Attention all Airlines: New Regulations Make Website and Kiosk Accessibility Mandatory

November 21, 2013 |

On November 4, the Department of Transportation issued the Air Carrier Access Act (ACAA) to require U.S. and foreign air carriers to make their websites that market air transportation to the American public accessible to individuals with disabilities. Outlined below are three of the key requirements included in the Nondiscrimination on the Basis of Disability in Air Travel: Accessibility of Web Site and Automated Kiosks at U.S. Airports regulations, as well as suggestions on steps that can be taken to meet compliance.

1. The core functions (including reservations, frequent flyer accounts, etc.) must comply with the W3C’s Web Content Accessibility Guidelines (WCAG) 2.0 levels A and AA by November 2015. ALL web pages on the airline’s site must also meet these standards by November 2016.  Testing must include consultation with individuals with disabilities.

Revising the core pages of an airline’s website (i.e. ticketing, check in, manage your booking) to conform to WCAG 2.0 by November 2015 will be a challenge so airlines need to begin immediately.  To start, airlines need to benchmark for Web accessibility by auditing their current website to identify issues and map out a plan for remediation. If you’re stumped on how to do this enlist the help of a third party to conduct a Web accessibility assessment that uses an automated solution to validate the site against accessibility guidelines, combined with manual testing.

Every page that will be accessed by users with disabilities will need to be individually tested, both with automated and manual testing.  I recommend that airlines start thinking about developing robust test scripts that cover all of their core pages, manually test each of those pages with assistive technology, and use an automated testing solution that can perform test scripts. Note this requires an automated solution that does not merely “crawl” content, but also can intelligently interact with pages by inserting user content—such as credit card numbers or other user data—into pages.

The automated solution should test content as it is remediated and track progress against goals to keep projects on track so sites are ready in time for deadlines. The reporting will also provide insight into where more training might be needed. Keep in mind content is always changing so to ensure it remains accessible, you should employ an automated solution that regularly scans and monitors content to immediately identify issues as they arise, preventing major problems.

Why both manual and automated testing? 

Manual testing is needed because no automated solution can test all of the WCAG 2.0 requirements.  Automated testing is needed because it more thoroughly can test and pinpoint violations more clearly and rapidly.

In addition, beyond manual and automated testing, ALL of these pages will need to be manually tested by users with disabilities.  But disabled user testing is separate from manual testing for several reasons.  First and most obviously, a disabled user can only test what they know exists—and sometimes content appears visually on a screen and a disabled user has no way of knowing that the content was there and passes the page.  Second, disabled user testing serves a different purpose— as opposed to strictly looking at compliance with standards, disabled user testing focuses on the actual usability and practical user experience for persons with disabilities.

Airlines must then make the rest of the site i.e. non-core pages like the ‘about us’ for example accessible by November 2016. This can be as daunting because of the hundreds of thousands of constantly changing Web pages.  This is an area where automated testing is a must, because it can find infrequently accessed pages buried deep under layers of your site.  Manual testing is important here as well, but it may prove economically practical to limit manual testing to randomly selected pages.  This is particularly true for massive sites and where the structure of the pages is roughly identical (such as sites built on a basic template).  Again, however, this only applies to non-core pages; core pages must all be individually tested.

All of this work—manual testing, automated testing, and disabled user testing—needs to begin now and should definitely become part of any redesigns over the next two years.

2. By April 2015, all online discounts or opportunities must be given to persons with disabilities whose disability makes online access impossible.

To understand this point, consider how some airlines charge when you call to make a booking versus using the website. If you are a person with a disability, you should not need to pay extra because the airline’s website is inaccessible.

Airlines that comply with point one by scanning content for accessibility and remediating issues will ensure the widest possible audience can access discounts online, reducing the number of phone transactions required.

3. Any automated kiosks installed after November 2016 must meet basic accessibility requirements set forth in the rule, until at least 25% of all kiosks are accessible.  Notwithstanding this requirement for new kiosks, by November 2023, airlines must ensure that at least 25% of all kiosks are accessible.  Generally, all of the function available on inaccessible kiosks must be available on accessible kiosks.

Consider outsourcing accessibility testing of automated kiosks. If you just do not have the staff resources to address accessibility, consider having a third party help you get started.  There are a handful of companies that specialize in this work and can help you avoid a long, steep, and expensive learning curve.

While aimed at airlines conducting business in the US, these new regulations continue the global trend moving toward WCAG 2.0 AA as the standard for accessibility. I predict this will inevitably become a requirement for all US organizations with a web presence.

Download our Guidance at a Glance: Web Accessibility whitepaper which offers advice on what regulations apply to airlines and includes steps you can take towards building a comprehensive Web accessibility program and the role technology solutions can play in achieving compliance.

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Ken Nakata

Ken Nakata, JD, CIPP/US is the one of the most well-known attorneys in the area of IT accessibility and is the Director of Cryptzone’s Accessibility Consulting Practice (ACP). Nakata’s work focuses on Web and software accessibility from both a legal and technical perspective. Nakata’s ACP team helps organizations manage the change towards accessibility in all aspects, providing consulting services aimed at shaping their accessibility policies and practices, and evaluating the overall state of their Web properties leveraging Cryptzone’s accessibility solutions. He is also a board member for the International Association of Accessibility Professionals (IAAP),of which Cryptzone is a founding member.

Nakata worked for twelve years as a Senior Trial Attorney with the U.S. Department of Justice. He has argued on behalf of the United States government many times before the federal courts and has helped shape the government’s policies for the Americans with Disabilities Act and Section 508 of the Rehabilitation Act. Nakata also worked as Director of Accessibility and Government Compliance at BayFirst Solutions, a Washington, DC consulting firm.

In 2000, Attorney General Janet Reno presented Nakata with the Attorney General’s Award for Excellence in Information Technology. In addition to practicing law, Nakata is active in software and web-based technologies, including Java, JavaScript, SQL, and ColdFusion. In July 2001, he was certified by Sun Microsystems as a programmer for the Java 2 Platform. Nakata is a frequent speaker on both law and technology and is equally adept at conducting one-on-one workshops with programmers and developers as well as explaining law and policy to large audiences. He holds a Bachelors of Art degree in mathematics from John Hopkins University and a Juris Doctor degree from the University of Pennsylvania Law School, and is admitted to the bars of New York, the District of Columbia, Pennsylvania and Washington.

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