PDFs breaching the DDA
For those of you with access to Public Sector Forums, you might want to look here:
Dennis Kessler's article on non-accessible PDFs
for a thought-provoking article on why the use of PDFs may mean you're in breach of the DDA.
I am currently seeking permission to repost the article in full for those of you who can't access PSF. I will post my comments on the article here when (if?) permission is granted to fully repost it.
Jack Pickard The Pickards Information Services| Blog | Twit
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I saw some of that mentioned on the PSF bulletin. I must admit I am not sure whether it would be a breach of DDA. If inaccessible PDFs were the only method of getting the information then yes, but if there were alternative methods that were accessible then surely no breach would be committed?
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Hi Richard,
The problem as I see it is that most local authorities (and other organisations) use PDFs with no alternative. I've been arguing with my LA that this causes problems for some time.
Unfortunately, some authorities have also now seen Joe Clark's article on A List Apart, and are using that to justify using PDFs for most web content, without an alternative.
It seems that because Joe says PDFs "could" be accessible, some people are taking it to mean PDFs "are" accessible....
There's also the usability issue and the fact that it requires a plug-in etc. I think Joe Clark's article relates purely to web accessibility as the WAI describe it. ie. enabling people with disabilities to use the 'net.
However, there's the related issue of how easy it is to use, how easy/fast it is to use/download the plug-in etc.
PDFs are an absolute minefield, particularly now that local authorities in the UK have a deadline for making their websites accessible, and many of them are looking for answers due to their huge numbers of PDFs...
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okay, then, I'll include my comments ahead of the article itself... all these comments are of course IMHO...
| Dennis Kessler's PSF article wrote: |
| If you're creating and publishing PDF documents on your website which aren't accessible, you're also in breach of the Disabilities Discrimination Act (DDA). Why in breach? Because parts of the DDA relating to information and services provided via the Web cover all content on your site. This means all content - including downloadable PDFs - has to be accessible, not just web pages. |
I wouldn't necessarily say all content needs to be accessible... all of the information and service must be accessible - as Richard says, there may be more than one document containing each piece of information.
| DDA Code of Practise wrote: |
| In some cases, however, each of those means of service might be regarded as a service in itself and subject to the Act. Example: An airline company provides a flight reservation and booking service to the public on its website. This is a provision of a service and is subject to the Act. |
Your website must be accessible even if the same function can be provided elsewhere.
| DDA Code of Practise wrote: |
| The Act does not require a service provider to adopt one way of meeting its obligations rather than another. The focus of the Act is on results. Where there is a physical barrier, the service provider's aim should be to make its services accessible to disabled people. What is important is that this aim is achieved, rather than how it is achieved. If a service remains inaccessible, a service provider may have to defend its actions. |
This would seem to contradict the initial part about a service in itself as it seems to imply the delivery channel doesn't matter, provided the information is accessible... e.g. by a phone line. I would argue that this is dangerous reasoning and may land you in trouble, but I can see how that argument could be constructed. The reason I think it is wrong is that (for me) a phone line would be a different service even if it has the same function as something else, and the website service would still be inaccessible. I do think however that this is a strong indication that not necessarily every document on your site needs to be accessible - providing you are also providing that information in an accessible format.
It would be fair to say that I agree with the gist of Dennis' article: using PDFs (designed without accessibility) as a sloppy way to avoid having to produce pages will lead to inaccessible sites. You need to consider accessibility for everything you're putting on the web - not just HTML pages. (include also images, alternate media etc etc).
A key point is that if the information is available elsewhere on your site, and is sufficiently easy to find, and is accessible, then you won't fall foul of the DDA. It must be said however, that I don't believe Dennis' article to be inaccurate - it implies that an inaccessible PDF has been chosen as the sole delivery channel - I would just suggest this should be explicitly stated.
I would argue anyone claiming an accessible website (therefore all local Govt sites) should make PDFs as accessible as possible, and also provide the information in an alternative (e.g. HTML based) format.
Hopefully I'll have permission to post the full article on here soon so you can all see what I'm talking about!
For me, far too many PDFs without any concessions to accessibility - or even file size - are being published. I'll leave the final word to Lee28. Not that he's saying all PDFs are like this.... but I know how he feels.
| Lee28 wrote: |
| I think the fact that needs to be emphasised, particularly in local government, is that whether or not publishing your content in a PDF format is "against the law" it is often un-usable. I have a high-end PC at work with 2GB of memory, yet I despise having to click on PDF links as my browser then freezes for about 2 minutes. This is a basic usability AND accessibility question, and the nuances of WCAG shouldn't decide whether they're used or not. |
Jack Pickard The Pickards Information Services| Blog | Twit
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Ahh, Dennis Kessler attended the RNIB Media Briefing into accessible PDFs last week. I, and a large section of the audience, had no idea what he was going on about in the Q&A session.
| Lee28 wrote: |
| It seems that because Joe says PDFs "could" be accessible, some people are taking it to mean PDFs "are" accessible.... |
This is exactly the same problem as the web. It can be made accessible, but considering how people currently design websites is isn't accessible. PDFs can be made accessible. The RNIB demonstrated that something as complicated as a Financial Report can be made accessible. (There's nothing like a live practical demonstration!).
Information in PDF can be made accessible - same as the web, accessibility needs to be a component of the design and authoring. PDFs created in a structured fashion, with navigation or a decent header structure are accessible. PDFs which are scanned in images - they are inaccessible because they are just images - its the same GIGO.
| Lee28 wrote: |
| There's also the usability issue and the fact that it requires a plug-in etc. |
Thats disingenous. Every file format requires a "plug in". You needed to have a browser installed to surf the web. You need to install a screen reader to have a speech-based interface to Windows. The requirement to install software to get certain features is part and parcel of the PC industry. PDFs alone do not suffer this problem.
| Lee28 wrote: |
| I have a high-end PC at work with 2GB of memory, yet I despise having to click on PDF links as my browser then freezes for about 2 minutes. |
Hmmm.. interesting. I run a P3 600 with 256Mb of Ram and I don't see any problems of PDFs "freezing for about 2 minutes". I sense a badly configured PC, not a problem attributable to PDFs.
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I think this debate has already been done. It's unreasonable to expect a Government Department to tag thousands of PDFs or convert them to html pages, even gateway pages with summaries of the PDFs. Just think of the man hours involved, the spend in public money, how could you justify it? You can't say to fulfill a legal requirement because that legality has never been tested.
In my opinion the answer is create a point in time where you say ok all these old PDFs may be inaccessible, if they are then contact xxx and we will provide you with an accessible alternative. Then from this point on you create gateway pages for every new PDF which gives a summary of the document, details on where you can get a copy and then the link to the document plus links to the adobe reader, maybe even other readers and the PDF to html conversion service.
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| Isofarro wrote: |
| Thats disingenous. Every file format requires a "plug in". You needed to have a browser installed to surf the web. You need to install a screen reader to have a speech-based interface to Windows. The requirement to install software to get certain features is part and parcel of the PC industry. PDFs alone do not suffer this problem. |
That's quite true Mike but if I was to go into say a local library, I would be fairly certain that the PC would have IE with Internet access. What I couldn't guarantee would be that it would have the Adobe Reader software on the machine nor that I'd be able to install it. This could be my only means of Internet access so who is discriminating here? The library for locking the PC down or the website owner for providing content only in a format which requires me to install software on a machine. Let's face it, most PCs come with Windows and IE preinstalled, not necessarily Adobe Reader.
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| Daz wrote: |
| That's quite true Mike but if I was to go into say a local library, I would be fairly certain that the PC would have IE with Internet access. What I couldn't guarantee would be that it would have the Adobe Reader software on the machine nor that I'd be able to install it. This could be my only means of Internet access so who is discriminating here? |
There is nothing legally actionable here. Discrimination is not unlawful. Unreasonable discrimination on the basis of disability is unlawful (according to the DDA as I understand it).
| Quote: |
| Let's face it, most PCs come with Windows and IE preinstalled, not necessarily Adobe Reader. |
If you chose not to install the software required to view a file, this is hardly grounds for a claim of unreasonable discrimination. The technology is there to access content from accessible PDFs - when authored correctly, the vendor and the author have fulfilled their obligations toward accessibility.
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The example I gave wasn't out of choice, if you're on a restricted network which doesn't permit you to install software what can you do?
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My point about my PC freezing was incorrect, I meant my browser freezes.
Also, this happens on my laptop, my home PC, and every workplace i've ever been at....not sure what i'm doing wrong! It can't all be me surely! Anyway, my point is that PDFs hog resources, maybe it's Adobe Reader itself? Or opening them via Firefox? Anyway....
I never actually said that having to install a plug-in was strictly an accessibility issue. In fact, on the PSF where this article was posted, I yesterday made this exact point. Using PDFs does not contravene laws such as the DDA as long as they are properly tagged (which I believe the RNIB had to get an external company to do, as they couldn't figure it out), but it's clearly a usability issue.
To compare having a PDF reader installed to having a web browser installed is not remotely a fair comparison. I have to have a web browser to get on the 'net, so that's clearly a pre-requisite for browsing.
However, I may or may not (as Daz wrote) have access to install other software or plug-ins, in which case this document is unusable.
I don't personally subscribe to the view that accessibility revolves around the WAI or laws like the DDA, for me its tied up with usability too, and accessibility restrictions other than disabilities. Basically, it's about making the web accessible for all.
I understand the WAI is about disabilites, and that Joe Clark ( http://www.alistapart.com/articles/pdf_accessibility ) regards PDFs accessible when judged against these parameters. I don't contradict that point of view, but I think if you genuinely want to improve the web browsing experience of all users then there's more to it than that.
Last edited by Lee28 on 26 Oct 2005 11:07 am; edited 1 time in total
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| Daz wrote: |
| The example I gave wasn't out of choice, if you're on a restricted network which doesn't permit you to install software what can you do? |
Complain to the person enforcing these networking restrictions or move to a non-restricted network. Either way, its not the software vendors, nor the authors problem that whoever supplies you with access locks it down so much.
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Daz, I think your point about creating a future "point in time" after which you give a disclaimer with an e-mail address/minicom/phone no. is the best of a bunch of poor alternatives.
I'm currently working for a local authority and the sheer volume of PDFs is causing a massive headache. The major problem is that users choose PDF as the "default" format.
Ironically this has gotten worse because our new CMS (designed to improve the site's accessibility) has removed their ability to put everything in tables!
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| Isofarro wrote: | ||
|
PDF a format which is only useful when downloaded to disc and read like a book. It is a very bloated and clumsy format which simply isn't suitable for Web browsing, imho.
Many user agents are incapable of loading PDF content, such as text browsers, mobile devices, WebTV, etc. Any Web device can load efficient, standards-compliant HTML or XHTML. One must not forget that accessibility includes the endless diversity of devices and not just the endless diversity of people. Both should be accomodated.
HTML is a much lighter format which loads very quickly and is much easier to use. It has simple, familiar navigation elements (hyperlinks) which makes multiple page presentations in HTML easy and fast to navigate through. It is still printable via a media="print" stylesheet. It is better for users in every way but it places a burden on the website author. I feel burden is entirely reasonable. The freedom to access information is very important - especially accessing government information within a democracy.
Spending resources on the rare and specialist knowledge required to make PDF documents "accessible" seems like something of a waste. If these documents were converted into HTML web pages then accessibility would be improved and the usability for all visitors would be better. By applying common techniques for accessibility, the pages would become endlessly more accessible and usable.
HTML suits the Web far better than any other format, which isn't particularly surprising.
Last edited by Ben Millard on 26 Oct 2005 11:24 am; edited 9 times in total
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| Isofarro wrote: | ||
Complain to the person enforcing these networking restrictions or move to a non-restricted network. Either way, its not the software vendors, nor the authors problem that whoever supplies you with access locks it down so much. |
Complaining often won't get you anywhere or may take up to 16 weeks as I know some Gov Department have to wait this long for a simple network change. You have to accept there will always be situations where the person won't have the Adobe Reader and can do nothing about it, that's why the gateway page satisfies everyone's needs. Even as a "normal" user, a gateway page is helpful as it gives me enough info to decide whether or not I want to view the document. Personally I hate PDFs cause the can take so long to open or sometimes freeze, so telling me what's in it before I open it is a huge benefit.
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| Lee28 wrote: |
| Using PDFs does not contravene laws such as the DDA as long as they are properly tagged (which I believe the RNIB had to get an external company to do, as they couldn't figure it out), but it's clearly a usability issue. |
No, its an authoring issue. The RNIB's _publishers_ - the very ones that chose to use PDF decided they couldn't do it. In fear of getting it wrong, or in fear of actually trying is open to debate. The RNIB got some technical people involved to advise and guide them.
Its the same as accessible websites - many web designers don't know how to make a website accessible. They can learn. PDF authors can learn too.
Adobe Acrobat has the features to build accessible PDFs. Adobe acknowledge that these options are hidden. But education as well as bringing these features closer to the spotlight will remedy this issue.
| Lee28 wrote: |
| To compare having a PDF reader installed to having a web browser installed is not remotely a fair comparison. I have to have a web browser to get on the 'net, so that's clearly a pre-requisite for browsing. |
No. You cannot initiate and run a telnet session using the browser. Nor can you connect to a CVS over ssh using a browser, yet these are all net services. A browser is limited to dealing with resources delivered over HTTP (and some browsers handle FTP as well as WebDAV). A browser can opt to render certain resources (like images, html pages) in its own window, or can pass off other resources to being saved on a local disk or passed to another application. A browser is by no means the only piece of software required to be on the internet.
Resources on the World Wide Web are also not limited to files that only a browser can handle. So its unreasonable to suggest that only a browser is needed to view all resources on the web.
| Lee28 wrote: |
| However, I may or may not (as Daz wrote) have access to install other software or plug-ins, in which case this document is unusable. |
Only by your own choice (or delegation of that choice to others) not to install the software required to use the files.
| Lee28 wrote: |
| I don't personally subscribe to the view that accessibility revolves around the WAI or laws like the DDA, for me its tied up with usability too, and accessibility restrictions other than disabilities. Basically, it's about making the web accessible for all. |
You're on a different bandwagon. Please have the decency to name it differently, and not pass it of as web accessibility.
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