The Accessibility Ecosystem Proposal
To say that the route to almost all essential services is through digital systems is stating the obvious. Despite this reality, more than twenty-five years of regulations requiring accessible digital technology, a plethora of guidelines and resources to support accessibility, and a thriving industry checking and repairing inaccessible websites, people who require alternative ways to access digital systems face ever-multiplying barriers.
Digital accessibility standards have been legislated in jurisdictions around the globe, many with deadlines to achieve “full accessibility,” backed by monetary penalties and even prison sentences for non-compliance. Despite this, relative digital inclusion has not substantively changed. Given the critical necessity of digital inclusion to access essential services, the situation is far more dire than twenty-five years ago. Digital disparity has only increased.
At the crux of the challenge is how to regulate the digital. To be enforceable, our current laws and standards need to be simple, static and testable. Each of these qualities is problematic when regulating digital accessibility. Accessibility barriers arise because of a diversity of needs. Simple rules ignore that diversity, causing exclusion. Digital systems are the opposite of static, change is exponential, not linear, setting up a losing battle between innovation and accessibility regulations. An accessible user experience for a huge spectrum of products and individual needs is difficult to quantify and measure, resulting in “compliant” systems that are unusable. “Black box” systems, including automated decision systems, are impervious to testing but make more and more life-altering decisions that negatively impact people who are exceptional.
In Ontario, we acknowledged that the system to regulate the digital was broken and we needed to try something different. A group of us considered how to improve the failed design of provincial regulations. We proposed an alternative strategy that we called the Accessibility Ecosystem (aka Phase 2). The goals were to broaden participation in the effort, keep pace with changes in digital systems, encourage and integrate innovations in accessibility, provide a way for people facing barriers to provide input, and rethink how we measure progress and success. We have included the proposal below, along with explanatory infographics. This proposal received a positive public review in 2020. No action has been taken since to implement the proposal.
Richard Donovan is currently tasked with reviewing the Accessibility for Ontarians with Disabilities Act (AODA). This is an opportunity to make your views heard about the success of the AODA in the digital space and to propose alternatives. What do you think of the proposed Accessibility Ecosystem? Do you have proposals for how to improve the system?
Declaring a breakdown — a call for a new way forward
During their deliberations and interactions with constituents, it became clear to the members of the committee that the current approach to regulating the accessibility of information and communication in Ontario is flawed, and if the approach does not change, the policy aims of the regulations will not be fully achieved. There was consensus that reliance on a wholly prescriptive standard that is not responsive to changes in technology and its application is a fundamental shortcoming of the current approach. There is also a need to enhance the active participation of those who build and use technology daily both to understand and to mandate the application of technologies in ways that maximize economic and social participation for Ontarians with disabilities.
A new model for accessibility regulation
As mentioned at the beginning of this report, the Digital Inclusion Technical Subcommittee was asked to think about some very broad questions, including what accessibility means in today’s digital world, and whether the current regulatory system is really able to deliver the desired outcomes.
In the process of considering the broader questions, the subcommittee had thorough discussions which formed the basis of a broad new proposal, presented here in this second chapter of the report, to improve access for Ontarians with disabilities: The Accessibility Ecosystem model.
The Accessibility Ecosystem model responds to what the subcommittee perceives as weaknesses in the current regulatory model and introduces a response that is better suited to a world of rapidly changing technology and business models. The committee also recognizes the need for a more responsive model that is focused on equipping obligated organizations with the knowledge and tools to best serve Ontarians on the front lines of business and government service delivery.
Government’s broader use of the Accessibility Ecosystem model
Though the application of the Accessibility Ecosystem is proposed first for digital content and its applications, this model may prove to be more broadly applicable to other standards.
The Accessibility Ecosystem is presented at a very high level, both to maximize compatibility with various requirements and in recognition that more in-depth research and development needs to be done by government and relevant stakeholders to take this model to the next step.
The committee proposes:
- That the government adopt and operationalize phase 2 as the regulatory approach to accessibility in Ontario. The committee is aware that this approach will continue to evolve. The intent of the committee is to have phase 1 implemented in parallel with phase 2. Phase 1 should occur during the transition to phase 2.
- Note: The infographics and additional materials (for example, long descriptions) have been submitted alongside this report after the appendices.
Timeline: Two years from submission of the final recommendations for phase 2 to be fully implemented.
What this document contains:
- Committee investigates what the current regulatory model seems to be missing.
- The Accessibility Ecosystem model is proposed as a solution, and its advantages are listed.
Laws, Trusted Authority, Community Platform and Compliance
The Accessibility Ecosystem, listed and explained:
- How is the new model better?
- A look at what sets the Accessibility Ecosystem apart.
- Cost, funding and sustainability
- An explanation of how, far from being an onerous cost, the new model is actually a shrewd investment.
The subcommittee’s starting point was an acknowledgement of the fact that our understanding of accessibility has evolved since the act was drafted and implemented. People with disabilities are as diverse in their needs and perceptions as people without disabilities, and perhaps even more so. For that reason, one-size-fits-all approaches to accessibility often don't work. In addition, it is now understood that even the word "accessible" does not have a single definition and is more related to technical requirements than a person’s demand for a great experience. What is meant by accessible depends on the person and his or her goals and context. What this means is that accessibility can only be achieved through a process of inclusive design – one that recognizes that all people are variable and diverse, and our products and services must make room for a wide range of human differences.
It is also critical to understand that even if all the specified goals of the act were to be achieved by 2025, it would not be a case of mission accomplished. There would still be people with disabilities for whom Ontario is not accessible. Our society is changing all the time. New barriers to accessibility are constantly emerging, as are new opportunities for greater accessibility. The subcommittee concluded that creating an accessibility check list, however comprehensive, to address the needs of all Ontarians with disabilities is an impossible task. People not represented in the deliberations would likely be left out, unanticipated new barriers would not be considered, and new technologies that might be used to address barriers would not be leveraged. At that point, the subcommittee decided it was time to take a critical look at the current act and regulation model. What it found was five areas in which the current model is simply not meeting the needs of Ontarians with disabilities:
In the current model, the primary participants are the participating organizations and the provincial government compliance authority. The relationship is one of obligation and policing. The primary questions from obligated organizations are about what is required of them, and whether there might be exemptions. Their primary motivation for complying is avoiding penalties and/or reputational damage.
It is hard to blame organizations for this approach, because accessibility and inclusive design have traditionally been framed primarily as something that organizations must be legally compelled to do, rather than something that is also in their best interests. The fact is however, that there is significant evidence showing that inclusive design is in the interests of business. Research has shown that an organization that attends to inclusive design and accessibility, for customers and employees with disabilities, will garner economic, social and innovation benefits. There are both micro and macro-economic gains to be made for the participating company and for Ontario society as a whole, but that case is not being made clearly or often enough.
The current model also does not harness the significant energy, knowledge and support of many community stakeholders who are deeply committed to accessibility. These include:
- students, many of whom participate in projects such as “mapathons,” design challenges and curriculum-based assignments
- Ontario’s world-leading cluster of researchers specializing in accessibility and inclusive design
- non-obligated organizations that recognize the importance of accessibility without being compelled to comply by law
- persons with disabilities and their families or support communities
- professional organizations
- community volunteers
- civil society
The efforts made by these people, groups and organizations are significant, but there is currently no real way to collect, harness and showcase their contributions or quantify their economic impact.
Other than the five-year review, there is currently no mechanism for keeping the standards up to date. This is especially problematic when it comes to information technology systems and practices, which are changing at an accelerating rate and affecting more and more essential aspects of our lives. Barriers to accessibility emerge suddenly, and if they are not dealt with immediately they can spread and multiply. Opportunities for greater accessibility appear, but if they are not quickly seized they can disappear. In this fast-moving world, accessibility standards quickly fall out of date, and the system is not equipped to deal with that.
Ontario is home to many innovators, many of whom have turned their ingenuity to addressing accessibility challenges. Unfortunately, there is currently no easy way for these innovators, including obligated organizations or other stakeholders, to propose new and better strategies for addressing barriers. The relationship is strictly one way, with the act essentially telling organizations what to do. This removes an incentive to innovate in accessibility.
Review and feedback
Legislation often triggers new demands for services. The act has prompted the growth of the accessibility services sector in Ontario. Training, evaluation, design, development and remediation services are now effectively growth industries in Ontario. However, these businesses and services range in expertise and quality, and there is currently no mechanism for reviewing or providing feedback about them.
There is currently no way of tracking progress toward accessibility goals. No progress indicators have been established, making it extremely difficult to determine how well accessibility standards are working.
Based on all of this, the subcommittee concluded that an entirely new approach needs to be taken. This approach must move from presenting accessibility as an obligation to be borne by a specific group of organizations in Ontario, to a process that all Ontarians participate in, and benefit from. This is what the committee means when it refers to a culture change, and the vehicle for that culture change is the proposed new "Accessibility Ecosystem."
The Accessibility Ecosystem
Fundamentally, the Accessibility Ecosystem is a new way of organizing the standards within the regulation. Initially, it is being proposed for the Information and Communication Standards, though the committee believes that it could one day be the framework for the full set of regulation standards. The primary aim of the Accessibility Ecosystem is to encourage organizations to see the act less as an obligation than as something in which they participate for their own benefit, and the benefit of all Ontarians. For that reason, the first step in implementing this new system, however symbolic, would be to rename "obligated organizations" as "participating organizations." This reframing will also provide a way to keep improving and updating how we address barriers faced by persons with disabilities in Ontario, up to and beyond 2025.
Frame 1: Accessibility Ecosystem
A diagram representing the Accessibility Ecosystem using the visual analogy of a sailing ship in the water.
From obligation to participation: The AODA Accessibility Ecosystem is like a ship in an unpredictable and changing global and technical context. The laws provide the compass, the Trusted Authority steers the course, and the community uses the Community Hub to provide the ideas, tools and resources needed to make the journey.
Description of diagram
The sails of the ship are being blown by wind representing culture change and innovation.
The water has a shark fin representing barriers and fish jumping out of the water representing opportunities.
The ship represents the Ontario community and contains the three parts of the Accessibility Ecosystem: the Accessibility Law, the Trusted Authority and the Community Hub.
The Accessibility Law and Trusted Authority are two separate parts connected by a double helix that has the following phrases printed on it: “Needed Adjustments”, “How to Achieve It” and “What Must Be Achieved”. The Community Hub sits beside Trusted Authority outside the helix with arrows pointing into the helix.
Subtext for the three parts of the Ecosystem further explains each of the Ecosystem’s part. This subtext is as follows:
Measures that bring about long-term culture change
Functional accessibility requirements that remain constant
Regulating overall process
Ensuring tools and resources are available
Responding to changes in context
Retiring outdated methods
Qualifying innovative methods
Community feedback and monitoring
Pooled resources and tools
Research and guidance
Innovative approaches to addressing barriers
The objectives of the Accessibility Ecosystem are as follows:
- keep up with changes in technology
- respond to new barriers
- respond to new opportunities
- respond to barriers not anticipated when the standards were written
- encourage and support organizations and the larger community in finding innovative ways to address barriers
- discourage the "us-them" attitude towards accessibility, where the interests of persons with disabilities are seen as counter to the interests of businesses
- encourage working together to make things more accessible to the benefit of everyone
- communicate that accessibility is a responsibility we all share
- show how accessibility and inclusive design are a good way to do business, and a good way to grow the economy and economic participation for Ontarians with disabilities
- reduce confusion about the regulations and make it easier to find tools and resources needed to comply with them
- provide clear, up-to-date, specific advice regarding how requirements can be met
- create the conditions and supports so that all Ontarians feel that they can participate in removing barriers
The proposed ecosystem has three interdependent parts. They support one another, and all play a role in telling organizations what they need to do to remove barriers and expand opportunities. The ecosystem as a whole provides the balance between legal compulsion and alignment with current technical practices. All three parts require funding and ongoing support. The three parts are the laws, the Trusted Authority and the Community Platform.
This is the least flexible part. The laws would establish requirements, but not specify how they must be met. The Laws include three types:
Functional Accessibility Requirements (FARd) (contained in appendix B of this report). These are requirements that are constant. They do not mention specific technologies, to avoid a situation in which a technology changes and evolves to the point where the requirement no longer makes sense. If organizations need help understanding how to meet the requirements, they are linked to acceptable methods of doing so by the Trusted Authority. These requirements are modeled on and harmonized with requirements adopted by both the European Union and relevant US accessibility laws. The functional requirements do not replace technical requirements but specify what they are trying to achieve.
Regulations regarding the policies of the ecosystem. These govern the Trusted Authority, the Community Platform and updates to the laws.
Regulations that support system-wide long-term changes and improvements in the accessibility of Ontario. These include:
- integrating education about accessibility in all education, starting as early as Kindergarten – Grade 12
- integrating accessibility into professional training for all professions that have an impact on products and services
- requiring accessibility when purchasing products and services, especially when spending public funds
- including people with disabilities in decision making and planning processes, and ensuring that mechanisms for participation are accessible
The Trusted Authority would be an independent group that provides ongoing oversight and support to the system of accessibility standards, in order to ensure that the system is performing as it should and accomplishing what it is intended to accomplish. The Trusted Authority would include people with a wide range of expertise, including lived experience with disabilities.
As implied by the name, the Trusted Authority must be credible, understandable and reliable. All its activities must be transparent and open to public scrutiny. The Trusted Authority would have the power to consult with any individual or group to address knowledge and skill gaps.
The Trusted Authority would:
- Determine and provide clear up-to-date qualifying methods for meeting regulations. (The current set of qualifying methods includes the Web Content Accessibility Guidelines 2.0, the Authoring Tool Accessibility Guidelines 2.0 and other standards such as Electronic Publication (EPub) and International Organization for Standardization (ISO) 24751).
- In addition to qualifying methods, ensure that necessary tools and resources are available to use the qualifying methods.
- Provide guidance regarding how to achieve the functional accessibility requirements, specific to the particular organizations. This includes links to resources and tools in the Community Platform.
- Retire qualifying methods that are out of date.
- Clarify laws when there is uncertainty or when there are changes.
- Review new and innovative methods proposed by organizations and individuals to determine whether they can be used to meet the requirements.
- Address gaps in available qualifying methods to meet the requirements.
- Ensure that the barriers experienced by all Ontarians with disabilities are addressed by regularly evaluating who might be falling through the cracks. This includes individuals with a range of technical literacy, individuals in urban, rural and remote communities, Ontarians at all income levels and individuals with disabilities that are not visible or episodic disabilities. It also includes people who experience other barriers that might worsen the barriers experienced due to disabilities.
- Provide, track and make publicly available indicators of progress toward an accessible Ontario. Examples of those indicators might include the number of companies with an accessibility officer, the number of accessibility complaints received and their resolution, the number of employees who self-identify as having a disability, and the number of Ontarians trained in accessibility skills.
- Prioritize accessibility processes and tools rather than specialized technologies and services for people with disabilities. In this way, people with disabilities do not have to bear the additional cost of buying their own specific technology.
- Support innovation that recognizes the diversity of needs experienced by people with disabilities rather than a “winner takes all” or a “one winning design” approach.
- Support recognition that people with disabilities must be designers, developers, producers and innovators, and not only consumers of information and communication.
- Qualifying methods must include accessible tools and processes.
The Trusted Authority would maintain an online interactive guide for participating organizations. This guide would let organizations know which FARs apply to them, what qualifying methods they could use to meet the requirements, and what tools and resources are available to help them implement the qualifying methods. The guide would be inclusively designed to consider the different types and ranges of expertise of organizations in Ontario.
It is recommended that the Trusted Authority report directly to the Legislative Assembly. It is the responsibility of the Legislative Assembly to maintain the FARs and the responsibility of the Trusted Authority to maintain the qualifying methods. Funding commitments for the Trusted Authority must span two political terms to ensure sustainability and independence. Decision-making regarding leadership of the Trusted Authority should be transparent and inclusive of Ontarians with disabilities.
The Community Platform would be an online platform, open to everyone in Ontario, that provides a simple and clear way for community members to contribute their knowledge, expertise and constructive criticism about accessibility in this province.
The Community Platform would:
- collect and make accessibility resources and tools easily available
- share training and education
- make it possible for community members to monitor and review how organizations are doing in meeting the requirements
- empower communities to organize events and activities that support accessibility
- showcase and share good examples of accessible practices
- collect and showcase data on various economic and social aspects of disability
The Community Platform must be an open online infrastructure that is easy to get into, easy to use and easy to navigate. It would allow any community member to pool, share and review a large variety of resources that are helpful in implementing the qualifying methods. These resources might include training modules, software tools, evaluation tools, design tools, reusable software components, helpful example practices, examples of contract language for procurement contracts, examples of job description language and many other resources.
The platform would also provide a means for community members to constructively review the resources. Community members would be able to identify gaps in resources, and these gaps would be disseminated publicly to potential innovators and resource producers. The Community Platform will learn from similar initiatives to avoid the pitfalls involved in keeping resources up-to-date and usable by a large diversity of individuals and organizations. Financial support would be needed to maintain the infrastructure and keep the various resources relevant and up-to-date.
Frame 2: Accessibility Ecosystem
The same diagram represented in Frame 1 is lightened with further descriptions of the three parts of the Accessibility Ecosystem layered on top.
There are three important parts in the Accessibility Ecosystem: Laws, Trusted Authority and Community Hub.
Ecosystem parts descriptions
The Law is the compass that keeps the ship on course. The law achieves an accessible community and maintains rules about the structure of the overall ecosystem.
The Trusted Authority provides directions to steer the course. The Trusted Authority must keep a careful watch for new barriers, opportunities and changes in technology trends and adjust directions in response to these changes.
The Community Hub engages everyone in the community including the general public, people with lived experience of disability, and participating organizations. The Community Hub provides the ideas and resources needed to progress forward.
Clearly, compliance will have to be an important part of any successful accessibility ecosystem. The question, then, is how do we enforce and ensure proper compliance? Before making a more definitive recommendation, the committee would like to ask the public for input on how compliance might work, informed by its discussion on this topic summarized below:
The committee had an in-depth discussion of how compliance might work in phase 2. It was agreed that a reasoned, measured approach that rewards good actors and addresses bad behaviour is critical. In addition, greater accountability of leadership was a recurring theme. The committee also discussed greater connections between government bodies/ministries to enable government to be a better leader and using a greater spectrum of compliance measures. Some questions that came up were:
What is the right way to focus on organizations that want to do this right and actively build models that work well?
How do you evolve the current approach to compliance in order to encourage organizations to participate in this ecosystem, using a combination of both incentives and disincentives?
- examples of incentives include grants, loans, tax benefits and public recognition of success
- examples of disincentives include fines, levies to cover the cost of accessibility, surcharges and naming non-compliant organizations using social media
How best do you highlight the benefits of proactively investing in the integration of emerging technologies? How should we define emerging technology?
Frame 3: Accessibility Ecosystem
The same diagram represented in Frame 2 (Frame 1 lightened) with even further descriptions of the three parts of the Accessibility Ecosystem layered on top.
Each of the three parts plays an important role in the ecosystem. They rely on each other to be successful.
Ecosystem parts descriptions
The laws lay out the functional accessibility requirements and provide regulations to bring about the needed culture change. The laws are the most constant.
Participating Organizations and community members can propose innovative new ways to meet the Functional Accessibility Requirements. The Trusted Authority is responsible for keeping the qualifying methods for meeting Functional Accessibility Requirements up-to-date, understandable and do-able. This requires the support of the Community Hub.
Everyone in the community has a role to play and can benefit from participating in the community effort. The Community Hub is the place where new ideas, tools, resources, training, reviews and constructive feedback is gathered and shared.
How is the new model better?
There are several characteristics of the Accessibility Ecosystem that set it apart. It is a more aspirational system, focusing as it does on what is important and good about accessibility, rather than simply emphasizing that it is an obligation. It is also a more inclusive system, not just inviting but actually relying on input from the public and from stakeholders, including those organizations obligated to meet accessibility requirements. Finally, it is designed to evolve and adapt as technology and attitudes change around it. Specifically, the new model will speed progress toward an accessible and inclusive Ontario because:
- the Trusted Authority will intervene when new barriers arise
- the Trusted Authority will integrate accessibility into the foundation before barriers are created
- the Trusted Authority will be able to represent accessibility and inclusive design at technical and policy planning tables, to integrate inclusive design considerations from the start
- efforts to produce services and resources that address accessibility, which are currently fragmented, will be coordinated and strategically channeled
- new and current contributors to the goal of accessibility will be provided with productive ways to participate
- the Trusted Authority will have the opportunity to provide a more comprehensive set of qualifying methods to address more of the barriers experienced by all persons with disabilities in Ontario
- innovative practices that improve accessibility for people with disabilities will be showcased, rewarded and even adopted as qualifying methods
- the Trusted Authority be able to maintain the momentum of accessibility efforts across political terms
Frame 4: Accessibility Ecosystem
The same diagram represented in Frame 1 is darkened. Layered on top of the darkened diagram is a circle placed in the front part of the ship within the Ontario community. The circle represents Participating Organizations. Four lines with arrows extend out of the Participating Organization circle. Each line has a question attached to it with the arrow pointing to an answer within the ecosystem.
The questions and answers are as follows:
How can I make my services accessible?
Arrow points to Accessibility Law.
A second line with an arrow extends out of the question through the Trusted Authority and back to Participating Organizations.
How can I qualify my new method?
Arrow points to Trusted Authority: Qualifying innovative methods.
Where can I learn more?
Arrow points to Community Hub: Training.
What tools are there to help?
Arrow points to Community Hub: Pooled resources and tools.
Cost, funding and sustainability
Reports such as the Releasing Constraints report led by the Martin Prosperity Institute show that public investment in accessibility is one of the most economically rewarding investments of public dollars. By establishing a locus of expertise in accessibility, Ontario gains recognition as a global leader in meeting the growing demand for accessibility expertise and innovation, and achieves unprecedented gains in prosperity. This leadership potential has not been fully realized in the current act framework, but the Accessibility Ecosystem would change that.
The Community Platform would serve to reduce redundancy and significantly improve the effectiveness and efficiency of accessibility efforts. The Community Platform is also structured in such a way that while the infrastructure would be maintained through public funding, the resources, tools, training and review would be contributed by the community at large for mutual benefit. Support for the Trusted Authority and the Community Platform could be shared by multiple jurisdictions across Canada, including other provinces and the federal government. Other jurisdictions have expressed interest in collaborating and sharing these services.
Frame 5: Accessibility Ecosystem
The same diagram represented in Frame 4 (Frame 3 darkened). Layered on top of the diagram are two circles placed in the front part of the ship within the Ontario community. The circles represent the Public and Individuals with Disabilities. Three lines with arrows extend out of the Public circle and one line extends out of the Individuals with Disabilities circle. Each line has a question attached to it with the arrow pointing to an answer within the ecosystem.
The Public questions and answers are as follows:
How can I participate in drafting the laws?
Arrow points to Accessibility Law.
How can I propose new methods?
Arrow points to Trusted Authority: Qualifying innovative methods.
How can I provide feedback?
Arrow points to Trusted Authority.
The Individuals with Disabilities question and answer is:
How can I contribute to resources?
Arrow points to Community Hub: Pooled resources and tools.
A means of meeting a Functional Accessibility Requirement for a type of service or product that is sanctioned by the Trusted Authority. Qualifying methods can refer to specific technologies and formats, and the tools and resources needed to employ these methods would be available in the Community Platform.
Organizations within Ontario, including organizations obligated by the act, previously referred to as “obligated organizations.” The renaming recognizes that a role of all organizations in Ontario is to participate in promoting and advancing accessibility for their own benefit and the benefit of Ontario as a whole.
An online service that connects people who need something with resources or people that meet those needs. The platform provides a place to pool shared resources and tools, attach descriptions, including constructive criticism of the resources and tools. Platforms have points of entry suited to the different users and contributors of the platform.
Alternative access systems
Computer-based technology comes with a standard set of devices to interact with the technology, such as keyboards and displays. People may not be able to use these standard devices. Alternative access systems replace or augment these standard devices.
Appendix B: Functional Accessibility Requirements (FARs)
The following is a draft of the proposed requirements that would constitute one part of the laws. These requirements would be directly linked to qualifying methods for meeting the requirements (provided by the Trusted Authority), and then to tools and resources needed to use the methods (provided by the Community Platform).
Where visual modes of presentation are provided:
- at least one configuration must be provided that does not require vision
- visual presentation must be adjustable to support limited vision and/or visual perception or processing (magnification, contrast, spacing, visual emphasis, layout)
- at least one configuration must convey information without dependence on colour distinction
- visual presentation that triggers photosensitive seizures must be avoided
- it must be possible to render the presentation in alternative formats, including tactile formats
Where auditory modes of presentation are provided:
- at least one configuration must be provided that does not require hearing (captions and sign language)
- audio presentation must be adjustable to support limited hearing and/or auditory processing (volume, reduced background noise)
- it must be possible to render the presentation in alternative formats, including tactile formats
Where speech is required to operate a function:
- at least one configuration must be provided that does not require speech
Where manual dexterity is required for operation:
- the opportunity to use alternative modes of operation must be provided
- at least one mode of operation must be provided that enables operation through actions that do not involve fine motor control. These would include path dependant gestures, pinching, twisting of the wrist, tight grasping or simultaneous manual actions (for example, one-handed operation)
Where hand strength is required for operation:
- at least one alternative mode of operation must be provided that does not require hand strength
Where operation requires reach:
- operational elements must be within reach of all users
Where memorization is required for use:
- at least one configuration must provide memory supports or eliminate the demand on memorization or accurate recall (unless the purpose is to teach or test memorization)
Where text literacy is required for use:
- at least one configuration must provide literacy supports or eliminate the demand for text literacy (for example, text-to-speech, pictorial representation)
- at least one configuration must provide simple language (unless the purpose is to teach or test text literacy where a different level of literacy is required). Simple language means the literacy level of Grade 3.
Where extended attention is required for use:
- at least one configuration must reduce demand on attention or enable use with limited attention
Where operation has time limits:
- at least one configuration must enable extension or elimination of time limits
Where controlled focus is required for use:
- at least one configuration must provide support for focus or eliminate demand on controlled focus
Where specific sequencing of steps for operation is required:
- at least one configuration must provide support for sequencing steps, or eliminate the demand for specific sequencing of operation steps (unless the purpose is to teach or test accurate sequencing)
Where abstract thinking is required:
- at least one configuration must reduce demand for understanding abstractions such as acronyms, allegory and metaphor (unless the purpose is to teach or test abstract thinking)
Where accuracy of input is required:
- a simple undo must be available
Where biometrics are employed:
- alternative methods of identification must be made available