JIS Web Content Accessibility Guideline

This article was presented at CSUN's 19th Annual International Conference "Technology and Persons with Disabilities" (March 15-20, 2004, Los Angeles, CA) and was presented as a part of "IT Accessibility Standards- Equipment, Services And Web: JIS And ISO" presented by Mr. Seki and I.

Table of Contents

1 JIS Web content accessibility guideline will be published soon!

JIS (Japan Industrial Standard) X 8341-3 is a "Guideline for older persons and persons with disabilities -information and communications equipment, software and services- Part3: Web Content".

WG2, working group of this guideline, received comments from some important members of WAI and other 45 groups and persons during public-comment process last November. The development has almost finished and the JIS X 8341-3 is published on June 20.

I will show you some features of the current JIS X 8341-3 draft and explain the content by comparing it with WCAG 1.0 Recommendation and WCAG 2.0 Working Draft of W3C/WAI.

2 Feature of JIS X 8341-3

1. developed under the framework of ISO/IEC Guide 71 and a common guideline.
2. developed regarding WCAG 1.0 and other guidelines. also consider WCAG 2.0 WD. (We pay attention to the importance of international harmonization of Web accessibility standards)
3. technology independent (same concept as WCAG 2.0)
4. a lot of examples, which is technology specific. (same as WCAG 2.0)
5. JIS X 8341-3 is WCAG 1.4 +- something ?
6. aimed mainly for public use: public Web sites should use this guideline. 1st government, 2nd large private company, ...
7. consider Japanese specific issues.
8. incorporate some usability aspects:
   • mention the importance of process: life-cycle of design, development, evaluation, and maintenance.
   • end-user centered design. the intended user can perceive, understand, and operate content.

2.1 ISO/IEC Guide 71 (JIS Z 8071)

1. ISO/IEC Guide 71 (JIS Z 8071), "Guidelines for standards developers to address the needs of older persons and persons with disabilities", provides a general guideline.
2. Common guidelines are developed under the framework of JIS Z 8071.
3. JIS X 8341-1, "Guideline for older persons and persons with disabilities -information and communications equipment, software and services- Part1: Common Guidelines", is a common guideline in the area of information and communications equipment, software and services.
4. JIS X 8341-3 was developed under this common guideline. There is another guidelines such as JIS X 8341-2, "Part2: Information process equipment".

Thus, JIS X 8341-3 was developed under this three-layer framework; (1) ISO/IEC Guide 71 (JIS Z 8071), (2) a common guideline for ICT area, and (3) a Web content accessibility guideline. This framework is quite different from that of W3C/WAI guidelines.

3 Contents of JIS X 8341-3

• Introduction
• 1. Scope
• 2. Normative References
• 3. Definition
• 4. General Principles
• 5. Specific Requirements for Development and Production
• 6. General Requirements for Assurance and Improvement of Information Accessibility
• Annex 1 (informative reference) Examples Related to Web Content
• Annex 2 (informative reference) Reference Standards

4 Comparison between WCAG 1.0 and the JIS draft

Specific requirements of JIS X 8341-3 and checkpoints of WCAG 1.0 were compared because JIS X 8341-3 does not have checkpoints.

Links to a detailed correspondence matrix is shown in Section 6.2.1.

4.1 WCAG 1.0 Checkpoints not directly covered by the JIS draft

Checkpoint 9.1: Provide client-side image maps instead of server-side image maps except where the regions cannot be defined with an available geometric shape. [Priority 1]

We think server-side image maps, which sometimes cannot be replaced by client-side image maps, are allowed if an alternative methods are provided.

Checkpoint 9.3: For scripts, specify logical event handlers rather than device-dependent event handlers. [Priority 2]

We think JIS guideline "5.3.a) Web content must not assume operation with certain, single device, and at least all operations must be possible by keyboard." imply the same concept.

Checkpoint 11.4: If, after best efforts, you cannot create an accessible page, provide a link to an alternative page that uses W3C technologies, is accessible, has equivalent information (or functionality), and is updated as often as the inaccessible (original) page. [Priority 1]

Our guideline includes some statements that say "When this is not possible, an alternative must be provided.". We think the concept of checkpoint 11.4 is included in our guideline as a whole.

Other checkpoints

Some checkpoints of level 3 Priority do not have specifically corresponded guidelines in JIS. Some of those checkpoints not covered by JIS are also not covered in the current WCAG 2.0 Working Draft.

4.2 JIS draft Guidelines not directly covered by WCAG 1.0

5.2.e) A page must have a title which enables users to identify content of the page.

We understand that sometimes it is difficult to give a unique title for every page. Unique page titles, however, provide a variety of benefits. In 5.2.e), we give an example that says "For page specific titles which can be the same, provide additional information to make it easier to understand.". Thus, this guideline does not impose impossible solution and gives almost the same guideline as WCAG.

5.3.c) There should not be a timeout for input. Users must be notified when there is a timeout. and 5.3.d) Users should be able to extend or remove the timeout when it is set. When this is not possible, an alternative must be provided.

Guideline 2.2 of WCAG 2.0 WD gives a corresponding guideline about a time-limit issue.

5.3.i) There must be a mean to recover the original state when users performed an unintended operation on the Web content.

Guideline 2.5 of WCAG 2.0 WD gives a corresponding guideline about a minimize-error issue.

5.5.b) Information required to understand and operate Web content must not rely on shape and location alone.

We pay attention to shape because of the following two reasons:

• There are many Zenkaku characters in Japanese such as "☆, ★, ※, ＊", which shapes are similar and all these Zenkaku characters are converted from the same hiragana "hoshi" with a Japanese input method. Japanese documents sometime use these characters as icons to represent list items. Differences of these characters are clear by sight but not clear for screen readers. A Character Set defined in Unicode is more ambiguous and complicated. Much more similar-looking but different characters are included in Unicode.
• Shape of an image sometimes gives specific information.

The first problem may raise "Japanese and/or Asian language specific issues" summarized in Section 6.2.2. The second problem is covered by checkpoint 1.1 of WCAG 1.0.

5.6.b) Font which is easy-to-read considering size and typeface should be specified.

Japanese and some other languages have characters that consist of many strokes. Japanese Kanji characters, Chinese characters, of "隷" is one example. Characters consisting of large number of strokes may require larger size to be recognized by a user. This problem may raise "Japanese and/or Asian language specific issues" summarized in Section 6.2.2.

5.7.a) Sound should not be played automatically. It must be indicated that sound is being played if sound is played automatically. If sound is played using the "bgsound" element, users cannot detect that sound is being played, or cannot stop the sound, or control the volume of the sound.

Guideline 1.5 of WCAG 2.0 WD gives a guideline of audio-contrast of a Web content. JIS 5.7.a) claims more than 1.5 and gives the following informative references in the guideline:

• Hearing impaired users cannot detect that sound is being played, or understands the content. Also, there may be a situation where Web content is used in an environment in which sound cannot be played.
• When using voice browsers, automatically playing sound can cause difficulty in listening to the speech synthesizer.

5.7.b) Sound should be controllable by users.

Part of JIS 5.7.b) may be user-agent issues. We, however, adopt this guideline because of its importance.

5.9.b) In Japanese pages, foreign terms that may not be understood by the intended user should not be used. When using such words, explanation must be provided when the word first appears on the page.

Guideline 3.1 of WCAG 2.0 WD may contain this issue. This problem may raise "Japanese and/or Asian language specific issues" summarized in Section 6.2.2.

5.9.d) Extensible use of words that may be difficult for the intended user to read (such as proper nouns) should be avoided. When such words are used, the pronunciation must be specified at the first appearance of the word.

Guideline 3.1 of WCAG 2.0 WD may contain this issue. There are some proper nouns which pronunciation is very difficult. This problem may raise "Japanese and/or Asian language specific issues" summarized in Section 6.2.2.

5.9.e) Whitespace or linebreak must not be inserted in the middle of a word for presentation purpose.

We adopt this guideline because of the following two reasons:

• Japanese words in a sentence are not separated by space characters. This is true also for some other Asian languages and is quite different from American and European languages, which causes problems in some cases. In addition to that, there is other problem: old Japanese word processors displayed a large-size word by inserting a space between characters such as

  C A U T I O N

  and

  指 示

  . This kind of presentation method is still used in Japan. The current screen reader, however, cannot recognize these characters as one word but as series of several characters, which does not make sense to a user because pronunciation of one word,指示(Shizi), is sometimes quite different from those of consisting characters,指(Yubi) and示(Zi).

• Japanese language has Tategaki (vertical) writing mode. Some books are written in vertical. Japanese newspapers and magazines often use both horizontal and vertical writing in the same page. Although the writing-mode of CSS3 enables vertical writing from top to bottom, sometimes Tategaki is displayed by inserting a line-break element into every characters such as "T<br>A<br>T<br>E".

These problems may raise "Japanese and/or Asian language specific issues" summarized in Section 6.2.2.

5 Comparison between WCAG 2.0 WD and the JIS draft

I use "WCAG 2.0 WD of May 11, 2004" for comparison.

Links to a detailed correspondence matrix is shown in Section 6.2.1.

5.1 WCAG 2.0 WD guidelines not directly covered by the JIS draft

Every guidelines of WCAG 2.0 WD are covered by JIS X 8341-3.

5.2 JIS draft Guidelines not directly covered by WCAG 2.0 WD

JIS guideline not covered by WCAG 2.0 WD is only one: "5.9.e) Whitespace or linebreak must not be inserted in the middle of a word for presentation purpose.".

There are some guidelines which correspondence is weak but have the almost same intention as WCAG 2.0 WD. They are:

1. 5.2.d) Table elements should not be used for layout. (it resembles guideline 4.1 of WCAG 2.0 WD)
2. 5.2.f) Frames should not be used more than necessary. Purpose of each frame must be made clear when frames are used. (it resembles guideline 3.2 of WCAG 2.0 WD)
3. 5.5.b) Information required to understand and operate Web content must not rely on shape and location alone. (it resembles guideline 1.1 of WCAG 2.0 WD)
4. 5.6.a) Character size and font must be able to be adjusted by users as needed. (it resembles guideline 4.1 of WCAG 2.0 WD)
5. 5.6.b) Font which is easy to read considering size and typeface should be specified. (it resembles guideline 1.4 of WCAG 2.0 WD)
6. 5.8.a) Image or text which changes or moves should be created with consideration in its speed, color, and change of brightness. (it resembles guideline 2.2 of WCAG 2.0 WD)

6 Concluding Remarks

6.1 Next step

The activities of "JSA (Japanese Standards Association) Information barrier-free committee " and its working groups are finished in this fiscal year. The working group developed JIS X 8341-3. We think the following activities are needed to enhance Web accessibility.

1. development of checkpoints
2. consideration of testability and development of test tools
3. other guidelines for user agents, and authoring tools.
4. education and promotion of a guideline
5. research

6.2 Toward the goal of international standard harmonization

W3C/WAI Web Content Accessibility Guideline is an international Web accessibility standards. As Japan cannot adopt W3C standards, we developed JIS X 8341-3. We, however, want to contribute to the goal of international harmonization of Web accessibility standards. W3C/WAI, in corporation with JIS, takes WCAG 2.0 or its modified version to ISO is one option to realize standard harmonization.

6.2.1 Correspondence Matrix between JIS and WCAG

In order to facilitate the harmonization, we made the following correspondence matrices that shows the detailed relationships between JIS guidelines and checkpoints of WCAG 1.0 and guidelines of WCAG 2.0 WD:

1. Correspondence matrix between JIS X 8341-3:2004 and WCAG 1.0 or WCAG 2.0 WD (Microsoft Excel, includes Shift_JIS Japanese)
2. Correspondence matrix between JIS X 8341-3:2004 and WCAG 1.0 or WCAG 2.0 WD (XML spreadsheet, encoded in UTF-8. very large file: 5MB!)

Our major concern is if there are any issues that are not covered by upcoming WCAG 2.0.

6.2.2 Japanese and/or Asian language specific issues?

As mention in the earlier section, there seems to be some issues that may not be important in English and other European languages.

1. Emphasis on shape of characters and images. This may be derived from that Japanese and some other Asian languages are based on semantic characters. (text-equivalent issue?)
2. Font size and typeface. Kanji characters are more complicated than Roman characters. (usability issue?)
3. Difficult foreign terms and difficult words for the intended user of the Web site. (meaning issue?)
4. Whitespace or linebreak inside a word. (use-spec issue?)

We put emphasis on font shape because differences of font shape between some Zenkaku characters such as "ー" (Tyou-on), "―" (Zenkaku dash), and "−" (Zenkaku minus) are ambiguous. A Japanese word "リード" is a correct word that means "lead" in English, while "リ―ド" makes no sense. Sighted users even does not notice this mistake, while users who use a screen reader cannot understand that word. Other example is "Ｚ" (Zenkaku Z) and "Z" (Hankaku Z).

There are some other problems that is not Web content accessibility issues but often raises problems in Japan. They are:

1. Non-standard Coded Character Set: In Japan, Windows Character Set is often used. This character set has characters that is not included in JIS X 0208. These non-standard characters often raise problems. (Actually it hangs up my Emacs!)
2. Various Character Encoding Schemes: Various encoding schemes such as ISO-2022-JP, EUC-JP, and Shift_JIS are used to represent Japanese characters. Co-existence of different encoding schemes often raises problems. This problem will be dissolved when Unicode is widely used.
3. Unicode: Special attention should be paid for Unicode. A Character Set defined in Unicode is more ambiguous and complicated; much more similar-looking but different characters are included.
4. Proper nouns written in Kanji characters sometimes have various pronunciations. For example, "三田" can be read as "みた" (Mita) or "さんだ" (Sanda). In these cases users cannot imagine the correct pronunciation if it is not presented by a content creator.

In November 2003, we received a public comment from some members of WAI that said the following two JIS guidelines would be discussed in WCAG 2.0:

1. 5.9.c) Abbreviations, technical terms, words in vogue, slang, etc. which may not be understood by the intended user should not be used. When such words are used, they must be defined at their first appearance in the page.
2. 5.9.d) Extensible use of words that may be difficult for the intended user to read (such as proper nouns) should be avoided. When such words are used, the pronunciation must be specified at the first appearance of the word.

We must investigate (1) is there any additional Web content accessibility issues in terms of language, society, and/or culture?, and (2) does WCAG 2.0 cover Web content accessibility issues all over the world?

7 References

1. Web Content Accessibility Guidelines 1.0
2. Web Content Accessibility Guidelines 2.0 (W3C Working Draft 11 March 2004)
3. JSA (Japanese Standards Association) Web Store

Last modified: Wed Mar 24 15:02:13 JST 2004 : WATANABE Takayuki

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