Voluntary Product Accessibility Template (VPAT) Review

Criteria 1194.22

This Criteria section is titled Web Based, as traditional coding practices were very limited. With modern coding practices we look more at what is the function of the product/service being reviewed and does this section contain information relevant to determining the accessibility in the related review.

The CSU reviews this section in relation to functionality regardless of that the product or service. The subsections below will contain the following:

  • The text of the section 508 criterion
  • Explanation of what the criterion is asking along with resource links if available
  • Cross reference information if applicable
  • Verification notes we give our campuses for reviewing VPAT's
  • Information on how this looks like it will overlay into the Section 508 Refresh
Criterion Resources

Criteria 1194.22(a)

A text equivalent for every non-text element shall be provided (e.g., via "alt", "longdesc", or in element content).

Clarification:

Images that convey information and are not purely decorative must have associated text descriptions. Text equivalents must be provided for all functional images.

  • W3C Non-Text Content
  • Further technical explanation of image criteria
  • Section 508 Refresh
    • WCAG 1.1.1 Non-text Content
    • WCAG 1.2.1 Audio-only and Video-only (Prerecorded)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects the specific methods used to provide text equivalents for functional images.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(b)

Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Clarification:

Videos must have captions and knowing the media player being used as the accessibility of the player can affect a users ability to view the captions. For example the captioning seen on videos such as YouTube or on some broadcast Television. CSU Captioning Guidelines: Captioning Methods for Delivery

  • Section 508 Refresh
    • WCAG 1.2.2 Captions (Prerecorded)
    • WCAG 1.2.3 Audio Description or Media Alternative (Prerecorded)
    • WCAG 1.2.4 Captions (Live)
    • WCAG 1.2.5 Audio Description (Prerecorded)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects the method that the captions are created and how accuracy is verified. (e.g. machine-generated vs. human transcriber, in-house vs. outside contractor).
    • A statement that reflects on the accessibility of the video player.(e.g. keyboard accessible controls)
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(c)

Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.

Clarification:

  • The context or meaning can be determined without color.
  • For example required form fields shown in red also need an asterisk to depict requirements. Further technical explanation of color criteria
  • For example link text only being shown with a color does not enough the use of underline or italics will help convey the meaning. Further technical explanation of link criteria
  • Section 508 Refresh
    • 407.7 Operable Parts - Color
    • WCAG 1.4.1 Use of Color

Cross References:

  • Section 508 - 1194.21(i) and 1194.25(g)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects what method is used to conveyed information with and without color. (e.g. bold, italic, font size or style etc.).
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(d)

Documents shall be organized so they are readable without requiring an associated style sheet.

Clarification:

  • Users must be able to apply their own cascading style sheets (CSS) to web applications or disable them all together without the loss of function or data. CSS controls the layout and color scheme of the application. If a Submit Button on a web application is lost when CSS is disabled, that would be a loss of functionality.
  • Further technical explanation of style sheets
  • Section 508 Refresh
    • WCAG 4.1.2 Name, Role, Value

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects the functionality and data integrity when user’s apply individual style sheets or disable the style sheet altogether.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(e)

Redundant text links shall be provided for each active region of a server-side image map.

Clarification:

  • Image maps are pictures with active regions that once clicked takes the user to other webpages.  HTML allows each active region to have its own alternative text. Because this is done in an image format the assistive technology cannot indicate the url to the user.  Creating a redundant links solves this issue.
  • Further technical explanation of image map
  • Section 508 Refresh
    • WCAG 1.3.1 Info and Relationships

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that redundent text links are consistantly used for image maps..
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(f)

Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape. Redundant text links shall be provided for each active region of a server-side image map.

Clarification:

  • Similar to above however, client side image maps allow for text to be assigned to the hot spots, which makes an alternative text for screen readers.
  • Further technical explanation of image map
  • Section 508 Refresh
    • WCAG 1.3.1 Info and Relationships

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that redundent text links are consistantly used for image maps..
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(g)

Row and column headers shall be identified for data tables.

Clarification:

  • Sighted users typically can read the column and row headers of a table to discern what the data is within the table. Additional identifying information related to a cell in a table (e.g. row header, column header) is needed for user that are not sighted or use other methods to navigate the table.
  • W3C Tutorials home » Tables Concepts
  • Additional information from CSUN UDC table structure criteria
  • Section 508 Refresh
    • 502.3.2 Applications - Alternative User Interfaces
    • WCAG 1.3.1 Info and Relationships

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the row and column headers are identified in data tables with a <TH> tag.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • The impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(h)

Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

Clarification:

  • Can user agents (e.g. browsers, AT) can determine the relationship between cells and multiple levels of headers.
  • Section 508 Refresh
    • 502.3.2 Interoperability with Assistive Technology - Accessibility Services - Row, Column, and Headers
    • WCAG 1.3.1 Info and Relationships

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that header cells have been identified and that the relationship between multiple levels of header cells has been identified consistently.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(i)

Frames shall be titled with text that facilitates frame identification and navigation.

Clarification:

  • Web pages created based on viewing areas may have separate navigation, these need to be announced to the user.
  • Further technical explanation of frames criteria
  • Section 508 Refresh
    • WCAG 2.4.2 Page Titled

Verification Notes:

  • Only applicable if there are separate viewing areas with separate navigation.
  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that the navigation for each viewing area is being announced to the user.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(j)

Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz..

Clarification:

  • Look for the screen to flicker similar to transitioning to one slide to another.  When the flicker is unexpected, unintended, and noticeable the frequency rate can trigger seizures, migraines, and be distracting to the end user.
  • This criteria does not address the flicker of the viewing device itself.
  • Section 508 Refresh
    • 405.1 Flashing - General
    • WCAG 2.3.1 Three Flashes or Below Threshold

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that flashing or blinking meets the requried standards.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(k)

A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.

Clarification:

It is preferable to make the actual page accessible rather than have a separate text only page or site. If created then it must contain all of the same information and functions of the main page or site.

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that all of the same information and functions of the main page were retained.
    • A statement that reflects that the entire accessible version has been tested to verify that all of the standard AT key shortcuts have not been overridden.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(l)

When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by Assistive Technology.

Clarification:

  • It is important that the vendor describe how A.T. functions with the scripting language.
  • Further technical explanation of scripting criteria.
  • Examples of scripting language: Javascript, Aria, Java, Python, ActionScript, etc.
  • Most modern webpages use some kind of scripting language within the product.
  • Section 508 Refresh
    • 502.3.5 Interoperability with Assistive Technology - Accessibility Services - Hierarchical Relationships

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that the product has been tested to determine that A.T. fucntions correctly with the scripting language.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(m)

When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l).

Clarification:

If another application is required in order to view or access the information then a link, plug-in or applet must be provided to download the program. For example a PDF requires a PDF viewer. The link, plug-in or applet must comply with all requirements ins section 1194.21.

Cross References:

  • Section 508 - 1194.21(a), 1194.21(b), 1194.21(c), 1194.21(d), 1194.21(e), 1194.21(f), 1194.21(g), 1194.21(h), 1194.21(i), 1194.21(j), 1194.21(k), 1194.21(l)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that appropriate links, plug-in or applets are availble to provide downloads of requried items for viewing informaiton.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(n)

When electronic forms are designed to be completed on-line, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Clarification:

  • Are the fields programmatically related to the labels? For Example explicit labels, keyboard operable, ‘required’ attributes.
  • Further technical explanation of Web Forms
  • Section 508 Refresh
    • 502.3.4 Interoperability with Assistive Technology - Accessibility Services - Label Relationships
    • 502.3.5 Interoperability with Assistive Technology - Accessibility Services - Hierarchical Relationships
    • WCAG 3.2.1 On Focus
    • WCAG 3.2.2 On Input
    • WCAG 3.3.1 Error Identification
    • WCAG 3.3.2 Labels or Instructions

Cross References:

  • Section 508 - 1194.21(l)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that all form fields are programmatically related to the labels.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(o)

A method shall be provided that permits users to skip repetitive navigation links.

Clarification:

  • Users need a method to skip to the main content of the page.
  • This method must avoid repetitive global navigation and navigation such as “breadcrumbs”.
  • Section 508 Refresh
    • WCAG 2.4.1 Bypass Blocks

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that skip navigation is available at the top of each webpage in the product.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.

Criteria 1194.22(p)

When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Clarification:

  • This is frequently seen on secure sites when the user is warned that they will be logged off.
  • Further technical explanation of timed response criteria
  • Section 508 Refresh
    • 407.5 Operable Parts - Timed Response
    • WCAG 2.2.1 Timing Adjustable

Cross References:

  • Section 508 - 1194.25(b)

Verification Notes:

  • When Supports is chosen look for the following information in Remarks and Explanation column:
    • A statement that reflects that the entire application was tested to verify that the user will have sufficient time to extend their login without being automatically logged out.
  • When Supports with Exceptions is chosen look for the following information in Remarks and Explanation column:
    • What is the impact of the user’s inability to complete any core functions of the application due to the exception or lack of support for this criterion.
  • Note that for responses that include Supports with Exceptions and Not Supported drive the completion of the elements of the Accessibility Road Map and information to users on the Accessibility Statement.