PAS 78

PAS 78

Introduction: Public Available Specification

PAS 78 refers to the Publicly Available Specification published in 2006 by the British Standards Institution (‘BSI’). The BSI worked with the Disability Rights Commission (‘DRC’) and other organisations to develop the specifications which are intended to be used as a guide for businesses and individual who are commissioning a website from developers and require a point of reference to determine whether or not accessibility standards are being met. In this sense PAS 78 acts as best practice guidelines for website accessibility.

While websites in the UK have been required by legal to be made accessible since 1999, the standards and specifications laid out under PAS 78 allow website designers and owner to meet the requirements under the Equality Act 2010 (UK), ensuring that websites are accessible by and usable by disabled people. Typically the users of the PAS 78 will be UK businesses – the PAS is written from a business perspective - although non-profit organisations and charities will also find the specifications set out useful.

Function of the PAS

The function of the PAS 78 allows clarification, standard setting, and lets businesses make their expectations with respect to website accessibility clear to website designers. The PAS 78 includes usability testing requirements. While the standards is comprehensive, website designers are encouraged to consult with disabled people to test their designs at different stages rather than simply using accessibility software for testing inaccessibility problems.

For laypeople, PAS 78 highlights various technical aspects of website design, including HTML, CSS and JavaScript and then considers how disabled people use computers and websites. Issues such as technical testing or page validation and user testing and maintenance for disabled users are examined. The guideline also outline success criteria, accreditation schemes, accessibility auditing services, setting up CMS for disabled users, and further resources on web accessibility. It outlines how disabled people use websites as well as how to defining the accessibility policy for the website. PAS 78 refers to existing World Wide Web Consortium (‘W3C’) standards and guidelines.

The PAS 78 is not legislation. No obligations arise directly from the guidelines although obligations under the Equality Act 2010 (UK) will make use of the PAS 78 for definitions. Rather than providing a list of obligations that developers and owners can “tick off” on, the PAS 78 is to be used as an explanatory document that defines and explains web standards and technologies. For the layperson, it provides all the information and issues that they will need to communicate with customers and designers to commission an accessible website. In court proceedings, the PAS 78 could be used in cases where parties are seeking to enforce the Equality Act 2010 (UK).

Incentives to Ensure Accessibility

Beyond ethical and legal duties to make websites accessible to all people, there is a financial incentive to ensure accessibility. Recent estimates place the amount spent by individuals with disability to be at £80 billion annually¹. Where consensus for best practice for accessibility has been low in the past, the release of the guideline has since allowed for standards to be clarified. In cases where an organisation’s product or service is available exclusively through online channels, or where crucial information is made available through online channels, having best practice guidelines can ensure that individuals or entities relying on these channels are able to push for enforcement through court proceedings and courts can making rulings with greater clarity and consensus.

As the PAS 78 include guidance on formation of an accessibility policy, it helps organisations such as web design companies observe the law when formulate internal policies and procedures for website design, testing and maintenance of accessibility standards. Web consulting companies can use the guidelines to create accountability frameworks as they incorporate – but do not require – a high degree of technical knowledge. Arguably this is PAS 78’s most important function – promoting accessibility within organisations.

Relation of the PAS to Web Content Accessibility

While the PAS 78 was formulated with reference to the W3C’s Web Content Accessibility Guidelines (‘WCAG’), it differs from the WCAG because it was designed for laypeople and business owners without technical knowledge in mind – the guideline’s namesake being the goal of the creators to encourage public availability. The guideline states that measurable criteria must conform to WCAG’s Level AA standards, as opposed to the AAA standards. However, this is only a recommendation and it is not the purpose of the PAS to dictate the particular standard of WCAG that web developers are to observe. The higher the WCAG level the greater the number of disabled users able to access a site.

Benefits of Compliance with the PAS

PAS 78’s importance can be seen when one considers the fact that there are no national systems of accreditation for developers claiming accessibility in a website. A design company that can claim it is compliance with PAS 78 will establish more credibility among those who want to access the spending power of disable people.

Compliance with PAS 78 also encourages search engine listing or SEO. Because a website is more accessible, its content can be more easily transfer to other media – television, iPods, or mobile phones, allowing for a broader access when it comes to the organisation’s websites.

The positive impact of such guidelines flow on to the legal industry and legal compliance. Greater transparency and a set of criteria that provides tangible, measurable answers will assist those who begin proceedings with the goal of enforcing accessibility.

Litigation under the Equality Act 2010 (UK) (or the Disability Act 1995 (UK), repealed in 2010) present a real possibility to companies whose websites are not web friendly and accessible to disabled people. In this way, risk of incurring costs and delay through litigation were high for organisations that lacked internal policies or a general procedure for ensuring accessibility to users. However, accessibility brings with it other benefits such as an increase in organic search-engine results. Search engines are sophisticated enough to perceive a website’s accessibility and adjust rankings accordingly. Accessibility will lead to pages loading more quickly, which will tend to also increase search engine rankings as well as enhance user-friendliness of a website, and the general customer experience of  website. So making a website disabled-persons-friendly will also make it more accessible for non-disabled persons, which leads to more traffic and cost savings. Cross browser-compatibility and mobile device accessibility encourage increases in traffic numbers. Generally, accessibility will minimise the amount of time spent on managing existing content and site maintenance. Overall, companies that follow the PAS 78 will find a very real material benefit through optimised site performance as well as being able to connect with more disabled users.

Standards and Government Position on the PAS

The Central Office of Information released a document on website accessibility in 2007 intended to clarify the operation of the PAS 78². The document made clear that for best practice, government websites must ensure a minimum level of accessibility by the set timeline – which is considered to be Level AA of the W3C guidelines. With respect to the role of the PAS 78, the document pointed out that beyond the legal drivers, there were social, financial and technical incentives to observe the accessibility guidelines that would lead to tangible benefits for any organisation, and that it was up to any organisation to compose their own cost-benefit analysis. Citing Online Social Responsibility (OSR), the paper pointed out that there was a real social reason for government entities to address the needs of citizens by providing accessible websites and thus provide information on a wider scale – a benefit that can be translated to better market reach in the private organisation.

The paper also considered the fact that user-friendly and accessible websites tended to have reduced direct and indirect costs. While accessibility may not be the most urgent organisational concern, its cost benefits make it worth prioritising from any organisation’s point of view. It recommended the use of user profiles to define target audience for those commissioner websites which would then in turn assist with defining the appropriate assistive technologies to use. Different technologies may be available to those with vision impairment, motor difficulties, cognitive and learning, deafness and hard of hearing. Assistive technologies may include screen readers, Braille displays, screen magnifiers, speech recognition application, adaptive input devices such as on-screen keyboard emulators, and signing avatars.

Conclusion: Impact of PAS

In summary, the introduction of PAS 78 in 2006 has been very positive for all concerned. Within the web design industry, great transparency has allowed companies to formulate internal policies to ensure accessibility compliance. Companies, organisations, and individuals seeking to commission a website are able to define what they mean by accessibility when previously a lack of technical knowledge might have prevented them from being able to do so. Those seeking to enforce accessibility in court proceedings have also benefited from the clarity of the PAS 78 guidelines. Where previously civil proceedings under the Equality Act 2010 (UK) had no fixed guidelines to define inaccessibility, courts can now refer to the guidelines for a fairer and more consistent determination.

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