Accessibility and Re: [LINK] Smart Card Submissions Online

[Marghanita da Cruz]

There are probably two issues here...

A PDF file containing an image of a document is problematic for 
everyone, particularly those wishing to comment/quote from  the document.

Bring on HTML...but there is still a risk that it will then just link to 
a JPG or GIF file....I am yet to conclude whether this is deliberate 
perversion or ignorance.

M


Irene Graham wrote:
> 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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> 


-- 
Marghanita da Cruz
Ramin Communications
http://www.ramin.com.au
Phone: 0414-869202
Email: marghanita at ramin.com.au