September 2019 - Section 508 Compliance: 6 Tips to Stay on Track When Preparing Accessible Public Documents

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Public involvement is an essential component of the National Environmental Policy Act (NEPA), and when the Federal Government produces accessible documents, individuals with disabilities can review and engage with the project. It’s also the law! Section 508 of the Rehabilitation Act of 1973 requires Federal documents and websites to be compatible with assistive technologies, which make them accessible to individuals with disabilities. This section was created in 1998, as Congress recognized the need for regulations governing accessibility in technology and electronic devices. On January 19, 2017, the U.S. Access Board issued a final rule that requires contractors to provide Section 508-compliant deliverables for media that will be released to the public. Therefore, digital NEPA documents, such as Environmental Impact Statements (EISs) or Environmental Assessments (EAs), need to be Section 508-compliant. By creating high-quality documents that conform with Section 508 rules, you will ensure that the greatest number of people will have the opportunity to engage with the project and provide their comments.

Composite image of photos of the sun setting behind the mountains and hands using a tablet.
Source: GSA

Source: GSA

The U.S. Department of Health and Human Services (HHS) has produced a set of resources, including in-depth checklists and tools to help government and non-government users comply with Section 508. The checklists are based on the recommendations in the Web Content Accessibility Guidelines (WCAG 2.0). The guidelines are designed to assist website designers and document producers to create accessible digital documents.

We have gathered a few tips on how to create and publish Section 508-compliant documents that comply with the guidelines published by HHS. Although there could be additional changes that may be needed to bring a document into compliance, implementing these six tips will help you get your document on the right track and avoid unnecessary delays during the publication process.

Tip 1 – Use and customize Microsoft Word’s built-in heading styles for Headings and the Table of Contents

The Table of Contents is a guide for large documents and is a useful navigation feature for all users. WCAG 2.0 states that the Table of Contents should link to the correct sections of the document. Heading styles that are correctly applied throughout the document will ensure that the Table of Contents has the correct page number for each section. Using styles also ensures consistent formatting and easy updates to the look of the document. Tables of Figures and Tables can also be easily created using unique styles applied to the table and figure captions.

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Tip 2 - Generate and attach alternative text for all images in the document

Alternative Text Examples

Alternative Text Examples

Section 508 rules state that if a graphic is part of the narrative, it must have a text description associated with the image. Using only captions or a figure label below the image is not enough, so alternative text applied to the image ensures that the description is always available. The text description is called “alternative text” or “alt text” and is typically applied in the document processing program, as it can be applied once instead of during each Section 508 review. Logos, watermarks, and background images are often considered decorative, and would not need alternative text. They should be labeled as decorative or an artifact, so the screen reader will skip them.
Alternative text should be brief but contain enough description so that someone who is visually impaired can interpret what the image is showing. The image of the black puppy provides an example of appropriately descriptive text.

Tip 3 - Create simple tables without split or merged cells, or blank rows

Screen readers have the capability to distinguish tables from formatted text, so information presented in columns and rows should be inserted into a table instead of separated by tabs or other formatting methods. Tables that are correctly tagged have header and data cells in defined columns and rows, so users with adaptive devices can understand their relationship.
Tables can be considered simple or complex, and each writer should aim to create a simple table with well-defined rows and columns. Complex tables with multiple merged cells and inconsistent formatting mean that the screen reader can’t easily determine the relationship of the data. Identifying column headers is another easy way to ensure that the basic structure of the table is clearly presented.

Tip 4 - Use meaningful text and a contrasting color for hyperlinks

Readers with low vision may need high contrast colors to distinguish color changes. Hyperlinks and other highlighted items need to be presented in high contrast or otherwise identified so that users can identify them and select the link. The hyperlink text should also be meaningful. For example, the words “Section508.gov website” are more meaningful than “Click here”. The create link feature in Microsoft Word is a good start to create Section 508-compliant hyperlinks.

Tip 5 - Use list styles for bulleted or numbered lists

Lists use numbers, bullets, or other symbols before short sections of related text. Some assistive technologies allow the user to directly move from one list item to another, so applying numbered or bullet list formats creates the structure that the program can identify. Using a list structure also identifies list bullets as decorative, so they do not need alternative text.

Tip 6 - Use the “Save as Adobe PDF” option when converting to PDF

Finally, documents are typically published as PDFs for the public. When converting a PDF from Word, use the “Save as Adobe PDF” option under File or the Create Adobe PDF button under the Acrobat ribbon. These options will generate a tagged PDF, retain the alternative text, and save headings as bookmarks within the PDF. Using the Print option or a third-party PDF program is not recommended, because the tag structure and bookmarks may not be retained and would have to be manually recreated.

CONCLUSIONS

It can take time to ensure that publicly accessible documents like EISs or EAs are compliant with Section 508. However, knowing how to create an accessible document from the start will reduce the risk of schedule delays during the publication process and produce accessible documents that benefit the general public, while meeting NEPA and agency goals. Additional information on how to use Adobe Acrobat’s accessibility tools can be found in this paper, recently presented at the 2019 National Association of Environmental Professionals conference in Baltimore, MD. For more information on how PHE can help you with the NEPA process, or how to ensure your documents comply with Section 508, contact Melissa Secor, Project Manager at melissa.secor@phe.com.