accessibility compliance: one state, two approaches
TRANSCRIPT
Accessibility Compliance:
One State, Two Approaches
Stephanie J. Adams Tennessee Tech University
Jennifer Mezick Pellissippi State Community College
Corey Halaychik The University of Tennessee, Knoxville
Overview
Accessibility defined
Types of disabilities and accessible design features
Laws and lawsuits
Task Force formation
Tennessee Board of Regents (TBR) Libraries Accessibility Task
Force activities and plans
Accessibility documentation standards
University of Tennessee System process, results, and plans
Accessible vs. Accommodation
“Accessible means a person with a disability is afforded the opportunity to
acquire the same information, engage in the same interactions, and enjoy the
same services as a person without a disability in an equally effective and equally
integrated manner, with substantially equivalent ease of use. The person with a
disability must be able to obtain the information as fully, equally and
independently as a person without a disability.”-U.S. Department of Education, Office for Civil Rights (OCR resolutions with South Carolina Technical
College System, University of Cincinnati, and Youngstown State)
https://dso.dasa.ncsu.edu/what-does-accessible-mean/
“Accommodations are reasonable academic adjustments or auxiliary aids that provide
equal access to programs and services on an individual basis.”-Tennessee Tech University Accessibility Initiative
https://www.tntech.edu/accessibility/accessibility-vs.-accommodation
Examples of Accessible Design Features
Types of Disabilities
Visual
Auditory
Neurological
Motor/Mobility
Cognitive
Speech
Accessible Features
Alternate text for images
Captioning for audio/video
Absence of flickering images
Full keyboard support for navigation
Simple navigation tools and page
layouts, conceptual explanations
Help or tech support via a variety of
methods (not just telephone)
WebAIM: Introduction to Web Accessibility: http://webaim.org/intro/
W3C Web Accessibility Initiative: Diversity of Web Users: https://www.w3.org/WAI/intro/people-use-web/diversity
Laws Related to Accessibility
in Higher Education
Section 504 of the Rehabilitation Act of 1973
Section 508 of the Rehabilitation Act of 1973 as amended (in 1998)
Title II of the American with Disabilities Act of 1990
Title III of the American with Disabilities Act of 1990
In Tennessee: Senate Bill No. 1692 (signed into law on April 16, 2014)
K. Ostergard’s “Accessibility from Scratch” – Table 1
DOI: 10.1080/0361526X.2015.1069777
Implementing Accessibility at UTM:
https://www.utm.edu/departments/acadaff/_pdfs/Implementing_Accessibility_at_UTM.pdf
Complaints in Libraries and Higher Education
Public Libraries: NOOK eReaders
Higher Education:
Websites
Course management/learning management systems and
online learning platforms
Kindle DX eReaders
Videos without captioning
Course registration systems
Textbooks and other course materials
Technology (including classroom clickers)
Gmail and Google Apps
Library systems and databases
Legal Action in Higher Education:
Library Materials
Penn State University (Resolution Agreement)
National Federation of the Blind (NFB) filed a complaint regarding
inaccessible websites.
University of California at Berkeley (Lawsuit settled in 2013)
Disability Rights Advocates (DRA) filed lawsuit citing inaccessibility of
library materials for students with print-related disabilities
University of Montana-Missoula (Resolution Agreement)
Investigated by the Office of Civil Rights (OCR) in the U.S. Department
of Education for complaints including inaccessible library database
materials.
Higher Ed Accessibility Lawsuits, Complaints, and Settlements http://www.d.umn.edu/~lcarlson/atteam/lawsuits.html
Tennessee Board of Regents System:
Who We Are
One of two systems of Tennessee public higher education
Largest system of higher education in Tennessee
13 Community Colleges
27 Colleges of Applied Technology
TN eCampus (46 partner institutions, 500+ certificates and degrees)
Serves 100,000+ students
6 Universities
Serve 88,000 students (75,000 undergraduate & 13,000 graduate and professional students)
https://www.tbr.edu/
Tennessee Board of Regents Libraries
Accessibility Task Force
Tennessee Higher Education Commission (THEC) Accessibility Task
Force charged TBR and UT with creating policies for accessible IMT
(information materials and technologies)
TBR Accessibility Task Force formed in Spring 2015
TBR Libraries Accessibility Task Force formed in Spring 2016
Members: interested library staff from any of the TBR and UT schools
Purpose: deliver a plan for an accessibility audit of library resources
TBR Libraries Accessibility Task Force:
Initial Goals
Initial audit of library instructional materials and technology (IMT)
Challenges
• Selecting tools/developing audit rubric (WAVE, WebAIM
checklist)
• Interpreting results
• Recruiting end-user testers
Develop a collaborative process for procurement of AIMT (Accessible
IMT)
Master list of eResources (divide and conquer approach)
Vendor form letter
Accessibility document roundup
AIMT database contributions
Accessible Product Documentation:
Standard Forms
Accessibility Statement: statement of commitment to ensuring equal
access to all users
VPAT: Voluntary Product Accessibility Template
WCAG 2.0 Checklist
EPUB 3 Accessibility Checklist
Standard Compliance Forms: Accessibility Statement
ProQuest Academic Accessibility Statement
http://support.proquest.com/articleviewpdf?id=kA140000000GuuQCAS&l=en_US
VPAT: Voluntary Product Accessibility
Template
Developed by ITI (Information Technology Industry Council) and the
GSA (U.S. General Services Administration)
Provides information on how EIT conforms to the Section 508
Accessibility Standards
Form is to be completed by vendors or publishers
Template available at: http://www.itic.org/policy/accessibility/
LUA (Libraries for Universal Access) maintains a VPAT Repository at:
http://uniaccessig.org/lua/vpat-repository/
Standard Compliance Forms: VPAT
Web Content Accessibility Guidelines
WCAG 2.0 – Levels A through AAA
Key Principles
Perceivable: Information must be presented in a manner that users can perceive (Example: captions for audio)
Operable: User must be able to navigate and operate the interface (Example: Keyboard shortcuts in place of using the mouse)
Understandable: User must be able to understand how to use the interface (Example: Consistent navigation on each page)
Robust: Content must be able to be interpreted by assistive technology (Example: Markup language contains start and end tags for screen readers)
WC3: Web Accessibility Initiative
https://www.w3.org/WAI/WCAG20/quickref/
Standard Compliance Forms: WCAG 2.0 Checklist
Blank checklist used by TBR available at:
https://www.tbr.edu/sites/tbr.edu/files/media/2016/02/WCAG2.0-Checklist_0.doc
Standard Compliance Forms: EPUB 3 Checklist
EPUB 3 Accessibility Guidelines: Accessibility QA Checklist
http://www.idpf.org/accessibility/guidelines/content/qa/qa-checklist.php
Accessible Product Documentation:
Additional TBR Forms
Conformance and Remediation Form: identifies
accessibility issues/gaps and indicates a timeline for
conformance
Alternate Access Plan: describes the process for accessing
AIMT when it does not conform to accepted accessibility
guidelines (for example: WCAG 2.0 Level AA)
Additional TBR Forms: Conformance and
Remediation Form
Blank forms available at:
https://www.tbr.edu/sites/tbr.edu/files/media/2016/02/Conformance%20and%20Remediation%20Form.docx
Additional TBR Forms: Alternate Access Plan
Blank forms available at: https://www.tbr.edu/sites/tbr.edu/files/media/2016/02/Alternate%20Access%20Plan_1.doc
Additional TBR Forms: Alternate Access Plan
Task Force Activities: Document Collection
Created by the TBR Libraries Accessibility Task Force.
Vendor Form Letter
Task Force Activities: Audit
Checklist created by Brittany Richardson and Sandra Wilford at Chattanooga State Community College and Livy
Simpson at Volunteer State Community College.
TBR Task Force: Moving Forward
Finalize audit checklist
Audit a sampling of databases
Continue to gather and share documents
Work with TBR to improve AIMT database format & features
Develop and share Alternate Access Plans
Follow-up on Conformance and Remediation Form timelines
TBR Licensing Language
Service and Software Accessibility Standards. The Contractor warrants
and represents that the service and software, including any updates,
provided to the Institution will meet the accessibility standards set forth
in WCAG 2.0 AA (also known as ISO standard, ISO/IEC 40500:2012) and
will be compliant with Section 508 of the Americans with Disabilities Act
(ADA) with exceptions, if applicable. Copies of Contractor’s Voluntary
Product Accessibility Templates (“VPATs”) for the various products and
other accessibility information are available at URL.”
University of Tennessee: Who We Are
Public university system
4 Campuses (Chattanooga, Knoxville, Martin, & Memphis)
3 Institutes (Agriculture-Veterinary, Public Service, &
Space)
1 Medical library (UT Medical Center)
Serves 49,000 students (38,000 undergraduate & 11,000
graduate)
http://tennessee.edu/
University of Tennessee: Status
UT Schools TBR Schools
University of Tennessee: Process
Libraries have been largely absent
No combined effort
System Office of General Counsel
System Procurement Office
Campus task forces
Libraries (internal & external)
Limited proactivity
No documentation, auditing, or testing
University of Tennessee: Language
University of Tennessee: Results
Lengthy drafting process
No standard language at outset
Vendors apprehensive
Walked away from a couple of purchases
Newer agreements contain some form of the language
Older agreements still need to be amended
No proof of compliance collected
University of Tennessee: Moving Forward
System
Supplied language but otherwise not involved
Campuses
Have task forces looking at all accessibility issues
Libraries
Electronic Resources Group is identifying ways we can work together to:
• Audit for compliance
• Compile documentation
• Modify language to include clauses for remedies, protections, and
reporting
Additional Resources
Recommendations of the [Tennessee] Higher Education Accessibility Task Force
https://www.tbr.edu/sites/tbr.edu/files/media/2015/08/Accessibility%20Task%2
0Force%20Recs-Final.pdf
TBR Libraries: Accessibility Audit Plan (as of April 2016)
http://www.tbr.edu/sites/tbr.edu/files/media/2016/05/AccessibilityAuditPlanTB
RLibraries_2016apr26.docx
Tennessee Board of Regents: Accessibility Initiative
https://www.tbr.edu/academics/accessibility-initiative
Questions?
Tennessee Board of Regents System
Stephanie J. Adams
Tennessee Tech University
Jennifer Mezick
Pellissippi State Community College
University of Tennessee System
Corey Halaychik
The University of Tennessee, Knoxville