Letter to CCL -- Sean Keegan, Accessibility Consultant | Council of Chief Librarians

"Accessible Technology for our Libraries and Institutions" from Sean Keegan, CCC Accessibility Center/CCC Technology Center

Whether for the acquisition of knowledge or sharing of ideas, libraries provide an opportunity for educational enrichment. Technology contributes to this opportunity by providing access to a diverse array of web-based resources and services, including online databases and journals, e-book reserves, and electronic document repositories. As we introduce these web-based technology solutions into our college libraries and across the institution, it is imperative that we ensure access for all members of the campus community, including our students, faculty, and staff with disabilities.

In 1999, the Web Content Accessibility Guidelines, 1.0 (WCAG 1.0) was released and provided guidance to web developers and designers as to how to make web content accessible to people with disabilities. Two years later, the US Section 508 Standards were enacted and set accessibility standards for the Federal government when developing or purchasing electronic and information technology products. In 2010, more than a decade after the original web accessibility guidelines were released, the Web Content Accessibility Guidelines, 2.0 (WCAG 2.0) was accepted as an international standard for accessible websites and web-applications. Yet while these accessibility standards established minimum levels of access for web and information technology systems, confusion and uncertainty persisted regarding these accessibility standards and what the term “accessible” meant for educational institutions.

To raise awareness of potential technology and accessibility issues for students with disabilities, the US Department of Justice, Civil Rights Division and US Department of Education, Office for Civil Rights (OCR) issued a joint Dear Colleague letter to college and university presidents in 2010. The Dear Colleague letter expressed concern about the use of inaccessible technology in the classroom environment and stated, “It is unacceptable for universities to use emerging technologies without insisting that this technology be accessible to all students.”

Since that letter, and from compliance reviews, resolution agreements and legal settlements, OCR has clarified the meaning of the term “accessible,” particularly as it applies to the use of websites and information technology at institutions:

“Accessible” means a person with a disability is afforded the opportunity to acquire the same information, engage in the same interactions, and enjoy the same services as a person without a disability in an equally effective and equally integrated manner, with substantially equivalent ease of use.” (OCR Compliance Review No. 11-11-6002)

Throughout many of these same resolutions and legal settlements, the Department of Justice and OCR identified WCAG 2.0, Level AA as the minimum technology standard for web accessibility. This has resulted in a two-fold outcome by defining what is meant by an accessible user experience as well as specifying a technical standard by which to measure that experience.

Libraries serve an important role both as a physical and virtual resource for the campus community. As technology transforms our physical into virtual environments, we must ensure our libraries implement online resources so as to provide students with disabilities the opportunity to participate in an integrated manner. Building the accessible technology environment can include multiple strategies, such as:

Establishing policies and procedures that includes accessibility as a requirement when purchasing web and information technology products.
Communicating with vendors the institutional expectations and accessibility standards (i.e., WCAG 2.0, Level AA) and insist vendors demonstrate how their products conform to these standards.
Reviewing all institutional websites and web applications for conformance with the WCAG 2.0, Level AA standard.
Using web browser tools and manual checks to validate remediation efforts.

As we adopt new web and information technology solutions for our students, faculty, and staff, we must pursue options that ensure support for students with disabilities. Building that accessible technology environment will take time and require ongoing commitment and dedication on behalf of those working locally, regionally, and system-wide. Libraries can serve as the institutional model for technology access, providing opportunity to all members of the campus community, including our students with disabilities.