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Comments and responses on CEN/BT WG 185 analysis of conformance schemes for accessibility. This web page is used for publishing responses to comments and questions regarding the CEN/BT WG 185 analysis on testing and conformance schemes of products and services meeting accessibility requirements.

Comments, contributions, and questions

Any stakeholder is welcome to send comments, contributions and questions to the project team assigned to provide the analysis, by using the e-mail address The project team will consider the submitted issue and decide how to deal with it. The response on how the issue will be dealt with, and the resulting impact on the output delivered from the team, will be published on this webpage together with the source and date of the issue. The webpage will be reviewed regularly by the BT WG who will be the final arbiter of any conflicts about the resolution of an issue or its entry into the register.

Comments and responses

comment start iconProject Team - 1 October 2008

More than 192 comments where received on the May Final Draft Version of the document. They where addressed by the Project Team in the Final Report (currently for approval in Nice, october 8th 2008. This document can be downloaded from the reports page.

comment start iconProject Team - 7 April 2008

Several contributors. From January to March 2008. Several members of the BTWG have made comments on the content of the first draft report (released in December 2007).

  • BTWG185 Project Team response, 13 March 2007.
    These comments have been taken into account when preparing the interim technical report. They are discussed in the collation of commentsl. This document can be downloaded from the reports page.

comment start iconMark Magennis - 13 Dec 2007

ANEC and EDF have published a joint position paper on e-accessibility.

comment start iconInformation on a White Paper on conformance and accessibility, 30 Nov 2007

Alex Li, SAP and James Thurston, Microsoft, has informed of a new report by the IDC on conformance and accessibility

comment start iconProposal from Shadi Abou-Zahra, W3C, 9 Nov 2007:

It would be really useful to be able to track new comments using an RSS feed, I hope it will be possible to provide this.

  • BTWG185 Project Team response, 14 Nov 2007
    At present, Verva does not provide RSS-services other than from its news page. Visitors to Verva's web site have not expressed any demand for RSS-services. However, Verva recognizes the usefulness of RSS both for the M376-page and for some other pages, and will consider the proposal.

comment start iconContributions from Richard Hodgkinson, member of BT WG 185, 6 Nov 2007

  1. some recommendations on testing web sites on the Australian Human Rights & Equal Opportunities Commission web site at see clause 3.5
  2. A checklist for software accessibility, by the Irish National Disability Authority: application-software-accessibility
  3. Guidelines on testing and evaluation of software, by the British Royal National Institute of Blind People:
  4. Clauses 52-69 in the document "Delivering inclusive websites", by the UK Central Office of Information. The document is available at

comment start iconContribution from  Hajime Yamada, member of the BT WG 185, 28 Oct 2007

A document which adresses the PT work directly, "ICT accessibility standardization and its use in policy measures". The document is available at

comment start iconThanks to Massimo Canducci, 31 Oct 2007

The Project Team expresses its thanks to Massimo Canducci for the possibility to contact him  about the italian law on accessibility, requirements set and application modality.

comment start iconProposal from Dr. Günter Dubrau of InterComponentWare AG, 31 Oct 2007

“In my eyes accessibility is usability for users with handicaps. Thats why I want to propose to use the ISO 9241-11 & -10 as one basis for conformance schemes for accessibility.”

  • BTWG185 Project Team response, 6 Nov 2007
    The issue of using ISO 9241-10 and -11 for accessibility requirements gives rise to (at least) two important questions which need to be further discussed in Phase 1 and 2:

    a) If accessibility is defined in terms of usability, such as in ISO 9241-171 on software accessibility, the accessibility is not an intrinsic characteristic of a product. Instead, it is dependent on the context of use, including the users. This makes it difficult to use in a procurement for a whole organisation, since there may be many different contexts of use. However, we might introduce two levels of accessibility:

    • “True accessibility”, which is the meaning of the ISO definition and would require to evaluate a product or service with every type of user and every context of use. It is something that cannot be truly stated for any product or service. Only each end user can tell us about the perceived accessibility of one product or service. This level of accessibility is applicable for a procurement for one specific context of use. 
    •  “Legal accessibility”, which is the conformance of accessibility criteria. Even if ISO 9241-171 defines accessibility in relation with usability, the standard contains a set of requirements and recommendations that can be tested in controlled ways (although the evaluation requires human expertise) and could lead us to state: “this product or service conforms to the accessibility requirements of ISO 9241-171”, for instance. This level of accessibility is applicable for organisation-wide procurements and requirements for conformity assessments.

    b) One of the elements of usability is satisfaction. Satisfaction can be measured on objective or (more likely) subjective grounds. Subjectivity seem to be in contradiction to transparency and predictability, which are principles that must be taken into account in public procurement. How is it possible to handle subjectivity in the evaluation of tenders and still consider transparency and treat tenders equally?

comment start iconComment from Carlos Velasco, 3 November 2007

You may want to look into the Unified Web Evaluation Methodology (UWEM), which is not a conformity assessment scheme, but it can support it. See:

  • BTWG185 Project Team response, 6 Nov 2007
    Thank you. The Project team is well aware of the UWEM, since a member of the team, Eric Velleman, is the coordinator of the Wab Cluster.