Let’s acknowledge a technicality and move on. Documents conform to the 508 standards. Agencies (people) comply with the 508 law. So technically, a document cannot be 508 compliant. Technicalities notwithstanding, we use the universally accepted terminology “508 compliant documents”.
We Make Documents Accessible (508 Compliant)
Wildly successful Google boasts that, “It’s best to do one thing really, really well.” We agree! Matrix is exclusively focused on making Word, PPT, and PDF documents (including fillable forms) 508 compliant. Whether Medicare Plans, EIS Reports (infamous Keystone XL Pipeline), EIAs, Annual Reports, Marketing Pieces, etc; Matrix certifies that the documents we deliver: 1) conform to mandated accessibility standards/requirements, and 2) provide a high degree of usability for the handicapped.
Unique: Most companies take the understandable approach of providing services and/or products that address multiple aspects of Section 508 Compliance. This includes web design, data management, consulting, staffing, training, testing & fixing web sites, specialized hardware/software, and more. Matrix is exclusively focused on accessibility of documents.
Remediating PDFs Is Our Specialty Within Our Specialty. Matrix has further refined its focus to specialize in making PDFs compliant (remediating) because both the public and private sectors have overwhelmingly adopted PDF as the format of choice.
Section 508 of The Rehabilitation Act requires that all website content must be equally accessible to people with disabilities. The Federal Acquisition Regulations (FAR) “Final Rule for Section 508” (EIT Accessibility) can be found at www.section508.gov.
Standards and Requirements. Implementation of the 508 law is achieved by complying with standards and requirements. If it’s posted on a government site, it must be compliant. The Access Board, an independent federal agency charged with developing 508 Compliance standards, continually improves accessibility by updating their standards based on disabled community feedback. See more on Access Board updating below in 508 Compliance Standards Refresh.
Legally, compliance is the responsibility of the document owner and the scope of what needs to be compliant has just been broadened. Increased awareness & enforcement has resulted in a recent ruling that Americans with Disabilities Act (ADA) laws extend to the work place because they are “places of public accommodations”. Ostensibly, all PDFs posted for the public must be accessible to the handicapped. Federal agencies: in order to enhance accessibility & ease of use, and to maintain uniformity, some agencies have adopted additional requirements beyond the Access Board Standards. These agency-specific requirements can include W3C’s WCAG (Web Content Accessibility Guidelines), the international standards. Agency-specific requirements can be found on their respective sites, usually in the form of a checklist. Private industry: privately owned companies are well advised to follow WCAG.
Accessibility is a moving target. Staying current with standards and requirements is essential for a 508 Compliant Contractor or Vendor.
Federal, agency-specific, and international standards and requirements are in a constant state of evaluation and are currently updated sporadically and independently. Attempts to merge these three are ongoing as in the adoption of PDF/UA ISO 32000, but universal acceptance is predictably slow.
Reason for standards and requirements: Assistive Technology (AT) tools provide the handicapped the ability to access, navigate, and interact with content. Since the sight impaired is one of the largest groups confronting document accessibility issues, it’s helpful to know how ATs for the blind are designed to work. Mindset for grasping the concept of providing equal access to the blind: no mouse, no monitor/screen, just a computer, keyboard and speakers. ATs “speak” the content of the PDFs aloud in its intended order. They also provide a means to navigate the document.
Tags do not affect the appearance of the PDF.
An AT uses its dictionary to identify the words for pronunciation. It uses/interprets Tags (assigned to all content) to speak the words in proper order & context and to provide structure for organization and navigation. ATs’ ability to perform depends on tags. Fundamentally, making PDFs 508 compliant is a matter of tagging content.
Documents’ Source File. PDFs are created from source files. There are many things about the source file that impact the work needed to make their resulting PDFs compliant.
Content complexity: Lists, footnotes, tables, tables of contents, math, links, etc. must be tagged in a specific manner. Creating them properly in the source file will reduce the effort needed to remediate the PDF.
Design complexity: A cruel irony is that often much time, money, and effort is spent on creating and vetting a unique and beautiful document design only to find that it causes additional work to make the document compliant. Ex: Every agency creates marketing pieces; Financial reports, Pamphlets, Brochures, etc. The point of marketing is to uh …, market. Advertisers are paid to create designs that attract and hold attention – of the sighted. But for 508 compliance, everything on a page must be identified and accounted for, thereby diluting the benefits of visual accoutrements. Furthermore, visual enhancements may be used to improve a document’s appearance, but they may not be the sole means to convey information. Since the blind cannot see, whatever information is conveyed visually must be explained in writing. Complex designs are certainly workable, they simply add to the time it takes to remediate.
Page building software: Source Files are created in authoring software (page-making tools) like Word, InDesign, Quark, etc. Each one has had multiple versions. The work required to make a PDF compliant is impacted by which tool and version was used to create the source file.
Formatting: All page-making tools provide the ability to format (or style) elements. Use of formatting helps to ensure the resulting PDF has structure, hierarchy, and consistency – all important to accessibility.
Fonts: Unusual fonts and special characters are the bane of accessible PDFs. If Acrobat doesn’t recognize a character, compliance becomes an issue. Some agencies have found this problem significant enough to limit suggested typefaces to Arial , Veranda, Tahoma, Helvetica, Calibri, and Times New Roman.
Layout: Page-making tools do not force sequential placement of elements. Art and design elements are often placed on a page with only the thought of printing in mind because sighted people can tell the implied reading order. Unsighted people cannot see intended reading order. Proper reading order is a fundamental 508 standard and can be made difficult if the placement of elements was not sequenced properly.
System/Platform: Source files “touched” by more than one system or platform can contain problems, especially if it involves both Mac and PC.
Saving to PDF: When saving a source file to PDF, knowledge and proper use of options & tools has a significant impact on the amount of work required to make the PDF compliant.
Imported content: Source files may include content over which there is little control. This introduces variables that necessitate “work-arounds”.
If you’re not constantly uncovering capabilities within any of these tools, you’re missing efficiencies.
Achieving accessibility includes mechanics. Since Adobe created PDF, it makes sense that their Acrobat Professional is the fundamental tool for remediation (making PDFs compliant). There are books and countless internet postings that explain how to make files compliant using Pro. This powerful software takes years to master. NetCentric’s CommonLook is the answer to some of Acrobat’s inefficiencies (eg. remediating lists and tables). Like Pro, it also takes time to become proficient and to know when it is the appropriate choice. For many jobs, a combination of Pro and CommonLook is best. For fillable forms, Adobe’s LiveCycle is the best tool for creating dynamic forms with complex interactivity and functionality through scripts. A PDF generated from LiveCycle (PDF XFA) is also much easier to edit by taking it back into LiveCycle. Since fillable forms are routinely updated, this an important advantage. Everything about this tool is unique, including its learning curve.
Depending on the condition of the PDF, skillful use of these tools can automate the bulk of the remediation work but software alone cannot completely assign proper tags. The rest must be done by hand and requires the skill of working in the navigation panes.
The Basics. Each and every element on every page must be accounted for (tagged), even if it’s irrelevant like an extraneous mark or design dingbat. Irrelevant elements (convey no information) do not appear in the Tag Tree but must be identified as an <Artifact> in the Content Tree.
The Tag Tree: “Tags” is one of the navigation panes in Acrobat Pro. In a compliant PDF, each element is identified and sequenced (ordered) by their tag. The identities are Heads (<H1> – <H6>), paragraphs (<P>), lists (<L>, <LI>, <Lbl>, <Lbody>), tables (<Table>, <TR>, <TH>, <TD>), figures (<Figure>), internal and external links (<Link>), etc. The order in which the tags are arranged determines the order in which they are “spoken aloud”. Tags also have a parent-child hierarchy for organization and navigation (an H2 is always the child of an H1; a List body is always the child of a List item and a List item is always the child of a List; etc.). Understanding appropriate tag identification, tag creation, tag order, and tag hierarchy is critical. There is simply no substitute for spending time working in the Tag Tree.
The Content Tree: Content is another navigation pane in Pro. All the elements (content) in a PDF are in the Content Tree regardless of whether they’re tagged. If it’s in the PDF, it’s in the Content Tree. The order of contents should match its intended reading order (tag order). Their order is initially determined by the order in which the author of the source file placed them on the page (layered). To tag and order elements properly, it is often necessary to manipulate them in the Content Tree, but this must be done carefully because changing the order (layer) in which they came from the source file may result in blocking elements from view—they disappear from view. Practice is the only way to become efficient.
The Order Tree: Order Tree (navigation pane) in a PDF is meant to display the order in which the page’s content will be read and is used to check proper Reading Order (proper reading order is a 508 standard) established by the Content Tree.
PDFs must be tested for compliance. Since it is not possible for each agency to test all the documents posted on their website, the responsibility of accessibility falls to the document’s creators (contractors) as is typically stipulated in the SOW. This is a serious mandate and we treat it as such.
Different agencies use different testing criteria. Some require documented results of a certain testing tool. Additionally, the international PDF Association uses the Matterhorn Protocol which is their set of criteria for accessibility. Regardless of the testing standards, approximately 35% of the criteria require human checking.
Judgment is needed: Standards and requirements cannot address every conceivable variable. Two prime examples: 1) Understanding 508 standard’s realities and limitations, and 2) Reading order.
1. Adherence to the law “all electronic content must be comparably accessible to the handicapped” is by definition, not always possible (Raman principle and future technologies aside). Effective conveyance of information may require the use of any of our five senses. For the sight impaired, one of the standards for 508 compliance is to provide an explanation (alternative text) for any content conveyed through the use of images or color § 1194.22 (a & c)]. A written description of comparable understanding can be difficult. For example: graphs are used to convey content that would otherwise be difficult to communicate. A simple two dimensional graph has a horizontal and a vertical axis on which specific data points are plotted. Points associated with a certain category are connected with a line of a particular color, and there can be several categories. This type of graph is a common, simple way to “show” the simultaneous relationships between all the data. 508 Compliance Problem: Writing a linear description (alt. text) explaining the plot point for each color is possible, but to explain the relationship of all the data simultaneously is not possible. Now imagine a graph with a third dimension—depth.
2. As previously stated, the Order Tree is meant to display the order in which the page’s content will be read and is used to check proper reading order. Theoretically, the sequence of elements in Order, Content, and Tag Trees of a compliant PDF are the same. Theory and reality occasionally conflict. Actually, tags control reading order. Layering of art and design elements (established in the source file) can force Tag Tree sequence to deviate from the Order Tree and Content Tree sequence.
Judgment regarding these and other issues depends on your understanding of the law and your ability to explain the realities of its implementation.
Bumps In the Road
You don’t know when they’ll come or what they’ll entail but they will happen. With few exceptions, “will do” is the only acceptable answer.
Just make it happen is a purposeful attitude that must accompany competence.
The key to superior 508 compliance support is to ensure it not be an impediment to the larger project. Generally, our clients are not interested in the mechanics of what it takes to get the job done; their preference is to give the simple directive – “make it happen”. At Matrix we do just that.
The need to know Acrobat Pro
Here we’ll set aside the obvious need to know the variety of accessibility standards, and address the format itself – PDF.
Millions of people use PDFs on a regular basis. The operative word here is use; not create, analyze, configure, manipulate, edit, or tag. The good news is that for the casual or even serious USER, it’s not necessary to know what had to be done to the PDF to enable its use(s).
Remediating PDFs for accessibility is different. It requires a knowledge of Acrobat Pro, the primary remediation tool. The requisite knowledge corresponds to the complexity of a document’s content and/or design. If it’s simple & repetitive, making the PDF accessible does not require a high level of PDF manipulation. As a document’s complexity increases, so does the need for knowing Pro’s capabilities.
In addition to content and design complexity, source file creation (and save-to-PDF) also impacts remediation effort. As mentioned elsewhere, a PDF is created by saving a source file (except a scanned image PDF). Source files can be created with a number of page building tools/software, each of which is capable of yielding the same (printing/appearance) results using different methods. Additionally, the settings used in the “save to PDF” process further establishes the underlying structure of the PDF. Logically, these variables affect the effort & skills needed to make the PDF accessible.
The learning curve to work on PDFs is more long than steep. During the first years you’ll wonder when you’ll know it all. At some point you’ll be sufficiently humbled, appreciate how complex and extensive Acrobat Pro’s (and other plug-in’s) capabilities are, and accept that you’ll never know it all. If you are a professional remediator, you’ll continue to run into situations/issues not previously encountered that call for yet another solution which then gets placed in your ever-expanding toolbox. If your toolbox isn’t expanding, you’re working in an isolated environment.
Fortunately, tools have been developed to make PDFs more pliable. These tools have one universal requirement; they can’t change the most valuable aspect of PDF – their “lock down” presentation from one computer to another.
Again, Acrobat Pro is the primary tool. As implied above, one can spend years learning its capabilities. Then the next version comes out. To put this into perspective, let’s say there are 10 settings (and there are hundreds). Each setting interacts with each of the other 9. This means there are 100 possible outcomes, not all of which are apparent. Obviously, there’s a direct correlation between knowledge/skill and time spent learning.
For several remediation issues, another tool/plug-in may be a better choice. Since you must always land back in Acrobat, this means mixing tools. You’ve just added more variables. The learning continues.
Lots of help
Reaching out for help is a wise practice, and there’s no shortage of people willing to share their knowledge. There’s also no shortage of misinformation so consider reaching out to more than one source.
Conclusion: Without question, remediating PDFs is a specialty that requires an ongoing dedication of time and resources.
508 Compliance Standards Refresh
As stated above, The Access Board is responsible for the ongoing process of improving the standards based on feedback from the disabled community. In a nutshell; the Board gathers feedback; debates its merits; posts proposed changes for public comment; makes decisions on the comments; and finally adopts, posts, and announces new rules. This refresh cycle takes years and then begins again.
There is another practical benefit to this process taking multiple years – standards affect every Federal Agency (including procurement of services and hardware/software). All agencies must incorporate the new standards.
This sounds like a massive undertaking, and it is. But all the stakeholders in “equal access to electronic documents” keep abreast of the current and proposed standards.
As of February 2015, proposed new rules were posted for public comment – a 90 day period. It is anticipated that the new refresh will be adopted in 2017.
Meanwhile, more agencies are adopting their own agency-specific requirements in addition to the Access Board Standards. Additionally, W3C is also constantly evaluating their WCAG standards. And PDF/A (PDF Association) has their own international standards and uses PDF UA as its designation of conformance. PDF/A also has a process for updating standards.