Web Magazine for Information Professionals

Bring Your Own Policy: Why Accessibility Standards Need to Be Contextually Sensitive

Brian Kelly, Jonathan Hassell, David Sloan, Dominik Lukeš, E A Draffan and Sarah Lewthwaite argue that rather than having a universal standard for Web accessibility, standardisation of Web accessibility practices and policies needs to be sufficiently flexible to cater for the local context.

Initiatives to enhance Web accessibility have previously focused on the development of guidelines which apply on a global basis. Legislation at national and international levels increasingly mandate conformance with such guidelines. However large scale surveys have demonstrated the failure of such approaches to produce any significant impact.

We review previous critiques of the limitations of such approaches and introduces a new scenario – content for people with learning disabilities – in order to illustrate the limitations of resource-based standards. We describe how BS 8878, a code of practice developed in the UK which provides a standard for the processes used in the development of Web resources, has been deployed in an institutional context.

We conclude by emphasising the importance of standards, especially to support the procurement of goods and services by government bodies. However rather than standards for describing Web content we argue that standards are needed which can be used across the wide range of uses which are being made of the Web, the variety of user contexts and the differences in interpretations of ‘accessibility’ and ‘disability’, especially across developing and developed countries.

Standardisation at national and international levels tends to focus on resource-based models such as the WCAG, ATAG and UAAG guidelines which comprise the approach to enhancing Web accessibility developed by WAI. In this approach the emphasis is on conformance with globally agreed technical standards for creating, viewing and describing digital resources. However despite such standards being well-established and well-known, evidence demonstrates the low level of conformance with such standards [1]:

According to the latest report from MeAC (Monitoring eAccessibility in Europe) still less than 10% of all websites in the EU are fully accessible.

The EU appears to regard such evidence as a call for further standardisation based on global standards [2]:

The European Commission's proposal for a new Directive aiming at the approximation of the laws, regulations and administrative provisions of the Member States on the accessibility of websites of public sector bodies.

In this paper we argue that in light of the failure in over a decade in which governments have mandated conformance with global standards there is a need for an alternative approach, which allows for appropriate measures to be implemented which take into account the context of the use of a Web product.

Problems in Mandating Global Accessibility Standards

Previous Work

The challenges of enhancing accessibility in an e-learning context were initially addressed in 2004 [3], with the limitations of WAI’s global model for enhancing Web accessibility summarised in 2005 [4].

More recently de Santana and de Paula [5] have reported on a study involving Alexa.com’s top 1,000 popular websites and a sample of random 1,000 websites to verify and contrast the conformance of these disjoint sets with WCAG accessibility guidelines. They reported that only 40 of the 922 (4.34%) popular Web sites had no problems whatsoever and, for the random selection of Web sites the findings were 147 out of 987 web sites (14.89%). Despite this evidence which suggests that conformance with WCAG guidelines is still not being regarded as important the authors argue that ‘the removal of accessibility barriers is required in order to promote user interface (UI) use’ (our emphasis) and concluded by stating ‘conformance with coding guidelines is not sufficient but is necessary’.

The authors of this paper argue that the evidence of a series of large-scale analyses of WCAG conformance dating back to 2004 [6] demonstrates that other approaches are needed. Our previous work focused on the limitations of the WAI model of web accessibility in isolation, in areas such as e-learning, highlighted the need for a contextual approach as first proposed in 2006 [7]. Recent WAI activities, such as the e2r activity [8] has highlighted the importance of contextual approaches related to the writing style used in Web resources. In the next section we use this example to illustrate further the need for contextual approaches to accessibility.

Accessibility Values and Types of Criticism

Little critical attention has been given to the values and principles that motivate and critique Global Accessibility Standards. At present, thinking about web accessibility tends to focus on evaluating technical feasibility, practical applications and operational outcomes; indeed these concerns constitute the latter part of this paper. However, attention to foundational concepts allow us to gain insights into the efficacy of particular approaches (as expressed in critiques of Universal Design [9]). From this perspective, Global Accessibility Standards can be viewed as normative; Standards supply one view of acceptable practice, arguably exporting a world-view that could be counter-productive in non-Western local contexts where disability is understood and constituted very differently [10]. Indeed, although anecdotal evidence indicates that (for example in the Middle East and Africa), technical guideline conformance is seen as a means to demonstrate an enlightened approach to supporting disabled people, in line with a desire to improve conformance with the UN Convention on Human Rights, this is arguably a hierarchical political action. Without context, it cannot fully engage with local knowledge and the reality on the ground.

From this point, many critics have demanded more evidence-based standards - this has brought forward a drive towards data collection, through activity such as survey work and web analytics. However, this has its own practical problems. It is difficult to ensure international and comparable measures or ensure sufficiently complete data. Moreover, as with normative and legal approaches, this way forward does not recognise how the process of categorising and sorting (disabled and non-disabled, accessible and non-accessible) shapes thinking about disability and difference itself [11]. It does not easily account for the contingent aspects of disability or grey areas that are context-dependent.

Contextually sensitive approaches allow for disability to be understood as an interaction, not a given property of a product or user. This situates the user, the developer and the product. From a theoretical standpoint, embedding a focus that engages local expertise and recognises the socio-cultural arrangement of diverse local contexts is essential to the evaluation of whether Standards represent the most coherent approach to creating accessible experiences with global reach. As disability studies have shown, ‘there is no neutral language with which to discuss disability’ [12]. Only contextually sensitive approaches can account for the complex power relations that govern who is understood to be disabled and who can and cannot access digital resources, to ensure that those who are most disenfranchised are empowered and enabled online. We now illustrate the need for context, using the example of simple language, in this case English.

Standards for Simple English

Debates over simple English underscore the need for contextuality. Simple English represents a drive to increase access to content by reducing complexity and ambiguity. However, these concepts are not straightforward or unambiguous. The notion of linguistic complexity has been hotly debated for over a century. It is clear that it involves more than length of words and sentences (the main measures used for automated scores of text readability) or a particular sequence of words (Subject-Verb-Object is often mistakenly quoted as somehow more direct than alternative word orders). We know that, according to these measures, children acquiring languages more complex than English experience little difficulty, nor do adults have much trouble in processing such structures. Indeed, sometimes a longer form is better for communication because it provides much needed redundancy in crowded communication channels. That's why a phone agent will use say 'A as in alpha' rather than just 'a' when spelling a word to provide more context to the customer.

Neither is ambiguity an unquestionable evil. As any reference dictionary will reveal, on its own, every word in the English language is ambiguous. Words need context to make any sense. Context will make it clear what function the word has, which particular sense of the word is being invoked and what intention the speaker has. And the same applies to phrases, sentences and even whole texts. Reading Gulliver's Travels is a vastly different experience for a modern child compared to what it would have been for a Whig politician of the 18th century. The former sees it as a wonderful and imaginative tale to be drawn, the other as vicious satire to be suppressed - it is not just the context within the text but also the context outside text, such as the knowledge the reader possesses at the time of reading.

This will often pit the principles of simplicity against each other. For instance, a speaker of English as an Additional Language is more likely to understand words with Latinate roots than their ‘simpler’ Germanic counterparts. Thus, ‘frequently’ maybe be more accessible to somebody with limited English than ‘often’.

One suggested method of achieving accessibility of text is ‘being conversational and direct’. But while ‘I get it’ is simpler than ‘I understand’, it is more ambiguous; and while direct, it is simply not appropriate for most written documents; the type of document being produced may be an equally important aspect of the context as anything else. It implies an audience, level of formality, expectation of background knowledge, mode of delivery, etc. ‘Exsanguinate’ may be a better choice for a medical paper than ‘bleed out’ but few doctors would choose that kind of language to speak to a patient.

In short, making the content of official documents presented by government or private institutions to the public as understandable as possible is a laudable goal. But it can only be achieved by understanding the audience, their prior knowledge, the context in which they will be accessing the content, as well as their expectation of what such a communication will look like. A checklist of ‘dos’ and ‘don'ts’ is a part of the process of achieving this, but without being accompanied by educated judgement, it may produce dire results.

Flexible and Contextual Standards

The example above illustrates the limitations of standards which aim to mandate a particular approach which is independent of the context of use and the intended purpose of the Web resource.

The purpose of a Web resource has a massive impact on the cost-benefits of making it accessible. To give an example of an edge-case: the purpose of YouTube is to allow people to share video publicly for the benefit of other people, wherever they may be located. There are two aspects of this purpose that cause huge problems in terms of accessibility:

  1. Compared to the costs of making an image accessible, the costs of enriching a 5-minute video with captions and audio description is currently substantial.
  2. The site owner is not in control of the amount and content of video uploaded to their site, and it is not clear whether it should be the responsibility of YouTube or the people who upload video to add those access services to the video.

The challenge is in developing a standard that enables the great diversity in use cases, context and circumstance to be addressed. We feel that such standardisation should be based on the standardisations of the processes used in the development and deployment of Web products, rather than the particular technical aspects of the Web products or, in the case of the content, conformance with style guidelines.

The BS 8878 Code of Practice

About BS 8878

BS 8878 Web Accessibility Code of Practice [13] is a process-oriented standard created in the UK to allow organisations to:

  1. understand why digital inclusion and accessibility makes good business sense;
  2. embed inclusion responsibility strategically across key job-roles, and into key policies;
  3. follow a user-centred production process which identifies the key decisions which affect inclusion and which are taken in a Web product’s lifecycle;
  4. adopt an informed way of making these decisions;
  5. adopt a way of documenting these decisions to provide a log for assessing accessibility risk and proving conformance with BS 8878; and
  6. synchronise these activities with similar processes for the inclusive design of non-digital products.

BS 8878 adds a framework to technical accessibility guidelines like WCAG 2.0 to ensure all aspects of an organisation’s activities which impact inclusion are covered. These include: procurement and selection of production tools and CMSs; outsourcing production to third-parties; project management of inclusive production; assessment of accessibility risk and impact on budgets; selection of the more effective testing methodologies to assure accessibility alongside usability, and governance of inclusion across a programme of Web production projects.

At its heart, BS 8878 encourages organisations to make all accessibility decisions based on the purpose of their product, its specific audiences, and a clear, researched understanding of the contexts in which those audiences will use the product. In the light of this research, organisations can then make high-level decisions on the overall degree of accessibility they wish the product to have, and more detailed decisions on the accessibility of user journeys to each of its goals based on the relative importance of the goals and the cost-benefits of making it accessible to that degree. From there organisations are advised on the relative cost-benefits of different testing methodologies for them to use across the lifetime of the product to assure themselves that they have achieved the degree of accessibility they were aiming for.

The Benefits of a Flexible Approach

Accessibility decisions are rarely made in a vacuum – with fixed project budgets and deadlines, most decisions are trade-offs of value between different users and parts of the product. Time spent on making a media player accessible may be time deprived from finessing information structures for navigation. Money spent on WCAG 2.0 AA auditing may be money deprived from testing the usability of the product with real people. Money spent on adding captions to a video to help people with hearing impairments will be money deprived from adding audio description to help people with visual impairments.

BS 8878’s focus on the specific purpose, audiences, and context of the product being created helps Web site production teams to make these tough decisions, balancing the relative needs of different groups of (disabled and non-disabled) users from different parts of the product. It prevents a ‘cookie cutter’ approach to accessibility, allowing accessibility decisions made in the creation of an online game-based site for 5-year-olds to be different from decisions made in the creation of a site to help older people appreciate Shakespeare.

It also enables up-to-the-minute changes in the context in which people use Web sites to be taken into account in decision making. BS 8878’s process-based approach allows organisations to make sensible decisions about where to prioritise their accessibility time across mobile (browser and app), tablet and desktop versions of their product, and points to accessibility standards that can be used to help accessibility on each.

Experiences In Using BS 8878

As part of the process of updating the Web services throughout the University of Southampton, the Web4All Project [14] (see Figure 1) was established with the goal of embedding accessibility processes throughout the lifecycle of university Web products.

Figure 1: The Web 4 All Web site

Figure 1: The Web 4 All Web site

The 16 steps in BS8878 were grouped into sections that could be completed in stages, allowing for an agile and iterative process of user-centred design [15]. Contact with the content manager is the beginning of the user requirements phase (steps 1-6). This is followed by an analysis of those requirements and then the allocation of team members to take the process through from steps 7-12. Finally the production team, who have been liaising with the content manager, take on the next phase.

This sounds simple, but universities are having to accept change and increased constraints, with a difficult economic climate and an ever-widening target audience. They require outward-facing Web services marketing ‘products’ in a similar fashion to commercial companies and yet they need to maintain academic rigour in terms of information provision. Their Web services also have to attend to the inward-facing requirements of those working and studying within an online administrative, teaching and learning environment that hosts an enormous range of materials.

BS 8878 sets out examples for ‘common degrees of user-experience for different user groups and goals’ under the headings of ‘technically accessible, usable and satisfying’ - for example, screen reader users must be able to reach the Web site, then read and navigate their way around in an enjoyable manner. However, multicultural European-based organisations may also have to accept an increase in imagery and use of videos in order to engage those from Asian and Middle Eastern nations who are more used to visual interpretations of information [16]. Audio-visual materials with captioning and transcripts have also been shown to benefit many students but there is a cost factor [17]. These requirements must be there at the outset, along with the acknowledgement of an increased use of massive open and online course materials with their ‘pick-and-mix’ offerings from different organisations, countries and cultures. Steps 1-6 are becoming more exacting and it is tougher to complete steps 7-12 under time constraints, not forgetting that responsive design and production needs to cater for accessibility in its widest sense, so that consumption on desktop and portable technologies is a satisfying experience.

The Need for International Standardisation

We live in a global world where organisations that own Web sites are increasingly multi-national, and the nationality of the components and suppliers they use to build their Web sites is not something they wish to constrain them. This ability to choose tools and suppliers from anywhere on the planet frees organisations to make decisions based on suitability of the tool rather than nationality of the supplier. But this freedom also comes with hidden complications: what Standards did the supplier use to create the tool? Was it built to the Dutch accessibility standards? Does it have a Section 508 VPAT? What level of accreditation did it achieve in the Hong Kong Web Accessibility Recognition Scheme?

To meet these real-world needs, proposals have been made that accessibility standards should be harmonised globally. The proposed EU legislation [2] is one of a series of moves by cross-national organisations and companies producing tools to establish a common standard for accessibility, so companies can sell products worldwide without needing to modify them for different national standards. The benefit for organisations monitoring or governing accessibility is a single Standard against which to monitor sites in all the countries in which they operate.

The benefits of internationalisaton are also borne out by case studies of the use of BS 8878 in organisations in the UK (e.g. see [18]). While Web site owners have found that BS 8878 provides them and their suppliers with a better framework than WCAG for understanding the importance of accessibility within the context of the project's user experience, leading to clear communication as well as cost and time efficiencies, the lack of international knowledge of BS 8878 compared to WCAG means that the standard needs to be introduced before it can be used. Calls for the internationalisation of BS 8878 as an accessibility process standard to sit alongside the already internationalised WCAG 2.0 (ISO/IEC 40500:2012) have been made as far back as February 2011, and moves in this direction are expected in 2013.

What Next?

The need to provide support for all stakeholders involved in the production of Web resources, in helping them ensure these resources are as accessible as possible to their target audience, requires that global standards for accessibility strike a balance between technical accessibility of a web product and the quality of the process that was undertaken to create that product. There are important and valid reasons for standardisation of measures of Web resource accessibility; but equally, contextual factors such as geographical location, culture and economic factors as well as purpose, target audience and intended user experience need to be taken into account when measuring resource accessibility.

Kline [19] describes the complexity of the task of promoting accessibility successfully within a large organisational structure. To recognise this complexity, while encouraging focus on defining, implementing and documenting the process of creating accessible Web content, process standards such as BS8878 need to become more visible and given greater support at a global level. Complementing this, we need greater sharing of success stories as narratives of problems to be addressed, constraints within which work had to take place, what was done and the measurable evidence of impact in terms of positive experiences of disabled people - and of other users. This recognises the maturation of User Experience as a key quality of an ICT system, and its close relationship to genuinely inclusive design.


  1. European Commission (2013), Make websites accessible: a proposal and a request, Digital Agenda For Europe https://ec.europa.eu/digital-agenda/en/blog/make-websites-accessible-proposal-and-request
  2. European Commission (2013), Proposal for a Directive of the European Parliament and of the Council on the accessibility of public sector bodies' websites https://ec.europa.eu/digital-agenda/en/news/proposal-directive-european-parliament-and-council-accessibility-public-sector-bodies-websites
  3. Kelly, B., Phipps, L. and Swift, E. (2004). Developing A Holistic Approach For E-Learning Accessibility. In Canadian Journal of Learning and Technology, 30 (3), http://cjlt.csj.ualberta.ca/index.php/cjlt/article/view/138
  4. Kelly, B., Sloan, D., Phipps, L., Petrie, H. and Hamilton, F. (2005). Forcing Standardization or Accommodating Diversity? A Framework for Applying the WCAG in the Real World. In Proceedings of the 2005 International Cross-Disciplinary Workshop on Web Accessibility (W4A). DOI: http://dx.doi.org/10.1145/1061811.1061820
  5. Vagner Figueredo de Santana and Rogério Abreu de Paula. (2013). Web accessibility snapshot: an effort to reveal coding guidelines conformance. In Proceedings of the 10th International Cross-Disciplinary Conference on Web Accessibility (W4A '13). ACM, New York, NY, USA
  6. Disabilty Rights Commission (2004). The Web Access and Inclusion for Disabled People: A Formal Investigation conducted by the Disability Rights Commission, ISBN 0 11 703287 5
  7. Sloan, D, Kelly, B., Heath, A., Petrie, H., Hamilton, F and Phipps, L. (2006). Contextual Web Accessibility – Maximizing the Benefit of Accessibility Guidelines. In Proceedings of the 2006 international cross-disciplinary workshop on Web accessibility (W4A). New York: ACM Press, pp. 121-131. DOI:
  8. Easy to Read, W3C http://www.w3.org/WAI/RD/wiki/Easy_to_Read
  9. Imrie, R. (2012) Universalism, universal design and equitable access to the built environment. Disability and Rehabilitation. 34 (10): 873-882.
  10. Lewthwaite, S. and Swan, H. (2013). 'Disability, Web Standards and the Majority World'. IN L. Meloncon (Ed.) Rhetorical AccessAbility: At the intersection of technical communications and disability studies. Baywood.
  11. Foucault, M. (1970). The Order of Things: an Archaeology of the Human Sciences. London: Tavistock Publications.
  12. Altman, B., M. (2001). ‘Disability, Definitions, Models, Classification Schemes, and Applications’ IN G. L. Albrecht, K. D. Seelman, M. Bury (Eds.) Handbook of Disability Studies, Sage: Thousand Oaks.
  13. British Standards International (2010). BS 8878:2010 Web Accessibility – Code of Practice
  14. Web 4 All, University of Southampton http://www.southampton.ac.uk/web4all/
  15. S. Chamberlain, H. Sharp, and N. A. M. Maiden (2006). Towards a framework for integrating agile development and user-centred design. In Extreme Programming and Agile Processes in Software Engineering: 7th International Conference, XP 2006, Oulu, Finland, pages 143-153. DOI:
  16. Würtz, E. (2005). A cross-cultural analysis of websites from high-context cultures and low-context cultures. In Journal of Computer-Mediated Communication, 11(1), article 13
  17. Murphy, S.K. (2013). Oracle justifies the Cost of Captioning and Transcription for On Demand Video Training, 3PlayMedia
  18. Case studies of implementing BS 8878 (2012). Jonathan Hassell, Slideshare
  19. Kline, J. (2011). Strategic Accessibility: Enabling the Organisation.
    Live Oak Book Company

Author Details

Brian Kelly
UK Web Focus
University of Bath

Email: ukwebfocus@gmail.com
Web site: http://www.ukwebfocus.wordpress.com/
Blog: http://ukwebfocus.wordpress.com/

Brian Kelly has been UK Web Focus at UKOLN, University of Bath since 1997. Brian has published a wide range of peer-reviewed papers on Web accessibility since 2004.

Jonathan Hassell
London Metropolitan University

Email: jonathan@hassellinclusion.com
Web site: http://www.hassellinclusion.com/

Professor Jonathan Hassell is lead author of BS8878 - the British Web Accessibility Standards that help organisations to embed accessibility competence within their workforce, culture and everyday business processes.

David Sloan
School of Computing
University of Dundee

Email: dsloan@paciellogroup.com
Web site: http://www.paciellogroup.com/
Blog: http://58sound.com/

David Sloan is an Accessible User Experience consultant with The Paciello Group. He previously spent nearly 14 years at the University of Dundee as a researcher, lecturer and advisor in inclusive design and accessibility.

Dominik Lukeš
Education and Technology Specialist
Dyslexia Action
Park House
Wick Road

Email: DLukes@dyslexiaaction.org.uk
Web site: http://www.dyslexiaaction.org.uk/

Dominik Lukeš, Education and Technology Specialist at Dyslexia Action, has published research in the areas of language and education policy. He has also worked as editor, translator and Web developer.

E A Draffan
Electronics and Computer Science
University of Southampton

Email: ead@ecs.soton.ac.uk
Web site: http://www.soton.ac.uk/

E A Draffan is a Speech and Language Therapist specialising in Dyslexia, as well as an Assistive Technologist and researcher in the Web and Internet Science (WAIS) Group at the University of Southampton with interests in the accessibility of digital publishing, online learning and social networks. She has published peer-reviewed papers on the subject.

Sarah Lewthwaite
King's Learning Institute
King's College London

Email: sarah.lewthwaite@kcl.ac.uk
Web site: http://www.kcl.ac.uk/
Blog: http://www.slewth.co.uk/

Sarah Lewthwaite is a Research Associate in Student Experience at the King's Learning Institute, King's College London. Her research interests focus on intersections between disability studies, education, social media and accessibility.