This page describes Oracle's interpretation and position on several accessibility standards included in Section 508 or WCAG 1.0. We provide it in response to customer inquiries regarding specific HTML content, particularly when automated validation tools indicate non-conformance. The majority of issues arise from the fact that these regulations and standards were written in 1999 or 2001, and the technology of browsers and assistive technology (AT) has advanced significantly since then. Oracle welcomes the rewrites of both Section 508 and WCAG, which modify or clarify many of the provisions discussed below to take into account technological changes, and we are actively participating on the committees that are effecting those changes.
For brevity, a reference such as '1194.22(l)' refers to provision 1194.22(l) in the Section 508 standards (which can be found at Part 1194 of Title 36 of the Code of Federal Regulations), and a reference such as 'WCAG 1.0 #6.3' refers to standard 6.3 of WCAG 1.0.
1194.22(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.
WCAG 1.0 #6.3 Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent information on an alternative accessible page.
WCAG 1.0 #8.1 Make programmatic elements such as scripts and applets directly accessible or compatible with assistive technologies.
VALIDATING TO PUBLISHED FORMAL GRAMMARS
WCAG 1.0 #3.2 Create documents that validate to published formal grammars.
Oracle's position Several HTML tags have no bearing on accessibility, and browsers are known to interpret tags differently. The key point is that the tags related to accessibility must be interpreted unambiguously by the browser and assistive technology. Oracle's HTML may not exactly adhere to a formal grammar for a variety of reasons:
In various cases we need to add extra information onto the HTML DOM and we use "expandos" for this purpose.
As recommended by W3C WAI-ARIA, we use tabIndex="-1" to make certain elements focusable.
Because browsers operate differently, we may optimize the HTML to account for specific browser behavior.
Provided the customer is current on technical support, Oracle will resolve any issue where 'non-standard' HTML impedes accessibility, in accordance with Oracle's standard technical support policies, but Oracle will not necessarily correct 'invalid HTML' that is reported by an automated tool but has no negative ramifications on accessibility.
WCAG 1.0 #6.4 For scripts and applets, ensure that event handlers are input device-independent.
WCAG 1.0 #9.2 Ensure that any element that has its own interface can be operated in a device-independent manner.
WCAG 1.0 #9.3 For scripts, specify logical event handlers rather than device-dependent event handlers.
Oracle's position Some customers have interpreted these standards to mean that any operation that can only be performed with a mouse, such as a double-click, is prohibited. Oracle is committed to providing a rich user experience to all users, and in situations where actions require complex mouse actions such as double-click or drag-and-drop, alternative mechanisms that can be performed with the keyboard only will be provided.
1194.22(i) Frames shall be titled with text that facilitates frame identification and navigation.
WCAG 1.0 #12.1 Title each frame to facilitate frame identification and navigation.
Oracle's position Oracle has encountered many situations where frames were viewed as either being a 'violation' of accessibility standards, or not considered 'proper HTML.' Oracle believes that frames are a legitimate part of HTML, and we only certify with browsers that support them. In our products, frames are properly marked up according to the relevant standards cited. One exception is the use of an iFrame, when it is being used simply to communicate with the server. In this case, Oracle intentionally does not title the frame so as to make the element invisible to the user (just as it is to a sighted user).
1194.22(d) Documents shall be organized so they are readable without requiring an associated style sheet.
WCAG 1.0 #6.1 Organize documents so they may be read without style sheets. For example, when an HTML document is rendered without associated style sheets, it must still be possible to read the document.
Oracle's position Oracle interprets this standard to mean that information ('content') and presentation should be separated. For example, HTML should have semantic markup identifying the information, and an external style sheet should be used to render a particular look and feel. When a user accesses the page with assistive technology, the information must be communicated in a meaningful sequence. However, Oracle does not accept that the product must run with style sheets disabled in the browser, because:
All modern browsers support style sheets
Setting style attributes such as display:none in the page content is commonly used to hide content from all users; disabling style sheets completely will cause this information to erroneously appear
Modern browsers support overriding the author style sheet with a user style sheet if required
TABLE FOR LAYOUT
WCAG 1.0 #5.3 Do not use tables for layout unless the table makes sense when linearized.
Oracle's position When possible, we will use Cascading Style Sheets (CSS) exclusively for layout, but the use of tables for layout purposes does not necessarily preclude an accessible solution, provided they are coded properly. In such cases, Oracle includes an empty summary tag on the table to indicate that it is a layout table as opposed to a data table.
LINKS TO PLUG-INS
1194.22(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with 1194.21(a) through (l).
Oracle's position Many plug-ins, such as Adobe's PDF viewer, are now ubiquitous, and are often pre-installed on computers. In some cases, such as with the Oracle JInitiator, the plug-in is shipped with the product and automatically installs itself. Furthermore, providing a link to a site outside a company firewall, or enabling a user to download and install a plug-in, may be in violation of corporate policy. Oracle products therefore will provide links to plug-ins that meet this standard when they are either not considered ubiquitous, or are not shipped with the product.
1194.22(o) A method shall be provided that permits users to skip repetitive navigation links.
Oracle's position Many Oracle products provide a link that will move focus to the 'main content' of a page. However, Oracle is also aware that most AT supports a mechanism that allows the user to move to various sections of a page using standard structural markup tags. Oracle may, when appropriate, use this mechanism as a means of accomplishing the goal of this provision.