PDF and Public Documents: A White Paper

Executive Summary

While we applaud Adobe's efforts to make Portable Document Format (PDF) more accessible, the limitations of existing practices and technological capabilities available to end-users who are blind or otherwise print disabled render documents and forms in PDF inaccessible to many members of the public. This white paper explains the problems that surround the use of PDF documents and forms in light of the section 508 standards and draws the conclusion that alternative, accessible formats must always accompany PDF versions of information and data that are made available to the public.

Introduction

The Workforce Investment Act of 1998 amended Section 508 (29 U.S.C. 794d), which covers federal government use of Electronic and Information Technology. Section 508 requires (among other things) "individuals with disabilities who are members of the public seeking information or services from a Federal department or agency to have access to and use of information and data that is comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities".

PDF is a popular format and is valued as a means of ensuring consistent appearance across computer platforms. However, the problems of access by people who are blind or otherwise print disabled and the mandates of section 508 lead to the conclusion that documents in alternative, accessible formats must always accompany PDF for information that is intended for the public. The views expressed in this White Paper represent both our professional, expert opinion and the views of a sizable population of the public who are blind or visually impaired regarding the use of PDF files. This white paper examines the serious difficulties that many continue to have while trying to access public information that is made available only in PDF or other proprietary formats.

The Problems with Publishing Government Information Using PDF

Adobe has made changes to their products and developed authoring guidelines for accessibility; nevertheless, many people who are blind or otherwise print disabled continue to experience significant difficulty with PDF files. This appears to be a combination of several factors, including:

• the prevalence of authoring tools that cannot produce accessible PDF
• the misuse of authoring tools that could produce accessible PDF
• authoring security features that block access to PDF
• the lack of accessible PDF support for all OS platforms and assistive technologies
• usage difficulties even with the accessible tools

Let's examine each of these problems in more detail.

The Prevalence of Authoring Tools That Cannot Produce Accessible PDF

Accessible authoring is not enforced by all available authoring tools. In fact, some PDF authoring tools simply do not support Adobe's accessibility guidelines. Without a massive effort to upgrade these tools and educate authors on how to use them or a systematic approach to prevent the use of these tools to create documents intended for public access, the government will continue to produce thousands of pages of inaccessible documents.

The Misuse of Authoring Tools That Could Produce Accessible PDF

No tool can guarantee the creation of accessible documents. Authors must understand and follow the Adobe guidelines for creating accessible PDF to ensure the creation of accessible PDF. A systematic program of outreach and education for all government employees involved in document production seems necessary. Otherwise, the investments in the accessibility tools will be wasted. To date, we see no evidence of an outreach and education program sufficient to meet this need.

Authoring Security Features That Block Access to PDF

Adobe's own products allow authors to prevent access by screen readers through the use of document security features. The common use of 40-bit encryption effectively blocks any access by persons using assistive technology. While 128-bit encryption with the latest version of the accessible Acrobat reader corrects this problem, there is an option that allows access through the use of assistive technology. This option is turned on by default, but authors must not uncheck this option or access will again be denied.

Accessibility is hampered by other security options, such as the blocks against exporting or printing documents. People sometimes make personal print copies of documents in order to add comments and annotations. People who are blind or visually impaired may do the same, making hard copy in braille or large print. The document security features, by preventing direct access to the text, block any media conversion and deny comparable access to information and data by individuals with disabilities.

The Lack of Accessible PDF Support for All OS Platforms and Assistive Technologies

Presently, Adobe distributes end user agents which incorporate accessibility support for 32-bit Windows environments. Adobe also distributes PDF readers for other platforms, but without accessibility features. Many persons who are blind or otherwise print disabled use other operating environments (such as Macintosh and UNIX) and they are effectively without access as defined in Section 508. The principle attraction of PDF is that it is platform neutral, allowing documents to be created with the confidence that they can be printed with identical appearance from any computer. The lack of access for some disability groups calls this notion of platform neutrality into question and should be a concern for government procurement officials until this situation is corrected.

The accessibility solutions Adobe offers for 32-bit Windows environments do not function with the full range of assistive technologies used by persons who are blind or visually impaired. However, the cost to the consumer to upgrade or switch their preferred assistive technology is not insignificant. This is a serious social concern because current federal programs only cover the assistive technology needs of a small percentage of the disability population. According to a recent NIH report, the number of citizens who are blind will double over the next 2 decades as the population ages. How will these retirees, who receive no particular support for computer assistive technology, access information from Medicare, Social Security and other public agencies if the documents are in PDF?

Adobe offers web and e-mail document conversion service alternatives. This service is not directly incorporated into any web browser agent, assistive technology product, or Adobe's end user agents and it will not get around the author security encryptions described earlier. This service can only be used if the PDF document has a web address and if the consumer can locate the URL. Nearly all web sites do not mention this service so consumers are expected to find and use it on their own.

This lack of support for the range of access technology and operating systems in common usage is not "comparable to the access to and use of the information and data by such members of the public who are not individuals with disabilities".

Usage Difficulties Even with the Accessible Tools

Many people who are blind or otherwise print disabled continue to have difficulty using PDF even when they have the accessible technology. Finding, downloading and installing third party plug-ins can be beyond the technical capabilities of many users. Whether due to problems with the end user agents, the assistive technology, the large number of inaccessible PDF documents still in the public domain or the lack of skill or training of the consumer, the result is considerable frustration and, ultimately, lack of comparable access.

Employees who are blind or otherwise print disabled may have support from their employers to deal with these problems, but many IT support services are unfamiliar with assistive technology and tend to blame the assistive technology for misbehaving when it is the accessibility obstacles in the applications that are at fault. The consequence is that the person with the disability is unable to access information independently unless, and until, someone can locate and implement the solution that harmonizes the separate pieces of technology needed simply to read documents. Also, nearly 70 percent of persons with disabilities are unemployed and thus do not have the technology staff of an employer to assist them.

Conclusion

The many problems associated with accessing PDF documents constitute a burden on the person with visual impairments that is significantly greater than the burden placed on non-disabled persons with regard to PDF files. We recognize the investment in products designed to produce and work with PDF files and we appreciate the efforts that Adobe has made to try to address the accessibility issues. We also applaud the efforts of Adobe to embrace XML technologies that provide for open source, non-proprietary formats. We call on Adobe and other developers to commit to accessible XML practices, as identified by the XML Accessibility Guidelines (XAG) currently in public draft. Proprietary technologies should be avoided when they may have certain visual benefits but add little to the core information content and create accessibility obstacles for public documents. We strongly urge that any file formats (especially proprietary, non-consensus formats) employed by the government be thoroughly evaluated by representative focus groups of consumers, including persons with disabilities, and that all accessibility problems be appropriately addressed before continuing to generate public documents in such formats. By far, the preferred approach is for the government to use open, consensus-based, non-proprietary formats. Today, well designed web content, authored in HTML, is meeting the test of accessibility. Accessible XML holds out the promise of expanding information access for persons with disabilities to where it will become, not a technology wonder, but a common, everyday experience.

Version 1.1, published April 25, 2002

by

Janina Sajka
Director, Technology Research and Development
American Foundation for the Blind

and

Joe Roeder
Senior Access Technology Specialist
National Industries for the Blind

2002, all rights reserved
American Council of the Blind
American Foundation for the Blind
National Industries for the Blind

This document may be freely distributed provided it remains intact with the copyright notice.