University of Wisconsin-La Crosse
Web Accessibility Policy
July 2003

Overview and Purpose

Access to information by all constituents of the UW-La Crosse community is inherent in our mission as an institution of higher education.  The World Wide Web provides a unique way to deliver many of the university’s information resources.  However, it is important to consider that the design of these resources be accessible to all members of our community, including those persons with disabilities.

In December 2000, a memo was sent to all UW-System Chief Information Officers from Ed Meachen, Associate Vice President at UW-System for Information Technology.  The memo requested, on behalf of President Lyall of UW-System, that all universities adopt a minimum set of web accessibility guidelines and incorporate into their IT plan an explanation of how they intend to assure that their web materials are accessible to all consumers.  To this end, in October 2001, John Tillman, CIO at UW-La Crosse, appointed the Universal Access to Information Technology Resources working group, chaired by Janice Ward, Manager, ITS Support Services.  The working group includes the following members:  Al Thompson, Gail Kettner, Mary Christie, Larry Sleznikow, Dave Faulkner, Heath Ahnen, Karin Bast, Joan Temple, Jen Holman and Gary Johansen.  Based on President Lyall’s charge, the working group wrote this Web Accessibility Policy for the University of Wisconsin-La Crosse. 

This policy outlines the web accessibility guidelines of UW-La Crosse. They have been established to ensure accessibility and meet the ethical and legal obligations under the Americans with Disabilities Act, the Telecommunications Act of 1996, and the Rehabilitation Act of 1973, Sections 504 and 508 as amended.  This document provides a set of guidelines for the development of web-based resources, which represent the University of Wisconsin-La Crosse.

Policy Guidelines

UW-La Crosse web sites must comply with the relevant subsections of Section 508 of the Rehabilitation Act of 1973, as amended.  Specifically, UW-La Crosse will maintain compliance with subsections 1194.1 through 1194.22 of Section 508.  Additionally, UW-La Crosse embraces the World Wide Web Consortium (W3C) guidelines and makes several additional recommendations based on these guidelines.   Details of the required and recommended guidelines are described in Appendix A of this policy.

In addition to the Section 508 requirements, each UW-La Crosse web page must contain contact information for users having trouble accessing the content.  See Appendix A, Item No. 17, for guidelines regarding contact information.

Scope of Websites

All University of Wisconsin-La Crosse web sites must comply with the required guidelines according to the timetable defined within this policy.  This includes pages representing any UW-La Crosse program, unit, department, division, or organization (including individual faculty members and student organizations) whether housed on the main university web server or elsewhere. 

Implementation

Each division is responsible for the implementation of this policy.  To assist divisions with implementation, Information Technology Services (ITS) will work with appointed division representatives to develop an implementation process for existing website materials, make web site/page monitoring tools available and provide appropriate web accessibility training.  It is expected that the university’s existing web site/pages will be compliant by December 31, 2003.

n addition to the schedule for revision of existing pages, all new and redesigned pages posted after the effective date of this policy must also comply with required guidelines.  Any non-compliant page for which a request for access is made must be revised in a timely manner in accordance with Section 508 guidelines or the content must be made available in alternative format.

Monitoring and Follow-Up

Each UW-L program, unit, department, division, or organizations has the responsibility to monitor the continued accessibility compliance of its web sites/pages.  We strongly recommend using the tools recommended and supported by UW-La Crosse Information Technology Services to aid in meeting this requirement[1] . 

ITS will conduct periodic reviews of web sites. Designated contacts of non-conforming pages will be notified of the guidelines and the resources available to assist them with meeting these guidelines.[2]   A timely response to correct identified problems will be expected in order to maintain compliance with this policy.  Formal complaints regarding web page accessibility issues will be handled according to current University procedures, including if necessary, the removal of offending pages from the University web.

Training and Support

A key component to the successful implementation of the Web Accessibility Policy will be the training and support for web developers across campus.  To that end, the ITS Support Center in cooperation with other University departments will offer training classes, support documentation and resources, and consultations to web developers of University web sites. 

Future Changes to Policy

As guidelines and technologies related to web accessibility evolve, this policy will be revised accordingly.  As such, it will be the responsibility of the University’s Chief Information Officer (CIO), to request that a committee revisit and revise this policy as needed. 

Appendix A
Web Accessibility Guidelines
 

The following guidelines represent the required items as specified by Section 508 of the Rehabilitation Act, as amended, along with additional recommended guidelines based on the World Wide Web Consortium (W3C) web accessibility guidelines.

A web site will be in compliance with 508 standards if it meets paragraphs (a) through (p) of Section 1194.22.  Each required guideline appears in bold type and compliance is required in order to meet accessibility requirements.   A brief description of each required guideline is also provided.   Descriptions have been adapted from the The Access Board, an independent federal agency dealing with accessibility for people with disabilities.  Additional recommendations for optimal accessibility appear with their related required guideline.  This document is not intended to serve as complete training on how to fulfill these guidelines.  It is recommended that all web developers receive training on the web accessibility guidelines in order to fully understand each requirement.

1.  Section 508 1194.22(a) – A text equivalent for every non-text element shall be provided.  (e.g., via “alt”, “longdesc”, or in element content).

Required – A text equivalent means adding words to represent the purpose of a non-text element. This provision requires that when an image indicates a navigational action such as "move to the next screen" or "go back to the top of the page," the image must be accompanied by actual text that states the purpose of the image. This provision also requires that when an image is used to represent page content, the image must have a text description accompanying it that explains the meaning of the image.

The number one issue with visually impaired persons accessing web pages has to do with content conveyed by images that is not contained elsewhere on the page.  Use ALT attributes in the image reference anchors and include descriptive text within the anchor.  When creating alternative text, aim for a functional label based on the context in which it is used rather than a visual description.  If alternate text is not necessary because descriptive text is already provided above or below the image, use ALT=”” in the IMG tag.  Many web publishing tools such as Microsoft^® FrontPage^® and Macromedia^® Dreamweaver^® have easy interfaces to add ALT tags to images.  Learning to properly use these tools when a graphic is inserted in the page will make it easy to add alternative text.

2.  Section 508 1194.22(b) – Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Required – Captioning for the audio portion and audio description of visual information of multimedia presentations are considered equivalent alternatives. This provision requires that when an audio portion of a multimedia production is captioned, as required in provision (a), the captioning must be synchronized with the audio. Synchronized captioning is required so that someone reading the captions can also watch the speaker and associate relevant body language with the speech.

If information presented is audio-only, a transcript of the audio must be available in order to satisfy item (a) for a text equivalent of a non-text element.

3.  Section 508 1194.22(c) – Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Required -  When colors are used as the sole method for identifying screen elements or controls, persons who are color blind as well as those people who are blind or have low vision may find the web page unusable.  For example, when a web page directs a person to push the green button to start, the button should also be identified in some other fashion besides green.

4.  Section 508 1194.22(d) Documents shall be organized so they are readable without requiring an associated style sheet.

Required – Style sheets can enable users to define specific viewing preferences to accommodate their disability. It is critical that designers ensure that their web pages do not interfere with user-defined style sheets.  When using Cascading Style Sheets (CSS), be sure that the document is still readable when CSS is turned off or a personal CSS is used.  For example, if you color code certain words using CSS, the colors will be lost in text-only browsers or screen readers.

Recommended –  

• Use headings (<H1>, <H2>, etc), lists, and consistent structure to keep the document organized. 

• Minimize the time it takes the web page to load.

5.  Section 508 1194.22(e) – Redundant text links shall be provided for each active region of a server-side image map.

Required - When a web page uses a server-side image map to present the user with a selection of options, browsers cannot indicate to the user the URL that will be followed when a region of the map is activated. Therefore, a redundant text link is necessary to provide access to the page for anyone not able to see or accurately click on the map.  It is preferable to avoid server-side image maps in most cases.

6.  Section 508 1194.22(f) – Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

Required - Unlike server-side image maps, the client-side image map allows an author to assign text to each image map “hot spot.” This feature means that someone using a screen reader can easily identify and activate regions of the map.

Recommended –  

• Use the client-side <MAP>, text for hotspots, and provide ALT tags for links.

7.  Section 508 1194.22(g) – Row and column headers shall be identified for data tables.

Required – When a table is used in a web site to provide data, appropriate markup for row and column headers is required.  Large tables of data can be difficult to interpret if a person is using a non-visual means of accessing the web. Users of screen readers can easily get "lost" inside a table because it may be impossible to associate a particular cell that a screen reader is reading with the corresponding column headings and row names.

8.  Section 508 1194.22(h) – Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

Required – When a table displaying data contains two or more levels of headers (see example below), appropriate markup must also be used to associate the data cells and headers cells correctly.

(Table with two levels of row headers)

Recommended – Summarize tables for clarity.  The “Summary” attribute of the Table tag may be used although some assistive technology devices do not support the “Summary” attribute.  Consider placing their descriptions either adjacent to their tables or in the body of the table, using such tags as the CAPTION tag. In no event should web developers use summarizing tables as an alternative to making the contents of their tables compliant as described above.

9.  Section 508 1194.22(i) – Frames shall be titled with text that facilitates frame identification and navigation.

Required – Use frames cautiously, always providing NOFRAMES content and giving titles to each frame.  (Remember to keep your NOFRAMES content up-to date.)  Each FRAME must reference an HTML file. 

Recommended – Consider designing a page without frames.  Frames provide a means of visually dividing the computer screen into distinct areas that can be separately rewritten. Unfortunately, frames can also present difficulties for users with disabilities when those frames are not easily identifiable to assistive technology. For instance, a popular use of frames is to create "navigational bars" in a fixed position on the screen and have the content of the web site retrievable by activating one of those navigational buttons. The new content is displayed in another area of the screen. Because the navigational bar doesn't change, it provides a stable "frame-of-reference" for users and makes navigation much easier. However, users with disabilities may become lost if the differences between the two frames are not clearly established.

10.  Section 508 1194.22(j) – Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

Required - Some individuals with photosensitive epilepsy can have a seizure triggered by displays that flicker, flash, or blink, particularly if the flash has a high intensity and is within certain frequency ranges.  Flashing or flickering elements are usually added through technologies such as animated gif's, Java applets, or third-party plug-ins or applications. 

11.  Section 508 1194.22(k) – A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished any other way.  The content of the text-only page shall be updated whenever the primary page changes.

Required – Creating a text-only page for your content is considered a last resort in creating accessible web pages.  When creating a text-only page, it must be updated whenever the primary page changes and an accessible link to the text-only page created from the primary page.

12.  Section 508 1194.22(l) – When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.

Required - Web page authors have a responsibility to provide script information in a fashion that can be read by assistive technology. When authors do not put functional text with a script, a screen reader will often read the content of the script itself in a meaningless jumble of numbers and letters. When using script (such as JavaScript), it is important that web page developers learn how to write accessible code.

13.  Section 508 1194.22(m) – When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with 1194.21(a) through (l).

Required- This provision requires that web pages that provide content such as Real Audio or PDF (Adobe Acrobat's Portable Document Format) files also provide a link to a plug-in that will meet the Section 508 guidelines for accessible software. This provision places a responsibility on the web page author to know that a compliant application exists, before requiring a plug-in.  Plug-ins or applets that require the use of non-accessible software should not be used.

14.  Section 508 1194.22(n) – When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Required – When using online forms, the web developer must use <LABEL> and <ID> tags to ensure that the label of a field is correctly associated with its field element.  For instance, if an input box is intended for receiving a user's last name, the web developer must be careful that the words "last name" (or some similar text) appear near that input box or are somehow associated with it.  However, the visual proximity of a form element and its title offers no guarantee that a screen reader will associate the two or that this association will be obvious to a user of assistive technology.  Use of the <LABEL> and <ID> tags will ensure the relationship between these elements.  Explicit labeling works extremely well with all popular assistive technology.

15.  Section 508 1194.22(o) – A method shall be provided that permits users to skip repetitive navigation links.

Required - This provision provides a method to facilitate the easy tracking of page content that provides users of assistive technology the option to skip repetitive navigation links. Web developers routinely place a host of routine navigational links at a standard location – often across the top, bottom, or side of a page.  For those who use screen readers or other types of assistive technologies, it can be a tedious and time-consuming chore to wait for the assistive technology to work through and announce each of the standard navigational links before getting to the intended location. In order to alleviate this problem, the section 508 rule requires that when repetitive navigational links are used, there must be a mechanism for users to skip repetitive navigational links.

Recommended – Make text links descriptive but not overly wordy.  Your text descriptors need to convey information about the nature and destination of the link.  For example, authors should not use “click here” as a link.

16.  Section 508 1194.22(p) – When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Required - Web pages can be designed with scripts so that the web page disappears or "expires" if a response is not received within a specified amount of time. Sometimes, this technique is used for security reasons or to reduce the demands on the computer serving the web pages. Someone's disability can have a direct impact on the speed with which he or she can read, move around, or fill in a web form.  For this reason, when a timed response is required, the user shall be alerted via a prompt and given sufficient time to indicate whether additional time is needed.

17.  Contact Information Requirement.  All web pages shall identify a contact for users having difficulty accessing web page content.

Required – Each UW-L web page shall have an email address and phone number as a contact for assistance.  This contact shall be a full-time University staff person within the relevant program, unit, department, division, or organization who is either the web page developer or who is able to work with the developer to correct the problem and address the needs of the user.  Contact information shall be clearly identified as such on each web page.

[1] The Universal Access to Information Technology Resources Committee is currently evaluating such tools and will publish a list of recommended and supported utilities through the ITS Support Center.

[2] The ability to conduct such reviews and monitor progress of the University is dependent upon the University’s ability to acquire a product to assist in web-wide review.  Such products are currently under evaluation by the Universal Access to Information Technology Resources Committee.