INSERM U592, Université Pierre et Marie Curie, Association BrailleNet, France
Dominique BURGER is the President of the Association BrailleNet.
Graduated from the Ecole Superieure d'Electricite and PhD in Electronics. Dominique Burger is Research engineer at INSERM (Institut National de la Santé et de la Recherche Medicale). Since 1982, his major research interests have been in the area of interface design for users with visual impairment, particularly in the field of education. He has been participating in several European projects, as scientific manager.
The Internet makes possible to provide more and more diversified services, public or private, to increasing numbers of customers or users, remotely. These services can be made accessible to people with disabilities and create better conditions for their cultural, social and professional inclusion. But a condition is the conformance to technical requirements at an early stage in the service design. Such requirements have been formulated by the W3C Consortium which are recognised by the European Community and most of the Member States. In reality, several studies have evidenced that these recommendations are quite poorly implemented.
For this reason, in several countries non governmental organisations have taken initiatives to raise the expertise of Web professionals concerning accessibility and created conformity labels based on the W.3.C. recommendations. Among other, one can mention AccessiWeb, Blindsurfer, Drempelvrij, See it Right-Useability, Sello de Accessibilidad. This is perfectly legitimate, generally based on private contracts between service providers wishing to demonstrate the quality of their products and reinforce their public image, and organisations being accountable of technical verification for which the providers have not the expertise. These initiatives have improved the clarity and the transparency in the attribution of accessibility labels and have contributed to make accessibility recognised as a necessary component in the development process.
Nevertheless, the success of these labels raises the question of a real control of their quality and their harmonisation. If this question were not solved, any policy for a large-scale implementation of the W.3.C. accessibility recommendations would probably fail. In this context, the Council of Europe stated in 2003, that a Quality Mark for eAccessibility should be set up, and the European Commission Européenne recommended certification as an instrument for fostering eAccessibility, in the Communication released on 13 September 2005. A mandate to European standardisation bodies concerning eAccessibility was released in December 2005 by the European Commission.
A specific Support Action was set up in order to explore the possibility to certify the accessibility of Internet services and the possible implications. This action is called Support-EAM. It is conducted by organisations having an expertise in Web site accessibility from 7 countries. It is coordinated by the association BrailleNet, France. One mission of Support-E.A.M. was to organise concertation of stakeholders within a CEN Workshop (W.S./W.A.C.) in order to establish a first level consensus for a certification scheme and a Quality Mark. This C.E.N. Workshop produced a document that will be amended and adopted as C.E.N Workshop Agreement (C.W.A.) after a period of public comments. In this paper we recall the basic principles underpinning any certification process, we review the main questions that were raised during the workshop and we summarise the main answers provided.
Service certification is a standard procedure for guaranteeing that a service is in conformance with requirements specified in a norm or a normative document, on an objective basis. Service certification is a voluntary action undertaken by providers that outsource the necessary operations to a third-party organisations, called certification body, in order to bring guarantees to customers and users . The certifying organisation uses verifications, called inspections, that they carry out themselves of with help of external organisations. The guaranty generally covers a certain duration. This guaranty is often associated with a Certification Mark in order to make it more visible.
Service certification and the related procedures are defined in standards such as ISO/IEC Guide 28:2004, I.S.O./I.E.C. Guide 65, I.S.O./I.E.C. 17020:1998. The certification body shall be competent, respect impartiality and transparency, is accountable for what it certifies. The certification body shall also insure that the normative documents are valid and accepted by stakeholders. If needed it shall organise their update with the parties concerned.
In many domains, service certification has proven to be an efficient instrument helping companies to build up confidence with their customers and improving their competitiveness.
In order to alleviate control procedures and reduce the costs another conformance certification system has been set up by companies, based on Supplier's Declaration of Conformity (S.d.o.C.). Suppliers may decide to adopt this scheme if they are convinced that their image is good enough to allow them to save the cost of third party-certification. Suppliers remain accountable for their declarations. In general SdoC is complemented by market surveillance. Declaration of Conformity shall respect the I.S.O. standard I.S.O./C.E.I. 17050. This approach has been successfully applied in several sectors like telecommunications or electrical goods.
Normative documents shall provide precise criteria and methods making possible to verify them on an objective basis. They allow for the caracterisation of the services to be controlled. They can refer to a technical norm, or to widely accepted recommendations. In addition to technical specifications, normative documents also specify how to inform customers and users about the verifications that are made and the guaranties that are given, and - possibly - commitments made concerning the service and reparations made in case of failure to the certified features.
Concerning Web accessibility, no international norm exists. But the WCAG (Web Content Accessibility Guidelines ) of W3C/WAI, are officially recognised by European countries. Thus, a normative document for certification in Europe should be based on these recommendations.
National organisations have undertaken the adaptation of these recommendations into national reference documents, norms, or technical rules for implementing the laws, in concertation with stakeholders, i.e. Web professional, consumers' and users' organisations, administrations . One can mention, for instance :
Nevertheless, nor the W.C.A.G., nor the national adaptations, can constitute by themselves the technical instrument for certifying a Web site, because these documents do not contain the methods for deciding the conformity or not. This is why the organisations that set up labelling schemes had to create their own methods in order to make their audits as impartial as possible.
It is sometimes objected that Web sites are changing permanently making any evaluation obsolete immediately after it has been completed. Several answers can be given to this point :
The number of labels that have appeared over the past months, corresponding to different technical definitions, based on local interpretations of the international recommendations, show the impact of the W.3.C. and the Web Accessibility Initiative (W.A.I.) since its creation in 1998. Nevertheless, the multiplication of schemes results in fragmentation and constitutes a serious obstacle to a real, large-scale implementation of Web accessibility.
The Specific Action Support E.A.M. has started to compare and propose a convergence plan for the evaluation methods used by several organisations for awarding accessible Web sites, including their technical documents, tools, and their codes of practices. It appears urgent to give a sustainable status to this kind of harmonisation work over Europe, in order to capitalise the lessons from different excellent experiences, which have produced a real expertise that should be promoted at European level.
A European Authority would be a concrete instrument to achieve this objective, would make collective expertise visible, and providing a place where to develop it and improve it collectively. Organisations having a solid experience in labelling Web sites should constitute the core of this authority that should also take on board all the interested stakeholders. The role of the Authority would be :
The Authority should respect the necessary rules for guaranteeing its independence, and should be submitted to quality controls.
The C.E.N./ISSS Workshop has elaborated a scheme which is submitted to public comments for a 60 days period (until 20 February 2006), according the the C.E.N./I.S.S.S. policy.
The global scheme which is proposed reflects the three types of demands that were identified (figure 1). It proposes a reasonable way for existing labelling schemes to improve and migrate towards standards, offering different options so that organizations wanting to improve Web accessibility on a voluntary basis could join the scheme and find a model fitting the best their needs.
An Institute would act as a central authority whose mission would be to organize, harmonize and control practices in liaison with international bodies concerned. It would have formal liaisons with W.3.C./W.A.I. and standardisation bodies. The Institute would be the owner of a Conformity Mark and would develop services for promoting Web accessibility certification according to three possible options:
Figure 1 : certification scheme proposed including 3 possible options: inspection, 3d-party certification, S.D.o.C.
The road towards a European certification scheme should go through the following steps:
User and consumers organizations, industry and governments agree that the accessibility of technology is a significant and relevant issue that shall be addressed seriously and coherently.
Accordingly, in its Communication on eAccessibility, September 13th, 2005, the European Commission proposes a set of policy actions that should foster eAccessibility. It calls on Member States and stakeholders to support voluntary positive actions to make accessible I.C.T. products and services far more widely available in Europe. It mentions certification as an instrument.
All see the accessibility of technology as a large-scale problem concerning many business domains and hitting a growing potential market. They consider that regulation, standards, e-procurement and some forms of recognized certification should help towards a society more beneficial to all citizens, matching the ethical objectives of modern democracies.
Also the work done by the W.3.C. under the Web Accessibility Initiative is recognized as a basis for building up Web Accessibility, particularly the Web Content Accessibility Guidelines (W.C.A.G.).
End of 2005 an E.C. mandate has been given to the European Standardisation Organisations (E.S.O.s.) to come with a solution for common requirements and conformance assessment.
This context is encouraging the creation of a certification system for Web Accessibility designed to work at European level. The experiences that organisations have conducted in several countries over the past few years constitute a favourable basis for that. The creation of an institute would offer an opportunity to bring together competences and energies, and to avoid the fragmentation of W.3.C./W.A.I. success into multiple schemes, whose paradox would be to make any further progress towards accessibility impossible in Europe.
The work undertaken by Support-E.A.M. and the C.E.N. Workshop clearly show that such an authority could emerge integrating different existing schemes supporting voluntary certification and serving the interest of all the parties concerned.