Ishihara plate for testing color-blindness.

Section 508: Color blindness

As rumor would have it, the Access Board released the Section 508 refresh Notice of Proposed Rulemaking (NPRM) today. I have only just taken a quick look at it so far and will have other comments in the future. I did want to make one observation that pertains to two proposed provisions:

302.3 Without Perception of Color. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that does not require user perception of color. (From the Functional Performance Criteria chapter of Appendix A.)

407.7 Color. Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. (From the Hardware chapter of Appendix A.)

These are important provisions and good for a sizable population (estimates range from about 5-10% of males have some form of color blindness). However, as currently worded, the provisions would allow for a non-visual means of perceiving or distinguishing a colored element. At an extreme, this could make a color-blind user have to use a text-to-speech mode that users who are blind might use. Should a person with color blindness have to put on headphones and use a screen reader in order to access an interface?

The fix is simple in for both cases—add the word visual to the provisions.

  • 302.3 Without Perception of Color. Where a visual mode of operation is provided, ICT shall provide at least one visual mode of operation that does not require user perception of color. (From the Functional Performance Criteria chapter of Appendix A.)
  • 407.7 Color. Color coding shall not be used as the only visual means of conveying information, indicating an action, prompting a response, or distinguishing a visual element. (From the Hardware chapter of Appendix A.)

About J. Bern Jordan

Bern is a Ph.D. candidate and researcher in accessibility, usability, user interface, and technology interested in extending usability to all people, including people with disabilities and those who are aging. He currently works at the Trace R&D Center in Biomedical Engineering at the University of Wisconsin-Madison.

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