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Complying with New York State’s
New Web Accessibility Policy
Debi Orton, IT Manager
NYS Governor’s Office of Employee Relations

What we’ll cover…
• Applicable and related Federal laws
• History of NYS accessibility policy
• Standards and Guidelines
• Overview of current landscape: new laws,
standards and guidelines

Americans with Disabilities Act
(ADA) – 1990: Title I
– Title I: Employment
• Covers employers with >= 15 employees
• Requires equal opportunity to full range of
employment-related opportunities available to others
• Prohibits discrimination in recruitment, hiring,
promotion, training, pay, social activities, etc.
• Requires reasonable accommodation for people with
disabilities, absent undue hardship

ADA: Title II
– Title II: State and Local Government Activities
• Regardless of size or receipt of Federal funding
• Requires that people with disabilities have equal
opportunity to benefit from programs, services,
activities (e.g., public education, employment,
trasnportation, recreation, health care, social services,
courts, voting and town meetings)
• Covers architectural barriers, fundamental alteration

ADA: Title III
– Title III: Public Accommodations
• Covers businesses and nonprofit service providers that
are “public accommodations” (private entities who
own, lease, lease to, or operate facilities such as
restaurants, retail stores, hotels, movie theaters,
private schools, convention centers, doctors’ offices,
homeless shelters, transportation depots, funeral
homes, zoos, day care centers, sports stadiums, etc.)
• Prohibits exclusion, segregation, and unequal
treatment

ADA: Title IV
– Title IV: Telecommunications Relay Services
• Covers telephone and television access to people with
hearing and speech disabilities
• Establishes telecommunications relay services 24/7
• Requires closed captioning of Federally funded public
service announcements

Telecommunications Act –
1934 & 1996
– Requires manufacturers of telecommunications
equipment and providers of telecommunications
services to ensure that equipment and services
are usable people with disabilities

Other Applicable Federal Laws
• Fair Housing Act
• Air Carrier Access Act
• Voting Accessibility for the Elderly and
Handicapped Act
• National Voter Registration Act
• Civil Rights of Institutionalized Persons Act
• Architectural Barriers Act

Individuals with Disabilities
Education Act (IDEA)
– Requires public schools to provide a free,
appropriate public education in the least
restrictive environment appropriate to their
individual needs

Rehabilitation Act of 1973
– Section 501: Affirmative action and
nondiscrimination in agencies of the Executive
Branch
– Section 503: Requires affirmative action and
prohibits employment discrimination by
contractors and subcontractors with contracts for
more than $10K.

– Section 504: “No qualified individual with a
disability in the United States shall be excluded
from, denied the benefits of, or be subjected to
discrimination under” any program or activity that
receives Federal financial assistance or is
conducted by any Executive agency or the USPS

– Section 508: Establishes requirements for
electronic and information technologies
developed, maintained, procured or used by the
Federal government
• Must be accessible to people with disabilities, including
employees and members of the general public
• NYS Policy adopts two parts of Section 508 explicitly
and a third implicitly

Web Standards
• Established and maintained by the World
Wide Web Consortium (W3C)
– Markup languages
• HTML
• XHTML
• XML
– Presentation language : CSS
– Accessibility Standards : WCAG, ATAG, UAAG,
ARIA

Accessibility Standards
• Two major accessibility standards:
– Section 508
– World Wide Web Consortium (W3C)
• Web Accessibility Initiative (WAI)
– Web Content Accessibility Guidelines (WCAG)
» 1.0 – May, 1999
» 2.0 – December, 2008
» 2.0 “last call” issued in May, 2004

NYS Accessibility Policy
• First policy published in 1996 – required
reasonable accommodation for IT
• Second policy published in 1999 – required
conformance to WCAG 1.0 level A
• June, 2004: Hybrid standard adopted,
amalgam of Section 508 and WCAG 1.0
– Separated into policy document and standard
document

NYS Validation Tool
• 2008 – NYS Forum developed customized
testing tool; provided tool free to state
agencies and contractors working for state
entities for one year
• 2009 – CIO/OFT picked up tool for another
year
• 2010 – No NYS validation tool available

• Hybrid reviewed and adjusted every two years
• 2010 – Policy changed to adopt Section 508
section 1194.22 (web standards, aligned with
WCAG 1.0) and 1194.31 (functional testing)
• 1194.22 requires web content to meet
provisions of 1194.21 (software applications
and operating systems)

• Covers all “state entities” identified in
Executive Order 117
• Covers all Internet, intranet, extranet sites and
web applications
• Covers all content on state entities’ web sites

Section 508, §1194.22
• § 1194.22 Web-based intranet and internet
information and applications.
– (a) A text equivalent for every non-text element shall
be provided (e.g., via "alt", "longdesc", or in element
content).
– (b) Equivalent alternatives for any multimedia
presentation shall be synchronized with the
presentation.

Section 508, §1194.22
– (c) Web pages shall be designed so that all
information conveyed with color is also available
without color, for example from context or
markup.
– (d) Documents shall be organized so they are
readable without requiring an associated style
sheet.
– (e) Redundant text links shall be provided for each
active region of a server-side image map.

Section 508, §1194.22
– (f) Client-side image maps shall be provided
instead of server-side image maps except where
the regions cannot be defined with an available
geometric shape.
– (g) Row and column headers shall be identified for
data tables.
– (h) Markup shall be used to associate data cells
and header cells for data tables that have two or
more logical levels of row or column headers.

Section 508, §1194.22
– (i) Frames shall be titled with text that facilitates frame
identification and navigation.
– (j) Pages shall be designed to avoid causing the screen
to flicker with a frequency greater than 2 Hz and lower
than 55 Hz.
– (k) A text-only page, with equivalent information or
functionality, shall be provided to make a web site
comply with the provisions of this part, when
compliance cannot be accomplished in any other way.
The content of the text-only page shall be updated
whenever the primary page changes.

Section 508, §1194.22
– (l) When pages utilize scripting languages to
display content, or to create interface elements,
the information provided by the script shall be
identified with functional text that can be read by
assistive technology.
– (m) When a web page requires that an applet,
plug-in or other application be present on the
client system to interpret page content, the page
must provide a link to a plug-in or applet that
complies with §1194.21(a) through (l).

Section 508, §1194.22
– (n) When electronic forms are designed to be
completed on-line, the form shall allow people using
assistive technology to access the information, field
elements, and functionality required for completion
and submission of the form, including all directions and
cues.
– (o) A method shall be provided that permits users to
skip repetitive navigation links.
– (p) When a timed response is required, the user shall
be alerted and given sufficient time to indicate more
time is required.

Reference to §1194.21
• § 1194.21 Software applications and operating
systems.
• Deals with the convergence of applications
and web sites
• Applies to NYS sites by virtue of §1194.22(m)

Section 508, §1194.31
• § 1194.31 Functional performance criteria.
– (a) At least one mode of operation and
information retrieval that does not require user
vision shall be provided, or support for assistive
technology used by people who are blind or
visually impaired shall be provided.

Section 508, §1194.31
– (b) At least one mode of operation and
information retrieval that does not require visual
acuity greater than 20/70 shall be provided in
audio and enlarged print output working together
or independently, or support for assistive
technology used by people who are visually
impaired shall be provided.

Section 508, §1194.31
– (c) At least one mode of operation and
hearing shall be provided, or support for assistive
technology used by people who are deaf or hard
of hearing shall be provided.
– (d) Where audio information is important for the
use of a product, at least one mode of operation
and information retrieval shall be provided in an
enhanced auditory fashion, or support for
assistive hearing devices shall be provided.

Section 508, §1194.31
– (e) At least one mode of operation and
speech shall be provided, or support for assistive
technology used by people with disabilities shall
be provided.
– (f) At least one mode of operation and
information retrieval that does not require fine
motor control or simultaneous actions and that is
operable with limited reach and strength shall be
provided.

NYS Policy Requirements
• New content must conform immediately
• Any content developed by contractor must
conform
• Provides language to include in any
procurement involving web content
• Policy requires annual validation and reporting
to CIO/OFT

How People With Disabilities Use
the Web

• People who are blind access the web via:
– Screen reading software
– Refreshable Braille displays
– CANNOT use pointing devices
• People with low vision may use those tools or:
– Screen magnification software
– External (larger) displays
Blindness / Low Vision

• Visual acuity also a factor for:
– People using mobile devices
– People using older equipment (smaller monitors,
lower resolutions)
• Visuals need to be described using “alt text”
• Videos or presentations containing instruction
needs to be audibly described
Blindness / Low Vision

• Cataracts
• Glaucoma
Low Vision

• Macular Degeneration
• Retinopathy
Low Vision

• Difficult to magnify graphical text without
distortion
Magnified graphical text

Color Blindness
Map of Hurricane Isabel (with color)

• Map of Hurricane Isabel (simulating red/green color
blindness)
Color Blindness

• Subway maps
Color Blindness

• Video or presentation content with audio
must be captioned
• Elearning content cannot rely on audio cues
• People whose computers do not support
sound
• Can be an issue for mobile device users
Deafness / Hearing Impairment

• Cannot use mouse for navigation
• Interaction through keyboard only
• May have difficulty with timed responses
Mobility Impairments

• Images are helpful for many with cognitive
impairments
• Avoid “Wall o’ Text”
• Use headlines and bullets
• Attention to “fog index”
Cognitive Impairments

Principles of Accessibility
• Users may require assistive technology to
effectively use technology or browse web
• Provide information in more than one format
• Navigation and layout should be consistent,
predictable
• Alternate text should describe visual content’s
purpose [not necessarily a literal description
of the content]

Testing for Accessibility
• Three basic ways to evaluate
– Automated testing
– Manual review
– Functional testing

Automated Testing
• Automated testing tools don’t usually fix
errors
• The best tools link error reports to the
standard being violated
• Web developers will need a fairly
comprehensive understanding of HTML and
CSS

Automated Testing
• Many free, but limited [e.g., can only test a
page at a time]
• Many for-fee tools customizable and can do
batch testing
• Most can select either of the two major
accessibility standards (Section 508 or WCAG)
• Automated testing not all that’s needed

Manual Evaluation
• Look at alternate text for images
• Turn off images and styles
• Turn off scripting
• Use keyboard to navigate
• Data table markup
• Look at use of color
• Proprietary formats

Functional Testing
• Have a user of assistive technology test site
while you watch
• Test with “one of each”
• User with visual impairments
• User with hearing impairments (if sound on site)
• User with cognitive impairments
• Etc.

The Short-Term Future –
Web Standards
• HTML & CSS Changing
– HTML5 – some backward compatibility, but would
deprecate some accessibility features available in
HTML 4
– CSS3 – little impact on accessibility
– ARIA – Might be used to mitigate some of the
accessibility problems currently existing in HTML5

The Short-Term Future –
Accessibility Standards
• WCAG 2.0
– Now a recommendation
– Support and implementation materials available
on the W3C site, WebAIM, etc.

The Short-Term Future – U. S. Law
• Section 508 about to undergo “refresh” –
move to harmonize with WCAG 2.0
• ADA is being modified to cover the web, both
public sector sites and private sector sites that
function as “places of public accommodation”
• ADA changes also suggest harmonization with
WCAG 2.0

The Short-Term Future – NYS Law
• Assembly bill in the last session required NYS
to comply with Section 508 in toto
• Working with sponsor to include supports
• Outcome will depend upon election

Resources – W3C
• W3C site: http://w3.org
– HTML & CSS:
http://www.w3.org/standards/webdesign/htmlcss
– Scripting and AJAX support:
http://www.w3.org/standards/webdesign/script
– Accessibility:
http://www.w3.org/standards/webdesign/accessibility
– Mobile Web:
http://www.w3.org/standards/webdesign/mobilweb

Resources – W3C
• List of web accessibility evaluation tools:
http://www.w3.org/WAI/ER/tools/
• Developing a Web Accessibility Business Case for
Your Organization:
http://www.w3.org/WAI/bcase/resources.html
• Developing Organizational Policies on Web
Accessibility:
http://www.w3.org/WAI/impl/pol

Resources – U. S. Government
• Section 508 : http://www.section508.gov/
• Section 508 draft changes:
http://www.access-board.gov/508.htm
• Americans with Disabilities Act:
http://www.ada.gov/

Resources – NYS Government
• Office of the Chief Information Officer/Office
for Technology:
http://oft.state.ny.us/Policy/indexa.htm
– Select the policy on Accessibility – download in
Word or PDF format
• NYS Forum:
http://nysforum.org/accessibility/resources/

Other Resources
• WebAIM: http://webaim.org/
• National Center for Accessible Media (NCAM):
http://ncam.wgbh.org/

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