Accessibility and Re: [LINK] Smart Card Submissions Online

Irene Graham rene.lk at libertus.net
Thu Aug 31 20:10:22 AEST 2006


On Wed, 30 Aug 2006 14:59:51 +1000, Tom Worthington wrote:
> I wrote Mon, 07 Aug 2006 08:44:59 +1000 (was: "Access Card Taskforce
> Submissions"):
>
>> ... I did suggest the KPMG report on the card be made available in an
>> accessible format. What was provided was a bitmap image of the
>> report, which was difficult to read and search. It would also be
>> inaccessible to the disabled, which may be unlawful. ...
>>
>
> Had a call from the Consumer and Privacy Task Force on the Health and
> Social Services Access Card (aka "Smart Card Taskforce") to say that
> they are seeing if they can get submissions in an accessible format.

I (as EFA) also received a call from them.

> The submissions which they have received, in PDF and/or RTF, are at
> <http://www.humanservices.gov.au/access/discussion_papers/>.

Actually, the submissions they received in PDF are not on that page yet 
(EFA's was sent as PDF file containing text) because they claimed that PDF 
is not "accessible" and so want the submissions sent again in... wait for 
it... Word DOC or RTF format (i.e. MS proprietary formats). 

The person who phoned me said they'd been informed by the Disability 
Commissioner that departments that publish documents only in PDF could be 
found in breach of the Disability Discrimination Act (DDA) (see more about 
that below).

[...]
> Unfortunately, the original "KPMG Access Card Business Case" is still
> in its difficult-to-read image PDF format
> <http://www.humanservices.gov.au/modules/resources/access_card/kpmg_acc
> ess_card_business_case.pdf>.

Exactly. Hence it's not credible that they can't publish submissions 
received only in PDF (containing text) for fear of breaching the DDA. If 
the Department was at any risk of being found in breach of the DDA it would 
be most likely to be as a result of publishing that government commissioned 
report in a format that is completely inaccessible to vision impaired 
people, rather than publishing submissions sent to them by members of the 
public in PDF format. 

I contacted a senior representative of the Disability Commissioner's office 
yesterday by phone and received verbal advice, followed by an email 
confirmation this morning that said, among other things, that the 
Commission does advise Commonwealth Departments that in their own 
publications they should provide alternatives to PDF, but have never 
published advice that governments "taking public submissions must or should 
refuse to publish material in PDF, and do not hold any such view".

I also phoned an organisation representing/advocating for vision impaired 
people and was advised that PDF files can be problematic for vision 
impaired people but this generally depends on the content of the particular 
file. Briefly, PDF files that are an image are not accessible, and PDF 
files that contain text with complex formatting, e.g. such as in column 
layouts etc, are very likely to problematic unless the file creator 
inserted PDF-tags. 

That seems to match my previous understanding about the issue, which was 
-partly- based on the fact that Google's "view in HTML" feature has no 
problem converting EFA's PDF submissions containing only text to HTML, so 
I've long assumed the text would also be able to be read by speech 
recognition software etc.

However, if anyone knows anything different in relation to accessibility of 
PDF files that contain basically only ordinary text paragraphs, I'd be very 
interested to know. While there is a lot of stuff about PDF findable by eb 
search, but I've not yet been able to find anything that makes clear 
exactly what the situation is with PDF files that only have text in paras, 
not also in columns, tables, etc.

EFA doesn't have a copy of our submission in DOC or RTF - our submissions 
are created in HTML and then converted to PDF and after several discussions 
with the departmental representative, I've been advised that they will be 
making submissions provided in PDF available. Meanwhile, EFA's is already 
available on our own web site in W3C standards compliant HTML:
http://www.efa.org.au/Publish/efasubm-dhs-accesscard-2006.html

Irene





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