Web accessibility in Australian schools: Opportunities and challenges
Owen ONeill and Kristena Gladman, Link Affiliates and eWorks
Table of Contents
© Copyright 2010 University of Southern Queensland
Introduction
In December 2008, the World Wide Web Consortium (W3C) released a new version of the de facto international standard for web accessibility called Web Content Accessibility Guidelines 2.0 (WCAG 2.0). In response, the Australian Government Information Management Office (AGIMO) in consultation with The Australian Human Rights Commission (AHRC) undertook a consultation process with government departments during 2009 in preparation for a transition to WCAG 2.0 as a government requirement for web content.
The move to the new standard by the Australian government should bring about positive changes to key stakeholders such as developers and users of e-learning content and systems. However, it will be important to provide clear and timely advice to the sector to ensure a smooth transition to the new requirements.
Unlike its predecessor, WCAG 2.0 has been designed to be technology neutral, enabling it to better cater to new and emerging technologies. The new guidelines will potentially impact all web systems and content used in the schools sector.
This report provides an overview of the potential opportunities and challenges that WCAG 2.0 brings to Australian schools and makes recommendations for further action to facilitate the sector’s transition to the new requirements.
Activity scope
Further clarification is expected from AGIMO on the details of the planned implementation of WCAG 2.0. As such, the scope of this activity was focused on the following two topics.
Build capability and assist the schools sector to understand the potential impact, challenges and opportunities WCAG 2.0 could present for the Australian schools sector
The focus group conducted information gathering and a number of facilitated discussions on the topic of accessibility in e-learning content and systems. In particular, these discussions were aimed at developing a better understanding of:
- The current level of understanding of accessibility requirements for web content
- The level of conformance to accessibility requirements of current e-learning content and systems
- The potential impact the WCAG 2.0 requirements would have on key stakeholders
Provide advice to DEEWR relating to AGIMO WCAG 2.0 consultations
The focus group considered the information currently available on implementing WCAG 2.0, and oversaw the development of demonstrator content which explored the potential challenges and opportunities that the new requirements may present to existing e-learning content and systems in Australian schools.
Methodology
Establish a Focus Group
A focus group was established which is representative of key school sector stakeholders who have an interest in web accessibility issues in Australian schools.
Research WCAG 2.0 and related documentation
An analysis of the WCAG 2.0 Guidelines and documentation was undertaken within the context of current accessibility approaches in the schools sector, and the impact of the new guidelines on these processes.
Gathering intelligence
Information on the Australian government response was sought, and the group provided a focus for better understanding and articulating schools sector requirements for web accessibility. This was achieved via the focus group, through monitoring of appropriate WCAG and W3C groups, and collaboration with the national VET sector’s Australian Flexible Learning Framework which is also analysing the impact of WCAG 2.0 on e-learning.
Demonstrator e-learning content
A small sample of existing schools-focused e-learning content was modified to conform to WCAG 2.0 requirements to gather practical experience with implementing WCAG 2.0 and to assess the amount of effort required to modify existing items. This process was documented along with challenges identified.
Recommendations for further action
In collaboration with the focus group, recommendations for further action in the Australian schools sector to address WCAG 2.0 implementation have been made in this report.
An introduction to web accessibility and WCAG 2.0
A broad definition of web accessibility
Accessibility can be loosely defined as the degree to which a product, device, service, or environment is readily available to all users. Accessible web design should ensure that all users can access the content regardless of their location, experience or type of computer technology - particularly users with disabilities. Whilst accessibility of web content is often aligned with catering to disabled users there are also significant benefits for the majority of users if content is accessible.
Web accessibility in the Australian context
In Australia the provision of accessible web content, like equitable access to buildings, education, employment, public transport and goods and services, is covered by the Disability Discrimination Act (DDA) which is administered by the Australian Human Rights Commission (AHRC).
The Australian Government endorsed the Web Content Accessibility Guidelines version 2.0 (WCAG 2.0) for all government web content in February 2010. This decision supersedes the previous mandate for compliance with WCAG 1.0 Level A checkpoints. The initial announcement came via ministerial press release on February 23, 2010 and the Australian Government Information Management Office (AGIMO), who have been managing the WCAG 2.0 evaluation and transition planning, amended the accessibility section of the Web Publishing Guide the following day:
Government agencies will transition to WCAG 2.0 over a four year period, reaching level Single A within two years, and Double A within four years. A Transition Strategy will outline the process for implementation, and will address scope and inclusion issues. The Transition Strategy will be made available on the Web Publishing Guide in July 2010.
An overview of the WCAG 2.0 specification
The Web Content Accessibility Guidelines 2.0 (WCAG 2.0) were published in December 2008 to replace the WCAG 1.0, which were the de facto international standard for web accessibility for approximately 10 years. WCAG 2.0 is maintained by the World Wide Web Consortium (W3C), and was the result of many years of consultations and debate.
Comparison between WCAG 1.0 and WCAG 2.0
WCAG 2.0 builds upon the foundation of WCAG 1.0, but also has some noteworthy changes. At the base level, a number of the changes in WCAG 2.0 aren’t obvious and the types of required outcomes remain the same; for example pages still need to be correctly structured, images require text alternatives and appropriate colours need to be used. However there is a significant difference in the approach to the guidelines. WCAG 1.0 is technology specific and the checkpoints are categorised by Priority level and the impact of achieving the checkpoint upon the user. In contrast WCAG 2.0 is technology neutral, and has 12 guidelines that are organised under 4 principles: perceivable, operable, understandable, and robust and each guideline has testable success criteria, which can be at any of the three levels: A, AA, and AAA based upon the potential for successfully implementing the criteria.
Making the guidelines principle-centred allows them to be relevant regardless of technology - any technology can be used but it is the way in which it is used and the degree to which it meets a success criteria that will determine whether it can be deemed accessible.
In addition to the principles, guidelines and success criteria all WCAG 1.0 content is required to meet five conformance criteria to be deemed conformant:
- All the information or content on a page must meet one of the Success Criteria levels (eg Level A) or an appropriate conforming alternative at that level has been provided.
- The whole page has to comply. Parts of a page that might have content that doesn’t comply can't be excluded. Non-complying content can be used if a conforming alternative is also provided and it doesn’t interfere with the page (see point 5).
- Where a page is part of a process (eg purchasing a ticket), all pages or steps in the process must conform at the specified Success Criterion Level.
- Only ‘accessibility supported ways of using technologies’ can be relied on and where this is not possible an alternative that is accessibility supported should be provided.
- Technologies that are not accessibility supported can be used, as long as the information is also available using technologies that are supported. Also, the non-accessibility-supported material on the page does not interfere with the ability of users to use the rest of the page (eg it doesn’t trap the cursor, or users can control the level of audio content).
Challenges
Interpreting technical requirements
There is a significant amount of official and non-official documentation advising people on how to implement WCAG 2.0. For web developers and non-technical content creators such as teachers it can be very time-consuming and difficult to wade through the resources to find the pertinent information. Content creators are likely to greatly benefit from simple guidance about where to source information.
Unlike its predecessor, WCAG 2.0 was designed to be technology neutral, meaning it should be able to be implemented for any web technology. However, guidance on how to interpret the information and produce content that can be deemed accessible may be needed for non W3C technologies (technologies other than HTML/XML and CSS) because the majority of the success techniques provided are for W3C technologies.
It is expected that AGIMO will provide more specific guidance for implementing WCAG 2.0, but the extent of this guidance is unclear at the time of writing.
Selecting appropriate software tools and systems
The use of software tools, systems and services are fundamental to the use of technology in education. In the school environment, common examples may be web portals, collaborative web based services, social networks (Web 2.0 tools) and learning management systems.
Software tools and systems can impact on accessibility in a number of ways. If the software system provides an environment for learners to access content, collaborate, etc., then it is important to assess the level of accessibility of the tool itself.
If the software tool is being used to create e-learning content, then it is the output from the tool (eg. the e-learning content created) that needs to be considered from an accessibility view-point.
Developing e-learning content
For e-learning content that is created and used in the schools sector, the appropriate level of accessibility should be determined depending on who the audience is, and who is creating the e-learning content. It is not realistic to expect non-technical stakeholders (primarily teachers) to create e-learning content that has the same level of technical quality as professional web developers. At the same time, professional web developers commissioned to create e-learning content will need to be given clear, concise and unambiguous instructions.
It should be possible to provide non-technical content creators with a base understanding of good practice usability design and development principles that incorporate the simplest accessibility requirements, so that they achieve a level of accessibility conformance without requiring expert knowledge.
The format of the content (image, video, text, etc) can also have a profound impact on the level of technical skills and knowledge required by the author to achieve an acceptable level of accessibility.
Addressing user-generated content
The explosive growth of user-generated content has made the web an increasingly interactive and collaborative environment. Students and teachers are not just passively absorbing information, but are also actively creating and sharing knowledge.
There is an ever growing number of tools available for creating user-generated content. Some common examples may be blogging software, wikis (including Wikipedia) and social networking services such as Facebook and Twitter.
For Web 2.0 technologies, WCAG 2.0 takes into account the notion that not all of the content is within the user's control. For example, comments on blog sites are usually outside the primary page author's control so there is a notion of a partial conformance claim through a “statement of partial conformance". The statement would need to say "This page would conform to WCAG 2.0 at level X if the following parts from uncontrolled sources were removed."
Addressing legacy content and systems
The demonstrator work undertaken as part of this activity took some existing schools focused web learning content and converted them to be WCAG 2.0 compliant. For full details of this work, please refer to the "21C Content and accessibility demonstrator project outcomes report".
The schools sector has a significant body of existing content developed and owned by the commonwealth, state and territory governments, ministerial companies, initiatives, schools and individuals that will be affected by the implementation of WCAG 2.0. Our work confirms that the following factors directly impact the ability to modify e-learning content to conform to WCAG 2.0:
- the type of content and the technologies used to create the content (HTML, Flash, Video, etc)
- the age, version of the authoring environment and script language/code
- the availability of documentation and source files for the content
- the current level of conformance to WCAG 1.0.
Understanding the accessibility implications of different content formats
We found that the Flash content we worked with took a significant effort to update to WCAG 2.0 requirements due largely to variations in different versions of Adobe Flash (including its proprietary programming language Action Script) and the relative lack of information about developing Flash content to meet WCAG 2.0 requirements, particularly in terms of migrating content built to meet WCAG 1.0. Differences in the way different screen reader applications interpret the content also caused numerous problems. These two issues could present significant barriers to developers trying to create accessible e-learning content. More targeted support materials are required for e-learning content developers.
Building sector capacity in accessible e-learning content
To better understand how to build capacity in the schools sector to deliver e-learning content and systems that meet an acceptable level of accessibility, it is important to better understand how content is created.
The question of who generates e-learning content is complex, particularly in the world of Web 2.0 collaborative services and functionality.
We identified a number of key stakeholders which may produce e-learning content in the Australian schools sector including:
- Teachers
- Professional web developers
- Students
- Cultural organizations
- Commercial publishers
This report will focus primarily on the impact on teachers and professional web developers commissioned to produce e-learning content.
Teachers
There is naturally great variation in the level of technical knowledge skills and experience in teachers who are engaged in developing e-learning content. Teachers may also be using a variety of software tools and systems to generate e-learning content, or they may even be creating content manually.
Example 1: LMS
David teaches a grade 6 class at Northpark Primary School. He has created an online course using the Moodle Learning Management System. Only registered students can log into the course, and David is able to control access. He uses this course to provide students with assignment details and reference materials.
Example 2: Wiki
Jane teaches year 11 biology at Westland High School. She uses a wikispaces wiki with her students to track the progress of a class project over a number of weeks. Students are actively collaborating on the wiki space and adding a range of video and still images depicting their progress.
Both examples may reach an acceptable level of accessibility depending largely on the tools selected (or available) and the choices and technical skills of the teachers.
Professional web developers
Some e-learning content used in schools is developed by professional web developers. Naturally, a higher level of technical quality and accessibility should be possible for this content. Many years of experience in both the schools and VET sectors of commissioning publicly funded e-learning content show however that it is vital that e-learning content developers are provided with clear, unambiguous instructions and technical documentation on what is required of the content.
In the schools sector, The Learning Federation (TLF) developed and maintains a widely used national collection of e-learning resources. TLF content is developed using rigorous processes for planning, designing and developing the content, and it is built by professional content developers1. In 2002, in response to a submission from TLF the Human Rights and Equal Opportunity Commission (HREOC - now known as the Australian Human Rights Commission) agreed to allow TLF to take a modified approach to accessibility and to develop content targeted to cater to the specific requirements of users with specific disabilities rather than meeting WCAG 1.0 priority levels.
A number of states and territories also fund the development of e-learning resources by dedicated web developers for use within the jurisdiction. Given that this content is expected to be able to be used across multiple classrooms, it should meet existing accessibility requirements.
The role and importance of tools
The use of software tools, systems and services are fundamental to the use of technology in education. In the school environment, common examples may be web portals, collaborative web based services and social networks (Web 2.0 tools) and learning management systems.
Sometimes these tools and systems are provided for teachers and students by the school or jurisdiction, in other cases the teacher may select them. These distinctions must be considered when determining the suitability of software tools and systems.
Any software tool or service selected nationally or by a jurisdiction for use in Australian schools should be tested and assessed for accessibility. This is particularly important if usage is required by learners or teachers. Given the length of time that the Australian government has required accessibility, accessibility considerations should already be built into procurement processes. However, it is timely to review such processes with the introduction of the new requirements.
It is not feasible for teachers to be able to evaluate software tools and systems for use in their classrooms with the same level of scrutiny as accessibility experts. Given the diversity of tools being used by teachers and learners, teachers should be provided with guidance on what accessibility is and how they should address the accessibility requirements of their learners when selecting or providing access to tools. This information should be generic, so it would be efficient to undertake this work nationally rather than at the individual jurisdiction level.
Targeted guidance for e-learning content developers
This report focuses on two primary stakeholders responsible for creating e-learning content and environments used by students (teachers and professional web developers). It is essential that guidance on accessibility is targeted to the audience, and the expected level of technical skills of that audience.
Providing advice to Australian governments on accessibility of e-learning content
The following recommendations are directed to the Department of Employment, Education and Workplace Relations (DEEWR) and State and Territory Governments. It is recommended that this work is coordinated by DEEWR with input from each jurisdiction.
Review AGIMO transition plan
Once AGIMO releases it’s guidance for implementing WCAG 2.0, this information should be reviewed from a schools sector context with input from each jurisdiction and other key stakeholders such as Education Services Australia (ESA).
It should be ensured that the DEEWR’s response to the AGIMO transition plan and any other implementation processes explicitly includes web learning content.
Seek clarification on implementation
To facilitate the transition to WCAG 2.0, implementation requirements for moving to WCAG 2.0 should be clear and unambiguous. For the schools sector, clarification may be required on the following issues:
- What constitutes a closed environment
- Requirements for closed environments
- Single use content within closed environments
- how existing collections of e-learning content are to be addressed.
Commission guidelines for key stakeholders
It is expected that the AGIMO documentation will require contextualization for key school sector stakeholders, particularly teachers and professional web developers. This work should explicitly address the key challenges identified in this report:
- Interpreting technical requirements;
- Selecting appropriate software tools and systems;
- Developing e-learning content;
- Implementing and testing accessibility;
- Identifying and accessing information about accessibility;
- Addressing user-generated content;
- Addressing legacy content and systems;
- Understanding the accessibility implications of different content formats.
A plan for review and maintenance of the guidelines should also be developed, along with a dissemination strategy.
Review and consolidate procurement policies
As previously noted any software tool or service selected nationally, by a jurisdiction or locally by a school for use with learners should be tested and assessed for accessibility. With the introduction of the new requirements and significant movements in web technologies including Web 2.0 tools and social networking, it is timely to review and consolidate procurement processes and policies to ensure appropriate consideration for accessibility requirements.
Conclusions
This report documents the outcomes of the accessibility activity funded via the Australian Government’s Technical Standards for Digital Education project. This work was undertaken in response to the Australian Government’s recent announcement of a change to the web accessibility requirements for publically funded web content with the planned introduction of the Web Content Accessibility Guidelines 2.0 (WCAG 2.0).
With planning and national collaboration, the transition to WCAG 2.0 could improve the accessibility of web content in Australian schools, as well as providing more certainty for developers of e-learning content and systems.
The report identifies two key stakeholders that need to be aware of web accessibility from a learning and teaching perspective; namely teachers and web content developers. Jurisdictions and schools also need to be aware of their obligations for providing accessible learning environments. A number of key challenges to the successful implementation of WCAG 2.0 have been described in this report, along with recommendations for further action.
Appendix 1: Focus Group Members
Gerry Gray | National Catholic Education Commission |
Brenton Westley & Gawain Duncan | Department of Education and Children’s Services |
Bruce Maguire | Australian Human Rights Commission |
David Appleby | Westone |
Kenneth Jewell | Department of Education and Training |
Kristena Gladman | eWorks |
Jerry Leeson | Education Services Australia |
The Technical Standards for Digital Education project is funded by the Australian Government's Department of Education, Employment and Workplace Relations (DEEWR).



