Tabulars that are not tables

[Sean Fitzpatrick]

With apologies, I am resurrecting an old sticking point that recently came up in the context of validation. 

APEX has a lot of what we call "small tables". A lot of these are tables of values for functions, and similar creatures. 

Originally these lived in tables. Long ago, someone, who may or may not have been David Farmer, insisted that these were not tables in the CMOS sense, and we made the change to put them inside of a figure.

But figure/tabular is not allowed in the schema, and many of these are referenced, so naked tabular is not an option. 

A workaround is to do figure/sidebyside/tabular, but this isn't ideal, and although it's schema-compliant, validation-plus will tell me that I should not have a sidebyside with one child. (I get this complaint now for some places where md was better than tabular, but the switch requires figure/sidebyside/p/md)

Do I make these tables again? Some of them will fail accessibility checks since they don't even have a header row. 

Is there a better solution?