Please note: This document may be freely distributed provided it remains
intact with the copyright notice.
Carol Boyer
Project Associate
RESNA Technical Assistance Project
DRAFT
WHITE PAPER: PDF AND PUBLIC DOCUMENTS
By Janina Sajka
Director, Technology Research and Development
American Foundation for the Blind
Governmental Relations Group
820 First Street, N.E., Suite 400
Washington, DC 20002
phone: (202) 408-8175
email: [log in to unmask]
and Joe Roeder
Senior Access Technology Specialist
National Industries for the Blind
1901 N. Beauregard Street
Suite 200
Alexandria, VA 22311-1727
phone: (703) 578-6524
email: [log in to unmask]
Published by:
American Council of the Blind
American Foundation for the Blind
National Industries for the Blind
Copyright 2002, all rights reserved
This document may be freely distributed provided it remains intact with the
copyright notice.
EXECUTIVE SUMMARY
While we applaud Adobe's efforts to make Portable document format (PDF)
more accessible, the limitations of existing practices and technological
capabilities available to end-users who are blind or otherwise print
disabled render documents and forms in PDF inaccessible to many members of
the public. This white paper explains the problems that surround the use
of PDF documents and forms in light of the section 508 standards and draws
the conclusion that alternative, accessible formats must always accompany
PDF versions of information and data that are made available to the public.
INTRODUCTION
The Workforce Investment Act of 1998 (Public Law 105-220, 112 Stat 936
codified as: Section 504 of the Rehabilitation Act, 29 U.S.C. § 794d)
amended Section 508, which covers federal government use of Electronic and
Information Technology. Section 508 requires (among other things)
"individuals with disabilities who are members of the public seeking
information or services from a Federal department or agency to have access
to and use of information and data that is comparable to the access to and
use of the information and data by such members of the public who are not
individuals with disabilities".
PDF is a popular format and is valued as a means of ensuring consistent
appearance across computer platforms. However, the problems of access by
people who are blind or otherwise print disabled and the mandates of
section 508 lead to the conclusion that documents in alternative,
accessible formats must always accompany PDF for information that is
intended for the public. The views expressed in this White Paper represent
both our professional, expert opinion and the views of a sizable population
of the public who are blind or visually impaired regarding the use of PDF
files. This white paper examines the serious difficulties that many
continue to have while trying to access public information that is made
available only in PDF or other proprietary formats.
THE PROBLEMS WITH PUBLISHING GOVERNMENT INFORMATION USING PDF
Adobe has made changes to their products and developed authoring
guidelines for accessibility; nevertheless, many people who are blind or
otherwise print disabled continue to experience significant difficulty with
PDF files. This appears to be a combination of several factors, including:
* the prevalence of authoring tools that cannot produce accessible PDF
* the misuse of authoring tools that could produce accessible PDF
* authoring security features that block access to PDF
* the lack of accessible PDF support for all OS platforms and asistive
technologies
* usage difficulties even with the accessible tools
Lets examine each of these problems in more detail.
THE PREVALENCE OF AUTHORING TOOLS THAT CANNOT PRODUCE ACCESSIBLE PDF
Accessible authoring is not enforced by all available authoring tools. In
fact, some PDF authoring tools simply do not support Adobe's accessibility
guidelines. Without a massive effort to upgrade these tools and educate
authors on how to use them or a systematic approach to prevent the use of
these tools to create documents intended for public access, the government
will continue to produce thousands of pages of inaccessible documents.
THE MISUSE OF AUTHORING TOOLS THAT COULD PRODUCE ACCESSIBLE PDF
No tool can guarantee the creation of accessible documents. Authors must
understand and follow the Adobe guidelines for creating accessible PDF to
ensure the creation of accessible PDF. A systematic program of outreach
and education for all government employees involved on document production
seems necessary. Otherwise, the investments in the accessibility tools
will be wasted. To date, we see no evidence of an outreach and education
program sufficient to meet this need.
AUTHORING SECURITY FEATURES THAT BLOCK ACCESS TO PDF
Adobe's own products allow authors to prevent access by screen readers
through the use of document security features. The common use of 40-bit
encryption effectively blocks any access by persons using assistive
technology. While 128-bit encryption with the latest version of the
accessible Acrobat reader corrects this problem, there is an option that
allows access through the use of assistive technology. This option is
turned on by default, but authors must not uncheck this option or access
will again be denied.
Accessibility is hampered by other security options, such as the blocks
against exporting or printing documents. People sometimes make personal
print copies of documents in order to add comments and annotations. People
who are blind or visually impaired may do the same, making hard copy in
braille or large print. The document security features, by preventing
direct access to the text, block any media conversion and deny comparable
access to information and data by individuals with disabilities.
THE LACK OF ACCESSIBLE PDF SUPPORT FOR ALL OS PLATFORMS AND ASISTIVE
TECHNOLOGIES
Presently, Adobe distributes end user agents which incorporate
accessibility support for 32-bit Windows environments. Adobe also
distributes PDF readers for other platforms, but without accessibility
features. Many persons who are blind or otherwise print disabled use other
operating environments (such as Macintosh and UNIX) and they are
effectively without access as defined in Section 508. The principle
attraction of PDF is that it is platform neutral, allowing documents to be
created with the confidence that they can be printed with identical
appearance from any computer. The lack of access for some disability
groups calls this notion of platform neutrality into question and should be
a concern for government procurement officials until this situation is
corrected.
The accessibility solutions Adobe offers for 32-bit Windows environments do
not function with the full range of assistive technologies used by persons
who are blind or visually impaired. However, the cost to the consumer to
upgrade or switch their preferred assistive technology is not
insignificant. This is a serious social concern because current federal
programs only cover the assistive technology needs of a small percentage of
the disability population. According to a recent NIH report, the number of
citizens who are blind will double over the next 2 decades as the
population ages. How will these retirees, who receive no particular
support for computer assistive technology, access information from
Medicare, Social security and other public agencies if the documents are in
PDF?
Adobe offers web and email document conversion service alternatives
(reference Access.adobe.com/onlinetools.html). This service is not directly
incorporated into any web browser agent, assistive technology product, or
Adobe's end user agents and it will not get around the author security
encryptions described earlier. This service can only be used if the PDF
document has a web address and if the consumer can locate the URL. Nearly
all web sites do not mention this service so consumers are expected to find
and use it on their own.
This lack of support for the range of access technology and operating
systems in common usage is not " comparable to the access to and use of the
information and data by such members of the public who are not individuals
with disabilities".
USAGE DIFFICULTIES EVEN WITH THE ACCESSIBLE TOOLS
Many people who are blind or otherwise print disabled continue to have
difficulty using PDF even when they have the accessible
technology. Finding, downloading and installing third party plug-ins can
be beyond the technical capabilities of many users. Whether due to
problems with the end user agents, the assistive technology, the large
number of inaccessible PDF documents stillin the public domain or the lack
of skill or training of the consumer, the result is considerable
frustration and, ultimately, lack of comparable access.
Employees who are blind or otherwise print disabled may have support from
their employers to deal with these problems, but many IT support services
are unfamiliar with assistive technology and tend to blame the asistive
technology for misbehaving when it is the accessibility obstacles in the
applications that are at fault. The consequence is that the person with
the disability is unable to access information independently unless, and
until, someone can locate and implement the solution that harmonizes the
separate pieces of technology needed simply to read documents. Also,
nearly 70 percent of persons with disabilities are unemployed and thus do
not have the technology staff of an employer to assist them.
CONCLUSION
The many problems associated with accessing PDF documents constitute a
burden on the person with visual impairments that is significantly greater
than the burden placed on non-disabled persons with regard to PDF files.
We recognize the investment in products designed to produce and work with
PDF files and we appreciate the efforts that Adobe has made to try to
address the accessibility issues. We also applaud the efforts of Adobe to
embrace XML technologies that provide for open source, non-proprietary
formats. We call on Adobe and other developers to commit to accessible XML
practices, as identified by the Xml Accessibility Guidelines (XAG)
currently in public draft (reference
http://www.w3.org/TR/xag.html). Proprietary technologies should be avoided
when they may have certain visual benefits but add little to the core
information content and create accessibility obstacles for public
documents. We strongly urge that any file formats (especially proprietary,
non-consensus formats) employed by the government be thoroughly evaluated
by representative focus groups of consumers, including persons with
disabilities, and that all accessibility problems be appropriately
addressed before continuing to generate public documents in such
formats. By far, the preferred approach is for the government to use open,
concensus-based, non-proprietary formats. Today, well designed web
content, authored in html, is meeting the test of
accessibility. Accessible XML holds out the promise of expanding
information access for persons with disabilities to where it will become,
not a technology wonder, but a common, everyday experience.
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