Working paper for e-commerce reference: web accessibility

Version 1.0
Human Rights and Equal Opportunity Commission, 1 December 1999


1. Summary
2. Introduction
2.1 Reasons for priority to Commonwealth sites
2.2 Best practice instances
2.3 Testing methods and standards
2.4 Accessibility required by Disability Discrimination Act
2.5 Compliance on large database driven sites
3. Overall results
4. Issues
4.1 Lack of alt text or text alternatives for images and image map links
4.2 Solutions through text only alternative pages
4.3 Excessive download times
4.4 Accessibility of PDF files
4.5 Requirements for other plug ins
4.6 Frames problems
4.7 Columns and tables
4.8 Separation of links
5. Recommendations for achieving accessibility

1. Summary

As part of the reference given to the Human Rights and Equal Opportunity Commission by the Attorney-General on access by older Australians and people with a disability to electronic commerce and new information and service technologies,  Commission staff have conducted preliminary tests of accessibility of Commonwealth Government sites. Similar testing of business and other sites will be reported shortly.
  • Most Commonwealth sites tested showed significant accessibility barriers to users who have a disability or do not have access to high speed connections and up to date computers
  • Many sites present barriers to users who cannot see images, cannot access documents in PDF format, or have difficulty with sites using frames
  • A substantial number of sites appear to require excessive download times even at the home page level
  • Most barriers found appear relatively easy for providers to remedy on existing pages and to avoid for new pages
  • Some sites appear to have dealt effectively with accessibility issues as well as long download times by implementing text only equivalent sites
  • These results show a need for agencies to conduct simple testing of their own sites at a minimum, and indicate a need for consideration of more detailed useability testing and quality assurance measures .
Delivery of information and services through the internet is clearly moving from experimental efforts by and within individual agencies to being a major and in some cases principal channel of government information, communications and services for Australia's diverse people. In many cases this move has already occurred, and in all cases must be regarded as required by the 2001 date indicated by the Prime Minister in the 1997 Investing for Growth statement. It appears appropriate to consider measures within this same timeframe to ensure that this channel of information, communications and services is effectively accessible to all Australians and in particular does not exclude older Australians and people with disabilities.

2. Introduction

The power of the Web is in its universality. Access by everyone regardless of disability is an essential aspect.:  Tim Berners-Lee:

Because the digital economy by definition requires a dynamic Internet environment, the very functionality required by the disability community can satisfy this dynamic requirement for web-based transactions. Accessible web design enables dynamic web sites- whether or not it is for business transactions, voting or long-distance learning. In addition, many benefits are emerging in the application of accessible web design. Accessible web design enables CD and videotapes to be archived through captioning. Accessible web design also enables electronic textbooks to be accessible. Even illiterate populations can access the Internet by listening to screenreaders audibly reading the web. And lastly, web accessibility enables low technology to access high technology. People with slow modems and low bandwidth can access the electronic content of the web. Even consumers without state of the art computer equipment or who only have a telephone, can participate in an accessible Internet environment using a telephone browser.

... inaccessible web page design either hides the text within images, frames, applets or animated gifs or renders the text unintelligently in table, columnar, or portable document format (pdf). Even on-line forms are inaccessible especially when designed to prevent keyboard navigation and input. Whether the form is posted for school or event registration or on-line banking or shopping transactions, people with visual and/or mobility disabilities are faced with a significant barrier to participation. But the impact is not limited to people with visual and mobility disabilities. People with specific learning disabilities are also finding that they can no longer access web pages audibly with screen readers. Even people with cognitive disabilities are becoming lost due to the absence of navigation elements at web sites. Moreover, people with hearing disabilities cannot access the content of audiostreaming and videoclips posted on the Internet due to the absence of captioning.: Cynthia Waddell, "The growing digital divide in access for people with disabilities: Overcoming barriers to participation",

The Commonwealth Government needs to be an effective role model in delivering accessible on-line and e-commerce services. The services the government delivers are important in the lives of every Australian, particularly older Australians and people with a disability. This is equally true of on-line services. Much of the information provided on-line by the Australian Government is also important in assisting Australians to exercise their rights and responsibilities as citizens. Older Australians and people with a disability must not be disempowered as citizens by lack of access to this information in an accessible form. The Government also needs to have credibility when it urges other suppliers of on-line and e-commerce services to ensure their services are accessible. Demonstrating how it can be done effectively and economically is an important role for the Commonwealth Government.: Submission, Vision Australia Foundation
As part of its inquiry under the reference given by the Attorney-General on access by older Australians and people with a disability to electronic commerce and new information and service technologies, Human Rights and Equal Opportunity Commision staff have conducted preliminary tests of accessibility of Commonwealth Government sites (as at 11 November 1999).

Commission staff have also commenced similar auditing of the most popular Australian business, news and information and education sites and are using preliminary results in discussions with the providers of those sites.

2.1 Reasons for priority to Commonwealth sites

At this interim stage priority has been given to reporting on accessibility of Commonwealth government sites for a number of reasons.

As pointed out by a number of submissions, if the Commonwealth is to take a leadership role in this area it is important that accessibility be understood and implemented in its own operations.

At present most Commonwealth government sites are undertaking tasks which are simpler (in most cases one way information provision), and able to be performed with longer established technology (where there has therefore been more time for accessibility issues and solutions to be identified) than ecommerce sites which are attempting leading edge functions such as secure on line transactions and using leading edge approaches accordingly. (The Australian National Audit Office report "Electronic Service Delivery, including Internet Use, by Commonwealth Government Agencies", tabled and released 15 November 1999 and available (only) in PDF form at estimates that even by 2001 the majority of commonwealth agencies will have gone no further than having a website which publishes information, with only 23 per cent even by then providing for the public to enter secure data and enter into transactions.)

In some more sophisticated ecommerce applications there appears more room and need for discussion of difficulties and need for further technical development to resolve these, particularly in the interaction between accessibility and measures to ensure security of online financial transactions.

Unfortunately ... it tends to be the most innovative, leading-edge and creative applications that are the most difficult to learn and use for people who are blind or vision impaired. This is because many of these programs break with some of the established conventions, in order to present information in a more visually appealing, effective or impressive visual format. It therefore also follows that since E-Commerce applications and webpages are some of the most leading-edge and innovative services, that these are often some of the most difficult or impossible applications and sites for a blind person to access or use.: Blind Citizens Australia, Accessible E-commerce in Australia.

2.2 Best practice instances

This is not at all to say that it is impossible or unnecessary for ecommerce sites to provide accessibility. The Commonwealth Bank's submission acknowledges the importance of providing accessibility in its own offerings and refers to positive feedback from users for accessibility features incorporated to date.
It is not an accident that the sites with the most traffic have an uncommonly low rate of violations of the top ten mistakes of Web design. On the contrary, it is because these sites are easy to use that they get so much traffic. : Jakob Nielsen, "Who commits the top ten mistakes of web design?"
It should also be noted that one of the few Commonwealth sites identified to the Commission as achieving best practice in accessibility is the web site commissioned by OASITO to support the recent partial sale of Telstra ( ), which of necessity was performing some innovative and demanding ecommerce functions and
consistently achieved a very high level of accessibility despite the need for many rapid updates of content and of the on-line forms that were needed through the short period of the share offer.: Submission, L.Stillman, K.Williamson, A.Bow
The same submission indicates that the Gold Medal Disability Access Strategy site of the Department of Family and Community Services ( appears to have fully met all the checkpoints in the WAI Guidelines.

The Commission's own testing indicated that the homepage and 55 out of 55 pages tested within the Commonwealth Office of Disability site passed for accessibility.

2.3 Testing methods and standards

Testing of sites to date has been done using downloaded versions of the "Bobby" automated checking program available for online use or downloading at

This program can be used to test pages against the accessibility criteria set out in the World Wide Web Consortium's guidelines, the Web Content Accessibility Guidelines. (These guidelines have been and continue to be the subject of extensive consultation. They are based on work by the independent and highly respected TRACE Centre at the University of Wisconsin Madison which appears to be the world's leading centre of expertise on universal access issues particularly in the area of electronic technologies.)

As noted in the current version of the Commission's advisory note, and in the Issues Paper, these guidelines provide detailed advice on accessibilty requirements and means of complying with them, as well as simpler accessibility check lists. These guidelines also take into account developments in the capacities of accessibility software and equipment on the user side, rather than assuming that all required progress rests with providers of content.

The Commission recommends reference to the full version of these guidelines for all professionally developed and maintained sites. A useful easy reference guide to some major issues is provided in "Quick Tips for Accessible Websites" , at :

  • Images & animations. Use the alt attribute to describe the function of each visual.
  • Image maps. Use client-side MAP and text for hotspots.
  • Multimedia. Provide captioning and transcripts of audio, and descriptions of video.
  • Hypertext links. Use text that makes sense when read out of context. For example, avoid "click here."
  • Page organization. Use headings, lists, and consistent structure. Use CSS for layout and style where possible.
  • Graphs & charts. Summarize or use the longdesc attribute.
  • Scripts, applets, & plug-ins. Provide alternative content in case active features are inaccessible or unsupported.
  • Frames. Use NOFRAMES and meaningful titles.
  • Tables. Make line by line reading sensible. Summarize.
  • Check your work. Validate. Use tools, checklist, and guidelines at
In addition to simple pass/fail accessibility ratings, the Bobby program can provide detailed reports on issues requiring examination and recommendations for improvement.

Bobby testing of reasonably large collections of pages has been found by Commission staff (policy officers, not information technology professionals) to take only a few minutes for each site tested, on equipment of a capacity (PCs with Pentium II 300 CPU, 128 megabytes RAM, testing done in part over ISDN link available in office and in part over 56k modem at home) which would available on many Commonwealth public servants' desks, and which would be significantly less capable than the equipment used by most professional web developers.

It seems reasonable therefore to expect that every Commonwealth government organisation responsible for a web site will ensure, or itself conduct, testing of its own site. It seems realistic for any Commonwealth organisation which does not conduct such testing or equivalent itself, and respond appropriately, to expect that such testing will be applied by interested members of the public or by one or more of the bodies within the Commonwealth with relevant accountability responsibilities.

As acknowledged by the providers of this program, automated testing can only be a guide. This is particularly true for sites undertaking more sophisticated interactive functions where automated programs may not always have ready made accessibility solutions to suggest.

These tests should highlight major access issues, [and] are valuable in reducing a number of accessibility barriers. However, some of these testing scenarios only replicate conditions caused by a disability; they do not simulate the full experience a user with a disability might have. In real-life settings, your pages may be less usable than you expected. Thus, one of the strategies recommends that content developers observe people with different disabilities as they attempt to use a page or site.: Techniques for Web Content Accessibility Guidelines

Thorough assessment of effective accessibility and usability requires more detailed manual checking of some issues where an automated program can only raise queries, and testing of issues of intelligibility of site structure and functions for users with limited familiarity with on line services or with limited ability to navigate complex sites.

A number of submissions and resources provided to the Commission recommend that the Commonwealth require useability testing at least for its own web sites.

2.4 Accessibility required by Disability Discrimination Act

As pointed out in the Commission's advisory notes in this area (first issued early in 1997), inaccessible sites are exposed to the prospect of complaint under the Disability Discrimination Act from any person with a disability who is disadvantaged by lack of access. These advisory notes emphasise that:
Provision of information and other material through the Web is a service covered by the DDA. Equal access for people with a disability in this area is required by the DDA where it can reasonably be provided. This requirement applies to any individual or organisation developing a World Wide Web page in Australia, or placing or maintaining a Web page on an Australian server. This includes pages developed or maintained for purposes relating to employment; education; provision of services including professional services, banking, insurance or financial services, entertainment or recreation, telecommunications services, public transport services, or government services; sale or rental of real estate; sport; activities of voluntary associations; or administration of Commonwealth laws or programs. All these are areas specifically covered by the DDA.

2.5 Compliance on large database driven sites

In discussions with Commission staff one agency raised the need of some large public sector (and other) sites to use Lotus Notes or similar database environments in publishing documents rather than direct HTML authoring, for effective workflow management and publication control, and suggested inability as a result to publish documents in standards compliant HTML.

The Commission's understanding of issues regarding publishing driven by Lotus Notes or similar database environments as against direct HTML authoring, however, is that any limitations in accessibility of resulting published pages are the result of the particular publishing approach or software selected , rather than being inherent in use of Notes or other database systems for document management.

The disability rights section of the Commission site is managed as a (relatively small) database and published through NetObjects Fusion, for example, and reporting of any accessibility errors or limitations in the published product is encouraged so that they may be remedied, rather than accepted as inherent. Discussions with another Commonwealth agency managing a larger and more technically demanding site using the ColdFusion program indicate good results in achieving accessibility even for more sophisticated interactive elements.)

One of the resources linked from the reference resource page suggests that database driven publishing should in fact operate as a means of guaranteeing accessibility across a site. On a number of sites (public and private sector) which would otherwise have been identified in this paper as representing models of best practice for others to follow, a few inaccessible pages were found, which seem to have resulted from an individual author or section of the enterprise failing to follow the practice or policy of the organisation.

In a large-scale enterprise, commitment to good, accessible design may lead to stronger enforcement of corporate publishing standards. Jakob Nielsen, SunSoft Distinguished Engineer known for his work on the theory and application of hypertext, says that while Sun is committed to a fully accessible Web site, "one major problem is the ability to coordinate contributions from literally hundreds of content authors, not all of whom may understand the subtle details of Web design." The solution may include database-driven publishing or a document-management system that ensures compliance." :Making your web site accessible, Liora Alschuler,,4413,1600180,00.html

3. Overall results

The results of this preliminary survey can be shortly stated.
  • Most Commonwealth sites tested showed significant accessibility barriers
  • Many sites present barriers to users who cannot see images, cannot access documents in PDF format, or have difficulty with sites using frames
  • A substantial number of sites appear to require excessive download times even at the home page level
  • Most barriers found appear relatively easy for providers to remedy on existing pages and to avoid for new pages
  • Some sites appear to have dealt effectively with accessibility issues as well as long download times by implementing text only equivalent sites
  • These results show a need for agencies to conduct simple testing of their own sites at a minimum, and indicate a need for consideration of more detailed useability testing and quality assurance measures .
The submission provided by the Office of Disability within the Commonwealth Department of Family and Community Services indicates a belief that, pursuant to their equity obligations under the Commonwealth Disability Strategy, most Commonwealth sites are already complying with AusInfo's Guidelines for Commonwealth Information Published in Electronic Formats (which emphasise accessibility issues and reference the Commission's advisory notes on web page accessibility). The Commission's findings at this point are not consistent with that belief.

This appears to support the need for AusInfo's current revision process for these guidelines to set out accessibility requirements more explicitly drawing on the World Wide Web Consortium's Web Content Accessibility Guidelines. It may also indicate need for further consideration of the effectiveness of arrangements for monitoring of access and equity requirements within the Commonwealth, in particular regarding internet and electronic service delivery accessibility.

At this point the Commission believes it would be most productive to report general findings only and to conduct direct discussions with organisations whose sites appear to need improvement, rather than seeking to emphasise a list of "offenders", since

  • the great majority of Commonwealth sites surveyed, the Commission's included, appear to require improvement
  • as already noted these results are only preliminary to more thorough useability and accessibility testing, the processes for which the Commission will be discussing with government and other organisations through the remainder of this reference
  • as would be expected, some sites are known to be undergoing significant restructuring and it could be confusing to publish results which refer to a superseded version of the site.
In general, submissions and comment from the community have taken the same approach as this paper, in identifying issues rather than "naming the guilty".

It should be noted however that any interested individuals or organisations remain free throughout the course of this reference to conduct and provide by way of submission the same simple testing as the Commission has done, or more sophisticated assessment if they are capable and so wish, and that the Commission is publishing submissions in this reference on its web site.

4. Issues:

4.1 Lack of alt text or text alternatives for images and image map links

Many pages tested failed accessibility testing because of a lack of provision of the "alt text" feature which can be attached to images to allow blind and low vision users, or users who have images turned off for download time reasons, or because of hardware or software limitations, to see what the image is.

The importance of this feature for blind and vision impaired users is, or should be, obvious. Submissions to the Commission have also noted its importance to older people:

It is often said that many older people start with "hand-me-ups", like an old 386 computer discarded by a family member who has upgraded. For such reasons, COTA's website has been made 'Bobby certified'. This means that alt tags for all graphics are provided so that the site can be accessed by people with disabilities who may wish to turn off the graphics, and by less up-to-date browser technology: Submission, Council on the Ageing.

The importance of accessibility features for rural users who may not have a disability has also been emphasised. "Web sites for rural Australia: designing for accessibility": J.Groves, points out that many rural people use the web with images turned off as a means of dealing with still limited bandwidth and slow download times.

Where the image is part of the "scaffolding" or decoration of a page lack of alt text may be simply annoying or puzzling rather than fatal to access. Where the image provides a link to substantial content, failure to provide alt text or a clearly available equivalent text link, renders that content inaccessible. This is a common problem for links presented on Commonwealth sites through image map hot spots in particular.

For example, on one Commonwealth department's homepage tested, alt text was missing for image map hot spot links and for several images serving as links, including the image link given to the Prime Ministers' home page, so that a vision impaired or rural user working without images would simply not see this link.

In some cases, image links had alt text provided, but this text did not present any useful information (whether because the alt text was only a default setting supplied by the authoring program used, or because it had been applied deliberately but without sufficient thought for its importance and function).

For example, on one Commonwealth department home page the image link for the Department's contact details had alt text saying only "image'. Many links on the same page had alt text saying "click to go" - but go where, was not specified.

On one major agency site most pages passed automatic checking with the Bobby program, but on checking manually (as recommended by Bobby and by the World Wide Web Consortium guidelines) for whether the alt text gave sufficiently meaningful information, "click here" was found as the alt text given for numerous links. Click here for what?

One another department's site the alt text for the main menu map read "picture".

On another important site a number of image links across the page had alt text provided only as follows: "toolbar – choose one of these icons" . A user unable to see the images would not know what the choices are.

In the Commission's experience and on the basis of available advice these problems should be simple to remedy on existing pages and simple to avoid in future by applying attention to the issue at the outset.

Provision of transcript for audio files requires more effort, but is technically reasonably simple to implement. A number of Commonwealth sites tested provided audio files but appear to have overlooked provision of text equivalents.

A few pages tested had dynamic content (such as a number of different headlines popping up or running across the page in turn) which was not reflected, or only partially reflected, in the static alt text provided.

Some commentators have recommended avoiding moving text (at least on pages whose purpose is information and service provision rather than entertainment). The Commission's understanding however is that these approaches can also be made accessible relatively simply, by appropriate use of alt text, and do not present the same fatal barriers to some users as for example the "blink" tag, which was present on some Commonwealth sites in the past but which sites tested seem now to have avoided or removed.

4.2 Solutions through text only alternative pages

A number of sites which failed Bobby testing for accessibility (including HREOC's own) provided a fully equivalent text alternative which passed accessibility testing at all or most points (the text alternative being generated automatically "on the fly" from the same data as the graphics site and thus avoiding the situation where text only users might have access to more limited or outdated information).

Centrelink's submission notes the importance of its text only site version as a means of ensuring effective access for its clients.

In some cases a text home page had been provided which passed Bobby testing for accessibility, but most pages linked from there on failed for the common reasons of lack of alt text for images and image map hot spots. As pointed out by one submission, it needs to be remembered that accessibility means more than access to the front page.

Several sites tested had the text only link as the first item to appear on the page, representing best practice and conforming with the Web Content Accessibility Guidelines in this respect.

The Commission's own site has similarly been modified to place the link to the text only version first. A problem encountered, which others might watch for in implementing a text only site, is that when this was first implemented the text only page started by stating "text only site", without indicating whose text only site it was.

A number of sites had text only versions but provided links to these only from the bottom of the front page. Users must therefore wait for much of the rest of the page to download before reaching it. In the case of users of screen readers and speech output, this may involve sitting through (and perhaps paying for) minutes of listening to, and being puzzled or annoyed by, a synthesised voice intoning statements such as "clearpixel.gif" , "spacer.gif" , "transpacer.gif", and so on as the system reads the names of decorative image files.

4.3 Excessive Download times

Testing with the Bobby program can also provide estimated page download times over a phone connection with 28.8 kbps modem.

Users having access to ISDN or other fast connections and faster modem or network connections (including most web developers and government and industry personnel responsible for sites, and including the Commission's staff) will of course experience much faster download times.

This may explain why problems in this area appear to have received inadequate attention in many cases – the people who have the ability to remove this problem simply do not see it, since in this respect they (we) are not compelled to follow Bill Gates' recommendation for information technology developers to "eat your own dog food" (W. Gates, Business @ the speed of thought, Penguin Viking, 1999, p323).

Conversely, the download times may well understate actual delays experienced where users are relying on slower phone connections (as remains the case for many rural and remote communities) and/or older equipment.

Long download times are not a simple reflection of the amount of useful information presented on a page – since a single page of images can require a file as large as that required for dozens of pages of text and take as long to download.

Long waits for pages to download can be frustrating for any user. One resource linked to the reference resources page points to research identifying 10-15 seconds as the frustration point at which many users will give up and go to a competing site if they can:

Traditional human factors guidelines indicate 10 seconds as the maximum response time before users lose interest. On the web, users have been trained to endure so much suffering that it may be acceptable to increase this limit to 15 seconds for a few pages: .Jakob Nielsen, Top Ten Mistakes in Web Design

Excessive download times may present particular barriers to accessibility for many people with disabilities and older people:

  • People using public access facilities may have only a limited time allocation available to them
  • People on low or fixed incomes may well resent or be simply unable to afford spending much internet access time, which they may be paying for from their own pockets, waiting to admire expensive design work however attractive (which they may also have paid for through taxation or service charges), particularly when what they are seeking is access to information or services
  • This is particularly likely for people who cannot even see the image files concerned.
A number of the Commonwealth site homepages tested by Commission staff give grounds for concern in this respect, as indicated by the following (non identified) examples.
  • Major service provision department homepage: Estimated download time on a 28.8k modem is 55.52 seconds (a very long time particularly for a site with no text only alternative apparent, which serves many older clients, who would for statistical reasons alone include substantial numbers with disabilities). Of this, 10 seconds is estimated for a picture marking an important national commemorative event, which may not be a permanent feature of the site. Less understandably, 14 seconds of estimated download time is taken for the image link to the department's own corporate plan.
  • On another department site, although all pages tested passed Bobby testing for accessibility, and navigation appears clear and helpful, home page download time appears excessive (particularly for a site likely to have many rural users) - estimated download time for 28.8k modem = 41.20 seconds. No text alternative apparently provided.
  • Department site homepage download time estimated at 40.70 seconds (no text alternative apparently provided; almost all pages fail accessibility testing)
  • Major service provision department site: Homepage estimated download on 28.8k modem = 32.61 seconds
  • Department site: Estimated homepage download time over a 28.8k modem for home page = 31.58 seconds
  • Department site: Estimated homepage download time = 30.14 seconds
  • Major agency site: Estimated homepage download time for 28.8 k modem = 27.58 seconds
One very important information site, recently redesigned, had an estimated download time over 28.8k modem of 35 seconds. This would be likely to be found unacceptably slow by many users. However, a link to a text version is presented at the top of the page. Estimated download time for this text version over a 28.8k modem is only 2.12 seconds - that is, 33 seconds faster than, or about 3% of the time for, the graphics version of the same page).

A few Commonwealth homepages tested gave estimated download times of only a few seconds, but for many sites, solutions may lie in the provision of a text only equivalent site (generated automatically from the same data set to ensure access to the same information and to avoid generating twice the labour in maintaining a site).

4.4 Accessibility of PDF files

Many non-W3C formats (e.g., PDF, Shockwave, etc.) require viewing with either plug-ins or stand-alone applications. Often, these formats cannot be viewed or navigated with standard user agents (including assistive technologies). Avoiding non-W3C and non-standard features (proprietary elements, attributes, properties, and extensions) will tend to make pages more accessible to more people using a wider variety of hardware and software. When inaccessible technologies (proprietary or not) must be used, equivalent accessible pages must be provided. ... Converting documents (from PDF, PostScript, RTF, etc.) to W3C markup languages (HTML, XML) does not always create an accessible document. Therefore, validate each page for accessibility and usability after the conversion process ... If a page does not readily convert, either revise the page until its original representation converts appropriately or provide an HTML or plain text version: Web Content Accessibility Guidelines.
The Commission's Issues Paper noted access concerns where pages or documents are made available on line only in PDF (Portable Document Format):
  • Although the "Acrobat" reader required for PDF files is available free on line for downloading, users of older equipment (which in this context may only mean 5 or 6 years old) may not have sufficient computer system disc space available to download the reader.
  • PDF files of text documents are typically significantly larger than HTML files of the same content, which may present access difficulties for users with slower equipment or phone connections.
  • PDF is, at least in its origins, essentially a graphics based format, which presents access problems for people who cannot see and who are relying on screen reader software to convert text into speech or Braille.
A number of disability community experts have reiterated this concern in submissions and research resources. Tim Noonan's report on Accessible E-commerce provides an informed and expert perspective on this issue (as well as on many others).

This appears to be a particularly significant area regarding Commonwealth and other government web pages, where many publications are provided in PDF format.

Reasons for this may include

  • requirements by Parliaments for reports to be tabled in a particular paper format, leading in turn to use of (inaccessible and not directly web publishable) desktopping formats for publications, for which PDF publication then represents the most convenient method;
  • organisations maintaining strategies, or habits, in which publication still necessarily means principally glossy desktopped paper publication, with electronic publication being a specialised supplementary format derivative from this, rather than the other way around;
  • a perceived need to use Portable Document Format to ensure authenticity and integrity of documents.
The Commission understands that the Federal Parliament has commenced a review of tabling requirements which will consider issues of electronic tabling among others, and that AusInfo will shortly be in a position to issue a revised edition of its Guidelines for Commonwealth Information Published in Electronic Formats to assist departments and agencies in considering appropriate relationships between electronic and other forms of publishing.

There seems limited point in publishing, retaining, or securing the integrity of documents if the audience cannot read them, and the audience for public documents necessarily (in fact and by the laws of the Commonwealth and all States and Territories) includes people with disabilities and others with similar accessibility requirements. It should also be noted that it is in precisely those cases where document authenticity most matters, that is where a particular form or format is required for legal validity of a transaction, that inaccessibility of that form or format is likely to lead to complaints of discrimination being made and upheld.

The Commission's understanding of sound regulatory and standard setting policy generally (from its own experience in disability access issues in other areas and from its reading of guidance from the Office of Regulation Review), and in particular in the rapidly changing area of information and communications technologies (as discussed in a number of papers for example available on the web site of the U.S. Federal Communications Commission), is that government and its agencies should be cautious in requiring or endorsing use of one technology over another without strong reasons. While at present HTML appears to offer superior accessibility, and related XML formats may offer potential for further improvements in this respect together with other advantages, it is possible that in future PDF publication might offer equivalent performance, or even superior performance regarding some issues (although it is equally possible that accessibility of PDF might deteriorate relatively, or even in absolute terms, if options to "lock" documents for authenticity or copyright protection prevent use of accessibility options).

It is fair to say that the Web Content Accessibility Guidelines indicate a strong preference for HTML publication over PDF and other formats. They do not, however, state that PDF must not be used, but rather state that where an inaccessible format is used an accessible equivalent must be provided.

The Issues Paper noted considerable accessibility efforts being made by Adobe Inc. (the authors of the PDF format) including provision of free online conversion services for blind and vision impaired users. Some developments in this area have occurred since the Web Content Accessibility Guidelines were published in May 1999. Comments were requested on whether these developments are sufficient such that PDF publication alone could now be regarded as providing access for people with vision impairments.

A downloadable text conversion plug in for the Acrobat reader is available from Adobe at Some users however (including many of those who experience difficulties with access to PDF documents in the first place) may be unable to use or install this plug in (because of the system features required - 486 computer CPU or better, Windows 95 or better, 3 megabytes of disc space for the plug in and 5 megabytes of disc space for version 4 of the Acrobat reader, without which the plug in will not work).

Download of programs of this size may be quick and inexpensive for government and business users having access to more capable computer and communications facilities. It could well be a more substantial barrier to other users, in terms of perceived or actual time, expense and difficulty involved, particularly for people who may be less familiar with or confident with using the internet.

A cost of, say, $3 for access to an important government document (and to other documents in the same format thereafter, using the now downloaded software) may well be negligible to people on incomes of $75,000, but may not be seen the same way by people on fixed and low incomes.

It should be noted that 5 minutes to half an hour of download time, and a resulting cost somewhere from 5 cents to $3, may well be very much less than the price and time which would otherwise have been involved in obtaining access to a document in print or other format as required. In many cases, even when internet publication is less accessible and more expensive to the user than it could or should be, it may well still be more accessible and less expensive than non-electronic alternatives. This is particularly the case considering that the great majority of government publications have never been made directly available in Braille, tape or large print.

The Commission does not believe that access to information and services for people with disabilities and older Australians would be well served by providers being discouraged from providing electronic access. The issue is rather whether information and service providers are taking advantage of the potential for electronic publishing to achieve more effective and equal accessibility.

To cater for blind and vision impaired users who cannot use the standard PDF Acrobat reader and are unable to use the downloaded text conversion plug in, Adobe provides email and web based options for conversion of documents to HTML, at . These services are a technically impressive attainment. However, they are not claimed to be a complete accessibility solution:

The service is intended only for blind and vision impaired users and Adobe's site requests that use be confined to this to avoid overloading the capacity of the facility (rather than being held out for example as the means by which all users of older equipment can avoid the need to download and use the Acrobat reader, or used by document providers to generate accessible versions of their documents for publication rather than using freely downloadable or commercially available conversion options).

As noted by the Web Content Accessibility Guidelines, availability to the user of downloadable and online conversion options does not guarantee that the results of conversion will be accessible or will work at all.

Adobe Inc. has recently published a White Paper on PDF accessibility ( linked from the resources page for this reference) which includes guidelines for PDF accessibility. These emphasise the same point and call on providers of documents to check that their work converts effectively.

If document providers are in fact checking that their documents convert effectively to accessible formats, by converting them, there seems little additional effort involved in providing a text or HTML alternative version on line alongside the "authentic" PDF version rather than requiring the user to do the conversion and undergo additional effort, expense or delay.

(Tim Noonan's report for Blind Citizens Australia on Accessible e-commerce notes a free product which can do bulk conversions from PDF to ASCII that runs in a Windows 95 or Windows 98 DOS Box and can be found at: .)

At a minimum, it appears that sites providing documents in PDF should be providing links not only to sites for downloading the Acrobat reader but to the accessibility options provided at as recommended by Adobe. This does not appear to be common practice at present among Commonwealth Government sites.

4.5 Requirements for other plug ins

The accessibility efforts by the authors of the PDF format are noted above. Equivalent efforts are not yet apparent from the providers of all specialised formats.

The Web Content Accessibility Guidelines require pages and their content to be accessible to users who have not downloaded or cannot use plug ins such as Shockwave or Macromedia animation. This does not mean that these plug ins cannot be used, although the need for and effectiveness of their use on sites offering information and services rather than entertainment might be questioned. The following comment from a leading commentator on usable web design might be interesting:

It is as hard as ever to read scrolling text, but aggressive use of distracting animation now causes even more problems than in 1996: users have started equating such designs with advertising which they routinely ignore.: Jakob Nielsen, " 'Top ten mistakes' revisited three years later".
Where plug ins for animation etc are used, effective equivalent access must be offered. Only a small number of Commonwealth sites tested use these plug ins but those which do, do not appear to have addressed accessibility issues completely effectively.

On one Department's site, although the front "splash" page passed Bobby testing and 15 of 23 pages tested also pass, a number of important pages failed because of lack of accessible alternatives to material provided through shockwave technology.

In particular, an important page providing information on a major current government initiative, where small business in particular requires detailed information, used shockwave animation and was simply invisible (black) to a user who has not installed or cannot use the shockwave program. A text alternative version was presented reasonably prominently on the front page, but not on all pages within the site. For example, there was no text to inform a user who comes direct to the page referred to above that shockwave was what is needed to render this otherwise black page visible, or that there was a text alternative provided and how to find it.

On another Department's site the home page required downloading of specialised software (the Macromedia flash animation player) with no alternative apparently provided for people who did not have or could not use this.

4.6 Frames problems

Frames are used by a number of Commonwealth government sites as a convenient means of providing navigation aids such as side bar menus in a constant position on screen while the user scrolls down through document content in another frame.

Site developers need to recall, however, that not all users are using or can use browsers which support frames. Frames can also present particular barriers for screen readers – which, for example, may not be able to find their way out of the first frame encountered to see the rest of the site.

The Web Content Accessibility Guidelines do not state that frames should not be used. They do require that frames should not prevent navigation by users who cannot see the whole page or cannot use frames and that the "no frames" option should be provided. The guidelines provide detailed advice on techniques to ensure that frames do not disable accessibility.

The intended point of elements such as frames is after all to improve site navigability and presentation for users, rather than to make it difficult or impossible.

Many of the Commonwealth sites which use frames do not appear to comply with these requirements. On one major departmental site, although a text only alternative version is provided, many text pages still fail accessibility testing with frames errors , including the entry level page.

4.7 Columns and tables

To get a better understanding of how a screen reader would read a table, run a piece of paper down the page and read your table line by line.: Techniques for Web Content Accessibility Guidelines
Presentation of information in columns and tables may present barriers for users relying on speech output. Screen readers may run one column of text into the next rather than recognising and delivering the intended structure.
While it is true that text is the best alternative for many non-textual page-design elements, it is also quite easy to make a text-only page that is highly inaccessible to many users because of the placement of the text on the display. For example, using a TABLE to lay out multiple columns of text to look like a newspaper or magazine page can cause no end of trouble for some visitors. This is especially true of people with visual impairments who use assistive technology called screen-readers with their graphical browsers to hear the contents of the page.: "Accessible web design: a definition", C. Letourneau,
A substantial number of sites appear to experience problems in this area.

These problems are acknowledged by the Bobby program as more difficult to fix on existing pages than errors such as lack of alt text, since more substantial restructuring of pages may be required, but the Web Content Accessibility Guidelines do provide recommendations which if followed for new and revised pages should allow accessibility for some screen reader and voice and braille output systems.

4.8 Separation of links

Another problem identified by Bobby on a number of sites is a lack of separation of adjacent links, which can present problems for screen readers. However, comments are made in some resources that this is no longer a problem for newer generation screen readers, and that this is an instance where automated checking has failed to keep up with progress on the user side in dealing with access barriers. Comments would be welcome on what priority this issue ought to receive.

5. Recommendations for achieving accessibility

Many sites tested have only a single type of error which appears relatively easily and quickly remediable, in particular those which fail to provide alt text for images and image map links. Some sites appear to require more substantial restructuring work.

A need for a compliance program at least within government has been suggested by a number of submissions.

The Australian National Audit Office's report identifies the Office of Government Online as well placed to assist agencies by providing information and promoting best practice in service delivery by means of the internet, but recommends that agencies monitor and evaluate their own service delivery via the internet to make continuous improvements.

What should they be doing?

One answer is, comply with the Web Content Accessibility Guidelines, as referenced by the Commission's advisory notes and AusInfo's guidelines. It needs to be acknowledged, however, that the Web Content Accessibility Guidelines present a large list of issues to address, not all of which will be simple for existing pages.

Where to start and how to proceed? One submission (Stillman, Williamson, Bow) recommends a phased approach:

Jakob Nielsen offers a very grounded and pragmatic overview of such issues. In one of his online editorials, he hits the proverbial nail on the head about the practicalities and politics of accessibility:

"The official standard tells you what ought to be done. In practice, it is necessary to prioritize standard-compliance on large sites and plan a staged roll-out of accessibility. The home page and high-traffic pages should be redesigned to follow the high-priority accessibility rules immediately. The same is true for any pages on the critical path to successful completion of e-commerce purchases or other important transactions. All new pages should follow the high-priority and medium-priority rules, and checking for compliance should be made part of the organization's verification procedures for new content. Medium-traffic pages should be gradually redesigned to follow the high-priority accessibility rules. As a longer-term goal, redesign high-traffic pages to follow all three levels of accessibility rules and recommend that new pages also follow the lower-priority rules as much as possible. Low-traffic old pages may be left alone unless they concern matters of particular interest to users with disabilities. Some accessibility advocates will deplore this staged approach and demand that all pages be made to comply with all the rules immediately. Unfortunately, this is simply not possible for most sites and managers will ignore accessibility unless they are presented with a plan that works and places the most important improvements first. " [ Jakob Nielsen's Alertbox, June 13, 1999: Disabled Accessibility: The Pragmatic Approach]

The same article makes an interesting suggestion for an approach to ensuring compliance, which might be applied within the Commonwealth government and elsewhere:
Obviously, the high-priority rules should be followed by all sites as a basic requirement for a web design to be acceptable. It would not surprise me if we start seeing money-back guarantee in design contracts that state that clients don't have to pay for sites that violate these rules.
The recommendation for a phased approach appears to have much to commend it. It is similar to the processes of transition to equal access over time which the Commission has promoted in other areas of achieving accessibility. This approach has been taken in the public transport area, for example, in the draft disability standards for accessible public transport and in decisions by the Commission in complaints and temporary exemption processes under the Disability Discrimination Act. In these processes the Commission and other parties involved have sought to promote universal access, in a way which will benefit all members of the community, including older Australians in particular as well as people with disabilities, while recognising that modifications to existing facilities take time to implement.

Clearly, however, the expense and work involved in making inaccessible web sites accessible is not of the same order as making public transport systems accessible. Some changes to public transport may legitimately take decades (as recognised for example in the Commission's decision on a temporary exemption application regarding the Melbourne tram fleet). Many, though not all, changes to make web sites more accessible could be implemented overnight.

The Prime Minister's commitment to have all appropriate Commonwealth Government services available on line by 2001 was referred to in the Commission's Issues Paper. The recent Australian National Audit Office report on electronic service delivery by Commonwealth agencies indicates that most agencies expect to be able to deliver on this commitment.

Delivery of information and services through the internet is clearly moving from experimental efforts by and within individual agencies to being a major and in some cases principal channel of government information, communications and services for Australia's diverse people. In many cases this move has already occurred, and in all cases must be regarded as required by the 2001 date indicated by the Prime Minister. It appears appropriate to consider measures within this same timeframe to ensure that this channel of information, communications and services is effectively accessible to all Australians and in particular does not exclude older Australians and people with disabilities

Further comments would be welcome.