Summary

Lisa Seeman's objection to WCAG's claim that WCAG 2.0 will address requirements for people with learning disabilities and cognitive limitations.

Author: Gez Lemon

The abstract of the Last Call working draft of the Web Content Accessibility Guidelines (WCAG) 2.0 contains the following in the abstract:

This document contains principles, guidelines, and success criteria that define and explain the requirements for making Web-based information and applications accessible.

The abstract continues to define accessible as:

"Accessible" means usable to a wide range of people with disabilities, including blindness and low vision, deafness and hearing loss, learning difficulties, cognitive limitations, limited movement, speech difficulties, photosensitivity and combinations of these.

If people with learning difficulties and cognitive limitations were directly addressed by the guidelines, they would be included under principle 3: Content and controls must be understandable; or more precisely, under guideline 3.1: Make text content readable and understandable. This guideline contains one Level 1 success criterion about the primary natural language, and one level 2 success criterion about the natural language of each passage or phrase. Level 3 has some success criteria about jargon, idioms, abbreviations, pronunciation, and a reading ability above lower secondary education. Not only does this dramatically fail to address an area of accessibility as complex as learning difficulties and cognitive limitations, but it doesn't even make sense against the proposed conformance scheme. If the natural language is required to be identified at level 1 (a minimum level of accessibility that is applicable to all web content), how come the way the language is used is at level 3 (additional accessibility enhancements that are not necessarily applicable to all web content)?

Lisa Seeman intends to make a formal objection about WCAG 2.0's claim that they address all requirements for learning difficulties and cognitive limitations, as they do not have the success criteria to back up their claim. Moreover, there are known techniques that WCAG have not included, and people who do intend to cater for people with learning difficulties and cognitive limitations would benefit from knowing of these techniques. If WCAG accept the objection, Lisa has kindly volunteered to help compile a list of "how to" documents and work on extensions for guideline 3 for understandable content. Lisa intends to submit the following letter of complaint:

WCAG 2.0 claims to define and address the requirements for making Web content accessible to people with learning difficulties, cognitive limitations and others. We object to that claim.

Specifically, the requirements for making content understandable ignore the needs of people with learning difficulties and cognitive limitations. Please note that there are guidelines published by other groups that will make content much more accessible to these users.

We would like to see continued work in this field and a statement in WCAG 2.0 abstract and introduction modifying the claim that they currently address accessibility for learning disabilities. Specifically we recommend removing learning difficulties, and cognitive limitations from the list of supported disabilities.

If you would like to support Lisa's objection, either leave your name in a comment, or contact me and I will pass your contact details on to Lisa. The more people that sign the objection, the more seriously the objection will be taken.

Category: Accessibility.

Comments

  1. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment1]

    Firstly, then word "people" is missing from the first paragraph in the proposed letter:

    [...] for making Web content accessible to [people] with learning difficulties, [...]

    Secondly, it seems a little odd to complain about the guidelines failing to address cognitive limitations and then propose a solution that simply removes all reference to addressing the disability. I think the proposed solution should be about either amending the current guidlines or extending them with new ones that do.

    Thirdly, do you have any information about, or are there any resources available anywhere that give an overview of techniques that actually do address these issues?

    Posted by Lachlan Hunt on

  2. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment2]

    While I am not happy with large sections of WCAG 2 including learning disabilities and cognitive limitations. I believe that taking learning disabilities and cognitive limitations out of list of disabilities addressed by WCAG 2 is sending the wrong message.

    That would be sound like the WCAG 2 saying "Learning disabilities and cognitive limitations are too difficult to deal with, so we are choosing to ignore them". And so will most organisations and people producing websites. "WCAG 2 does not deal with it why should we".

    Because it is so difficult to measure a web sites success in dealing with visitors with learning disabilities or cognitive limitations compared to visitors with blindness, low vision, hearing loss or limited movement. WCAG 2 needs to be strenghten in that area.

    I am willing to put my name (plus the pyschology degree, fancy job title and wa.gov.au email address) to any letter to the WCAG saying they are not doing enough for people with learning disabilities and cognitive limitations. I just do not want the end result to be WCAG 2 not dealing with learning disabilities and cognitive limitations.

    And like Lachlan I want to know of any resources in this area, I have very few and need more.

    Posted by Nick Cowie on

  3. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment3]

    Like the comments before me, I'm uncertain what the goal of removing reference to cognitive disabilities from WCAG 2.0 may be. I would be glad to sign on to this letter if it contained a demand or indication of an alternate plan to deal with standards for cognitive disabilities; perhaps the creation of a supplementary document to WCAG 2.0 handling cognitive disabilities.

    I think that the reason Lisa is proposing to remove the statement altogether is the generally held belief that it's "too late" to fix the version 2 document itself - there's not enough time, the committee won't accept radical changes, etc.

    I would hope that the committee will have some reaction to the incredibly negative response the accessibility community has had to this document; and, as such, I think it would be preferable to give them an option in the letter of protest: either commit to a serious overhauling of the document, or strike the offending phrases and create supplementary documents.

    Posted by Joe Dolson on

  4. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment4]

    Firstly, then word "people" is missing from the first paragraph in the proposed letter

    My fault - I must have removed it when formatting the text. I've put it back in.

    Secondly, it seems a little odd to complain about the guidelines failing to address cognitive limitations and then propose a solution that simply removes all reference to addressing the disability. I think the proposed solution should be about either amending the current guidlines or extending them with new ones that do.

    Lisa has offered to write extensions for guideline 3. The document is in Last Call, which means it either goes back to draft while this issue is addressed, or recognises that it doesn't address the needs of people with cognitive problems with the extension added at a later stage.

    Thirdly, do you have any information about, or are there any resources available anywhere that give an overview of techniques that actually do address these issues?

    Lisa will be better able to answer that than me, but I suspect it involves concepts like the concept coding framework http://www.conceptcoding.org/

    Posted by Gez on

  5. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment5]

    I think removing the references to cognitive differences is, on balance, the most honest approach. It would be pointless (and dishonest) to leave them in if they are inaccurate, which they clearly are.

    I agree with Lisa's points and I'm glad to see them being addressed publicly.

    There are very few resources in this area due to the diversity of differences that fall under the umbrella category of cognitive differences. Someone who is Rett's for example won't process input in the same way as someone who has Down's Syndrome. Its simply not as easy as identifying a homogeneous set of principles for a blanket term 'cognitive difference'.

    I think (as I've said before) that we need to go one step further back than even Lisa has identified and start with a realisation that a 'one size fits all' model won't be much better than we have now.

    This can and should be done. After all, we don't discuss users with a sensory disability do we? We differentiate between users who might having visual differences and thus need one type of solution and users with hearing based differences who may need another solution entirely.

    Posted by Kev on

  7. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment7]

    Given the recent uproar from the community at large (particularly concerning the difficulty of language used), sending it back to Working Draft status may not be such a bad idea.

    However, this document has been under development for many years and I'd expect the working group to be very reluctant about taking such action. But given that the community is highly unlikely to accept it in its current form, there doesn't seem to be much choice in the matter.

    Posted by Lachlan Hunt on

  9. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment9]

    I have been on WCAG for years, and appreciate it is hard for an international standard to address accessibility for people with learning disabilities.

    However, if WCAG claim to address learning disabilities (and they do not) then people who _want_ to cater to the needs of these users will not know that they need to look further.

    What I am trying to persuade them to do is drop the claim that WCAG 2.0 provides all the requirements for access for cognitive limitations, and instead continue work on an extension gridline that _will_ address these needs. This proposal does not stop adoption of core WCAG 2.0 or slow down their process. However at the end we need a standard that addressed learning disabilities.

    Any interest in cosigning the objection and proposal is warmly invited. The more people who sign the more seriously the objection will be taken.

    Posted by lisa on

  10. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment10]

    Lisa, I agree that if WCAG 2.0 goes through without major changes, then the claimed support for learning disabilities and cognitive limitations needs to be removed from WCAG 2.0.

    I would like to cosign your objection.

    Nick Cowie
    B. Psychology
    Web Services Consultant
    State Library of Western Australia
    nick dot cowie at slwa dot wa dot gov dot au

    Posted by Nick Cowie on

  11. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment11]

    Hi all, i was lead on the concept coding work mentioned above, i've spent many hours discussing this area with lisa and i was involved in wcag 2 for a while, then time commitments and funding got the better of me.

    I've got mixed feelings about this, but like comments posted earlier, i think the claim that wcag 2 addresses the needs of people with learning difficulties is not accurate, they have highlighted the problem and as such something needs to be part of the guidelines, so maybe its a case of watering down the claim and then pointing to the resources lisa's been compiling for a while. Unfortunately a solution for this group of users is far off, there is certainly limited resources around even discussing the subject (ldweb & conceptcoding are good places to start - i found other sites too and i'll update the links on conceptcoding.org). There are also many kinds of learning difficulties, conceptcoding is specifically for people with severe language impairements (ie. can't read text, use symbol representations / languages (PCS/REBUS/BLISS/...) to communicate) its a technique to do alternative content representation ie, provide symbol/graphic annotation to the text content and there is a long way to go before this solution even exists. The idea of alternative representation was also one of level 2/3 guidelines but as i've not looked for ages can't say for sure. Anyway, i'd be willing to sign something, wish i could be more involved. Andy.

    Posted by andy judson on

  13. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment13]

    @Andy Judson - One of the biggest problems I have is that WCAG 1.0 actually includes more checkpoints to assist people with cognitive disabilities than WCAG 2.0. I did a quick review of the WCAG 1.0 -> WCAG 2.0 mapping document to prove it.

    The one cognitive disability related checkpoint in Level 1 of WCAG 1.0 doesn't map to anything in WCAG 2.0

    Of the eleven cognitive disability related checkpoints in Level 2 of WCAG 1.0:
    - two checkpoints map to Level A in WCAG 2.0;
    - five checkpoints map to Level AA in WCAG 2.0;
    - two checkpoints map to Level AAA in WCAG 2.0; and
    - two checkpoints don't map to anything in WCAG 2.0

    Now, we need to take into account that most useful of the cognitive disability related checkpoints in WCAG 1.0 were in Level 3...

    Of the nine cognitive disability related checkpoints in Level 3 of WCAG 1.0:
    - one checkpoint maps to Level AAA; and
    - eight checkpoints don't map to anything in WCAG 2.0

    In total that's eleven checkpoints out of 21 that are no longer in the guidelines.

    Gian

    Posted by Gian Sampson-Wild on

  14. [formal-objection-wcag-claiming-address-cognitive-limitations.php#comment14]

    I am not sure when we are dealing with Cognitive issues that we can look for "direct hits" in the guidelines (guidelines specifically designed for cognitive issues) I think there is much benefit in looking at all the guidelines for places where they impact *some* people with cognitive issues.

    I agree that there are some Level 3 issues such as Acronyms that I would have liked to see at level 2 but in general there are many Guideline whose primary target may be blind people or people other disabililites which also give substantial improvement of accessibility to some people with cognitive issues also.

    In looking at Level one I would say there are 9 Sucess Criteria that improve access for some people with cognitive disabilities. For instance, I know a lady who has a form of dyslexia that prevents her from using a mouse. For her, every Success Criteria that makes the web site keyboard accessible is a benefit to her, in fact these Success Criteria are crucial to her employment. Some people with cognitive issues may benefit from have headings which programmatically determined because they may use a User Agent which takes advantage of Heading levels. Guidelines that prevent the web site from changing focus unexpectedly help some people with cognitive issues. Guidelines that extend time outs help some people with cognitive issues who are slower to respond. Contrast, and flashing related guidelines help some people with cognitive disabilities. The 4.1 guideline that makes sure all content of the site meets level one swings us back around to apply these issues to other technologies or at least provide the content in the baseline technology which does conform.

    I agree with Nick that we should not consider Cognitive disabilities as one big lump. When we look at the guidelines through the eyes of different kinds of cognitive issues we find many Success Criteria that help many different kinds of cognitive disabilities.

    Posted by David MacDonald on

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