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You Reap What You Sow - conclusion
Conclusions
The AGIMO report gets a lot of things right, especially in describing the typical experiences of AT users when encountering the vast majority of today's PDF files. While the Report correctly identifies a variety of difficulties for AT users, it does not usefully identify the reasons.
However, the Report does have a clear Finding in that properly tagged PDF files read by PDF-aware software in appropriate circumstances are fully accessible.
Regrettably, the Report fails to develop any case for one of its central claims: that achieving accessible PDF is significantly or inherently more difficult than the net effort required for other formats. While it's not as stringent as WCAG 2.0, many US Federal and State agencies figured out long ago how to reliably and inexpensively create accessible PDF files as are required for conformance with Section 508.
If one does not look, however, one surely will not find.
You Reap What You Sow
The Report, to the extent that its recommendations are accepted, is a self-fulfilling prophesy. The Australian government has never required accessible PDF (as they do HTML), so naturally enough, they don't encourage improvement. If they follow the recommendations of this report, they still won't. Instead, they'll get more inaccessible PDF, but they'll also pay for a lot of HTML and Word files that their users don't really need.
Better to insist that PDF files include valid tags as appropriate, insist that PDF creation software supports accessible PDF, and help educate and assist users in acquiring the PDF-aware AT that's currently available. The idea that PDF accessibility is some arcane science has no basis in fact. The same energies that went into this Report could have authored a superb collection of Best Practice guidelines for Australian government document authors and managers.
In sum, the Australian government policy requiring HTML files as the "accessible equivalent" of any PDF file, as sustained by this Report, is actually counter-productive for the following reasons:
- It does not encourage authors to learn or adopt accessible authoring practices when creating or managing PDF files.
- It does not encourage PDF software developers to improve their tools for ensuring, improving or testing PDF accessibility.
- It does not encourage AT vendors to improve their support for the PDF file format.
- It is not technology-neutral
In short, it is not good government policy.
In the Appendix below, I've provided starting-point recommendations for electronic document accessibility policies that better meet the needs of document authors, managers, administrators and (most importantly) AT users.
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Appendix: Four Basic Policies to Promote Accessible Electronic Documents
- In applicable settings, all electronic documents irrespective of format must comply with WCAG 2.0.
NOTE: The determination of whether an "applicable setting" exists is fundamentally common-sense, and made case-by-case. Generally speaking, documents posted to a website should be accessible. Drafts distributed only to specific users who do not require assistive technology probably don't have to be accessible. Documents produced only for specific purposes (eg, printing) should never have to be accessible. - Irrespective of file-format, if a user complains about a specific document, that file must be examined and if necessary, remediated and reposted within a reasonable period of time.
- Formal "Sufficient Techniques" are not required by WCAG 2.0(14). Document creation policies must be updated with best-practices guides for the creation of accessible content of any format (HTML, Word, PDF) capable of meeting WCAG 2.0 guidelines.
- Once ISO 14289 is published...
- When PDF documents are posted, such documents must comply with ISO 14289.
- PDF reader software must comply with the "Conforming Reader" provisions of ISO 14289.
- AT software must comply with the "Conforming Assistive Technology" provisions of ISO 14289.
Endnotes
- The Report, Executive Summary
- The Report, Executive Summary
- The Report, Introduction, About PDF
- The Report, Executive Summary
- The Report, Phase One, User Consultation
- The Report, Phase Two, Technical Evaluation
- The Report, Phase Three, User Evaluations Table 5
- The Report, Phase Three, User Evaluations Satisfaction Ratings
- The Report, Phase Two, Technical Evaluation
- See my review of PDF accessibility checkers and assessment of Acrobat's Read Out Loud tool.
- The Report, Phase Three, User Evaluations, Table 7 and following
- WCAG 2.0: Layers of Guidance, Sufficient and Advisory Techniques
- The Report, Phase Two, Technical Evaluation
- WCAG 2.0: Understanding Conformance Claims and Understanding Accessibility Support
References
The Australian Government's study into the Accessibility of the Portable Document Format for people with a disability, November, 2010.
Australian Human Rights Commission, Disability Discrimination Act Advisory Notes
WCAG 1.0 and WCAG 2.0, publications of the World Wide Web Consortium (W3C)
ISO/DIS 14289 (to be published in 2011) The Draft International Standard is currently available to ISO-accredited subject-matter experts and members of ISO TC 171/SC 2.
A presentation describing ISO/DIS 14289, presented by Adobe Systems, Appligent Document Solutions and Microsoft, all members of AIIM's US Committee for PDF/UA, to the ATIA Conference in October, 2010. This page includes an accessible PDF presentation.
Articles by the author referenced in the text
Why PDF is the world's de facto electronic document format
It “sounded” like a good idea at the time
REVIEW: PAC (PDF Accessibility Checker) 1.1
Word doesn't do Section 508, PDF gets the blame
Resources
PDF accessibility isn't mysterious. From product documentation to agency best-practice documents, accessibility websites and more, organizations around the world have been producing accessible PDF files and sharing their techniques and standards for years.
Draft WCAG 2.0 Techniques for PDF
Adobe Systems PDF Accessibility Resources
The WebAIM site includes some PDF Techniques, and hosts the respected WebAIM Listserv
US Dept. of Heath & Human Services PDF FIle 508 Checklist
Illinois Department of Human Services PDF Accessibility Resources
A list of software that can create accessible PDF files directly
Many other resources are a web-search away
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About Appligent Document Solutions
Appligent Document Solutions provides PDF tagging services and educational and training resources in the Section 508 Center for PDF
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