[Irl-dean] NDA Draft ICT Procurement Toolkit

Barry McMullin mcmullin at eeng.dcu.ie
Wed Jul 12 15:39:13 IST 2006

Hi Folks -

Unfortunately I have not had a lot of time to look at this, but
just a couple of quick comments.

First and foremost, this is a really great initiative and I
warmly congratulate the NDA and everybody else involved in
bringing it to this stage.

That said, of course, I do want to get picky about a few things,
particularly in the "web accessibility" area. Here's a short URL
for the page I am commenting on:


Under "scope" we see this includes "stand alone HTML
documents". Why the qualification of "HTML" here? Or, indeed, the
limitation to "documents"? I would much prefer to see "stand
alone electronic or digital resources (documents and other

(This is not at all a trivial point: the current text could
actually be misread as inviting a supplier to deliberately *not*
use HTML for "documents" because in that way they would be
conveniently pushed outside the scope of accessibility

In the "suggested text" for the RFT I suggest adding something

"Where a supplier considers that it is either not appropriate or
not achievable for some component of the tendered product or
service to conform to any WCAG 1.0 checkpoint then this must be
stated explicitly in the tender, together with an explanatory

(Otherwise the text may be so weak that the client would effectively
be expected to independently audit each tender for such
"deliberate" non-conformances.)

The description of WCAG level Triple-A as "often considered
unattainable, or at least too vague to argue about" is somewhat
confusing, given the comments elsewhere about the importance of
at least some priority 3 checkpoints.

The paragraph beginning "In practice, there is a certain amount
of debate about WCAG 1.0 ..." is, in my view, highly problematic.
While there is some basis to it, I feel it could leave the poor
clients, trying to use this toolkit, completely
floundering. Further, the final sentence seems to be positively

  "Irish legislation and Government policy does not mandate
  specific required compliance levels."

In fact, from the government document "New Connections - A
Strategy to realise the potential of the Information Society,
March 2002" we have this explicit (if now rather ironic!)

  "7.2.7 Accessibility - Under the eEurope Action Plan, all
  public sector websites are required to be WAI (level 2) [sic]
  compliant by end-2001."

I am not aware that this policy has formally changed, either at
national or European level - but maybe others have more recent

In any case, I would suggest replacing this whole paragraph, with
something more like this:

  Accessible design of web based, or digital stand-alone,
  products and services is a potentially complex topic.  Many of
  the guidelines require careful interpretation in the context of
  individual web site goals and requirements. It is very
  important to respect not just the technical "letter" of the
  guidelines, but also the underlying motivation or "spirit" of
  how they are designed to support accessibility for different
  disability groups. Web technologies are continuing to develop
  at a rapid rate, and the WCAG guidelines themselves are also
  under ongoing review. Accordingly, both in preparating an RFT
  and reviewing submitted tenders, it is important to have access
  to competent, professional, advice whether from suitably
  qualified in-house staff or external consultancy.

Finally, then, the paragraph reading:

"So if you are procuring a website or web content, you should
specify WCAG as a reference, but not state any requirement for a
specific compliance level."

definitely seems a step too far for me.  Yes, the conformance
levels are imperfect, and require informed interpretation in the
context of a particular site or service.  But they remain a very
good summarising mechanism, and, further, are the basis for many
policy statements and comparisons internationally (not to mention
that Double-A appears explicitly in the NDA's own draft code of
practice for the Disablity Act 2005).  So I think this needs some
more nuanced presentation.

That's my tuppence worth for now,

Best - Barry.

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