First Monday

Users with Disability Need Not Apply? Web Accessibility in Ireland, 2002 by Barry McMullin

Users with Disability Need Not Apply? Web Accessibility in Ireland, 2002 by Barry McMullin
Users with a variety of disabilities can potentially benefit greatly from using the Internet to mediate their access to products and services; however, this relies on the proper server side design of Web sites to facilitate such access. Design of accessible Web content is codified in the Web Content Accessibility Guidelines (WCAG) 1.0 of the World Wide Web Consortium (W3C). Compliance with WCAG (and/or similar, derivative, guidelines) is now the subject of considerable activity, both legal and technical, in many different jurisdictions. Within this overall international context, this paper reports on a project to carry out an automated baseline survey of WCAG compliance of Web sites based in Ireland. Summary results are presented and discussed. Recommendations are made for policy action, relevant both in Ireland and beyond.


Key Results
Pervasive Defects
Recommendations for Action





"If anybody asks me what the Internet means to me, I will tell him without hesitation: To me (a quadriplegic) the Internet occupies the most important part in my life. It is my feet that can take me to any part of the world; it is my hands which help me to accomplish my work; it is my best friend — it gives my life meaning."
— Dr. ZhangXu (Zhangxu and Aldis, 2001)

The technology of the Internet holds tremendous promise to improve access to information, goods, and services for many people with disabilities. Properly engineered Web sites can interoperate with dedicated assistive technologies to address a wide range of disabilities. It has become possible for a blind person to read papers, magazines and books, without assistance, and on the same day they are published; for a person with restricted mobility to shop for groceries, and pay her bills without even leaving home; for a deaf student to attend a "virtual" lecture, with sub-titling and text transcripts (W3C, 2001a).

The key is in the design of Web sites so that they facilitate — rather than obstruct — access by groups of people with disabilities. This is not rocket science: the basic requirements have been internationally codified since 1999 in the Web Content Accessibility Guidelines (WCAG) 1.0 published by the World Wide Web Consortium (W3C, 1999).

WCAG consists of 14 separate guidelines, each of which has an associated set of one or more individual checkpoints. There are a total of 65 checkpoints which are classified into three priority levels (1-3); these then give rise to three recognised conformance levels:

Design of Web sites in conformance with WCAG is clearly good for the community of people with disabilities — but it is also very good for the general community of Web users. It is well established that universal design frequently results in products and services that are more usable for all. In the world of the Web, where another site is only ever a hyperlink away, improved usability must be a key priority for all Web site operators. It seems to be the proverbial win-win situation.

However, although this is the promise, the reality depends on the extent to which the guidelines are actually observed in practice.

In many jurisdictions around the world there are now active public policy initiatives and/or legal instruments which are directing attention at this issue; for example:

By contrast, the status of Web accessibility in Ireland is, at best, unclear. The Irish Information Society Commission has stated that "... [w]here organisations are designing web-sites care must be taken to ensure that they are accessible to as broad a section of the population as possible" (Irish Information Society Commission, 2000). More recently, the WCAG guidelines have been formally endorsed for general application in Ireland (Irish National Disability Authority, 2002), albeit without specific legal force. Some legal protection may be available through the Equal Status Act (An tOireachtas, 2000), through there is no case law yet to test this. The Irish Disability Bill (An tOireachtas, 2001) proposed some more explicit (but still strictly limited) measures. However that bill was withdrawn following considerable opposition from disability groups. Finally, Ireland is party — in principle at least — to EU level commitments. Arising from this, a target was declared that all Irish Government Department Web sites should have achieved WCAG-AA conformance by the end of 2001 (European Commission, 2001). (We will comment more specifically on this particular commitment later.)

Given this overall public policy context, it is clearly important to have objective information about the state of accessibility of Irish Web sites, and to monitor trends in accessibility actively over time.

Over the last two years, with the support of AIB PLC, a project has been underway at the Research Institute for Networks and Communications Engineering (RINCE) at DCU to investigate the conformance of the Irish Web to the WCAG guidelines. Following the development of technical support tools, a detailed accessibility study of Web sites operated by Irish organisations, spanning a wide range of activities, information, and services, was conducted in the summer of 2002. This summary paper explains the methodology, distills the key results, identifies the most pervasive defects encountered, and, most importantly, presents recommendations for action that follow.




This section summarizes the methodology of the study; more extensive technical details are available in (McMullin, 2002).

Sampling the "Irish Web"

The objective of this study was primarily to inform and promote Web accessibility policy in Ireland. However: by its nature, the World Wide Web is a globally distributed network. Thus, a Web "site" (or "server") can be physically situated in a location which is geographical arbitrary, relative to the locations both of the operating organisations and of the users of those sites. The general criterion that has been applied here is to classify sites as Irish if (and only if) the organisation responsible for the site is incorporated in this jurisdiction (i.e., would be legally bound by the laws and courts of Ireland). This is applied regardless of the physical locations of the servers or the users. Informally then, we use the "Irish Web" to denote this subset of the Web as a whole.

Data available from whoisireland and the Open Directory Project (ODP) suggest that the order of magnitude of the Irish Web is approximately 10,000 distinct sites. In the context of the current study, it was clear that attempting an exhaustive study would be technically very demanding — and not necessarily appropriate. Web sites differ from each other in many ways: size, function, utility, popularity, etc. It is inevitable that a relatively much smaller subset of the total are actually significant to the needs of typical users.

Ideally, one might therefore attempt to identify the most relevant Irish sites by consideration of relative "traffic" or "activity". However, such an analysis is very difficult in the general case. There is considerable debate as to what the most appropriate measures of activity levels should be. Objectively certified usage data is not widely available. Finally, even where usage data is available it is typically intended to support commercial objectives (specifically, Internet based marketing), whereas, many important Web services are provided by public sector or otherwise non-commercial organisations (which may be therefore be seriously under-represented in such data).

Accordingly, the pragmatic approach taken here was to create a sample of the Irish Web based on largely subjective judgments of experienced Web users (drawn from within the project team). The ODP category for Ireland was used as a starting point, but sites were also identified from a variety of other sources, including other directories, public advertising, etc.

A target sample size of approximately 200 distinct sites was set. This was judged to be large enough to give a reasonably wide distribution across sectors and service types and serve as a proof of principle of the methodology and technology being used. Scaling up to significantly larger surveys can be considered subsequently, in the light of the experience with this initial baseline.

The following informal categories were taken into account in selecting specific sites:

Other less focused categories were also considered: entertainment, sports, trade unions, legal, medical, etc.

The final list of target sites contained 214 entries (McMullin, 2002, Appendix A). These sites vary significantly in size and in the types of media in which resources are offered. A further per-site sampling strategy was therefore required. Again, for the purposes of this initial baseline survey, a number of pragmatic decisions were taken:

Sampling was carried out on 9th April 2002. In total, 31 MBytes of HTML data, distributed over 3,270 separate pages, was captured. There were 10 sites for which no data was captured. For a further 18 sites, only the initial, "home" page was captured, indicating a failure to successfully follow any links from that page. The capture failures arose from a variety of causes including network connectivity problems, reliance on client side scripting for linking, and failed redirections (suggesting server mis-configuration). Finally, as will be discussed further in the following section, the accessibility evaluation was not successfully completed on a further 27 sites. Discarding all of these, the effective sample size was reduced to 159 sites (McMullin, 2002, Appendix H).

This is clearly not presented as a "statistically representative" sample in any formal or technical sense. Nonetheless, and subject to further critical testing in future studies, it is conjectured that overall patterns from this sample can usefully guide national policy development and implementation.

Accessibility Evaluation

There are a number of software products now available to carry out automated assessments against (subsets of) the WCAG guidelines. These have a variety of strengths and weaknesses, but are functionally very similar (by definition, as they are largely driven by the WCAG guidelines themselves). For the purposes of this study we chose to adopt one of the most widely deployed of these products, Bobby Worldwide (Core v4.0), originally developed by the Center for Applied Special Technology (CAST), and now distributed and maintained by Watchfire Corporation.

bobby implements 91 distinct tests or diagnostics, each of which maps onto a specific WCAG checkpoint [1]. A number of bobby diagnostics map onto (different aspects of) the same WCAG checkpoint.

The bobby diagnostics are classified into a number of different "support" categories, as follows:

bobby automatically detects violations.

Partial/Partial Once:
bobby performs some partial automatic checking, but this requires manual verification.

Ask Once/Summary Ask Once:
bobby does not do any checking, the diagnostic is presented only as a reminder to perform manual checking.

For all categories other than Full, further evaluation would be required by a human assessor to determine WCAG conformance. Accordingly, in the work presented here, bobby is restricted to implementing just those diagnostics with Full support. There are 25 such diagnostics, which map onto (aspects of) 20 distinct WCAG checkpoints, including some at all three priority levels, as follows (in order of WCAG checkpoint):


WCAG Priority
WCAG Checkpoint
Provide alternative text for all images.
Provide alternative text for each APPLET.
Provide alternative content for each OBJECT.
Provide alternative text for all image-type buttons in forms.
Provide alternative text for all image map hot-spots (AREAs).
Client-side image map contains a link not presented elsewhere on the page.
Use a public text identifier in a DOCTYPE statement.
Use relative sizing and positioning (percent values) rather than absolute (pixels).
Nest headings properly.
Identify the language of the text.
Provide a summary for tables.
Each FRAME must reference an HTML file.
Provide a NOFRAMES section when using FRAMEs.
Avoid blinking text created with the BLINK element.
Avoid scrolling text created with the MARQUEE element.
Do not cause a page to refresh automatically.
Do not cause a page to redirect to a new URL.
Make sure event handlers do not require use of a mouse.
Include default, place-holding characters in edit boxes and text areas.
Separate adjacent links with more than whitespace.
Give each frame a title.
Explicitly associate form controls and their labels with the LABEL element.
Create link phrases that make sense when read out of context.
Do not use the same link phrase more than once when the links point to different URLs.
Include a document TITLE.


Given that evaluation is limited to only a subset of the WCAG guidelines, and is applied to only a sample of the content of any given site, it cannot determine that any site positively satisfies the guidelines; but failure on any of these tests definitively demonstrates failure against the guidelines.

As already noted, bobby did not function properly for a number of sites. Discounting the 28 sites for which the capture phase had failed, an independent bobby failure was encountered on a further 27 sites. These failures were manifested in two ways:



Key Results

Of the sites studied:



Pervasive Defects

Of the 25 specific bobby accessibility diagnostics studied, the most pervasive (at WCAG priorities 1 and 2) were as follows:

Of course, many sites exhibited a combination of these defects, and others.

The list above should be interpreted carefully. It identifies a number of accessibility barriers which this study has identified as pervasively present across the Irish Web; however, the list is by no means exhaustive. As noted, the 25 bobby diagnostics included in the study address only a subset of the WCAG checkpoints (and do not cover even those exhaustively). The other WCAG checkpoints represent further potential accessibility barriers, at all three priority levels, which were not checked for at all in the current study. It is likely that at least some of these are as pervasive as some or all of the factors identified above. In other words, bleak as the above picture is, it is almost certainly an understatement of the difficulties faced by users with disabilities in accessing the Irish Web.

While this list may be a useful starting point for individual Web site operators in considering the accessibility of their own sites, it is, of course, no substitute for:




This section provides a brief critical review of the study, and of the tools and methodology adopted. It also considers some implications for future work.

First, the project has demonstrated that this sort of largely automated survey of selected accessibility indicators is technically feasible; and that once the appropriate tools have been developed and integrated, the technical resources to carry out such a survey are comparatively modest. This is contrast to surveying approaches that rely on significant manual intervention (e.g., Schmetzke, 2002).

However, the project has also identified a number of limitations and/or open issues, many of which will require further research.



Recommendations for Action

The primary motivation for this particular study was to inform public policy development in Ireland. The recommendations below are therefore specifically targeted at the Irish national context; however, at least some of them should have wider relevance in other jurisdictions.

Public Awareness

An Irish Web accessibility awareness campaign, targeted specifically at relevant policy and decision makers in both public and private sectors, should be an immediate priority. This should focus explicitly on the incorporation of accessibility requirements into all specifications, tender documents, etc., for Web services.

The accessibility barriers identified in this study appear to be primarily products of ignorance rather than design. Senior decision makers, responsible for commissioning Web sites and services, presumably do not set out to discriminate against users with disabilities. However, it seems that, in too many cases, they are still unaware of the requirements (and opportunities!) associated with making Web sites and services universally accessible.

There is some evidence that this situation is improving. The Information Society Commission has been active in promoting public debate on this and related issues (Irish Information Society Commission, 2000). The Irish National Disability Authority (NDA) has recently published over-arching IT Accessibility Guidelines (incorporating WCAG), and is actively promoting their adoption (Irish National Disability Authority, 2002). A number of Irish Web design consultancies now highlight accessible design. The recent requirements statement for the Public Services Broker, issued by the Irish Government Agency REACH, explicitly includes accessibility requirements (REACH, 2002).

Nonetheless, the results of the current study indicate that these efforts are certainly not yet fully effective, and it is recommended that advocacy efforts be intensified.

New Tools and Technologies

Organisations developing software and tools for Web site development should ensure that these conform to relevant standards and guidelines for producing accessible content and services. Organisations sourcing or evaluating new Web development tools should make conformance to accessibility guidelines an essential qualifying condition.

It is increasingly the case that Web content and services are developed using a variety of more or less sophisticated authoring tools, packages etc. The accessibility of the developed content and services then depends significantly on the extent to which those tools have been designed to support this. The W3C has again been to the forefront in promoting good practice in this area, for example in specific guidelines for authoring tools and applications (W3C, 2000, 2001b). Unfortunately it seems that many tools still do not incorporate such techniques adequately.

Leading by Example

A detailed timetable should be immediately published for all Irish Government Department Web sites to achieve WCAG-AA conformance. Reports on progress against this timetable should be issued regularly. A co-ordinated project to achieve conformance across the wider public sector should be centrally initiated and monitored. Private sector organisations should initiate similar comprehensive commitments to an accessible Irish Web.

As noted earlier, in the context of the E-Europe Action Plan, Ireland declared a target that all Government Department Web sites should have achieved WCAG-AA conformance by the end of 2001 (European Commission, 2001). This is a very laudable goal, and substantial resources are evidently being directed to it. However, it was apparent from the current study that this had certainly not been achieved by the target date; in fact, defects were detected on all such departmental sites included in the sample. In any case, this initiative should surely not stop at Government Departments, but should extend to all publicly supported agencies and institutions. Similar initiatives can, and should, by taken by private sector companies, representative organisations and professional bodies.

Education and Training

Training materials, courses, etc., relevant to universal design should be developed and promoted by the widest possible variety of organisations involved in education and training. Professional bodies should require that Universal Design be incorporated in the curriculum of all relevant educational programs.

It is apparent that specific, pervasive, Web design flaws identified in this study could be drastically reduced or eliminated if the issues were adequately understood by relevant personnel. There is a particular need to provide appropriate training for technical and design professionals. Some progress is being made in this front at the European Level, particularly through the E-Europe Action Plan (European Commission, 2000), which includes a commitment to the development of a European curriculum in "design for all" for designers and engineers. However, effective engagement with such European initiatives relies on support from national agencies in individual member states.


There should be clear Irish legislation setting explicit, comprehensive, and legally enforceable standards for accessibility of all Web products and services to users with disabilities.

As noted in the introduction, there is ample evidence from other jurisdictions (notably Australia, the U.S. and the U.K.) that strong legislation to protect the rights of citizens with disabilities (in all areas of life) is a regrettable, but nonetheless essential, element in achieving comprehensive engagement with accessible design. Given the demise of the previous Irish Disability Bill it is to be hoped that a revised bill, inter alia specifically addressing accessibility of information goods and services, in both public and private sectors, will now be published as a matter of urgency.

Further Research

Research and development of technologies to support social inclusion in the information society should be encouraged actively, and supported materially, by both public and private sector agencies and organisations.

The current study provides only a crude baseline assessment of the accessibility of the Irish Web. The detailed report (McMullin, 2002) discusses in more detail both the strengths and limitations of its particular methodology; and lays out a programme of further work to extend, clarify, and refine our ability to monitor the evolving state of Irish Web accessibility — as an essential tool for informed policy formation. There is also an ongoing need for research and development of new Web technologies to support both service providers and users with disabilities. The previous Disability Bill (An tOireachtas, 2001) proposed the establishment of an Irish national Centre for Excellence in Universal Design to promote and support research in all aspects of Universal Design, on a continuing basis: this proposal should be elaborated in the drafting of any new bill. By this means, or otherwise, there should also be strong engagement by Ireland in international fora (such as W3C) concerned with accessibility of information society technologies.




This study should be a national "wake-up call" — for the Irish government, for public agencies, for private companies, organisations and individuals. It signals that, despite Ireland's justifiable pride in its economic and technological development, despite very laudable goals in documents such as the E-Europe Action Plan (European Commission, 2001, 2000), the current commitment to accessibility of the Irish Web for users with disabilities is, at best, aspirational — and, at worst, cynically inadequate.

This is doubly unfortunate. It is not just that Web technology is not being applied — as it could be — positively to improve opportunities and capabilities for users with disabilities; but on the contrary, as Web services become more pervasive and essential, to the extent that they remain inaccessible this will actually impose progressively more disadvantage and exclusion on groups with disabilities in our society.

And, of course, failure to take effective action in this area affects all citizens regardless of ability: through correlation with poor general usability, through continuing reduced participation in the emerging Information Society, and, crucially, through the inevitable compromising of Ireland's ability to trade in Web-mediated goods and services with countries having stronger legal safeguards and requirements.

It is hoped that the results of this study will serve to highlight these issues, and to further encourage the many agencies and organisations who are already actively promoting and supporting voluntary improvements in Web accessibility in Ireland. Ultimately however, there must surely also be a role for compulsion — legislation and regulation — to fully guarantee and vindicate the rights of all citizens to equal treatment in a digital democracy. End of article


About the Author

Dr. Barry McMullin is a senior lecturer in the School of Electronic Engineering of Dublin City University (DCU). He directs the eAccessibility Lab of the Research Centre for Networks and Communications Engineering (RINCE) at DCU.



The work described here could not have come about without generous financial support provided by AIB PLC. I am especially indebted to John Kelly, Head of Business Banking at AIB. He demonstrated an enduring faith and commitment to the the project, and the ultimate value that it could have in setting the agenda for Ireland's emerging information society.

Detailed research and development for the project was carried out by my two research students, Esmond Walshe and Carmen Marincu.

The work was carried out in the Research Institute for Networks and Communications Engineering (RINCE), established at DCU under the Programme for Research in Third Level Institutions operated by the Irish Higher Education Authority.

The final text of the paper has benefited significantly from constructive comments by the First Monday reviewers.



1. There are an additional three bobby diagnostics which do not relate to the WCAG guidelines, but only to the requirements of Section 508 of the U.S. Rehabilitation Act; since this Act does not apply in the Irish jurisdiction, these diagnostics were excluded from the current study, and will not be discussed further.

2. It should be noted that bobby is not distributed in source form; this makes further investigation in cases such as this problematic.

3. Note that, to be properly effective, this technique does rely on the author/designer of the Web site having a clear understanding of the need for, and the appropriate use of, such alternative text (Flavell, 2002).



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Editorial history

Paper received 24 October 2002; revised version received 25 November 2002; accepted 29 November 2002.

Contents Index

Copyright ©2002, First Monday

Copyright ©2002, Barry McMullin

Users with Disability Need Not Apply? Web Accessibility in Ireland, 2002 by Barry McMullin
First Monday, volume 7, number 12 (December 2002),