after 20 years working as a user experience designer, developer, strategist, and lead in higher education, at Yale University, Dartmouth College, and Harvard University. She has done outreach to improve user experience, including books (Web Style Guide and Access by Design), working groups, presentations, and articles, including an article on web accessibility for the New York Times. Her latest book, with Whitney Quesenbery, is called A Web for Everyone: Designing Accessible User Experiences. Sarah is closely involved with TPG's accessible user experience offerings, including usability testing and organizational process reviews.


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