The BS 8878 Draft Code of Practice on Building Accessible Experiences for Disabled People

The draft BS 8878 code of practice on “Building Accessible Experiences for Disabled People” is currently open for review, with the deadline for comments being 31 January 2009 [Note link changed as the original resource is no longer available 19 July 2009].

That’s great, you may think, we do need to have an agreed set of national guidelines which can help organisations commissioning and developing accessible Web sites. And the tight deadline seems to indicate that the code of practice will be out quickly.

Limitations of The Reviewing Process

Sadly, I feel, this isn’t the case. If you register to access the draft document (that’s right, you need to register not only to give comments but also to view the document) you’ll see that the first set of comments (29 at the time of writing) are very critical of the usability of the processes for accessing, reading and commenting on the document:

Given that this is a draft code of practice for web accessibility, it’s astounding the lengths to which BSI has gone to make this document inaccessible and difficult to follow.

it is appaling that the BSI should even think of publishing this information in a non-accessible format. Clearly the BSI has no moral authority to recommend accessibility standards to anyone else

Accessing this document was the hardest web related task i had to do today. Comical when the goal was reaching a web accessibility document.

Is this supposed to be a demonstration of how NOT to make web documents accessible?

I had similar difficulties accessing the draft document – and I am an experienced Web user :-). But eventually I discovered that there were MS Word and PDF versions of the document available which I printed out for reading at home.

Flaws in the Content

Despite this draft Code of Practice supposedly being intended, I understand, to document agreed industry achievable best practices the document simply requires use of the WAI model (WCAG, ATAG and UAAG) despite the fact that, for example, the document itself acknowledging that “At the time of publication, no single authoring tool that supports all ATAG priority 1 checkpoints is known“.

The document also seems to have a view of the Web as it was in the late 1990s – there is no recognition of the diversity ways in which the Web is being used, the complex workflows, the importance of user generated content, etc. There is also a failure to take into account the work of the research community in gathering evidence and using such evidence to develop more achievable approaches to Web accessibility.

The latter part of the document is better, buy medications from mexico requiring organisations to develop and publicise accessibility policies and involve people with disabilities in the planning and testing processes.

Dangers in its Implementation

There’s a danger, I feel, that this document will end up being published with the expectations that public sector organisations, in particular, will be forced to implement such recommendations. And I am concerned that this will be counter-productive – if there’s one thing that is worse that a lack of standards or codes of practice it’s severly flawed standards and codes or practice, in my opinion.

The document states that “Organizations wishing to claim conformance with BS 8878 should do so in hard copy, electronic media or any other medium“. Now although I don’t understand the structure of this sentence (organisations must claim conformance in any medium – how could they not do so?) it is clear that there is an expectation that organisations will state that they conform with the code of practice. Indeed the document goes on to mandate that “In making such a claim, a business or organization should address all of the provisions of BS 8878“. OK, so organisations can’t simply choose parts of the specification which they conform to (such as the reasonable and achievable parts of the document!)

What Next?

Now you may disagree with me. And whilst I would welcome further discussion on this topic, I would encourage you to read the document first, and give your feedback to the BSI.  You should bear in mind that the code of practice will be updated before publication to refer to the newly published WCAG 2.0 guidelines. And as that document makes it clear that the guidelines are format-independent, the principles will apply to, for example, MS Word and PDF documents on Web sites as well as HTML resources.  If you don’t feel it is likely that you’ll be providing accessible PDF and MS Word resources on your institutional Web sites (including institutional repositories) surely you should ask the BSI to revisit this document in order to describe more achievable goals.

Or to put it another way, is this code of practice intended to describe best practices which are achievable in the complex Web environment in which we now live or a set of well-meaning aspirations which are unlikely to be achievable in practice? And remember, if the code of practice is accepted in its current form the danger is that institutional conformance with the code of practice (in its entirety, remember) will be required.  And what will then happen if existing services fail to conform?  Will we see institutional repositories containing inaccessible PDF documents being removed from service in other that institutions can claim conformance?