Creating an Organizational Accessibility Roadmap to Address Air Carrier Access Act Requirements

Travelers with Disabilities

• According to the U.S. Census, 56.7 million Americans (18.7% of the US population) had some type of disability in 2010

• Global population estimated at 600 million• Disability Types

– Visual (Blind/Low Vision)– Auditory (Deaf/Hard of Hearing)– Mobility– Speech– Cognitive– Age Related (At least 37% of people 65 and

older have a disability)

The World is Changing

• The number of people with disabilities is on the rise due to many factors.

• Technological advances• The United States, along with many other

countries, has been taking major steps to ensure the rights of people with disabilities.

• Air Carrier Access Act• FCC CVAA• Digital Divide• Corporate Social Responsibilities

Disability is Part of Diversity!

Air Carrier Access Act

• Prohibits discrimination on the basis of disability in air travel and requires airlines and agents to accommodate the needs of people with disabilities

• The U.S. Department of Transportation issued rules on Nov 12, 2013 related to Accessibility of Web Sites and Automated Kiosks at U.S. Airports

• U.S. and foreign air carriers (operating at least one aircraft with 60+ seating capacity) operating flights for or selling tickets to the U.S. public must ensure that the public-facing content of websites they own or control conforms to the WCAG 2.0 Level AA

Overview

Air Carrier Access Act

• Effective on December 12, 2013• Requirements will be implemented in two phases:

– Phase I: Web pages that provide core air travel services and information (e.g., booking and changing a reservation) must be accessible by December 12, 2015

– Phase II: All remaining pages on a carrier’s Web site must be accessible by December 12, 2016

• Requires ticket agents that are not small businesses to disclose and offer Web-based fares to passengers indicating they are unable to use an agent’s Web site due to a disability

• Requires carriers to test the usability of their accessible primary Web sites in consultation with individuals or organizations representing visual, auditory, tactile, and cognitive disabilities.

Requirements and Deadlines

Why Does Accessible IT Matter?

Web content must be perceived, operated, and understood by users with disabilities and support use with assistive technology

Example Challenges:• Users who are blind cannot identify images without textual alternatives

and may have difficulty completing forms when not labeled properly• Users with low vision have issues when font size is fixed and cannot be

enlarged or when there is poor contrast between background and foreground colors

• Users who are deaf or hard of hearing may have issues with Lack of textual equivalents for audio content or the inability to hear sound alerts

• Users with impaired mobility may struggle with inks and buttons that are too small to select or navigating/completing closely spaced form controls

• Users with cognitive and learning disabilities may have issues with a lack of page structure (headings, lists) which can lead to confusion or distractions from popups or animation

Auditing

Automatic Testing• Cheapest and most commonly used• Catches easy to detect items, covers only a small fraction of

requirementsManual Testing• Requires extensive subject matter expertise• May require the use of assistive technologies, API monitoring tools, or

other complex techniques to validate a best practice• May require judgment calls on the part of the tester to determine if an

item meets a requirementFunctional Testing• Accurate functional testing requires a user with disabilities• To execute functional tests a user must have a high degree of familiarity

with assistive technology• Different versions of assistive technologies, drastically different results

Testing

ManualAutomated

Assistive Technology

IdentifyModules

IdentifyUse Cases

Groundwork

Prioritization

Analysis

Authoring

Delivery

Reporting

• At SSB we use a Unified Audit Methodology• One process for testing all technology platforms• Process should allow for different testing formality• Must be repeatable and scalable• Must provide concise remediation guidance• Require vendors to provide testing artifacts from the process

Core Testing Methodology

Global

Accessibility Testing Plan

Training Plan

• Lots of technical standards• Accessibility issues have a power

law distribution• Small set of issue types cause vast

majority of issues • Issues recur across (a) development

teams and (b) industries• Focus on “optimal compliance”• Mix it up over time

Power Law Distribution

Violation NumberV

iola

tion

Cou

nt

Requirements

Roadmap Planning

• Ask for and receive leadership’s commitment for accountability.

• Champion ACAA compliance reviews with legal.• Collect inventory of all sites.• Evaluate all sites and forms by doing accessibility scans.• Start detailed requirements analysis.• Send report findings with recommendations to leadership.• Identify a prioritized list of deliverables, defects, and

enhancements for testing.

Roadmap Planning cont.

• Build a test plan.• Launch integration and rollout plans.• Invest to remediate/program all sites to WCAG 2.0 Level AA

compliance.• Track, train and test for best practices.• Yield services and positive benefits for accessible travel.

Accessibility Management Platform (AMP)

SSB’s Accessibility Management Platform (AMP) is a web-based platform for the implementation and management of accessibility across an enterprise

• AMP provides the operating system for accessibility

• It provisions your team with the infrastructure to implement the three key compliance activities: – Auditing – Software to complete

formal and informal accessibility audits

– Training – Online access to training courses and curriculums

– Standards Management – Manage compliance across time, standards and technology

Infrastructure

About SSB BART Group

• Unmatched Experience• Accessibility Focus• Implementation-Oriented

Solutions• Solutions That Reduce Legal

Risk• Organizational Stability and

Continuity• Knowledge That Is Up-to-Date,

All the Time• Published and Peer Review

Auditing Methodology

• Fourteen hundred organizations (1452)

• Fifteen hundred individual accessibility best practices (1512)

• Twenty-three core technology platforms (23)

• Twenty-two thousand audits (22,408)

• Fifteen million accessibility violations (15,331,444)

• One hundred twenty-one thousand human validated accessibility violations (121,290)

(Statistics provided as of January 2013)

• Contact Eduardo to get further details or to schedule an Accessibility Management Platform (AMP) demo.

Contact:Eduardo Meza-Etienne

(202) 600-8932

eduardo.meza@ssbbartgroup.com

Next Steps