ETSI TR 102 612 - British Computer Society TR 102 612 European ... ICT products are not always accessible: ¾ Assistive technology may be required and may not be ... services for every

World Class Standards

ETSI TR 102 612 European Accessibility Requirements for Public Procurement of Products

and Services in the ICT domain (EC Mandate M376, Phase 1)

ETSI HF STF 333Nikos Floratos, Sean Hayes, Gunnar Hellström, Richard Hodgkinson,

Walter Mellors and Bruno von Niman

© ETSI 2008. All rights reservedICCHP Conference, Linz, July 2008


ICCHP Conference, Linz, July 2008.

European Telecommunications Standards Institute?

Official European Standards Organisation recognised by the European Commission (…CEN & CENELEC)Produces globally applicable standards for ICT, including fixed, mobile, radio, converged and broadcast technologies.“Not for profit” organisation funded by subscriptions from almost 700 members across 60 countries worldwide.Located in Sophia Antipolis in southern France.Standards are freely available…no cost!Go to www.etsi.org

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ETSI Specialist Task Force HF 333

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Some facts and figuresICT enables people with disabilities and the elderly to participate more in society.Accessible products benefit everyone:

People in noisy environments...lost spectacles...broken arm...ICT products are not always accessible:

Assistive technology may be required and may not be compatible.

“Digital exclusion” could cost European companies and governments €85 billion over the next 5 years.In the UK the disposable income of people with disabilities is estimated at €62 billion.

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How to encourage manufacturers and suppliers of Information and Communications Technology to provide accessible products and

services for every European citizen?

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Global ActivitiesUS Section 508 of the Rehabilitation Act 2001:

Requires products and services sold to the US Government to be accessible by citizens with disabilities,Product not accessible = No bid = NO SALE!Resulting products available to all consumers,Similar requirements in Canada, Australia and Japan.

Europe sees this as the way to go:Various European ICT accessibility initiatives,Some successes, but chequered implementation,Main focus is government web sites.

ISO/IEC JTC 1/SWG-A….

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ISO/IEC JTC 1/SWG-AISO & IEC Joint Technical Committee 1 (IT), Special Working Group - Accessibility (standards).Established in 2004 to:

Gather accessibility user requirements,Publish an inventory of accessibility standards,Identify areas where voluntary standards are not being addressed,Track public laws, policies, measures and guidelines,Encourage the use of globally relevant standards, andAssist fora in submitting their specifications to the formal standards process.

Preparing 3 part ISO/IEC TR 29138 - Accessibility considerations for people with special needs.

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EC Standardisation Mandate M376 Phase 1 – Research:

To identify a set of functional European accessibility requirements for public procurement of products and services in the ICT domain, to harmonise and facilitate the public procurement of accessibleICT products and services,Work period: September 2007 to March 2009,Final draft ready for ESO cross-approval 24th September 2008.

Phase 2 - Implementation:To provide an EU Norm (a standard) and a mechanism through which the public procurers have access to an electronic toolkit,enabling them to make use of these harmonised requirements in procurement,Work commences: post March 2009?

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EC Mandate M376 – Phase 1 AssignmentsCEN/BT WG 185 PT:

Prepare a report which:• Provides an analysis of testing and conformity schemes of products

and services meeting accessibility requirements,• Provides an analysis on conformance schemes of this nature at

European and International levels.

ETSI HF STF 333:Prepare ETSI Technical Report 102 612, which:

• Lists ICT products and services bought by public procurers,• Lists existing functional accessibility requirements,• Lists existing national, regional and International standards which

might comply with those requirements,• Provides a proposal for standardisation work for requirements that do

not currently exist.9



EC Mandate M376 – Co-ordinationProvided by EU ICT Standards Board (ICTSB), Design for All and Assistive Technologies Standardisation Co-ordination Group (DATSCG).Direct liaison at working group level (ETSI STF 333 –CEN/BT 185 PT). Public workshops held in Brussels, April & June 2008:

Draft v40 presented (June),110 stakeholders attended (June),TEITAC, GSA, W3C, EICTA, EDF, ANEC, EDeAN, ETSI, AENOR, CEN/CENELEC, BSi, IBM, SAP, HP, Microsoft... (June).

Go to www.ictsb.org/DATSCG_home.htm

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ETSI STF HF 3331,000+ stakeholders involved from disability, business and standards organisations worldwide.270+ contacts in European Public Procurement Network.4 public (41 private) drafts produced of TR 102 6124th (and final) public draft available:

Currently 211 pages,Commenting period closed 11th August 2008.

All comments and responses logged.For the final draft and more information go to http://portal.etsi.org/STFs/STF_HomePages/STF333/STF333.asp

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ETSI TR 102 612 – Structure & ContentForeword, Introduction, 1. Scope, 2. References, 3. Definitions and abbreviations (standard clauses).

4. Approach, methodology and context of use.Two approaches investigated to generate an inventory of ICT products and services, together with a listing of associated functional accessibility requirements:1. Product-centered approach: Listing of products identified by

8 digit Common Procurement Vocabulary code and associating the user requirements with each product...impracticable.

2. User-centered approach: Identifying generic user requirements for each feature of a product, applying these to any product with the relevant feature...done!

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ETSI TR 102 612 – Structure & Content5. ICT products bought by public procurers:

International situation surveyed…Untied Nations, WHO, EU legislation and Common Procurement Vocabulary (CPV) codes.

6. Existing functional accessibility requirements for public ICT procurement:

International, trans and pan-European, EU and EFTA requirements compiled from:270+ contacts in the European Public Procurement Network,Government web sites,MeAC report (10/2007).

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ETSI TR 102 612 – Structure & Content7. Relevant European and International standards:

Lists and describes ICT standards published (and in development)that address accessibility issues,Standards sources: ITU-T, ISO, IEC, W3C (ATAG, WCAG & UAAG), ETSI, CEN, AENOR/UNE (Spain), BS (UK), Australia* and Japan.

8. User requirements and ICT:Maps user needs from:

• ISO/IEC PDTR 29138-1 (ISO/IEC JTC1 SWG-A),• UN Convention on Rights for Persons with Disabilities,• ETSI EG 202 320 Duplex Universal Speech and Text (DUST),…to relevant technical requirements.

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ICCHP Conference, Linz, July 2008. 15



ETSI TR 102 612 – Structure & Content9. Technical requirements:

User needs from clause 8 translated into functional requirements,More than 50 standards reviewed, listed in:

ISO/IEC PDTR 29138-2 – Accessibility Considerations for people with Disabilities – Part 2: Standards Inventory (ISO/IEC JTC 1 SWG-A),ETSI SR 001 996: 2007 - An annotated bibliography of documents dealing with Human Factors and disability,Tiresias web site - List of accessibility standards in development (www.tiresias.org),International Telecommunication Union – Telecommunications,TEITAC – US Telecommunications, Electronic and Information Technology Advisory Committee (Access Board “Section 508 Refresh”).

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ETSI TR 102 612 – Structure & Content9. Technical requirements:

Unable to review some standards due to expense, availability, language or time constraints,Exact matches between user needs and functional requirements rare,Gaps identified where a user need exists, but no technical requirement available = proposal for a new technical requirement.

10. Gaps in accessibility requirements:48 potential new technical requirements identified (v40),Submission to ISO/IEC JTC 1/SWG-A (Tokyo meeting) for consideration…carried forward to 1st revision.To be submitted to US Access Board for consideration.

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ETSI TR 102 612 – Structure & ContentAnnex A. US Section 508 and the Canadian toolkit.Annex B. List of applicable CPV codes.Annex C. Procurement legislation and ICT products and services procured in the EU and EFTA member states.Annex D. National eAccessibility procurement requirements:

Currently used by EU & EFTA member states, Australia, Japan and the USA,Requirements address public Web sites, telecommunications, policies & strategies, toolkits, procurement support, etc.

Annex E. BibliographyFurther list of accessibility and accessibility-related standards and guidelines.

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European Accessibility Requirements for ICT Public Procurement (M376)

Actions Required to Progress the Work

ETSI HF STF 333

M376 Open Conference, Brussels, 3rd & 4th June 2008



”Accessibility as a competitive edge”One, globally harmonized standard (European Norm).One usable and accessible toolkit:

Based on user needs and contexts of use,Relying upon competitive innovation,With at least two profiles:

• Procurers,• Providers, • (and Testers/Assessors?)

Providers positioning and competing with accessibility as a competitive edge.



Actions planned and agreed until the end of the project

Comments on draft 4 accepted until 11th August.Resolutions, draft updates, final review.5th public draft may be released (and announced) for validation purposes, without any commitment:

For a compacted period, e.g. 8th to 18th September.Final draft for ESO approval on 24th September 2008.ETSI TC Human Factors and cross-ESO approval on 8th October 2008.ETSI publication after editorial processing:

In October- November 2008.



11 – Two Main Possible Approaches1. “Shopping list” - An exhaustive listing and reference to existing

external standards, adding only minimal new content (not recommended):

10.000 pages?, 2-5.000 €?, own structures and vocabularies, limited accessibility,Would require all stakeholders to purchase, or otherwise obtain, all necessary referenced standards.

2. “One-Stop-Shop” - A self-contained standard which, while supported by previous work, stands alone and provides the basis for procurement:

More accessible & usable for the intended users, easier to maintain,Would enable a more useful toolkit – with login profiles and contextual applicability.



Considerations and recommendationsRegardless the approach chosen, a “refresh” policy should be defined (3-5 year “refresh” cycle). Close collaboration with the US Access Board is strongly recommended.More insight about the user segment requirements and contexts of use (including procurers and processes).Toolkit requirements:

Usability and accessibility requirements similar to those on products,Languages and translations,Maintenance, etc.



M376 - Five Phase 2 Tasks1. A European Standard (ES/EN):

Specifying the requirements for accessibility for all ICT products and services within each of the technical areas (to be used in terms of Technical Specifications in the sense mentioned in the PublicProcurement Directives).

2. A report on the standards and specifications (building on the ETSI TR).

3. Guidelines on accessibility award criteria that are relevant to each technical area, to be used in the procurement process.



M376 - Five Phase 2 Tasks4. Guidance and support material for public

procurements, which should address at least the following areas:

Information Technology planning guidelines,Broad circulation of materials on accessible information technology, Technical advice on new ICT hardware or software, Training of IT staff on the use of the developed material, Inventory of existing accessibility support services and of accessibility support needs, Inclusion of accessibility in ICT call for proposals, Verification of supplier claims of accessibility, Tracking of non-compliance of products and services with accessibility requirements in tenders,Information on the testing and conformity aspects.



M376 - Five Phase 2 Tasks5. An on-line, accessible toolkit providing:

Structured access to the full content of the EN, the report, theguidelines and the guidance material, In particular, thorough guidance and ready-to-use text to public procurers who will use it.



M376 - Phase 2Enough information has been found in Phase 1 to permit a single EN to be written in Phase 2 which contains all of the functionalrequirements:

Will need to refer to other International and/or European standards, particularly for test methods (which need to be based on harmonized International requirements).

For each requirement identified references will be noted:The first work is to merge them into consensual statements,Conformance statements need to be associated with each requirement.

Gaps will need to be filled:Need to agree that the gaps are genuine,Requirements will need to be written.

International Standard bodies must be approached to write several new standards.



M376 - Phase 2...continuedA report will list all standards referenced out from the EN:

Update of status of standards currently under development.

Guidance may be needed on applying the various requirements to actual products.The current work can provide all necessary information to support preparation of an on-line toolkit for public procurers:

The toolkit should also be able to assist suppliers, developers/designers and testers/assessors,The toolkit should be structured to permit a number of approaches to the information that it contains.



Phase II continued

Documents

ETSI TR 102 612 - British Computer Society TR 102 612 European ... ICT products are not always accessible: ¾ Assistive technology may be required and may not be ... services for every