From Well Meaning Guideline to Stealth Standard
Access to learning for all students is a value that is hard to dispute for anyone working in the education sector. Within the areas of education that are concerned with supporting disabled students, it has almost become dogma that in order to provide this 'universal access' we must have standards in design that can accommodate all (disabled) learner needs. This view is supported by legislation:
"...it can be seen that there is likely to be a duty on higher and further education institutions to ensure that their online teaching resources and VLEs are provided in a form accessible to disabled students. Further, institutions will be expected to make 'reasonable adjustments' to overcome these problems and are unlikely to be able to justify continuing discrimination." 
However, unpicking the legislation is a little more difficult and at no point in his article does Sloan state that compliance with any form of standards ensures compliance with legislation.
The rapid development of e-learning and the continuing development of technologies associated with it have generated a host of standards, mainly aimed at ensuring that formats are interoperable, facilitating the sharing of resources. Whilst there was development in this area, it seemed that many people were quite happy to cite the W3C Web Content Accessibility Guidelines (WCAG) as a 'standard'. This view was perhaps brought about because of the close links that many web developers had with e-learning, and in some areas e-learning is still synonymous with 'the web'.
With regard to e-learning, what needs to be remembered are the needs of the end user: the learner.
"...Careful and judicious use of internationally recognised pan-disability design guidelines is important, but never forget that the best way of ensuring an accessible piece of e-learning content is to actively involve disabled people while developing it - engagement with institutional disability support is an obvious and essential first step." 
In education, the long-term strategy must be by treating the issue in a holistic manner, by looking at the role of a web site in the overall delivery of learning and teaching - using e-learning to enhance the accessibility of the traditional learning environment. Accessibility must be embedded into institutional policy through staff development programmes, provision of appropriate tools to help staff create accessible e-learning, and a staged improvement in accessibility of current resources.
Kelly  reports that recommendations were made at the national Institutional Web Management Workshop held in September 1999 that the WAI-Quick Tips Card  be ordered in bulk and distributed widely in institutions. Whilst this was appropriate at the time, in context it may have been the beginning of a misunderstanding in the provision of e-learning to a diverse student body. Undoubtedly, at that stage e-learning developers would have used these quick tips as a starting point for accessibility, whereas it was aimed solely at staff involved in the development of institutional websites. This approach was reinforced by other agencies (including these authors and TechDis) which in the absence of guidelines for e-learning accessibility grasped the WCAG and suggested that it was a good approach for e-learning accessibility.
In Ideology Or Pragmatism? Open Standards And Cultural Heritage Web Sites  begin to identify some of the problems associated with applying a set of guidelines aimed at a web technologies to areas of learning and teaching. They further argue that the W3C WCAG had in fact become a 'stealth standard', whereas the original intention was they were (as stated) guidelines. These ideas were developed further in papers in both learning technology journals and learning and teaching journals addressing issues such as quality assurance  and pedagogic issues . It could be argued that the W3C WCAG have themselves made the situation worse. Web site authors can be quick to state they comply with a WCAG level, when in reality, they only comply with a limited set of automated checks. This leads to the authors thinking they have met the accessibility criteria by complying with an ill-defined 'standard'.
In 2004/5 TechDis were asked to provide a defining set of guidelines for the Joint Information Systems Committee (JISC). Initially a review of existing guidelines and standards was undertaken as well as legal clarification in light of disability legislation. A consultation then sought to bring together a series of guidance notes. However, it proved very difficult to retain the integrity of the notes and after several wider consultations it became clear that any form of guidance would be interpreted as prescriptive, the antithesis of the original intentions.
A Pragmatic Approach
In trying to provide pragmatic guidance what emerged was a suggested framework for developers that could be applied at various points in an e-learning development cycle. What is demonstrated below is the result of discussions with colleagues in both the disability and e-learning areas of education. It is also 'work in progress'; we are not seeking to claim that this is the final answer, but hope that it does help contribute to the discussion. The final caveat is that this is designed to be applicable to UK education institutions; we are not trying to create a model that will fit all areas of e-learning.
In using the framework below it is suggested that developers document in some way the process as they work through it. This will be useful if challenged, but also as a means of reflecting on the process when undertaking further developments.
|Stage One||Stage Two||Stage Three||Stage Four|
|Understanding of resources under development in relation to inclusion||Identification of existing established practices||Assessment of applicability||Identification of Alternative, Intervention or Adjustment|
Stage One - Awareness
Here the developer is asked to consider specific issues relating to the development of e-learning material and consider the needs of disabled students. For example, it is suggested that, if an online assessment is being created, the developer should be aware that there are issues related to how someone with a vision impairment would access it.
Stage Two - Investigation
Here the developer, after becoming aware that there may be some issues with the resource, investigates what existing guidelines, 'standards' or practices are available that would support the resource under development in relation to inclusion. For example, it may be that the use of W3C guidelines are applicable in the creation of some content.
Stage Three - Understanding
This is where the developer must make a value judgement: are the practices they have identified in stage 2 valid for the resource under development? Furthermore, they must ensure that the application of the guidelines, 'standards' or practices does not compromise the learning objective or outcome. For example, in an online assessment using images, an alt tag (describing the image) must not give away the answer.
Stage Four - Implementation
This is probably the most important stage to document, after working through the processes and either developing a resource that is 'accessible', or one that may be inaccessible to some audiences it may be necessary to identify other ways of achieving the learning objective. For example, a totally inaccessible online assessment, due to the material or system constraints, may be overcome by holding a viva voce for the student, or an inaccessible discussion group may result in a small group discussion with other students. Documenting these areas is important to ensure that the developer recognised the issues and began the process of identifying alternatives or adjustments.
By adopting the framework approach it will be straightforward to include user feedback into the design process at all stages and thus will assist the development of achievable, sustainable services that benefit all users.
The Next Steps
Currently TechDis is working with the Higher Education Academy Subject Network  and the JISC to identify cases at each stage of this framework as a basis for guidance. This will occur over the next twelve months and involve various other agencies. In addition TechDis is also working with the e-Learning Research Centre at Manchester , identifying ways in which the process of harvesting practices can be automated and also the formalisation of the process.
- Sloan, M. (2002). E-Learning and Legislation. Retrieved September 1, 2004, from TechDis Web site: http://www.techdis.ac.uk/
- Witt N.A.J and Sloan D (2004), access as the norm, not an as add-on, Times Higher Education Supplement, ICT in Higher Education, April 30, pp14-15.
- Kelly, B. (1999) Report on the "Institutional Web Management: The Next Steps" Workshop http://www.ariadne.ac.uk/issue21/web-focus/
- W3C (1999) WAI-Quick Tips, http://www.w3.org/WAI/References/QuickTips.html
- Kelly, B. Dunning, A. Guy, M and Phipps L (2003) Ideology Or Pragmatism? Open Standards And Cultural Heritage Web Sites. Presented at the ichim03 conference held in Paris on 10-12th September 2003. Paper published in the conference proceedings http://www.ukoln.ac.uk/qa-focus/documents/papers/ichim03/
- Kelly, B. Phipps, L and Swift, E. (2004) Developing A Holistic Approach For E-Learning Accessibility. Canadian Journal of Learning and Technology, 2004, Vol. 30, Issue 3 http://www.ukoln.ac.uk/web-focus/papers/cjtl-2004/
- Phipps L (2002) Are You Reasonably Adjusted? Educational Developments 3.4, Staff and Educational Development Association
- Higher Education Academy Subject Network Page http://www.heacademy.ac.uk/474.htm
- The e-Learning Research Centre http://www.elrc.ac.uk/