DECIDING HOW TO TEST FLASH
AGAINST THE SECTION 508 E&IT ACCESSIBILITY STANDARDS
Presenter(s)
Bruce Bailey
ED OCIO ITOMS Assistive Technology Program
400 Maryland Avenue SW, FB6 BC1O1
Washington, DC 20202
Day Phone: 202—377—4932
Fax: 202—401—8469
Email: bruce.bailey@ed.gov
Presenter
#2
Don Barrett
ED OCIO ITOMS Assistive Technology Program
Washington, DC 20202
Day Phone: 202—377—4079
Fax: 202—401—8469
Email: dcn.barrett@ed.gov
Follows
is one analytical response to the above summary quandary, hut that was only the
beginning. This session will present ED’s process and internal dialog with
trying to apply the 508 Accessibility Standards to Flash in actual practice.
Flash
objects are web applications so use the full §1194.22 criteria, including
1194.22(m). As written, 1194.22(m) invokes the criteria §1194.21(a) through (1)
for each instance of Flash content.
Taken
at plain face value, Flash falls into the category of internet information and
applications” (1194.22). Many of applicable (e.g., style sheets, image maps)
but several are
text equivalents, multimedia).
One
concern with sufficiently complex Flash content is there may be controls or
other
elements that are not explicitly addressed, but that is only the case if
§1194.22(m) is assumed not to be applicable. Such an assumption would be a
mistake. This error may be caused by too literal interpretation, a lack of
understanding, or applying a too contemporary definition or artificial
segmentation to the terms involved and the phrase used: “applet, plug—in, or
other application.”
At
the time the Section 508 E&IT Accessibility Standard were. developed, and
the W3C WAI Web Content Accessibility Guidelines )WCAG1) before that, there was
not the clear distinction between web applets, plug-in, and applications that
some people feel now. The use of the whole phrase, and not the atomic
individual terms, was deliberate and meant to address the (then) current and
(now) future technologies.
Two
examples illustrate the above fact: (1) Macromedia Shockwave and Flash were
known technologies at least as early as 1998 and were explicitly considered and
intended to fall into the category of web applets, plug—in, and applications.
(2) Java at the time, and even now under some circumstances, requires that a
plug—in be preloaded. This is exactly the same situation as with modern
instances of Flash and there is no confusion that Java is covered by
§1194.22)m).
Some
Flash content is fairly trivial) essentially being just a movie or animation)
and a review against the criteria associate with §1194.22(m) will be very quick
and easy. In these circumstances, accessibility is ensured by the other 1194.22
criteria.
Often,
a Flash object is the only significant content on a particular web page. As a
reminder, all web content on every page, including html containing a Flash
object (and not just the Flash object alone), must be reviewed against the
§1194.22 standards.
The
Subpart C Functional Performance Criteria are meant for technologies or
components for which there is no specific provision in Subpart B Technical
Standards. The Functional Performance Criteria are wholly compatible with the Technical
Standards and may he helpful to consider as a double check. This step is not
necessary for Flash, nor for other technologies or components for which there
is a specific provision.
The response to this question is intended to promote a better understanding of the requirements of Section 508 and its implementing regulations. This clarification is purely informational and neither creates new policies nor changes existing policies.
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