Draft: Comparison of UAAG 1.0 and Section 508

Status of this document

This document has been produced as a tool for developers to understand where the requirements of Section 508 and the User Agent Accessibility Guidelines 1.0 converge and depart. These are initial notes by the authors; this document does not represent UAWG consensus.

It is also important to note that the United States Access Board (or The Architectural and Transportation Barriers Compliance Board) has not reviewed or sanctioned this document. The Access Board was the agency designated in (Section 508(a)(2)(A) to publish standards setting forth a definition of electronic and information technology and the technical and functional performance criteria necessary for accessibility for such technology, for the United States Government.)

This document is part of a series of accessibility documents published by the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C). WAI Accessibility Guidelines are produced as part of the WAI Technical Activity. The goals of the User Agent Accessibility Guidelines Working Group are described in the charter.

Summary of relationships between two documents

The two documents are sufficiently different that we attempt only a rough comparison here, limiting ourselves to these relationships: subsumes, roughly equivalent to, and has no equivalent.

Section 508 paragraph 1194.21 requirements

1. (a) is subsumed by 1.1
2. (b)
   • The following has no equivalent in UAAG 1.0: "Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards."
   • The following subsumes 7.1 and 7.2: "Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer."
3. (c)
   • The following is roughly equivalent to parts of 9.1, 9.2, 9.3, and 10.2: "A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes."
   • The following is roughly equivalent to part of 6.5: "The focus shall be programmatically exposed so that assistive technology can track focus and focus changes"
4. (d)
   • The following is subsumed by 6.4: "Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology."
   • The following subsumes checkpoint 1.3: "When an image represents a program element, the information conveyed by the image must also be available in text".
5. (e) has no equivalent in UAAG 1.0. However, it is likely that the P2 checkpoint 7.3 relates (as it involves UI design and conventions).
6. (f)
   • The following is subsumed by 6.3 and 6.4: "Textual information shall be provided through operating system functions for displaying text." Note that UAAG 1.0 allows user agents to exchange text programmatically through higher-level interfaces instead.
   • The following has no equivalent in UAAG 1.0: "The minimum information that shall be made available is text content, text input caret location, and text attributes." UAAG 1.0 does not require implementation of a text caret. Access to content is assured through checkpoints of Guideline 6. Character encoding is assured through checkpoint 6.7, but no other text characteristics are required by UAAG 1.0.
7. (g) is subsumed by checkpoint 4.3.
8. (h) has no equivalent in UAAG 1.0 since it seems to assume that the author has provided alternative content for a different display mode: "When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user." However, UAAG 1.0 requires that the user be able to turn animations off in 3.2.
9. (i) subsumes parts of 10.2, 10.3, 10.4 (P2), 10.7.
10. (j) is subsumed (for text) by 4.3, since 4.3 makes a broader color range requirement.
11. (k) has no equivalent in UAAG 1.0 since UAAG 1.0 only talks about blinking text content (not UI controls). However, P2 checkpoint 7.3 is expected to cover this (related to UI design).
12. (l) is subsumed by 6.1 and 6.2.

Section 508 paragraph 1194.24 requirements

1. a-d have no equivalents in UAAG 1.0
2. (e) is subsumed by 2.5.

Section 508 paragraph 1194.25 requirements

1. (b) is subsumed by 2.4.
2. (f) is subsumed by 4.13 (although specific decibel levels are not part of UAAG 1.0).
3. g, h, and i are covered by 1194.21 requirements.
4. Other requirements have no equivalent in UAAG 1.0.

Section 508 paragraph 1194.41 requirements

1. (a) is subsumed by 12.1.
2. (b) is roughly equivalent to 12.2.
3. (c) has no equivalent in UAAG 1.0.

Conclusions

• Whichever specification the user agent conforms to, it has to do a lot to conform to the other.
• If a user agent satisfies Section 508 paragraphs 1194.21, 1194.24, 1194.25, and 1194.41, it also conforms to UAAG 1.0 Level A (for all content types, etc.) if it satisfies these checkpoints: 1.1 (for all functionalities), 1.2, 2.1, 2.2, 2.3, 2.4 (unless interaction is available in a time-independent manner), 2.6, 2.7, 2.8, 2.9, 3.1, 3.2, 3.3, 3.4, 3.5, 4.1, 4.10, 4.12, 4.13, 4.14, 4.17, 4.2, 4.3, 4.4, 4.5, 4.6, 4.9, 6.1, 6.2, 6.3, 6.4, 6.5 (bullets 2 and 3), 6.6, 6.7, 8.1, 8.2, 9.1 (bullet 2), 9.3 (bullets 2 and 3), 9.4, 10.1, 10.2 (bullets 3 and 4), 10.7 (bullet 1), 11.1, 11.2, 12.1, and 12.3.
• If the user agent satisfies UAAG 1.0 Level A (for all content types, etc.) it conforms to 508 if it does the following:
  • 1194.21 if you satisfy b (first sentence), d (second sentence), e, f (second sentence), h (unless 3.2 counts), i, and k.
  • 1194.24 if you satisfy all other requirements than e.
  • 1194.25 if you satisfy all other requirements than b, f, g, h, and i.
  • 1194.41 if you satisfy (c) and accessible documentation is available at no additional charge.

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  Ian Jacobs and Jon Gunderson
  Last modified: $Date: 2002/02/08 19:58:01 $ by $Author: ijacobs $

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