[Irl-dean] Redevelopment of the NDA IT Accessibility Guidelines

Mark Magennis Mark.magennis at ncbi.ie
Wed May 31 17:14:41 IST 2006

Like Brendan, I've just read through the draft auditing guidance and  
sent the following comments to the NDA. I'm reposting them here in  
order to back up Donal's encouragement for list members to provide  
feedback. The draft guidance is an easy to read document and it would  
be good to get the opinions of those of us who actually carry out  
audits commercially. You might ask yourself - "would I be happy if  
someone came to me expecting me to carry out an audit on the basis of  
this advice?". Good question.


** The summary looks a bit funny consisting of single sentences  
separated by white space. I like the way Bunyfoot have laid out the  
text in their Guidance, including picking out key issues in bold  
(actually this is also done within the auditing guidance, e.g. in 6.  
What is a web accessibility audit?).

** The reference links [1], [2], [3], etc. don't work.

** In 6. What is an accessibility audit? and 7. What does this  
guidance cover? it seems a little restricted to WCAG 1.0 AA. Okay,  
this is important, but I would like to see it stress the fact that  
WCAG 1.0 was a first stab, is now old and is considered imperfectly  
prioritised and overly concentrating on technical accessibility at  
the expense of some practical usability issues for people with  
disabilities. So I would like the guidance to suggest WCAG 1.0 AA as  
a minimum with WCAG P3 checkpoints also considered and extra  
consideration of usability issues. So section 7 might say, for example:
"...this guidance will help you to improve the accessibility of your  
website by auditing its accessibility. This process will:

* Show where your website stands in conforming with the WCAG standards;
* Highlight usability problems that people with disabilities might  
* Indicate how it can be improved;
* Give you an implementation plan to better accessibility.
7.1. Do I need to carry out an audit?

You probably need to have an accessibility audit of your website if:

1 Your organisation is in the public sector;
2 You do not have proof that it meets at least WCAG Level Double-A  
3 You know that the site is not at least WCAG Double-A compliant;
4 You are not sure that the site is equally usable for people with  

** In section 8 Types of accessibility audit, it says "An  
accessibility audit can ... be entirely manual, or use automated  
tools, or mix the two." Whist it is true that you could do an audit  
entirely manually or entirely automatically, the former would be  
inefficient and the latter would be inadequate. Although these issues  
are explained later on in the section, I think it's possible that a  
reader might interpret this sentence as "A SENSIBLE AND ADEQUATE  
accessibility audit can ... be entirely manual, or use automated  
tools, or mix the two.". This would not be true, so perhaps the  
sentence should be changed to something like:

"An accessibility audit can ... be done entirely manually, or make  
some use of automated tools."

I would also state under Automated:

This type of audit is inadequate. Most accessibility checkpoints  
cannot ..."

** In 8.3. Self-audit, perhaps the word "afresh" should be changed to  

** 11.1 and 11.5 both make reference to the Procurement Toolkit. I  
think the toolkit should also be referenced in 11.4 which should  
state that it provides sample text that can be cut and pasted into an  
RFT. Since this is probably the major contribution of the procurement  

** In 13.2 it says "The report summary ... should contain about 400  
words...". I think this is unnecessarily prescriptive.

** In 15.4 the CFIT website address should be www.cfit.ie.

** A general issue concerning duplication. I'm aware that the NDA  
guidelines has a section on legislation and policy and the  
Procurement Toolkit also has its own section on legislation and  
policy. These auditing guidelines have yet another one (though I  
think it might be the same or similar to the existing NDA Guidelines  
one, except that it's given a new introduction. I'm not saying this  
is bad, but just raising it as an issue. Same goes for Introductions.  
In the auditing guidelines we have an introduction to Web  
accessibility. The NDA Web guidelines have their own introduction and  
the Guidance documents have another. A similar situation exists with  
explanations of WCAG. It may be worth taking a general look at the  
amount of duplication and whether it is the best way to do this.

Dr. Mark Magennis
Director of the Centre for Inclusive Technology (CFIT)
National Council for the Blind of Ireland
Whitworth Road, Dublin 9, Republic of Ireland

mark.magennis at ncbi.ie   tel: +353 (0)71 914 7464

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