Joe Clark: Accessibility | Design | Writing

Comments on AODA information and communications standard

The Accessibility for Ontarians with Disabilities Act (AODA) is a rather weak piece of legislation that gives businesses and other organizations in Ontario until the year 2025 to become accessible to people with disabilities. One of the tasks of the Accessibility Directorate of Ontario is the creation of a standard for information and communications.

That sounds like trouble right there, doesn’t it? A government agency setting down rules for how you communicate? These things have a tendency not to end well.

I applied for membership on the committee and was turned down. The membership list is filled with unknowns (except for Geoff Eden, a known blind activist). That isn’t so bad, of course, but here “unknown” could be synonymous with “no existing knowledge of accessible communications.”

When forming the committee, the ministry involved did at least resist the temptation to stack it with functionaries from known organizations, though the CNIB is in there, an important point we will return to shortly.

I have an initial “draft” of the committee’s standard, still very much unfinished and dated 2007.11.06, and have certain comments to give.

The most serious defect

The accessible information and communications standard will recognize and consider other similar standards, regulations and legislation, including standards developed under the Accessibility for Ontarians with Disabilities Act... and the Ontario Human Rights Code.

“Recognize and consider” may be the goal, but in practice, the “draft” simply rubber-stamps other standards and gives them the force of law. It does so even when the standards really aren’t standards, were never user-tested, and have been rejected by the open market. That describes several of the standards mentioned in the draft.

This is a job for the Open & Closed Project

Captioning and description standards need to be developed independently and tested to prove they work. Having the industry jot down its own best guesses is self-serving at best. It’s been attempted over and over again and has failed.

I never used to be interested in government funding for the Open & Closed Project, but if this is what the Ministry wants to do, it’s time to submit an application. The government can’t force every organization in Ontario to comply with rules that somebody else pulled out of thin air.

Claim of technology-neutrality

The standard will not prescribe specific technology so as to promote innovation.

That’s badly written. More substantively, staying technology-neutral can produce incomprehensible standards (Cf. WCAG 2). Many sections of the current “draft” refuse to say what they mean. What are they actually talking about?

Some technologies, like actual fonts, are specifically required. (That isn’t a stretch; see my Clear Print discussion. And technology-neutral is explicitly defined as “not predicated on any individual technology or style of interface” [emphasis added]. Fonts are a style of interface.)

Being technology-neutral isn’t a bad idea; it’s just very difficult to do in practice.

So let’s go through some examples.

“Timely” access

Information must be “timely,” that is, “in a timeframe equivalent to that experienced by others.” (There’s no verb in the sentence.)

This is impossible in practice. Only in the highest-profile, highest-budget cases do accessible versions of books, for example, appear exactly when the regular-print editions do. It is imaginable that standard and accessible versions could be produced simultaneously, but not without undue hardship in some cases. Of course, for certain electronic documents, the standard version is the accessible version.

As written, every publisher in Ontario that refuses to issue large-print books (solely the copyright holder’s prerogative), or that does so after the regular-print book is issued, could be hauled before a human-rights tribunal. And that will happen, because members of the Alliance for the Equality of Blind Canadians have been talking about doing exactly that for years. Now they’ll have a legislative method to launch such nuisance complaints.


Many definitions are ill-written or simply incorrect. (Like the entire document, copy-editing is atrocious and I have cleaned up their numerous Windows 98–style mistakes.)

But that’s not all!

They haven’t finished two other topics yet (among more than eight):

With the CNIB on board, there will inevitably be an insistence on using only Tiresias for every sign. The committee, I speculate, is trying to figure out how to finesse the timing of the release of its own spec to coincide with WCAG 2 so it can require the use of WCAG 2 everywhere in Ontario.

Posted: 2007.11.26 ¶ Updated: 2008.03.20 11:32

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