Presentation for the first inter- Ministerial meeting for minimum accessibility standards on ICT

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Amar Jain

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Jan 2, 2025, 1:33:15 PMJan 2
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Dear all,

Please see attached the first presentation for your top level comments if any.

The meeting is tomorrow at 10.30 A.M. and my sincere apologies for a very short notice and rush.

This is more of an ideation exercise and the detailed asks will be fleshed out soon however broadly within this framework.

Regards,
Amar Jain
(Also on behalf of Mr. A.S. Narayanan)

Mandatory (Non-negotiable) Accessibility Rules.pptx

Bhavani Shankar R

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Jan 2, 2025, 6:45:13 PMJan 2
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On Fri, Jan 3, 2025, 00:03 Amar Jain <amar...@amarjain.com> wrote:
Dear all,

Please see attached the first presentation for your top level comments if any.

The meeting is tomorrow at 10.30 A.M. and my sincere apologies for a very short notice and rush.

This is more of an ideation exercise and the detailed asks will be fleshed out soon however broadly within this framework.


Dear Amar,

Went through the entire presentation now. 

Looks good for a start although I would wish the below points to be addressed/added in the future.

1. Legal Enforcement and Monitoring to Be Improved

The GIGW needs to be updated as soon as possible and to incorporate in detail non-web ICT components.
Enforce all the above through strict monitoring so that even minimum compliance cannot take place without penalization.
Use of IS17802, WCAG 2.1

2. Widening Consumer Products Accessibility

The tactile identification markers or embossed markings to identify consumer products without difficulty.

Develop adaptive packaging technologies that are easier to open and manipulate, taking into account the fine motor skill impairments.

3. Improve Digital Payment Systems

POS devices should be accessible to all by including voice guidance and providing tactile feedback.

QR code payment systems should be optimized for screen readers and accessible to users with visual impairments.

4. Improve Transportation Accessibility

Accessible interfaces for public transportation systems, such as tactile maps and accessible apps for scheduling and navigation.

Mandate the inclusion of ramps, elevators, and auditory and visual notifications in public transport vehicles.

5. Neurodiversity Focus

Include considerations for neurodiverse individuals in ICT standards, particularly around simplification of instructions, customizable interfaces, and predictable navigation flows.

6. Banking and Financial Accessibility

Address the limited guardianship issue for account access and ensure legal frameworks support inclusive practices.

Automate cheque clearance systems with accessible user guidance and verification steps.

7. Enhance Employment Accessibility

Encourage assistive technologies in the workplace, including voice-to-text systems, ergonomic equipment, and accessible software.

Offer tax breaks to companies that have implemented accessibility measures for employees with disabilities.

8. Assistive Technology Ecosystem

Promote the development and use of affordable assistive devices, such as screen readers, braille displays, and speech recognition tools in regional languages.

Create a national repository of assistive technologies for easy access and dissemination.

9. Universal Accessibility in Education

Ensure e-learning platforms are accessible with captioning, transcripts, sign language support, and alternative input methods.

Provide schools and colleges with accessible infrastructure, adaptive lab equipment, and learning materials.

10. Public Awareness and Training

Provide extensive training to the public and private sectors in implementing and maintaining accessibility standards.

Run campaigns that raise awareness of the need for accessibility in daily products and services.

These, as I said are only a starting point of my wishlist for usage of technology for betterment of lives of PwDs and we can have a detailed discussion in the near future if the points deem fit.

Regards,
Bhavanishankar Ravindra PhD
National award winner as a role model with disabilities 2017.




Amar Jain

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Jan 2, 2025, 9:17:02 PMJan 2
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Understand a few members are travelling and would prefer the PDF version. Please see attached.

Regards,
Amar Jain
PPT for ICT Accessibility[1].pdf

Arun Koormamtharayil

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Jan 2, 2025, 9:39:31 PMJan 2
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Hi,

Nice work!
Some quick suggestions are:

1. Digital content, software to conform to
ADA (American Disabilities Act)
WCAG 2.2
EAA (European Union Accessibility Act)
We need to leverage those as much as relevant for Indian context.

2. Screen Reader: The content navigation hierarchy (focus needs to move in a hierarchical manner)

3. Web user should not get caught in a loop/behind a pop up. See video:


Best Wishes!

Regards,
Arun Koormamtharayil 
Industrial & Experience Designer
Product Accessibility Group

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> On 3 Jan 2025, at 12:03 AM, Amar Jain <amar...@amarjain.com> wrote:
>
> Dear all,
> <Mandatory (Non-negotiable) Accessibility Rules.pptx>
>
> Sent from my iPhone

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Shilpi Kapoor

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Jan 2, 2025, 9:53:03 PMJan 2
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Good start.  first part of POUR slides are from a visual disability perspective.

We need to reference complete Success criteria of the standards. 

We need to look at all disabilities. 

I would recommend the min. Standard can be Level A of WCAG. And give people 2 years post to achieve Level AA for legacy.

For new ICT, need to be Level AA after a period of 1 years from announcement. 

ICT definition needs to be reiterated and socialized 

Functional Performance Statements in IS 17802 will help us develop ICT that is accessible.

Regards
Shilpi Kapoor
BarrierBreak


From: sac-ict-f...@googlegroups.com <sac-ict-f...@googlegroups.com> on behalf of Arun Koormamtharayil <akoo...@gmail.com>
Sent: Friday, January 3, 2025 8:09:17 AM
To: sac-ict-f...@googlegroups.com <sac-ict-f...@googlegroups.com>
Subject: Re: [SAC-C-ICT] Presentation for the first inter- Ministerial meeting for minimum accessibility standards on ICT
 

Arun Koormamtharayil

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Jan 2, 2025, 10:26:47 PMJan 2
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Hi,

Quick way to check contrast ratio is to use this web tool in tandem with 'Color Picker' app on Android:

Color Picker app 
You can select colours from images,..

Visibility, Readability, Accessibility, Colour Space

There are a few aspects to consider:
*1. Typeface*
     For Dyslexia,.. friendly, use from
     following Typefaces that provide near 
     geometrical or rounded forms.
     Lexend
     Arial
     Helvetica
     Verdana
     Tahoma
     Calibri
If there is a lot of small text, Calibri 
Provides good clarity, soace & distinction
between characters

*2. Font Sizes (multiple)*
ADA, WCGA compliance says 16 pt for
body text, 20 to 24 for presentations.

*3. Line spacing*
For better readability, a mnimum of 1.2 
or 120% line space to be used.

*4. Contrast Ratio*
Type to Background contrast ratio > 4.5:1
This is the bare minimum,i.e A rating. 
AAA rating could go from 9 to 12.


_______

*4. Colour*
*Colour for Digital is RGB (WCAG 2.2)*
*Colour for Signages/ Print is CMYK*
     
RGB is light based, transluscent.
CMYY is pigment based, opaque.
Both don't readibly translate to each other, some adjustments needed to match

For digital content & physical signages
one also needs to consider colour blind
aspects. Some colour sensing issues:


The Typeface, Font size, Line Space,  
Contrast Ratio,... are probably covered 
but not difference between RGB & CMYK.
Probably the difference for disparity in
actual vs compliance of standards.
  
We should go by what ADA/WCAG 2.2
recommends. What vendors / manufacturers do could be compared with these. 

Regards,
Arun Koormamtharayil 
Industrial & Experience Designer

Supreme Court Accessibility Committee NALSAR University of Law

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Jan 2, 2025, 11:01:22 PMJan 2
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The most important question at this point and in these meetings where do you wish to begin from? This is important because at this. Point we are stating those standards which if not followed will result in the website become non-operational. Since technology has progressed we can raise the bar within  an year but if nothing has been done today, can you start from level 2? 
More importantly, if the law says level 2 from the start will it be strictly enforced? If not then the minimum mandatory rules will become guidelines. 
We need to remember at this point we lay down that level for all impairments which if not fulfilled must result in stoppage of service. 

Best wishes for the New Year
Amita


Ashutosh Singhal

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Jan 3, 2025, 12:05:50 AMJan 3
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;Dear sir, 
Meeting joining link will come in this Google Group. Right?

Arun Koormamtharayil

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Jan 3, 2025, 12:10:58 AMJan 3
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Hi,

Very true. Time to implement, uninterrupted services, incremental improvements needed. 

Pathways to Accessibility:

For both Digital Content & Physical products/environments/services:

Timelines: 
Timeline / pathway from A to AAA. Where possible, aim for higher than A rating & suitable publicity/reward.

Information Sources:
Resources, links, standards, guidelines, educational info to implement universal accessibility need to be in place.

Clarity of Rules:
Clear, unambiguous non-negotiable and amnatory performance based rules need to be published for content creators, institutions, manufacturers and goverment, service providers and any other entities.

Tools & Techniques 
Tools to enable and check accessibility, techniques, examples and such like support to be put in place.

Auditing:
Mechanism to certify compliance, audits schedules.

_____________

Meanwhile, here is something I found intriguing. In Architecture, there is something called:
Performance Based Rules & 
Regulatory Rules.

The first allows for greater freedom during design, while the later is more constraining and does not give great results. We need to aim to build in Performance based rules for accessibility.

Here is a short write up about the two:

The main difference between performance-based rules and regulations in architecture is that performance-based rules focus on the general performance of a building, while regulations establish minimum standards of compliance: 

Performance-based rules
Focus on the general performance of a building, such as its design, operation, and maintenance.

Performance-based rules allow for a variety of solutions to meet the same performance goals. 

Regulations
Establish minimum standards of compliance for a building, such as structural strength, fire safety, and ventilation. Regulations are intended to prevent harms to public health, safety, and welfare. 

Performance-based rules can have several advantages over regulations, including: 

Innovation
Performance-based rules can encourage innovation and creativity in design and construction.

Adaptability
Performance-based rules can adapt to changing technologies, materials, and practices.

Cost reduction
Performance-based rules can reduce costs and waste by allowing for the use of optimal materials and methods.

Regards,
Arun Koormamtharayil 
Industrial & Experience Designer

Bhavani Shankar R

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Jan 3, 2025, 12:18:04 AMJan 3
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On Fri, Jan 3, 2025, 09:31 Supreme Court Accessibility Committee NALSAR University of Law <s...@nalsar.ac.in> wrote:
The most important question at this point and in these meetings where do you wish to begin from? This is important because at this. Point we are stating those standards which if not followed will result in the website become non-operational. Since technology has progressed we can raise the bar within  an year but if nothing has been done today, can you start from level 2? 
More importantly, if the law says level 2 from the start will it be strictly enforced? If not then the minimum mandatory rules will become guidelines. 
We need to remember at this point we lay down that level for all impairments which if not fulfilled must result in stoppage of service. 

Best wishes for the New Year

[ Using my Gmail ID now ]

Hello everyone again!

I agree with the fact that starting from Level 2, which is the higher level of accessibility, would be a better approach. That way, it would ensure websites are built in an accessible way and can grow with future advancements.

- Enforcement: Without strict enforcement, these standards are doomed to fail. If there is no legislation that requires people to follow Level 2, then other methods of enforcement have to be established to make them comply.

- Full Accessibility: There should be clear accessibility requirements for all types of impairments. This will ensure that websites are usable by the widest possible audience.

 - Consequences of Non-Compliance: I support the idea of making websites non-operational in cases of non-compliance. This strong consequence will make website owners prioritize accessibility.

 Now, having said that, we can:

a) Agree to discuss concrete standards of accessibility (for example, WCAG) in relation to the industry's best practices.

b) Discuss potential involvement by the users themselves in the formation and implementation of the standards.

This would be a good starting point I guess for further discussion over a meeting perhaps.

Just my 2 cents opinion. 

Regards,
Bhavanishankar Ravindra PhD 
National award winner as role model with disabilities 2017.


Bhavani Shankar R

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Jan 3, 2025, 12:52:36 AMJan 3
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Hello Arun,

Your points on Performance-Based Rules vs. Regulations in architecture are spot on. 

For genuine accessibility, as an open source software and AI enthusiast, I belive we would need to push towards a far more flexible, innovative approach, and here's the way AI as well as open-source tools might help us move toward that path:

1. AI-Powered Design Tools:

* Generative Design: Using AI algorithms, it can generate a vast range of design possibilities that satisfy the accessibility performance goals. It could be something innovative that was not thought of in traditional design.

 * Accessibility Simulation: Create AI models that simulate the built environment from the point of view of people with disabilities. It would help architects find potential barriers at the earliest stage of the design process.

* Predictive Analysis: Use AI to make long-term accessibility predictions for a building and its inhabitants, based on changing demographics and advancing technologies.

2. Open-Source Accessibility Libraries:

 * Design Guidelines: Develop and freely distribute open-source libraries of accessible design patterns and components, which contributes to shared knowledge and collective understanding among architects.

* Accessibility Checkers: Design open-source tools that can automatically check building designs for accessibility compliance, suggesting improvements to rectify the shortcomings.

 * Data-Driven Insights: Use open-source datasets on accessibility needs and usage patterns to feed into design decisions and improve the accuracy of accessibility simulations.

3. AI-Driven Performance-Based Rules:

* Develop AI-driven systems that can analyze building performance across a variety of accessibility criteria rather than simple checklist compliance.

* A dynamic and adaptive framework for performance-based rules that evolves with new technologies, research, and user feedback.

 * Leverage open-source platforms to collaborate and share knowledge among researchers, architects, and accessibility experts in developing and refining these AI-driven rules.

4. Open-Source Tools for Collaboration and Education:

* Develop user-friendly platforms that enable architects, accessibility consultants, and building owners to collaborate on design decisions and ensure accessibility throughout the entire building lifecycle.

 * Create open-source educational resources and training programs that empower architects and other stakeholders with the knowledge and skills to design accessible buildings using AI and open-source tools.

To reiterate my feelings, I strongly believe that by embracing AI and open-source solutions, we can move beyond rigid regulations and create a more inclusive and accessible built environment for all.

Regards,
Bhavanishankar Ravindra PhD 

Srinivasu Chakravarthula

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Jan 17, 2025, 12:37:52 AMJan 17
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Hello all,
Good conversation to start with. In addition:

To speed up things, we should consider adopting all the awesome work that has already went into government such as tools that they have created through NIC's innovation challenge, GIGW guidelines etc., 

Amita Dhanda

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Jan 17, 2025, 1:59:55 AMJan 17
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You have to decide what they must adopt in order to run the service. The standards may be desirable but should they be made non-negotiable that is the question. 

Best
Amita

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Harish

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Jan 20, 2025, 9:56:14 AMJan 20
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Hi

In my view adopting the standards as nonnegotiable should be indeed a baseline and that itself will make the law and rules made therein relevant, if we are unable to enforce, even this, it will reduce the entire exercise to a paper tiger.

 

Harish Kotian

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