Whether accessible goods are procured is critical to the success of accessibility programs
This article is not legal advice. This is a general opinion article and should not be relied upon for any legal situation. Always consult an attorney who specializes in accessibility for your needs.
When I start talking to a new organization about accessibility, I start with three basic questions, none of which have to do with testing the products the company sells.
- Does the organization have a robust disability ERG? I’ve written three articles on this topic that you can access from this list.
- How difficult is it for the disabled employee to navigate the organization’s accommodations program? I’ve written five articles on accommodations from the perspective of employees, managers, COVID-related requests, and mental health-related requests that you can access from this list.
- How does the organization focus on procuring accessible goods and services? That will be the focus of this article.
Repeatedly, I’ve seen these three factors as reliable leading predictive indicators of whether an organization will have a successful and sustainable accessibility program that is holistically integrated throughout the organization.
But what is so special about these three questions that are almost totally unrelated to an accessibility testing program?
- Even large accessibility programs typically have a ratio of accessibility testing engineers to developers of only 1:600 to 1:1000.
- Successful accessibility programs require people to talk about accessibility when those accessibility team members are not in the room.
- To have people talking about accessibility when those accessibility team members are not in the room, organizations need many employees that have disabilities and are willing to talk about them without fear of reprisal.
- To have many employees with disabilities they are willing to talk about, organizations require a robust disability ERG.
- Organizations must support disabled employees with a procurement program that doesn’t exclude them.
- When an accessible choice can’t be procured, the fallback (not the first approach) is how easily the disabled employee can get an accommodation.
If disabled employees can’t be authentic about their disabilities and their needs are constantly being ignored (at best), or they are being actively discriminated against (at worst) when procurement decisions are made, they may look for employment at an organization that does a better job at making them feel like they belong. While the organization’s products may be periodically accessible, maintaining proactive accessibility will be a struggle because of the lack of disabled employees participating in the process.
Accessibility Conformance Reports / Voluntary Product Accessibility Templates (ACR/VPATs) contain precise information about the accessibility status of a given product. Depending on the product complexity and the number of exceptions that need to be described, they can run hundreds of pages. Most private-sector procurement teams don’t have an accessibility subject matter expert onboard.
All that introduction leads to the big question:
How do you ensure you aren’t excluding employees with disabilities when the procurement team has no accessibility experts?
Alternative 1: Use the experts you do have from other teams
Accessibility testing teams should be ready, willing, and able to support the procurement team to help them buy more accessible products. On average 30 % of accessibility team members have disabilities, and they will directly benefit from the procurement of more accessible tools.
Two years is generally enough experience for an accessibility subject matter expert to give a quick thumbs up or down of a particular product’s level of accessibility. If an organization doesn’t have an accessibility team yet, or if the accessibility team doesn’t have the bandwidth, the procurement team could bring on a short-term contractor with the appropriate experience level to provide input to the procurement professionals. Short term contractors come in all budgetary shapes and sizes from low-cost vendors outside the United States to expensive US-based contractors. However, getting an accessibility SME does not need to be difficult or complicated.
What do you do if you are on such a thin budget that you can’t afford even the cheapest outside accessibility consultant? Then what?
Alternative 2: Digest the ACR/VPAT yourself
There are 3 parts to digesting an ACR/VPAT quickly without having to comprehend and read the entire novella. The steps I identify below will cover the most common disabilities.
Part 1: Identify what kind of ACR/VPAT you have.
There are four types of ACR/VPATs — Section 508, WCAG, International, EN 301 549. This is listed on the first page.
Part 2: Check the date and version number.
To be useful, the version number of the product in the ACR/VPAT should be close to the version number you are planning to buy and should have been done in the previous 12 months. This information should also be on the first page of the ACR/VPAT.
Part 3: Check some ACR/VPAT specifics, disability by disability.
If you have an INT or EN 301 549 ACR/VPAT, the following three functional performance criteria will tell you a lot about how accessible the product is. ACR/VPATs usually are posted in .PDF files which may be locked from editing but still can be searched. These are:
•302.4/302.5 — Without Hearing / With Limited Hearing
•302.3 — Without perception of Color
•302.1/302.2 — Without Vision / With Limited Vision
If any of these sections say anything besides “Supports,” that means the product is not fully usable by people with the identified disabilities. Making things work for people who are deaf or blind is easier than making things work with a switch for someone with cerebral palsy or quadriplegia. If the three FPCs identified here have exceptions identified, chances are nothing was done for people who use more rare forms of assistive technology like sip and puff devices.
If you have a WCAG or Section 508 type of VPAT, there are no functional performance criteria, so you need to know which specific WCAG criteria look for. The ones I recommend looking for first are:
- WCAG 2.1.1 and WCAG 2.1.2 indicate whether the product is fully keyboard accessible. If this is anything but “supports,” stop. There is no way the product will be accessible.
- WCAG 1.4.4 and WCAG 1.4.10 indicate whether the product will work via magnification and reflow properly for people who have low vision. People who are low vision also have more need of keyboard focus indicators, those rules are identified by WCAG 2.4.7 and WCAG 1.4.11
- WCAG 1.2.2 Are videos captioned?
- WCAG 1.1.1, WCAG 1.3.2, WCAG 4.1.2 are the most important criteria that indicate whether the product will work for screen reader users. If any of these have anything but “supports” it doesn’t matter how good the rest of the product is with respect to screen reader use, it probably won’t be good enough.
What if there are no accessible options?
Blockchain has no accessible options that I know of. Neither do design tools. If you need to buy something where there are no accessible options and you want to demonstrate that you are a disability-inclusive organization, then it should be on the business owner making the purchase to put together an accommodations plan. You made the decision, you should bear the work. Don’t shift it to the people with disabilities you are discriminating against, but work with those individuals to make sure that you are creating an accommodations plan WITH them, not FOR them. Then discuss with the vendor the fact that accessibility is important to you as a customer.
The first step in making your tools selection more inclusive is to STOP THE BLEEDING. You can’t resolve your accessibility debt until you drastically slow down, or eliminate, inaccessible purchases. Then create an inventory of what you have that your employees with disabilities can’t use, prioritize by the number of people using them, and start to work with those vendors to make their tools more accessible. If you do that, you are making them more accessible for everyone, not just your disabled employees. That is the definition of true disability inclusion.