The following statement was prepared for a Human Rights and Equal Opportunity Commission hearing (originally to be in March but actually held 8 & 11 August 2000) and placed on-line 13 August 2000. For background see: Olympic Failure: A Case for Making the Web Accessible, prepared for INET 2001: Internet Society Conference, 8 June 2001, Stockholm.

Tom Worthington
11 May 2001


HUMAN RIGHTS AND EQUAL
OPPORTUNITY COMMISSION

Complaint No. H99/115

BETWEEN: BRUCE MAGUIRE

Complainant

AND: SYDNEY ORGANISING COMMITTEE
FOR THE OLYMPIC GAMES (SOCOG)

Respondent

Statement of Tom Worthington

On 30 June 2000, I, Tom Worthington, of 60 Dumaresq Street, Dickson ACT 2602, Australia state that;

1. I am an electronic business consultant, author and information technology professional, with 17 years experience in information technology, including nine years on high level IT policy and five in Internet applications. I attach to my statement a copy of my curriculum vitae and a list of my publications.

2. I am currently a Visiting Fellow in the Department of Computer Science at the Australian National University.

3. From March 1995 until May 1997 I was the first Web Master for the Australian Department of Defence. As such I am one of the architects of the Commonwealth Government's Internet and web strategy. My book "Net Traveller - Exploring the Networked Nation" was published in 1999 and looks at web policy issues, including public access and equity.

4. In 1999 I was elected a Fellow of the Australian Computer Society for my contribution to the development of public Internet policy. I am a director and past President of the Australian Computer Society and a voting member of the Association for Computing Machinery (USA). ). I attach a copy of my CV: http://www.tomw.net.au/twexp.html and a list of my publications and activities: http://www.tomw.net.au/twpubs.html

5. At the request of Mr. Simon Moran of the Public Interest Advocacy Centre, Sydney I have prepared this report on the accessibility issues facing Mr. Bruce Maguire when accessing the Sydney Organising Committee of the Olympic Games (SOCOG's) Website at http://www.olympics.com. ("SOCOG's website").

6. On 27 April 2000 I read a draft statement by Mr. Maguire which sets out his difficulties at May 1999 in attempting to access the SOCOG website. The draft statement also sets out his difficulties accessing the website as at the date of signing of this statement.

7 It is my understanding, gained from reading his statement that Mr. Maguire seeks the following parts of the SOCOG website, in its current form, to be made accessible to him;

  1. that SOCOG include Alt text on all images and image map links on the SOCOG website.
  2. that SOCOG ensure that I can access the Index of Sports from the Schedule page.
  3. that SOCOG ensure that I can access the results tables that will be used on the SOCOG website during the Olympics.

Background

8. Website accessibility guidelines have been developed to assist website designers to make websites which are accessible to the greatest range of users of the internet. These guidelines give recommendations as to which options are easiest for readers to use. The following website accessibility guidelines are relevant to this complaint;

  1. W3C Recommendation Web Content Accessibility Guidelines 1.0, 5-May-1999 at (http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505).

  2. AusInfo Guidelines at http://www.ausinfo.gov.au/guidelines/index.html.

  3. IBM's Web Accessibility Guidelines and Checklist at http://www-3.ibm.com/able/accessweb.html.

9. Web accessibility guidelines provide a set of recommendations on techniques to be used to make web pages available on the maximum range of hardware and software, on communications links of differing speed and by people with disabilities.

10. While the details of web accessibility guidelines, such as the W3C Recommendation Web Content Accessibility Guidelines 1.0, 5-May-1999 at http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505 can appear complex and technical, the principles are simple.

11. I used "Bobby" to search the SOCOG website for useability issues. Bobby is an automated tool for testing implementation of web usability guidelines, as well as to formal web syntax. It allows a quick and easy test of the pages.

12. Bobby was created by the Center for Applied Special Technology (CAST). Founded in 1984, CAST is a not-for-profit organization whose mission is to expand opportunities for people with disabilities through innovative uses of computer technology. The home page for "Bobby" http://www.cast.org/bobby. a web-based tool that analyses web pages for their accessibility to people with disabilities, provides a simple summary of principles:

provide text equivalents for all non-text elements (i.e., images, animations, audio, video)

provide summaries of graphs and charts

ensure that all information conveyed with colour is also available without colour

clearly identify changes in the natural language of a document's text and any text equivalents (e.g., captions) of non-text content

organise content logically and clearly

provide alternative content for features (e.g., applets or plug-ins) that may not be supported

11. In my opinion there may also be benefits in putting these principles into practise to those with normal vision. Those in remote areas using slow dial-up Internet connections will find the non-text version will load more quickly. The ALT text captions(a text caption for each image on each web page) on images can be read by software, such as language translators and search engines, aiding in interpreting and finding information.

12. In my opinion useability changes in compliance with the above principles will have benefits to the institutions and corporations setting up and maintaining websites. Web users not selecting graphics will place a lower load on the web server and telecommunications links, due to the smaller volume of material to be transmitted. In my opinion in the case of the SOCOG website this would mean approximately a two-thirds reduction in the amount of information being transmitted. This may reduce the cost of equipment and telecommunications links required to support the website.

Useability issues: making a website accessible

ALT-text on images

13. The easiest and most useful change to make a web site accessible to the blind is to provide a text caption (commonly called "ALT text") for each image on each web page. In the absence of seeing the image, the ALT text can be read out by a talking terminal or displayed as Braille. Adding ALT text requires the web designer to type in a phrase or sentence describing the image. No additional equipment or expertise is required.

14. The level of detail provided in the textural description is a matter for judgement for the author of the document. The author needs to judge the level of detail the reader is likely to require. If a photograph is provided for stylistic purposes, then little detail may be required. However, if it is included to provide detailed information, then a correspondingly detailed text description is required. As an example, describing a photo as "North west side of the aquatic stadium" and a seating plan as: "there are three banks of seats in the hall. The goal ends of the court hold approximately 200, in 5 banks of 40; the sidelines have 7 banks of 400" may be sufficient. Alternatively it may be considered necessary to provide a textural description detailing the features of the hall visible in the photo and the location of each seat.

15. A special type of images are image maps. An image map consists of a photograph or diagram, a set of spatial coordinates and a set of instructions for a function to be carried out corresponding to each area defined by the coordinates. Portions of an image map are sensitised, so that when the area is selected, a function (such as going to another web page) is carried out. ALT text on an image maps is not sufficient for its use. Some form of alternative text based menu, duplicating the items on the image map is required. Otherwise the ALT text would just tell the operator there is a menu, but not allow items to be selected.

Page Template

16. A web site is usually made up of many pages, which conform, to one of a small number of standard formats (or "templates"). The individual templates are developed by an experienced "web master" and then copies filled in by less expert staff to produced the hundreds or thousands of web pages used. In some instances the templates are used by an automated system to produce the web pages (with the data entered into a database).

17. The useability of the web site depends on the design of the templates used (assuming that data the templates allow for is correctly entered). To assess the useability of a large web site in detail requires knowing how many templates there are and being able to examine the templates, rather than having to survey the mass of individual pages. To estimate the cost of changes the site, to improve useability, would require knowing the number of templates.

18. In my opinion, to enhance useability, the results pages for the sport of swimming, should have the same format but with different data entered for different swimming events. It would therefore be sufficient to examine one page using the swimming template to assess the useability text.

19. Depending on the tools used to generate web pages, it is possible to more easily make global changes to sets of pages at once. Presumably the descriptions of each sport and results will be extracted from a database which is automatically formatted to web pages, not hand coded. Sport results will be entered into a computer system once and it is to be assumed that the web pages are generated directly from the entered data. It would make little sense to print out the results from one computer and then re-enter them (with resulting transcription errors) into another computer).

Specialised Technologies Not Examined

20. The World Wide Web was developed in 1989 to display text using a format called HTML. Subsequently the ability to display images was added. Since then a large number of additional formats for sound, three-dimensional images, animated images and video have been added. Many of the added visual formats lack provision for alternative display for the visually impaired (as with ALT text for still images). It would be possible to provide long text descriptions for each visual, but in practice a short caption might be the best that can be hoped for. As an example "photo of high diver" or "Opening ceremony oath from the 1994 Olympics being recited", may be sufficient description and take minimal effort to prepare.

Why have low useability features ?

21. In my opinion, in many cases the elements of web sites that make accessibility difficult for the visually impaired appear to have little practical reason for being used at all. The web is a new medium and many features have been added which are of questionable benefit to any user. It may be that a site designed to be easy to use for the visually impaired is easier to use for everyone else as well. It may be that the only people not pleased with this approach are the marketers of the add-on web features and the marketing department of the company.

Inspection of the SOCOG Website

22. On 27 April 2000 I inspected the following pages:

23. The web pages were displayed using Internet Explorer (Version 5.0 for Windows 95), with image display switched off (to simulate use by a blind person). The display of the web pages was inspected for useability and then an examination of the HTML source code made. HTML source code is the textural instructions used to indicate what is displayed on a web page. As an example the instruction <i> indicates that what follows should be displayed in italics and <b> indicates bold text.

24. It should be noted that a more detailed analysis would be required to more formally rate the site against established useability guides, such as the HREOC Recommended Guidelines, which cite the work of the World Wide Web Consortium (W3C).

Problems found using the "Bobby" useability test tool

25. On 27 April 2000 I conducted a test on the home page of the SOCOG website at Home page: http://www.olympics.com/eng/index.html/eng/home.html using the "Bobby" useability test tool at http://www.cast.org/bobby. This initially failed to give useful results, as the home page contains a "no frames" option which has the text "Welcome to the Official Site of the Sydney 2000 Olympic Games". While strictly speaking, this passes the useability test, it does not provide useable functionality

26. When the main frame "home.html" was submitted separately to Bobby it failed due to three images with no ALT text and a request for tables to be checked for tables headers for the table rows and columns.

27. An issue which is not one usually covered in useability guidelines was the title used for the site. All pages appear to have the one title: "Official Site of the Sydney 2000 Olympic Games". This makes it difficult to quickly navigate between web pages. This is somewhat like looking through a library where only the name of the library appears on the covers of the books.

28. Another problem was that the background colour (dark blue) of the home page matched the colour of the ALT text used for some images. The result is that! the ALT text is invisible. Paradoxically this is not a problem for the completely blind, whose text-based equipment will ignore the background colour, but is a problem for the partially sited and other users.

29. The "Sports home page" http://www.olympics.com/eng/sports/home.html includes a confusing menu system, with "a choose a sport" button and a list of sports which are on the bottom of the screen in one large image map (where they would only be seen by scrolling down). This could be supplemented (or replaced) by a simple text list.

30. After an inspection of the SOCOG Web Site I found that it is inaccessible to Mr. Maguire and other blind people using similar software for the following fundamental reasons:

  1. ALT text is not included on small number images of the web site. As an example the graphic at the top of the page which links to "home" and the button bar (with "feedback", "about" and "privacy") have no text captions. The visually impaired user would be unable to discern what these items were for, due to the lack of a readable label.
  2. Tables are not laid out so as to be read a linear way. Tables contain multiple lines of wrapped text, which are read across the rows, as for example by a Braille reader, and so are not intelligible. As an example the table in the "What's on - December 1999" page http://www.olympics.com/eng/schedule/Event_1299.html has three columns of text. The first column has the dates broken across three lines: "4 Dec to 5 Dec". This would be read by a Braille reader as three separate items starting three lines of the table, not as one phrase.

  3. The "Sports home page" http://www.olympics.com/eng/sports/home.html has a list of sports in one large image map, which is unreadable by non-text readers.

Problems found and compliance with Web Accessibility Guidelines

i. W3C Recommendation Web Content Accessibility Guidelines 1.0, 5-May-1999 at (http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505).

From: Guideline 1. Provide equivalent alternatives to auditory and visual content. Checkpoints (http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/#gl-provide-equivalents):

"1.1 Provide a text equivalent for every non-text element (e.g., via "alt", "longdesc", or in element content). This includes: images, graphical representations of text (including symbols), image map regions, animations (e.g., animated GIFs), applets and programmatic objects, ascii art, frames, scripts, images used as list bullets, spacers, graphical buttons, sounds (played with or without user interaction), stand-alone audio files, audio tracks of video, and video. [Priority 1]"

Guideline 5. Create tables that transform gracefully. (http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/#gl-table-markup)

"5.1 For data tables, identify row and column headers. [Priority 1] For example, in HTML, use TD to identify data cells and TH to identify headers.

5.3 Do not use tables for layout unless the table makes sense when linearized. Otherwise, if the table does not make sense, provide an alternative equivalent (which may be a ). [Priority 2]"

From: Guideline 1. Provide equivalent alternatives to auditory and visual content. Checkpoints (http://www.w3.org/TR/1999/WAI-WEBCONTENT-19990505/#gl-provide-equivalents):

Checkpoints:1.1 Provide a text equivalent for every non-text element ...

For image maps, either use the "alt" attribute with AREA, or use the MAP element with A elements (and other text) as content. "

ii. AusInfo Guidelines at http://www.ausinfo.gov.au/guidelines/index.html.

4.2.1.2 Equal access and the web: some issues (http://www.ausinfo.gov.au/guidelines/standard01.html#4.2.1.2)

"Availability of information and services in electronic form via the web has the potential to provide equal access for people with a disability; and to provide access more broadly, more cheaply and more quickly than is otherwise possible using other formats...

Current text readers and Braille output devices are not able to deal with information or links presented only in graphics or photographic format. "

iii. IBM's Web Accessibility Guidelines and Checklist at http://www-3.ibm.com/able/accessweb.html.

Version 2.1 January 11, 2000 (http://www-3.ibm.com/able/accessweb.html#checklist)

"Checkpoint

1: Images and animations. Use the alt="text" attribute to provide text equivalents for visuals. Use alt="" for visuals that do not convey important information or convey redundant information.

2: Image Maps. Use client-side image maps to provide accessible text for image map hot spots. If you use server-side maps, provide equivalent text links.

...

9. Tables. For tabular data, use the CAPTION element and/or the summary attribute. For tables with complex row and column headers, use the headers attribute on cells."

Changes required to make the site accessible to Mr. Maguire

31. In my opinion the SOCOG website can be made accessible to Mr. Maguire by making the following changes.

  1. Add ALT text to the images where it is not already included. Supply a text based menu as an alternative to image maps.
  2. Lay out tables so as to be readable in a linear way (or provide a linear alternative to tables). Identify headers for the table rows and columns to aid reading.
  3. Supplement (or replace) large image map list of sports on the "Sports home page" http://www.olympics.com/eng/sports/home.html with a simple menu.

Information required to estimate the cost of the website

32. To make an exact costing of all the changes required I need to know the exact size of the website. Specifically I need the following information from SOCOG;

  1. the number of templates to be used for the SOCOG website.
  2. details of the tools used to generate the pages of the SOCOG website.

as the results tables are not yet on the website I also require a sample page, in electronic format, from the proposed results table on the SOCOG website and the number of templates for the results tables.

33. I have not received this information at the time of signing this statement. As a result I have made a number of assumptions, based on the pages which were examined.

Assumptions made to cost the website

34. The number of templates used on the website. An Alta Vista web search for pages hosted at "www.olympics.com" found 204 web pages. Alta Vista is the web search engine linked from the Olympic web site and so presumably the one with the most comprehensive set of links. Based on my experience of designing web sites, I have assumed that these pages consist of 10 subsidiary pages for each template, giving an estimate of approximately 21 general templates.

35. I have assumed that the tools used to design the web site have provision for useability options (such as the inclusion of "ALT") tags and tools for searching for particular structures (such as tables) which need to be checked. Therefore no additional cost is included for the cost of tools to fix the website.

36. The number of results templates. The "Organising the Games - Overview of the Sydney 2000 Games" http://www.olympics.com/eng/about/programs/overview.html Fact sheet gives the estimate of "28 sports, will compete in some 300 events". To arrive at this figure I took the number of events and divided it by the number of sports.

37. As a result of the assumptions I have made the number of the templates on the website are likely to be somewhere in the following range;

Type of template No Templates
21 general web templates 21
28 sports web page templates 28
28 sports web page templates, each with 11 event result templates 308
-----
Estimate of the total number of templates 357
===

My estimate of the time required and cost estimate for the website

38. Given the size of the site, I estimate that it would take approximately 3.1 weeks for a competent developer to make these changes. I have assumed that 1 day is 7 hours. This estimate is based on the following individual time estimates:

  1. i. Survey web site and assess the extent of requirements for changes as identified in paragraph 29: 4 days
  2. Design, document and test changes for each type of template: 2 days
  3. Carry out changes for each template: 10 minutes per template x 357 templates = 3570 minutes 8.5 days
  4. Test changes to templates: 1 day.
  5. Total time required:
    Task Days
    Survey: 4
    Design 2
    Change templates 8.5
    Test 1
    ----
    Total 15.5 days
    ===

39. I would estimate the cost of the changes on the basis of my usual consultant's rate per day, $1,900.00. The cost estimate is therefore as follows;

15.5 days x $1,900 per day $29,450.00

Benefits to people without vision impairments

40. The changes that are required, in my opinion, to make the website accessible for Mr. Maguire will make the SOCOG website more accessible to people without vision impairments in the following ways;

  1. it would be quickly accessible by users with slow connections or older software and hardware.
  2. the site would be useable by non-English speakers in Australia and around the world who would be able to automatically translate the material on the site into other languages into other languages
  3. the look of the site would not be significantly changed for other users and their use would not be impaired.

Signed


See also:

Copyright Tom Worthington 2000.