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08 July 2009
Dr Dave Merchant
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Dave Merchant explains why accessibility beyond the realms of the DDA should be one of the first things you think about when introducing new gadgets or software.

Technology made easy logoTechnology is a wonderful thing, until it turns round and bites you. Some of us are bitten more often than we should be. If you think "accessibility" is all about ramps and fire escapes, then read on.

For most of you, mention of computers means the Health and Safety (Display Screen Equipment) Regulations 1992, and a deep lack of love thereof. Mention of mobile phones means newspaper stories about cancer, and no insurance cover for your organisation if they turn out to be true. Both of these are the subject of next month's article, where we're looking at the health risks from our gadgetry. But this month we're concerned about just being able to use it.

You'd be forgiven for thinking that accessibility is about walking into an office, running out when it catches fire, or about making your website work with a screen-reader, as those aspects tend to dominate the business world. They're important, given the power of the Disability Discrimination Acts (DDA) 1995 and 2005. But all too often these legally required provisions are all an employer bothers to think about. And these aspects were covered by Bridget Leathley in the last issue of HSW (read the article here).

More than compliant

The DDA requires every employer to make reasonable adjustments to the workplace and their business functions and services to permit use by disabled people, but it only applies to those with legally defined disabilities, and there is an important exclusion to maintain health and safety (it's impossible to make forestry work safely accessible to a blind user, no matter how much technology you throw at it).

The point at which a person becomes "DDA disabled" is legally complex, with current guidance running to over a thousand pages, but the tipping point is a "substantial impairment in normal daily activities" (SINDA), and daily activities include tasks such as typing on a standard keyboard or using a telephone, but not a work-specific task such as operating a lathe or driving a cherry picker.

Technological accessibility is about making a piece of electronics or software usable by all its potential users, disabled or not, literate or not, computer-savvy or not. It's not simply about making allowances for DDA. There are many things to consider, such as not being an English speaker, or not being particularly nimble with your thumbs, which aren't SINDA disabilities.

Unfortunately, the web doesn't make it particularly easy to find out about this non-DDA stuff. Search online for "accessible" and you'll be told a million times about accessible website content, but nothing about subtitling your induction video. The Disability Rights Commission (DRC) closed in 2007, and its replacement body hasn't set up a website yet, so all the official government advice links to a half-dead archived copy of the DRC's pages, with lots of the content broken. Such is public sector computing.

DDA does of course apply to significant impairment of vision and hearing, so your carefully crafted mandatory induction video is presumptively illegal without a voice narration, subtitles or transcript (especially if the induction is required for site visitors who may have any type of disability).

But there are more obscure cases where SINDA doesn't apply but health and safety requirements still do, such as damage to the sense of smell, which could be a liability if you work in a chemistry lab, and is why we use gas detectors and not our noses. However, a poor olfactory sense isn't a disability under DDA (neither is deficit in taste or perception of heat, pain or touch).
Workplace computer equipment clearly has to be accessible, and for standard computers it's not too difficult to get modified hardware and software (see www.abilitynet.org.uk for advice). Blind users can touch-type or use text-to-speech or Braille keyboards; partially sighted users can use screen magnification systems; and all manner of hardware add-ons cater for other disabilities. In some ways, the computerisation of the world has given disabled users access never before imagined, but it may surprise you how important the word "some" is in that statement.

Software, on the face of it, should be simple to make accessible, and it used to be. When computers just spat out text, making it bigger was trivial. Many programs can magnify the screen, read text out loud, and use keyboard shortcuts instead of a mouse, but as the on-screen content becomes richer, it's getting harder.

TV on demand is a case in point. Broadcast TV is normally very accessible (with subtitles for almost every show, and audio description and in-vision signing available for much pre-recorded output), but the new online versions (such as the BBC iPlayer, ITVPlayer, 4oD, DemandFive) aren't anything like as good, because their video delivery and website interfaces rely on Adobe's Flash code, which doesn't like talking to screen-reader software or keyboards. The BBC has made more of an effort in its new iPlayer site, but still tells disabled users to revert to the old download software. Of course Flash is there to make the place look good, and to allow security of downloaded content, but by doing so it throws sand in the face of any screen-reader or clicker control trying to talk to it.

The moral of this is, whenever you're specifying new software, be it for training or to run your risk assessment system, make sure it handles accessibility as well as the thing it's about to replace. Upgrades are not always upgrades, and if that software provides a core business service (such as when you're training people online), then the DDA applies in all its glory.

The hard stuff

With hardware, the problem is that accessibility is rarely engineered in at the start, so tends to lag behind the version released for "normal" users. The faster we invent and upgrade, the less likely an accessible version is to make it into the shops before the product's obsolete, so fewer manufacturers even bother to try. DDA doesn't apply to consumer goods, so it's perfectly lawful to design and sell a gadget that disabled users cannot use, and flat-out refuse to engineer an accessible version on the grounds of "commercial viability".

Take the phone, for example. Many of you will have company-issue mobiles, and you probably don't like them. Unless you're in upper management, it's a candy-bar style, with "style" used loosely. Wouldn't it be great if we were all issued with new PDAs or BlackBerrys?

Well not entirely, because they have touch-screens. You can't use a touch-screen phone if you're visually impaired, as the place you need to press keeps changing. As I write, Apple founder Steve Jobs is announcing the new iPhone 3G-S has a vague attempt at accessibility through its VoiceOver system, but it's far from perfect and far from clear whether any other brands will take up the idea. 

As things stand, what if the company tried to use its new fleet of smartphones for a core business function, such as data entry or risk assessments? At that point, an awkward DDA-regulated silence falls. An employee with impaired vision or manual dexterity would find it hard, or impossible, to use the PDA, and reasonable adjustments are therefore required.

You could give those who have difficulties the old phones back, and implement a parallel accessible system on paper, or you could stick with the paper and forget the entire phone idea, but that's like banning TV because some people are blind. The sensible approach is to find a way to make the new technology work for as many users as possible, narrowing the final gap to something easy to fix. TV did it with audio descriptions and subtitling, and you can do it by choosing your software and hardware sensibly, so everyone can use the system as much as possible (often more than they could use the old one).

There are, of course, fundamental limits. If you're totally blind, nothing about a smartphone other than the iPhone 3G-S is currently accessible, apart from the ability to answer calls, but the things the phone can do (make calls, answer emails, browse the web, and so on) can all be done accessibly on a laptop or desktop PC, so the solution is for workers with disabilities to use those instead. You're not excluding someone from your new system, or giving them second-class access; you're giving them access a different way. This is the advantage of technology, but with proprietary software/hardware combinations (data terminals, scanners, control pendants) you may find it difficult to get an alternative without cooperation from the manufacturer.

Press here

The touch-screen issue is by no means limited to phones. Many of you will have photocopiers, switchboards or vending machines which rely on them.

A national hotel chain was almost floored  when it installed touch-screen lift controls without thinking about DDA. Luckily in that case the position of the buttons on the screen never changed, so it was possible to make a stick-on tactile overlay, but for many devices, the screen content moves over time.

Biometrics, the current fetish of the security industry, is fundamentally non-
inclusive (not everyone has fingerprints and irises), so for every biometric measurement there has to be a backup system for exceptions. Major schemes, such as passports, allow for that, but keep it in mind if you're planning your own system, especially if it will be used by the public.

In many cases, visual safety indicators are made accessible by adding audio, but audio can be problematic if used alone. In years gone by, the fire alarm was a big red bell, or possibly a smouldering employee running past the door. Then it gained a flashing light, to cater for the hard of hearing. Now, thanks to enterprising alarm salesmen, it can politely tell you where the fire is, which doors to use, or that it's not a fire at all, rather a toxic gas release in the executive bathroom. These intelligent notification alarms can improve safety in emergencies a lot, but accessibility suffers unless you address it at the design stage. If the alarm announces several types of event, fit different colours of flashing light or a message display. Consider vibrating pagers for sites where lights can't be seen. If some of your staff or visitors are non-English-speakers, be sure to use different tones or multi-language messages, and of course make sure your site induction explains what they mean to everyone regardless of their status. The maritime sector learned that lesson the hard way.


Colour sensitive

Most aspects of old-fashioned health and safety notification are accessible in ways you didn't realise. Why are safety signs the shapes they are? Why isn't there a hazard symbol that uses green and red at the same time? Because they're designed to be clear to illiterate people and non-English-speakers with all three types of colour-blindness, and in the light from sodium bulbs. Is that true of your home-grown signs?

You may be teaching a group of MEWP drivers and assume none of them can possibly be blind, but they can still be colour-blind. Legally, red-green colour-blindness isn't a SINDA (total colour-blindness is) so DDA may not apply, but practically you still need to teach them which lever works the boom. It can help to have a diagnostic image handy in case someone seems to be struggling (you can download Ishihara patterns, which test for colour-blindness, from the web), and to design your PowerPoint slides to avoid bad colour combinations. If you're handling chemicals, the contrasting colours of your containers (and your gloves) might need a bit of a rethink.


Allied to the accessibility issues of not

being able to use a gadget is the stress of feeling you're being pressured into becoming a slave to something you don't understand. You'll give your staff training on the new database software you install, but how many have been offered training on their new mobile phones? Since the phone's probably more powerful than their computers were a few years ago, why assume they'll "get" how it works?

Resentment of new gadget-based work systems can be a major stress factor, but equally it's unlikely someone will admit they thought "pairing your Bluetooth" was a medical procedure, so be considerate when rolling out a new idea that you think is brilliant.

The crucial thing to take from this is that you should be thinking about the goal for the gadget, not the gadget itself. If you're putting all your risk assessments onto PDAs, it's not the PDA that matters, it's the fact the documents are becoming electronic, so you can use an accessible desktop PC too.

There's an acronym in tech support, FLBKAC, or "fault lies between keyboard and chair", which isn't entirely an insult to the caller; it's a reminder that any technology you implement has to be useable to be useful. If people found it easier to use the old forms on paper than the new ones on computer, you've got something wrong - and that's true if they're disabled or not, old or not, geeks or not.


Categories:
Disability Discrimination Act, Display Screen Equipment (DSE), Article

Related articles:
Employers' obligations on sight tests for DSE users
Hazards of call centre headsets
New DSE site launched

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