EPA's Approach to Social Media and Accessibility
A few weeks ago, there was a vibrant discussion on the Gov't Web Mgrs Forum (open only to gov't employees) about how to both ensure accessibility and use social media sites like YouTube.
There are as many interpretations of what's required and what's best practice as there are people discussing these issues.
So I took my thinking offline and had further discussions with people on the Access Board, the federal agency responsible for implementing section 508, and our 508 coordinator. My goal: decide how to proceed for EPA. After the Access Board folks confirmed our approach was valid, I sent the following to the listserve. Note that the reasoning is as important as the approach; it's based on the law, the desire to serve everyone's needs, and technology reality.
Message to the Forum:
Hi everyone. I've followed with interest the continued discussion of section 508 and YouTube (and similar sites). And I've had further discussions with people on the Access Board, the federal agency responsible for implementing section 508, and our 508 coordinator, Amanda Sweda. My goal: decide how to proceed for EPA. Being who I am, I'm writing this to share our reasoning and decision with all of you for your consideration. However, I'm not really trying to continue debating what should and shouldn't be.
Before I get to the details, I think the question of whether YouTube's captioning is good enough is a distraction from the general case; there are plenty of sites we should be using that simply aren't accessible, and we need a general approach for all of them.
The question isn't "must we produce accessible materials?" That answer has been and remains "absolutely."
Rather, the questions are:
1) Should we be using social media sites at all?
My answer is: absolutely. The simple facts, as I see them:
a) YouTube receives 100,000,000 daily views of their videos, compared to EPA's entire site receiving about 1,300,000 daily page views.
b) Facebook has 150,000,000 active users, compared to our 3,000,000 "unique hosts" each month.
The people are out there much more than on our own site. In physical space, would you build your kiosk in your office's reception area or in the busiest mall in the world?
I'd say both. Use the social media sites to be more easily found, but keep the same materials on your own site, too. Social media should be a supplement, not a replacement, for gov't sites. Setting aside accessibility, keeping your own site provides multiple other benefits, including credibility, permanence, records management, and the ability to offer related information.
So I think the answer to #1 is yes.
2) If they're inaccessible, can they be made accessible?
The top multimedia sites aren't as accessible as we'd like.
And I acknowledge the difficult dilemma: if we never ask them to change, they might never do it. Nevertheless, I believe that no agency will be able to force them to. I'd strongly support any cross-agency effort to apply pressure, but it doesn't exist today, and we're missing these communication and engagement opportunities right now.
Therefore, I think it's an undue burden to try to change sites like YouTube.
What 508 says is: if it's an undue burden to provide an accessible version, "agencies shall provide individuals with disabilities with the information and data involved by an alternative mean of access that allows the individual to use the information and data."
So I think the answer to #2 is yes, provided we can find that alternative.
3) How can we use them while also ensuring access for people with disabilities?
At EPA, we believe that posting to social media sites and linking back to an accessible copy on our own site qualifies as that alternative means. Therefore, we're convinced this approach meets both the spirit and letter of section 508.
There are as many interpretations of what's required and what's best practice as there are people discussing these issues.
So I took my thinking offline and had further discussions with people on the Access Board, the federal agency responsible for implementing section 508, and our 508 coordinator. My goal: decide how to proceed for EPA. After the Access Board folks confirmed our approach was valid, I sent the following to the listserve. Note that the reasoning is as important as the approach; it's based on the law, the desire to serve everyone's needs, and technology reality.
Message to the Forum:
Hi everyone. I've followed with interest the continued discussion of section 508 and YouTube (and similar sites). And I've had further discussions with people on the Access Board, the federal agency responsible for implementing section 508, and our 508 coordinator, Amanda Sweda. My goal: decide how to proceed for EPA. Being who I am, I'm writing this to share our reasoning and decision with all of you for your consideration. However, I'm not really trying to continue debating what should and shouldn't be.
Before I get to the details, I think the question of whether YouTube's captioning is good enough is a distraction from the general case; there are plenty of sites we should be using that simply aren't accessible, and we need a general approach for all of them.
The question isn't "must we produce accessible materials?" That answer has been and remains "absolutely."
Rather, the questions are:
1) Should we be using social media sites at all?
My answer is: absolutely. The simple facts, as I see them:
a) YouTube receives 100,000,000 daily views of their videos, compared to EPA's entire site receiving about 1,300,000 daily page views.
b) Facebook has 150,000,000 active users, compared to our 3,000,000 "unique hosts" each month.
The people are out there much more than on our own site. In physical space, would you build your kiosk in your office's reception area or in the busiest mall in the world?
I'd say both. Use the social media sites to be more easily found, but keep the same materials on your own site, too. Social media should be a supplement, not a replacement, for gov't sites. Setting aside accessibility, keeping your own site provides multiple other benefits, including credibility, permanence, records management, and the ability to offer related information.
So I think the answer to #1 is yes.
2) If they're inaccessible, can they be made accessible?
The top multimedia sites aren't as accessible as we'd like.
And I acknowledge the difficult dilemma: if we never ask them to change, they might never do it. Nevertheless, I believe that no agency will be able to force them to. I'd strongly support any cross-agency effort to apply pressure, but it doesn't exist today, and we're missing these communication and engagement opportunities right now.
Therefore, I think it's an undue burden to try to change sites like YouTube.
What 508 says is: if it's an undue burden to provide an accessible version, "agencies shall provide individuals with disabilities with the information and data involved by an alternative mean of access that allows the individual to use the information and data."
So I think the answer to #2 is yes, provided we can find that alternative.
3) How can we use them while also ensuring access for people with disabilities?
At EPA, we believe that posting to social media sites and linking back to an accessible copy on our own site qualifies as that alternative means. Therefore, we're convinced this approach meets both the spirit and letter of section 508.
Comment
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Comment by Jeffrey Levy on February 12, 2009 at 12:06am -
Dan: YouTube isn't the place to have thoughtful exchanges. That said, we'll take a shot at accepting comments and see what happens. We expected a lot of puerile stuff on our blog, but out of more than 5400 comments, maybe 10 were the kind of thing I see all over YT.
So yes, for us, it'll be primarily another outlet so people can find our videos when searching for stuff having nothing to do with EPA
And we'll continue exploring other routes to have meaningful dicussions with people. For example, we're working on a discussion forum where people can exchange thoughts about an upcoming regulation before they formally comment on it.
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Comment by Joe Flood on February 11, 2009 at 3:17pm -
Here's an effective government-sponsored page that I had a part in creating:
http://www.youtube.com/oceanexplorergov
It's the NOAA Ocean Explorer channel. It contains copies of videos that are also posted on NOAA Ocean Explorer, thus complying with Sec. 508 requirements. It also has the NOAA logo and brand on it, per a special partnership with YouTube. We decided not to allow comments because we were unsure of the policy implications and resources weren't available to reply to them. The channel has been a big success, reaching a new audience on YouTube and in driving traffic to Ocean Explorer. YouTube is one of the top referrers to the site. It's also been a model for other government agencies trying to set up their own YouTube channels. Ignoring YouTube in this day and age is like saying you don't want your videos on TV - it is the TV for the wired generation.
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Comment by Daniel Bevarly on February 11, 2009 at 12:13am -
Jeffrey - This is a very thoughtful approach and I wish the EPA good luck. I still have concerns over the use of You Tube as a social media site to deliver your content. I have yet to identify an effective government-sponsored page there, and I am not sure of their intent other than to publish content. Comments/Questions are not responded to; at least not on the page so that others may read them. Other comments are senseless if not insulting. I understand the traffic patterns and potential for viewers. However, I think of other sites, or communities that focus on your mission, whether they be grassroots, public-private or industry-specific and their potential to provide effective avenues to supplement the EPA's inventory and connect to a more engaging audience. Still, I applaud EPA for taking a thoughtful and determined position to reach out and inform citizens of its activities.
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Comment by Marilyn Clark on February 10, 2009 at 5:37pm -
Jeffrey, I so appreciate you posting this, following up from our call this morning. Accessibility has become a strong focus in our organization (in face I rant about this a little here in my post from yesterday. We need to be able to support exploration of social media tools for our ongoing strategic communication, and agree that the spirit of section 508 is maintained if by providing accessible media on our own site.
Out of curiosity, it sounds like there is quite a bit of structure around how accessibility is managed at Federal agencies in terms of design, test and compliance. Can you shed any light about organizational structure and responsibilities in this area? Thanks!
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Comment by Jeffrey Levy on February 10, 2009 at 5:29pm
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Sarah: I agree completely that the government should exert pressure on these sites to do better with accessibility! I'm just not sure how, and I think we should accept this solution in the meantime.
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Comment by Joe Flood on February 10, 2009 at 4:22pm
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I agree (obviously). Another potential argument is that all of these videos are in the public domain. Since they're in the public domain, the public is encouraged to take these videos and distribute them as widely as possible. After all, the public paid for them and there should be no restrictions on their use. They should not be "banned" from a particular site, especially since they're also posted on a fully accessible EPA site.
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Comment by Sarah Bourne on February 10, 2009 at 4:10pm -
I for one look forward to "pushing back". Over the years, I have known people with a variety of disabilities, and I can't think of one who deserves to be treated like a second class citizen.
Also, just as curb cuts mandated so people who use wheelchairs can be self-sufficient have been a boon for people with rolling luggage and baby carriages, the things you do to make web content accessible improve the usability for all users.
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