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NYS Policy (P04-002) and Standards (S04-001):
Frequently Asked Questions (and Answers)

DISCLAIMER: This document is the work of members of the NYS Forum's IT Accessibility Work Group. The views and opinions expressed therein do not necessarily state or reflect those of the NYS Forum, the State of New York
or any agency or entities thereof. References to any specific commercial product, process, service by trade name, trademark, manufacturer, or otherwise, does not constitute or imply the endorsement, recommendation, or
favoring by the NYS Forum or any entities thereof.

Topic List

Adobe PDF Documents

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001
Standard 1: Text Equivalents for Non-Text Content

1.1  A text equivalent will be provided for all non-text element(s). Non-text elements will include, but are not limited to, images, graphical representations of text (including symbols), image map regions, animations (e.g., animated GIFs), applets and programmatic objects, ASCII art, frames, scripts, images used as list bullets, spacers, graphical buttons, sounds (played with or without user interaction), stand-alone audio files, audio tracks of video, and video.

1.2  Ensure that equivalents for dynamic content are updated when the dynamic content changes.

1.3  Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent information on an alternative accessible page.

1.4  A text equivalent will be provided for all non-text element(s) through the following means: "alt", "longdesc", or in element content.

1.5  An alt attribute will convey the same information, in a textual manner, as intended by the image.

1.6  Graphics which are strictly for decoration, such as bullets, will have an alt attribute filled with one space (e.g., alt=" ").

1.7  An alt attribute, within an image element, will not exceed 150 characters.

1.8  A longdesc attribute is required within an element if alt text exceeds 150 characters. A descriptive link will also be provided.

Standard 14: Downloadable/Embedded Objects

14.1 When downloadable documents (e.g., word processing documents, spreadsheets, Portable Document Format (PDF), java applets) are used, a link to accessible HTML or text version(s) will be made available.

14.2 When hardware software and assistive technology devices are controlled by a state agency, downloadable documents (e.g., word processing documents, spreadsheets, Portable Document Format (PDF)) available through an intranet or extranet will be allowed.

From NYS Technology Policy No. P04-002
Part 1. State Agency Content Accessibility for Persons with Disabilities
Paragraph B. Review of Existing Content

In accordance with the time period set forth in this Paragraph, state agencies will review all content for the purpose of making it accessible to persons with disabilities. Any revisions identified pursuant to theis Paragraph will be completed in accordance with the timeframes set forth in Paragraph C of this Part.

All state agencies will within 90 days of the effective date of this policy identify and document the following:

  • high-traffic pages, home pages, and critical path pages;
  • medium-traffic pages; and,
  • low-traffic pages

In order to establish the categories set forth above each state agency will review its logs and any other relevant documentation. For purposes of this policy, critical path pages are those pages that are essential to the completion of a transaction, service, or application.

Part 1, Paragraph C. Compliance Schedule

On or after the effective date of this policy state agencies will revise existing content to comply with this policy as follows:

Compliance Schedule
Content Timeframe for Compliance
New Content (Part 1 A) Immediately
High-Traffic Pages, Home Pages & Critical Path Pages (Part 1 B) Within 180 days after the effective date of this policy
Medium-Traffic Pages (Part 1 B) Within 270 days after the effective date of this policy
Low-Traffic Pages (Part 1 B) Upon content changes

Part 2. Notice and Contact Information

State agencies will post contact information (email address and telephone number) with respect to accessibility for persons with disabilities on their web sites to enable individuals to contact the state agency. Such links will be posted, at a minimum, in the footer of the state agency's home page and be clearly distinguishable from any other link found in that footer.

QUESTIONS AND ANSWERS

Q1.   [NYS Standards] S04-001 seems pretty clear but I'd like some clarification on Standard 14. If I read 14.1 and 14.2 correctly, I'll need to see to it that there are html (or browser-displayable text) versions of all PDFs and Word docs currently served to the public. Is that true?

A.  Yes. Standard 14.1 is clear in this regard.

Q2.  How does the timeline described in P04-002 apply? My PDFs aren't really 'trafficked pages' and most will never receive "content changes".

A.  Per Part 1, Paragraph C. Compliance Schedule of the Policy, if these are existing pages that will never be updated and are rarely visited, then you can probably defend leaving them as PDFs — until someone with a disability requests access to them.

In this case, contact information is critical. Refer to Part 2. Notice and Contact Information of the Policy above.

Q3.  What about PDFs that are scanned or captured text? Do such PDFs need to be fully transcribed?

A.  In order to be accessible, these will need to be either passed through an OCR scanning system or transcribed (and in some instances described) in order to be accessible. Keep in mind that a scanned PDF is simply a large graphic, and therefore falls under NYS Mandatory Technology Standard S04-001, Standard 1: Text Equivalents for Non-Text Content.

Q4.  We have many documents that are offered to the public via the web precisely because it is easy to turn originals of various origins into PDFs. Must this stop henceforth unless each andevery example is rendered simultaneously as html or plain text?

A.  Yes. Per the policy, you cannot post a PDF without posting an accessible alternative. This is an issue not only for visually impaired users, but for users with less powerful/current computing systems. Posting only in PDF also raises an obstacle to visitors with non-traditional web access devices, such as PDAs and web-enabled cell phones.

Q5.  What about making the PDFs themselves accessible using currently available Adobe Acrobat technologies, as described here: http://www.adobe.com/products/acrobat/access_overview.html?

A.  This solution may accommodate a portion of the previously excluded audience. However, it will still exclude the aforementioned users of PDAs and web-enabled cell phones, as well as visitors using older technology.

From Sharon Trerise, Cornell's Northeast ADA & IT Center:
In a brief conversation with Patrick DeCastro, it sounded like there may be some flexibility in the future to post just the PDF, if it is indeed created to be accessible. However, currently, even an accessible PDF does require the user to have Adobe Reader 5.0 or greater and the newest version of either JAWS or Window Eyes in order to read it. Since these conditions are quite limiting (other screen reading software may be used or older versions of JAWS and Windows Eyes may be used since screen readers are very expensive), I think the policy requiring an accessible HTML version was designed to make sure that the information in PDFs would be accessible to the broadest audience.

As time goes on, the ability to create an accessible PDF will improve and more screen readers will be upgraded, etc. so that the option to provide just an accessible PDF may be viable. But for the time being, providing an accessible HTML alternative is the solution that ensures accessibility for the greatest number of people, including those using other devices such as PDAs, to view web content.

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Applicability of Policy to Applications

RELEVANT STANDARD AND POLICY TEXT

From NYS Technology Policy No. P04-002
Purpose

The purpose of this policy is to make state agency web-based intranet and Internet information and applications accessible to persons with disabilities.

From NYS Mandatory Technology Standard No. S04-001
Purpose

The purpose of this mandatory technology standard is to provide the mechanism for state agencies to comply with OFT Policy, P04-002, Accessibility of State Agency Web-based Intranet and Internet Information and Applications, which provides that all web-based intranet and Internet information and applications, (hereinafter referred to as "content"), made available by state agencies to the general public, state employees and any other persons are accessible to persons with disabilities.

Scope

The following mandatory standards apply to state agency content, including, but not limited to, web-based applications, plug-ins, applets, on-line documents, forms and multi-media.

QUESTIONS AND ANSWERS

Q.  I have a question about the new Policy and Standards I am wondering if you can help me with? The OFT site says, "The purpose of this policy and the accompanying standards is to make New York State agency web-based intranet and internet information and applications accessible to persons with disabilities." I would like to know if "applications" means all application for example Oracle and Access? I have people here who say it only applies to Internet and Intranet applications and I would like to give them an answer. I say all applications but I need to hear it from someone else and then maybe they will listen to me.

A.  The Policy and Standards both apply to "...state agency content, including, but not limited to, web-based applications, plug-ins, applets, on-line documents forms and multi-media." In determining their applicability to your agency's applications, you might want to consider whether these applications are web-based in nature. Are they processed via a web server? Are they accessed via browser?

The intent of the policy is not that the actual software application (Oracle and Access) is accessible but rather that the interface to and output generated by these applications (HTML) are accessible. The interface and output screens must meet each of the standards.

From Patrick DeCastro, Office for Technology:

The Policy applies only to intranet- and Internet-based applications. For these applications, if the there is no specialized client required to use the application (that is, if you can access and use the application with just a browser), then it should be made accessible in accordance with the Policy and Standards.

If, however, an application is accessed through the Internet or intranet and then requires establishing a Citrix or similar type of specialized software connection to use it, the application would not fall under this Policy nor would any client-server type application. All exemptions and compliance schedules apply to applications in the same manner as other web content.

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Various Technical Questions on Standards

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001
Standard 4: Navigation and Links

4.1 Web pages will be designed to enable users to skip repetitive links.

4.2 All text links will indicate the destination or purpose

4.3 All state agency web pages will allow the user to return to that state agency's home page

4.4 Web pages will be designed to be device independent; for example, allow navigation with or without a mouse

QUESTIONS AND ANSWERS

Q1.  Standard 4.1 (Web pages will be designed to enable users to skip repetitive navigation links) — can I assume this means on every Web page we have to have a link at the top that says "skip to content?" Can it be "hidden" from people who can see, but audible to screen readers? (In other words, can we make it a hidden element in a style sheet.)

A.  If you have the same navigation choices on each page, then yes, you would need to have a "skip navigation" or "skip to content" link embedded in the page. You may also want to make this "skip navigation" link visible so that those with mobility impairments can benefit from it as well.

(See our discussion of Standard 4, which includes some examples of how to implement this technique.)

From Sharon Trerise:
It is best to make the "skip to main content" link visible so that people who have mobility impairments and are not using a mouse can utilize this feature. If the link is invisible and the use is only using a keyboard, and would not have a reason to be using a screen reader because they are sighted, then they would not know about the skip to content link. It can be very tiring for someone using for example a mouth stick to activate keys on a keyboard to have to Tab through numerous navigation links to get to links in the main body of the page. A visible skip navigation link makes it much faster and easier for them.

Other Useful Resources:

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001
Standard 7: Tables

7.1  All tables are required to have a summary attribute.

7.2  Tables used solely for formatting will specify that purpose using a summary attribute (e.g., summary="format" or summary="for layout only").

7.3  Tables with tabular data will use the scope attribute to identify both horizontal and vertical headings.

7.4  Row and column headers will be identified for data tables.

QUESTIONS AND ANSWERS

Q2.  Standard 7.3 — I'm not familiar with the "scope attribute." Can you provide further clarification and examples?

A.  The SCOPE attribute is used in table/row header cells to indicate how much table data the header applies to. Typically, they are used as <TH SCOPE="col">and <TH SCOPE="row">. To see an example of how the SCOPE attribute is used, see http://www.nysfirm.org/committees/access/resources/5-13-04/tables/goodsampletable.html and view the source code. You will see that the SCOPE attribute (as well as the ID attribute) is used for column and row heading cells.

From Sharon Trerise:
See the information on http://www.webaim.org/techniques/tables/2

Other Useful Resources:

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001
Standard 13: Forms

13.1  On-line forms will allow people using assistive technology devices to access the information, field elements, and functionality required for completeion and submission of the form, inlcuding all directions and cues.

13.2  A label element will be used for all form controls that do not have implicit labels.

13.3  Form elements will be in logical tab order.

QUESTIONS AND ANSWERS

Q3.  Standard 13.1 — I'm not familiar with how assistive technology devices operate with forms, and do not understand what I can do to be sure they can access it.

A.  When a screen reader accesses a form, it starts at the top left and reads to the right. If your form is not formatted with tables, this process is pretty straight forward, just as one would read a page. However, the scanning path is slightly different if your form is set up in tables.

If you use tables to format your form, the scanning path is still top left to bottom right. However, if you've formatted your table with the field labels in one column and the input elements in another, the screen reader cannot provide context for the input elements.

Forms with field labels in the row above the field are also a problem for screen reader users.

For more information on making forms accessible, please see http://www.nysforum.org/accessibility/resources/curriculum/forms/index.html. You will find a PowerPoint presentation that outlines some of the common screen reader problems with forms, how to fix them, and several examples of bad form design with suggestions on how they can be improved.

From Sharon Trerise:

For information on creating accessible forms, see http://www.webaim.org/techniques/forms/.

For information on different types of AT, see some of the information under the "Concepts" block of http://www.webaim.org/techniques/.

Q4.  Standard 13.2 — I'm also not familiar with this 'label' element that is referred to here. Can you provide further info/examples?

A.  When coding a form, it's good practice to associate a label with each input element. Here's a simple example of a related label/input element:

<label for="fname" accesskey="F"> <u>F</u>irst Name*:</label> <input type="text" tabindex="1" size="20" name="firstname" id="fname">

The first item here, the <LABEL>element, uses the FOR attribute along with the ID assigned to the <INPUT>element associated with it (note that the NAME attribute is separate and is assigned a different value from the ID attribute). This also demonstrates the use of the ACCESSKEY attribute, which is useful for individuals who cannot use a mouse. In this case, the ACCESSKEY for the First Name field is the "F", which is identified with an underline. The <INPUT>element also uses a TABINDEX attribute, which provides a logical tab order for users.

So, the short answer to your question is that the <LABEL>element allows you to associate label text with a form's input element.

For more label examples, please refer to http://www.nysfirm.org/committees/access/resources/5-13-04/forms/index.html and refer to the document source code.

From Sharon Trerise:
Same as above, see http://www.webaim.org/techniques/forms/.

Other Useful Resources:

Q5.  Standard 13.3 — How can I be sure form elements are in logical tab order? Would that be just adding the value of "tabindex" and the appropriate number in sequence to each input/select item?

A.  Yes, that is correct. Using the TABINDEX attribute on your form elements allows someone to complete the form by tabbing through it.

Q6.  Will there be training/informational sessions by the OFT for state agencies on these new policies and standards?

A.  We cannot answer for OFT, but we (the NYS Forum's IT Accessibility Committee) have designed a curriculum for use in teaching accessible web design, which we presented in May in Albany. We are actively seeking opportunities to present the training again, either as a full-day session or as a series of concentrated topic-specific sessions. We are also seeking volunteers to use our curriculum and act as trainers to provide the training to others.

Please check the NYS Forum for Information Resource Management web site http://www.nysfirm.org/committees/access/ periodically for announcements about upcoming training opportunities. There are also many resources included on the Accessible Web Sites materials that our Committee has posted on the Forum's site. See http://www.nysfirm.org/committees/access/resources/5-13-04/.

From NYS Mandatory Technology Standard No. S04-001:
Scope

The following mandatory standards apply to state agency content, including, but not limited to, web-based applications, plug-ins, applets, on-line documents, forms and multi-media.

Definitions

State Agency — Will have the same meaning as defined in Executive Law §205(4). This will mean any department, board, bureau, commission, division, office, council, committee, or officer of the state. Such term shall not include the legislature or the judiciary.

From NYS Technology Policy No. P04-002:
Definitions

Undue Financial or Administrative Burden — will mean significant difficulty or expense. In determining whether an action would result in an undue burden, state government entitles must consider all resources available for use in the funding and operation of the service, program, or activity

Compliance

Each state agency, or its designee and/or contractor, will prior to posting any content validate the content's accessibility for persons with disabilities against NYS Mandatory Technology Standard S04-001, Accessibility of State Government Web-based Intranet and Internet Information and Applications, and any other applicable New York State Technology Standards regarding accessibility for persons with disabilities.

Each state agency will annually validate the accessibility of their content for persons with disabilities, and develop a plan of correction to address that state agency's content that does not comply with this policy and NYS Mandatory Technology Standard S04-001, Accessibility of State Agency Web-based Intranet and Internet Information and Applications, and any other applicable New York State Technology Standards regarding accessibility for persons with disabilities. Each state agency will maintain all documentation required pursuant to this policy, and make it available upon request to OFT.

If making specific content (e.g. an application or document) accessible in compliance with this policy would cause a fundamental alteration in the service, program, or activity, or would result in an undue financial and administrative burden such content may be exempt from this policy. Any state agency making a determination of fundamental alteration or undue financial and administrative burden under this policy will document such determination and maintain such documentation. In the event of an exemption, the state agency will identify the information or services subject to such determination on the relevant web page(s) and specify the alternative method for obtaining such information or services. Nothing in this policy alters a state agency's independent authority and responsibility to determine what constitutes a fundamental alteration or undue financial and administrative burden.

OFT may request to review any determinations of exemption from this policy. Such review may include, but is not limited to, review of the technical and business analyses, and other project documentation, technologies or systems which are the subject of this policy or any applicable standards.

Q7.  I know this question was asked with the onset of the first policy 99-3 in 1999/2000, but I never heard a definite response. As a SUNY campus, we allow our faculty/staff/students Web space on our servers for their own personal Web pages and organization pages most are not publicly available through our Web site unless they specifically request a link. Are we expected to patrol those pages as well, make them comply with these guidelines, and remove them if not? Or is that a local campus policy that needs to be addressed?

A.  Please keep in mind that we are NOT the "official" word on this, but the policy specifically addresses intranets as well as public web sites. It may not be reasonable to expect you to "patrol" student web pages. You could probably argue that such a requirement would pose an undue hardship (as defined in the policy, excerpted above).

However, as a matter of basic equality, faculty posting curriculum-related material for their students should be required to make it accessible to all of their students. If you inform your faculty and students about the policy and standards and make training resources (such as the web sites cited above) available to them, we expect most will make the right decision once they understand what the issues are. And the college might want to sponsor some training, given the potential lawsuit liability involved.

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Accessibility Issues with Scripts

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001:
Standard 12: Scripting

12.1  If web pages utilize scripting languages to display content or create interface elements, the information that is provided by the script will be identified with functional text that can be read by assistive technology devices.

12.2  Event handlers used in any script will be device independent. Device-independent event handlers will be used instead of event handlers that require a specific input device (e.g., mouse). If a generic event handler is not available, more than one device-specific event handler will be used.

12.3  The use of "onDBLClick" event will not be allowed.

12.4  A mechanism (e.g., a text notice — the following link will bring you to a new browser) will be in place to alert the user prior to the opening of an additional web browser, pop-up window or a redirect that disables a browser's back button.

12.5  All documents with client side scripting will provide equivalent content or functionality via a noscript element.

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001:
Standard 14: Downloadable/Embedded Objects

14.1  When downloadable documents (e.g., word processing documents, spreadsheets, Portable Document Format [PDF], Java applets, etc.) are used, a link to accessible HTML or text version(s) will be made available.

14.2  When hardware, software and assistive technology devices are controlled by a state agency downloadable documents (e.g., word processing documents, spreadsheets, Portable Document Format [PDF]) available through an intranet or extranet will be allowed.

QUESTIONS AND ANSWERS

Q1.  The accessibility policy mandates that we provide the same functionality on forms for people with no JavaScript. My JavaScript is mainly form validation. Do they want us to provide server-side form validation?

A.  Server side validation would eliminate the potential problem with users not able to run or not allowing JavaScript. This is not just a disability issue. Think about web-enabled cell phones and PDAs. And those dozen people out there still using WebTV.

Q2.  I can do this in Lotus Notes web forms but not using FormMail. In that case the user would be submitting an unvalidated form? Does that fulfill the requirement or will I have to replace my FormMail forms with a database form?

A.  If you look under the "Compliance" section of the policy, the third paragraph discusses situations in which making items accessible causes an undue burden or a fundamental alteration to the service. These are determinations that agencies make and document on their own. If we are interpreting what you wrote correctly, you're presently using something that just generates an e-mail message, after checking to be sure that certain fields are filled in, or filled in with an acceptable value.

It sounds (although again, I can't be sure) that the alternative might require a back-end database to process and a server-side scripting language to validate the output. If that is the case and this environment is not available to you already, I think that this might be one of those circumstances where a NOSCRIPT alternative might be to post a contact phone number that the individual can call to get a copy of the form or have someone help them fill out the form (e.g., if the person has visual impairments).

On the other hand, if the environment is available and the changes required would be minimal, I would advise moving to server-side scripting for validation.

Q3.  How do you turn off JavaScript in your browser for testing?

A.  In Netscape 7, it's Edit/Preferences and then click on the "Advanced" heading. There are choices on that page to "Enable Java" and "Enable native object scripting." You would un-click both checkboxes. Expand the "Advanced" heading to display the "Scripts & Plugins" item. Click on it and you'll see, at the top of the window, a check box for "Enable Javascript." Un-check that box and restart your browser. Scripts should now be disabled.

In MSIE, I believe it's under Tools/Internet Options/Security/Custom Level. There are also Java options under the Advanced tab list.

Other Useful Resources:

Q4.  Do you have to have a special browser that does not support JavaScript that you use for testing?

A.  There is no requirement to have a special non-JavaScript browser. You can try Lynx, which is a free text-only browser. That's a good choice for accessibility testing in general, as it only provides the text equivalent of your page.

Q5.  We use JavaScript to authenticate users on our intranet. Do the new standards prohibit this?

A.  Mandatory Technology Standard 14.2 applies here. Since the JavaScript authentication is part of an application available on your intranet, presumably you're able to ensure that all of your audience has JavaScript-enabled browsers.

Q5.  I went through the OFT Web Accessibility standards. I'm wondering why there is a standard that says we should not use scripting. The Standard says its purpose is to make sites accessible to persons with disabilities. We use scripting extensively but our web pages pass the Bobby test and can be read by JAWS. We take accessibility very seriously and have worked with Jeff Bennet [sic] to insure that our pages are accessible.

I understand that if a person has scripting turned off, our site will not work whether you are disabled or not but it is not an 'Accessibility' issue per say [sic]. I'm trying to assess how our web pages meet the OFT standard and need to report to exec management. We can't do away with scripting without redoing all of our web pages which would be quite a burden.

A.  The accessibility aspects of using client-side scripting on your public web site are more problems of having no control over what your visitor has to work with. That can have a negative impact on the individual's ability to access or interact with your web site.

Some users now turn scripting off to avoid malicious code; some others may be visiting your site with a web-enabled PDA or web-enabled cell phone with no scripting capability. Some users might even be using Web TV (yes, it's still out there!), or some other user agent that isn't capable of doing independent processing.

You also can't control which screen reader/OS/browser combination a visually impaired person will be using, either. Jeff Bennett will be the first to tell you that he's using the latest version of Jaws. Jaws is extremely expensive, and not all screen reader users are able to stay current with the software. So what works for Jeff might not work for your next visually impaired user.

There are issues for people who have mobility impairments with rollovers, fly-out menus, etc. Also, there are issues with people using older technology, again, which you have no control over with a public site.

I guess the crucial question would be, what is scripting required for? Navigation? Calculators? (For example, we have a "NOSCRIPT" example of a calculator on the web site at (http://www.nysfirm.org/committees/access/resources/5-13-04/scripting/index.html) that demonstrates one way of providing the same service to someone who cannot use scripting.) Authentication? What part of the user's experience with the site would be negatively impacted if they did not use scripting? What alternatives would there be for someone with a visual impairment who did not have a computer to acquire the same information or services? How would they be able to get the same information? The same services?

What the Standard is requiring is that your web site provide the same information/services to people who, for whatever reason, cannot use scripting as is available to those who do use scripting. There are options for doing that — for example, UsableNet has a product which will provide text-only pages on the fly (the LIFT Text Transcoder,http://www.usablenet.com/products_services/text_transcoder/text_transcoder.html). You can contact UsableNet for a demonstration.

Agencies are responsible for the decision as to whether or not remediation of a non-complying web site constitutes an undue burden, and all they need to do is document that decision. However, such documentation may not be a defense against a lawsuit, and any new pages, per the policy, are required to comply.

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IFRAME Element

RELEVANT STANDARD AND POLICY TEXT

From NYS Mandatory Technology Standard No. S04-001:
Standard 8: Frames, Context and Orientation

8.1  If frames are used, a noframes alternate will be provided.

8.2  If frames are used:

8.2.1  Each frame must be identified with a descriptive title attribute that describes the purpose of each frame(s) and how they relate to each other.

8.2.2  For title text greater than 150 characters a longdesc attribute will be used.

Q.  I have been asked if "IFrames" [the IFRAME element] are acceptable with the new policy. Can you let me know?

A.  Since that's not technically a frame, it should be okay as long as you specify the loose DTD. It would probably be helpful too if you noted in advance that you're using them so that it won't confuse someone using a screen reader. I'm not sure how they display on web-enabled phones or PDAs, so I'm not sure whether they'd be a problem there.

From Jeff Bennett, OFT (a Jaws user):
This web site [URL provided by the person posing the question, which contained an example of the IFRAME element] poses no problems with Jaws. The Iframe is read by the Jaws screen reading software program.I believe that Google uses Iframe, and Jaws also has no problems with it.

I would strongly suggest that labeling the frame with meaningful text should be done so users will know what the frame represents.

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Questions on Deprecated Elements

RELEVANT STANDARD AND POLICY TEXT

From the NYS Mandatory Technology Standard No. S04-001:
Standard 3: Document Structure

3.1   Web pages will be created using the most current web document specifications (e.g., HTML, XML, XHTML).

3.2  All web pages will include a valid document type declaration (DTD).

3.3  The use of deprecated elements or attributes is not allowed (e.g., the usage of BLOCKQUOTE element to indent text is deprecated).

3.4  Web pages will be created using style sheets to achieve formatting and stylistic effects whenever possible. When style sheets are utilized the web pages must convey all relevant information in an accessible manner if the style sheet is disabled for any reason.

3.5  All natural language usage will be clarified using the Lang attribute when the written language is not English.

From NYS Technology Policy No. P04-002
Compliance

Each state agency, or its designee and/or contractor, will prior to posting any content validate the content's accessibility for persons with disabilities against NYS Mandatory Technology Standard S04-001, Accessibility of State Government Web-based Intranet and Internet Information and Applications, and any other applicable New York State Technology Standards regarding accessibility for persons with disabilities.

Each state agency will annually validate the accessibility of their content for persons with disabilities, and develop a plan of correction to address that state agency's content that does not comply with this policy and NYS Mandatory Technology Standard S04-001, Accessibility of State Agency Web-based Intranet and Internet Information and Applications, and any other applicable New York State Technology Standards regarding accessibility for persons with disabilities. Each state agency will maintain all documentation required pursuant to this policy, and make it available upon request to OFT.

If making specific content (e.g. an application or document) accessible in compliance with this policy would cause a fundamental alteration in the service, program, or activity, or would result in an undue financial and administrative burden such content may be exempt from this policy. Any state agency making a determination of fundamental alteration or undue financial and administrative burden under this policy will document such determination and maintain such documentation. In the event of an exemption, the state agency will identify the information or services subject to such determination on the relevant web page(s) and specify the alternative method for obtaining such information or services. Nothing in this policy alters a state agency's independent authority and responsibility to determine what constitutes a fundamental alteration or undue financial and administrative burden.

OFT may request to review any determinations of exemption from this policy. Such review may include, but is not limited to, review of the technical and business analyses, and other project documentation, technologies or systems which are the subject of this policy or any applicable standards.

QUESTIONS AND ANSWERS

Q1.  Regarding standard 3.1: The use of deprecated elements or attributes is not allowed (e.g., the usage of BLOCKQUOTE element to indent text is deprecated). Being depreciated [sic] in text, how are we suppose to indent?

A.  You can indent non-quote text through styles — either via style sheet or inline style (e.g., <p style="margin-left: 100px; margin-right:100 px; ">).

From Raydeen Gallogly, Department of Health:
Another way of achieving the same effect as the BLOCKQUOTE element is to use the PADDING element:
<DIV style="padding: 0 0 0 2em; ">.

The STYLE attribute uses the "box model," and start at the top border. In this example, the top padding would be 0, the right padding would be 0, the bottom padding would be 0 and the left padding would be 2em.

Q2.  I've taken a look through div and p commands but don't see anything that will commit this formatting short of a table or blank spaces (which, even then, is a sloppy way of getting a one inch push over).

A.  Here's an example of how you could do this within a paragraph. Let's assume that your page margins are 10% on either side:

<p style="margin-left:15%; margin-right:15%;">

It would work the same way within a DIV element.

Q3.  Looking at the table on the w3 site the BLOCKQUOTE tag its self [sic] says it is not being depreciated [sic], though the formatting on using it has changed (http://www.w3.org/TR/REC-html40/struct/text.html#edef-BLOCKQUOTE). Was this being used as an example with no merit to it, was there a mistake on this, or is there still another way to indent chunks of text? (other then tables and blank space).

A.  The BLOCKQUOTE element is NOT being deprecated. What the policy is discouraging is the practice of using structural elements for non-structural uses (e.g., formatting only). In other words, it is still correct to use the BLOCKQUOTE to denote a lengthy quoted passage from another source. It is not correct to use it for any other reason.

Q4.  I understand that we are to adhere to the current standard and avoid deprecated elements and attributes. However, according to my web stats, a number of my visitors are using browsers too old to support styles. I use the ALIGN attribute in many of the elements to manage test alignment. I incorporate the style method of controlling alignment in my style sheet and implement the stylesheet on my web page, can I still incorporate the deprecated attributes to accommodate my visitors using older browsers?

A.  Yes, including the deprecated attributes should be acceptable under these circumstances. Just be aware that your page may not validate correctly because of this anomaly, and that you should document this exception to the policy for your records, per the Compliance section of NYS Technology Policy P04-002.

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Questions on Tools to Create Accessible Surveys

Q.  Does anyone have recommendations to make for web development software which generates code that is OFT P04-002 compliant? We are currently evaluating web-based survey software for a future purchase and would also be interested in any other development software that may have been useful for other agencies.

A.  No answer to this question yet, or at least no answer posted to the list.

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Request for Code Examples to Support Policy/Standards

Comment:  I am please [sic] we have standards, but wanted to express the desire for greater technical documentation. The current standard leaves, I believe, too much latitude.

For example, from Standard 3:
"Web pages will be created using the most current web document specifications (e.g., HTML, XML, XHTML)." We should pick one, tell users why, and give a snippet of code example. HTML is dead, not "the most current web document specification", why would it be recommended?

Each item also needs code to illustrate the point and provide reference to the NYS standards.

A.  We can appreciate some of your comments, and the NYS Forum's IT Accessibility Committee is working to provide such support materials for the policy. We'll include your ideas in the list of requests for supporting material that we're already compiling.

The policy and standards, however, are OFT products, and improvement suggestions for those documents should be directed to Patrick DeCastro (patrick.decastro@oft.state.ny.us) in OFT.

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