Statement on the U.S. Access Board December 2011 ANPRM

While applauding the approach taken by the U.S. Access Board in choosing to reference established technical accessibility standards, the PDF Association wishes to express concern regarding the implementation of these regulations in the PDF context, and likely, other contexts as well.

The following paragraph occurs in Advisory E205.1 and Advisory C203.1.

“WCAG is written to be technology neutral. While oriented towards web pages which are defined as being delivered using HTTP, it is straightforward to apply the WCAG 2.0 Success Criteria and Conformance Requirements to all electronic content.” (emphasis added)

In each case, the applicability of the preceding regulatory requirements appears to entirely depend upon the degree to which it is “straightforward” to apply WCAG 2.0 to “all electronic content”.

WCAG 2.0 is a valuable normative standard designed expressly for web content. But is it the right or sufficient standard, for “all electronic content” as the December 2011 ANPRM states?

PDF has rich features and operates in many distinct contexts, including the web. We respectfully disagree that accessibility requirements developed for and expressed in web content terms are “straightforward” to apply in PDF. We believe that ISO 14289 (PDF/UA) is the appropriate normative standard for accessible PDF files.

We’d like to highlight the fact that the PDF/UA project was created to address industry confusion over how to achieve consistent accessibility in PDF. PDF/UA’s committees have included both accessibility and PDF subject-matter  experts from many countries, including individuals with disabilities. While PDF/UA began in 2004 as a US-led initiative, the ISO process included numerous international ballots of 20 member countries, receiving hundreds of comments from subject matter experts.

PDF/UA was created in the spirit of WCAG 2.0 to meet a demonstrated industry need. The two standards are entirely complimentary, with no conflicts.

PDF serves vital functions throughout the economy with specific qualities that distinguish it from web technologies. We do not believe that implementing ISO 32000-1 (PDF) in light of WCAG 2.0 alone will promote a consistent experience for individuals relying on a wide variety of assistive technologies.

We urge the US Access Board to include ISO 14289-1 (PDF/UA) as a referenced Standard in the refresh to Section 508 and wherever standards are set for accessibility in electronic documents.

About PDF
The world’s de facto electronic document format, the Portable Document Format is an electronic document file produced by thousands of different software components in hundreds of languages. Tens of billions of PDF files are in existence serving vital line-of-business functions in government, business operations world-wide. In 2008, PDF became an open International Standard: ISO 32000-1:2008.

About the PDF Association
With over 120 member organizations from over 20 countries, the PDF Association is the single purpose-built PDF-centric technology association in the world. Its function is to promote engagement with and understanding of ISO Standards for PDF technology including  PDF itself, PDF/A, PDF/E, PDF/VT, PDF/UA and PDF/X.  www.pdfa.org

About PDF/UA Competence Center

The PDF/UA Competence Center focuses on developing a specification for accessible PDF, in particular ensuring conforming PDF files are accessible and usable to all, including those who use assistive technology.

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