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PAS 78: a new standard in Web accessibility

By David Sloan, published 14th March 2006, updated 5th June 2006.

A new UK standard relating to web site accessibility was formally launched at an event in London on March 8th 2006. Having commented on the draft of the standard last summer, I travelled down to London to find out how the published version had evolved.

The standard was produced by the British Standards Institute (BSI) and commissioned by the Disability Rights Commission (DRC), and has a potentially very significant role to play in efforts to improve the accessibility of Web sites. The formal title of the standard is Publicly Available Specification PAS 78:2006 Guide to good practice in commissioning accessible web sites - or PAS 78 for short. A PAS is not the same as a full standard, in that it has a lifetime of only two years, at which point it can be updated to reflect new developments in for example browsing technology or design techniques.

Update 05-06-06: Based on some public comments by Julie Howell of the RNIB, and who was the technical author of PAS 78, some minor edits have been made to this review. Julie emphasises that that PAS 78 is not a standard. I've used "standard" in this article to refer to PAS 78 becasue, although it is not a full standard under BSI's definition, it is a formal document commissioned by the Disability Rights Commission and published by the leading UK publisher of standards, having undergone a formal drafting and review process (although not necessarily consensus based). It's therefore something to which we can refer as a stable, authoritative document (at least for 2 years) relating to the commissioning (as opposed to design) of accessible web sites. After 2 years, it is likely to be replaced by a new document - but in the meantime, with that definition in mind, I'll continue to refer to it as a standard (with a small s) in this article!

Who's the standard for?

The standard's name gives an indication of the most important feature of the standard: unlike other existing accessibility standards and guidelines, PAS 78 is aimed at people commissioning - rather than designing - web sites.

One of the recommendations of the DRC's Formal Investigation into the accessibility of UK web sites [1], published in 2004, was a lack of awareness and knowledge in accessibility amongst people who commissioned web sites, either within their own organisation or by engaging other organisations to carry out the work for them. Some people commissioning Web sites were unaware of the importance of ensuring that the web sites they commission are as accessible as possible to disabled people. Other web site commissioners were aware of their responsibilities under the UK's Disability Discrimination Act (DDA), but did not have the technical knowledge necessary to:

Given the increasing significance of Web accessibility, this has led to a great increase in the number of organisations who claim to offer accessible web design as part of their services. Some commentators, such as Roger Johansson [2], have noted the increase in 'cowboy' operators who claim to offer accessibility services but do not have the necessary skills to support their claims.

So, for example, we see organisations who offer 'DDA compliant' web sites when it is currently impossible to make such a claim, given the nature of the DDA legislation. This point is explicitly made in page 34 of the PAS 78 document. But if a web site commissioner is equally uninformed, these organisations may continue to be engaged, resulting in the continuation of the development of poorly designed web sites with accessibility problems.

What does it say?

The value of PAS 78 will be as a document that gives web site commissioners an overview of the process of accessible web design. As well as providing background information on how people with different disabilities use the Web, the standard conveys the following key messages:

There is also useful guidance on the role and use of non-W3C technologies, such as PDF and Flash, and (thankfully) an acknowledgement that judicious use of these formats can enhance rather than reduce accessibility.

What's in it for accessible web site developers?

For people who already design accessible web sites, PAS 78 should not contain any surprises. For these people, the main value of purchasing the standard will be to understand what it means when a prospective client is being guided by PAS 78 in defining the requirements of the web site being commissioned. Annex C also provides information to suppliers of web sites on how they can demonstrate the use of a design process that incorporates accessibility throughout.

A note on user testing

The emphasis in PAS 78 of the importance of user testing in the development and evaluation of accessible web sites is very welcome. It comes from the recommendations of the DRC's Formal Investigation into Web Accessibility, and is also in line with UK legislation, which requires that disabled people can access and use goods, facilities and services. The clear message throughout the launch event was that a basic technical level of accessibility is not enough. In his article "Web accessibility - what not to do" [3], Jim Thatcher provides a fine example of how a site can apparently achieve technical accessibility yet fall far short of providing an acceptable user experience for disabled people.

PAS 78 does set rather a high bar in terms of user testing. Rightly, it acknowledges that testing with a number of users with different impairments is important; and also notes that these evaluators should ideally exhibit a range of skills and use a range of access solutions. It also notes that reliance on one or two evaluators may lead to a bias in interpreting the results of the evaluation into findings suited specifically to that evaluator, rather than more generally applicable findings.

However, the danger of this is that it may pressure people into an "all or nothing" approach to user testing, particularly given that during the launch event, the issue of recruitment problems was raised (and is also acknowledged in the standard itself). Finding evaluators of sufficient variety, finding an accessible test environment, conducting evaluations and transforming the findings into design recommendations are all challenges too. There are organisations that can provide user evaluations with disabled people, (such as ourselves!) but a pragmatic view would be that there is certainly value in engaging even one disabled person in evaluating a site, so long as the findings of the evaluation are taken in the context of that person's experience and level of impairment, and in the context of other findings from accessibility evaluation of the site.

The launch event

A welcome feature of the launch event was the opportunity to hear the experiences of some major organisations that have reaped the benefits of commissioning accessible web sites.

The experience of Tesco in developing an accessible web based grocery ordering service after they experienced a screen reader user struggling to use an old version of their web site is perhaps the most well known. Nick Lansley from Tesco explained why they initially opted for a separate 'Access' version of their site, risking accusations of segregations of disabled people, rather than redesign their existing site. Their key aim was to ensure that users could complete the task of purchasing a 'typical' amount of groceries in 15 minutes, and they considered that this would not be possible for all groups by retrofitting their existing site. However, Tesco are in the advanced stages of a new project which will allow people to choose the appearance of a new version of the company's site based on their accessibility requirements.

A presentation by a representative of Legal and General, the financial services company, outlined their reasons for ensuring accessibility was an important factor in commissioning a redevelopment of their web site. The presentation also gave the audience some very interesting statistics illustrating the impact of the site redesign, statistics so powerful in illustrating the benefits of accessible Web design that they are likely to be quoted for many years.

The financial benefits as quoted by Legal and General:

Other benefits:

Jonathan Hassell from the BBC talked about their efforts, with AbilityNet, to produce the "My Web My Way" [4] web site supporting people in making their own adjustments to their computer in order to improve accessibility. This has a potentially significant contribution to make in enabling web users to benefit from accessible web sites by making changes to the display of the site or the way the site can be navigated to best suit their own accessibility needs.

Implications of PAS 78

So what impact will PAS 78 have on the accessibility of Web content? It's clear that PAS 78 will be an important reference to include in contracts, and something against which delivered work can be assessed. This makes it a potentially important tool from a legal perspective, in that if an organisation demonstrates conformance with PAS 78, this could be seen as evidence the organisation had taken "reasonable steps" to avoid unlawful discrimination as required by the DDA.

Similarly, if a web site commissioner specifies PAS 78 conformance within a contract, yet the web site delivered by the supplier contains accessibility problems, the customer may be able to prove that the development team were in breach of the contract by failing to follow the standard.

The standard is not freely available - it costs 30, which for a formal standards document is relatively cheap. Of course, by comparison, design guidelines such as the WCAG are free, and in the days following the launch there have been worries have been expressed that the price of the standard may put people off from accessing and using it.

However, unlike the WCAG, the value of the standard is as a tool for commissioners of web sites to raise their own awareness of the issues and responsibilities, to demonstrate their commitment to accessibility and to take steps towards meeting their responsibilities under the DDA.

Organisations supporting the rights of disabled people, such as the DRC, will of course also be aware of the standard. So, should any case or alleged discrimination come to court, the courts will likely assess the degree to which the organisation providing the web site have ensured it follows PAS 78. In this context, spending 30 (a sum not much more than the cost of a good book on standards compliant web design) on a standard seems to be a 'reasonable step' towards ensuring compliance with the DDA.

How to get a copy of the standard

The standard is available to order on the BSI web site, and also from other stockists of standards, in hard copy and digital format, and also (appropriately) in a variety of alternative formats. Details on how to purchase a copy of the standard are available on the BSI web site:

BSI Press Release - Launch of PAS 78

BSI - Where to buy standards.

Other Perspectives

Other accounts of the launch event and the potential impact of the standard are available from:

Bruce Lawson - the perspective of a web developer and web standards advocate: - a legal perspective:
Joe Clark - accessiblity expect and advocate. Joe wasn't at the launch event but provides his detailed critique of the standard:


  1.  DRC (2004) Formal Investigation report: web accessibility
  2.  Johansson R. (2005) Accessibility Charlatans. 456 Berea Street, February 9th 2005:
  3.  Thatcher J. (2002) Web Accessibility - What not to do.
  4.  BBC (2005) My Web My Way