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.