About the European Blind Union (EBU)
The European Blind Union is a non-governmental, non profit-making European organisation founded in 1984. One of the six regional bodies of the World Blind Union, it is the only Europe-wide organisation representing the interests of blind and partially sighted people.
EBU aims to protect and promote the interests of all blind and partially sighted people in Europe. EBU currently has 44 member countries ; each represented by a national delegation. Its work is directed by an Executive Board of 11 elected members, which is accountable to a General Assembly held every four years. The detailed work of EBU is carried out by Standing Commissions and Working Groups, whose areas of activity reflect the interests of EBU members.
The Central Office of EBU is based in Paris. It is responsible for communication within EBU and for information to the general public. It produces a quarterly Newsletter in English, French, German and Spanish. The English version is also available in accessible formats (tape and braille).
Further information about EBU can be obtained from our website www.euroblind.org. For further information about this response, contact Mr Rodolfo Cattani, Chair of the EBU EU Liaison Commission on
inter@uiciechi.it or +39 06 699 88388.
EBU is happy for the Commission to use and disseminate this response and to be further consulted as need be.
eAccessibility
The Information Society has huge potential to improve the quality of the lives of EU citizens, and to create a more inclusive and equal society. For people with disabilities, the potential for communication and participation is even stronger. Technologies such as speech output systems enable blind and partially sighted people to access the Internet. In the UK for example, a recent RNIB questionnaire (2004) on Information Communication Technologies found that accessibility was paramount to most respondents. Ideally, the ICT environment would be totally accessible to all from the moment of switch-on. Yet lack of standardisation, convergence and harmonisation hinders this potential.
In the European Union, approximately 7.4 million people are visually impaired. However this figure is based on estimates provided by the national members of the EBU, and is only an approximation of a highly complex reality. Lack of official statistics and varied legal definitions of blindness and partial sight make it particularly difficult to work out accurate numbers. Not all Member States have a central registration system, and even where such a system exists, a true figure cannot be achieved due to under-registration. The true number of the EU population with sight problems could be far higher than 7.4 million. In addition, many older people who lose their sight do not consider it useful to start rehabilitation courses and, as a consequence, fall out of official registers.
People with disabilities make up 20 per cent of the population of Europe, a percentage that is set to rise. At the same time, we live in an increasingly ageing society with the projection that almost 40 per cent of the EU population will be older than 65 by 2020. Their access needs must be addressed now if we are to ensure all citizens will achieve the goal of full and active participation in fifteen years time. To achieve this, the Design for All approach must be adopted for ICT design, so that key access features are incorporated into mainstream equipment and services. New technology will therefore meet the access needs of all EU citizens and consumers - including the ageing population, people with disabilities, children and those with a lower level of literacy.
Access to information is a basic right, and one that is particularly important for people with disabilities. As public information is increasingly made available on-line and through other channels, it is essential that no EU citizen be denied the ability to access this. People with disabilities - particularly those with visual impairments may find it hard or impossible to access information others take for granted. It is unacceptable that the very technology with the potential to reach all EU citizens may lead to a new knowledge discrimination. When considering the challenges that people with disabilities face when attempting to use IT products, training is paramount, and this is discussed in more detail below.
EBU welcomes the Commission's commitment to achieving accessibility and to ensuring an Information Society for All. EBU particularly welcomes the Commission's stated intent to overcome the barriers that ICT can create for people with disabilities and elderly people. EBU has submitted a questionnaire to the Commission's on-line consultation on eAccessibility, but has particular comments on the following aspects of the consultation that could not be addressed therein.
Design, Certification and Standards
People with sensory impairments often have multiple access problems. These can range from inaccessible software to computer keyboards or mobile phones. The software industry in particular is often unsure how to design visual impairment friendly materials with a huge gap in the knowledge and skills of designers.
Industry should base its products on Design for All principles, so that all citizens have equal access to ICT. Incentive schemes should be developed - in conjunction with sensory impairment experts and NGOs - in order to encourage manufacturers to create accessible products, with designers being trained in making both products and websites accessible. EBU welcomes the fact that trials have taken place for a basic EU Design for All curriculum for engineers and designers. However, the Commission should ensure that information gathered be disseminated widely and the findings should lead to a full curriculum. The Commission should also ensure that people with sensory impairments are included in such trials. A specific EU digital curriculum for designers should also be considered with a possible certified accessibility qualification.
The issue of convergence could be addressed here. Ideally, there should be a 'one-solution-for-all-accessibility difficulties' which should mean that there are no inherent barriers to access with the right access technology. All too often, blind and partially sighted people have to buy different, and often incompatible, software solutions for different problems. This could be combated by the development of 'open standards' as suggested in the Television Without Frontiers programme. Were the Commission to push for such standards to be implemented, solutions - such as USB ports, which are common to all computers on the market - would enable universal accessibility products to be developed. This would enable people with a sensory impairment to be able to pick and choose their IT components to suit them rather than being tied to the products of a single manufacturer. European-wide standards are also needed for a wide range of enabling services - such as Audio Description, the textphones used by deaf and hard of hearing people, and third generation mobile phones.
The embedding of communication capabilities based on open standards into these devices could also extend accessibility beyond TV and PC use to consumer electronics and public access terminals. Thus a blind or partially sighted person might have a single individually-tailored device, perhaps the size of a mobile phone, which would translate the outputs from each of these devices to the person's preferred perceptual modality. This would enable them to use their TV, operate a bank cash dispenser or ticket machine etc. The Commission is encouraged to target research in this area.
In its forthcoming communication, the Commission should also consider certain future technologies which require attention such as :
· Technologies which involve the remote use of one device by another one
· Document management systems
· The semantic web (see
www.w3.org and
www.semanticweb)
· Global positioning systems
There is also a need to certify and label eAccessibility-enhanced products and services as both a guarantee and as information to the consumer. The Council has called for this since 2003, and the time has come for the Commission to advance plans for a European eAccessibility mark or certification system. Not only would such a system enable
all consumers - not only those with sensory impairments - to make informed purchases, it would also reward manufacturers of ICT who take steps to make their products accessible and available to all.
EBU welcomes Commission proposals that the European standardisation organisations become involved with drafting eAccessibility requirements and standards and agrees that such a status will ease their reference in legislation and regulation. However, any such drafting of standards should also be done in consultation with eAccessibility specialists and with NGOs and other organisations working to support those with sensory impairments, who are experts in this field. Follow up work on the eAccessibility situation should be taken according to a prearranged timescale, with the Commission taking further action - including new legislation - as needed.
Public Procurement
The 2004 EU Procurement Directive offers an opportunity to introduce accessibility criteria into Member States guidelines for procurement, and this should be strengthened and consolidated. Public authorities in particular should be encouraged to procure quality accessible ICT products and services wherever possible, and thus to lead on inclusion issues. For example, the Disability Discrimination Act extension in the UK specifically applies to services that are offered to UK citizens by central and local government, schools, colleges, the National Health Service etc., as well as goods.
The development of such accessibility criteria would also be advantageous to EU software companies. The Commission is aware of the public procurement standards already mandated in the USA for example. However, whereas companies in the US are addressing the legislation and creating accessible products, EU companies will find themselves increasingly hampered when exporting their own inaccessible products. It is also inevitable that EU citizens may choose to purchase the most accessible products, possibly buying products from the US rather than from within the EU.
There is a need for information, education and guidance through the complex process of public procurement, from the initial stage of defining the requirement and writing the specification, through the tendering process, the selection and award of contracts, development, testing, and finally implementation. Both procurers and suppliers will need to refer to suitable standards that have been designed to lead to accessible products, systems and services - for example, the Web Accessibility Initiative's Web Content Accessibility Guidelines (WCAG) are often used as a standard for procurement and development of accessible websites. At present, only public websites have to be accessible. In Spain, for example, legislation exists to ensure that information on public websites is accessible to people with disabilities and older people
[1]. Spain also has specific provision related to the universal accessibility of new technologies included in its law on Equal Opportunities, Non-discrimination and Universal Accessibility for People with disabilities (BOE - Official State Gazette - 03/12/03).
The Commission must promote the implementation of accessibility guidelines for websites accessibility, as discussed by telecom ministers at the Crete symposium. These guidelines should include
both the W3C WAI Web Content Accessibility Guidelines
as well as the W3C WAI Authoring Tools Guidelines. The former will ensure that a website is accessible on day one, the latter will help ensure that is stays that way. The Commission should also take forward proposals to extend this provision to private websites - with existing standards and guidelines in the public domain being analysed and applied as best practice where necessary.
It will be important for the EU to facilitate discussion and agreement on suitable guidelines, standards and testable statements that are appropriate to ICT user interfaces, including screen-based interfaces, smart cards, remote controls, telephones, any hard copy or permanent outputs, and other ICT products and public services of all types. In its communication, the Commission should highlight the fact that public procurement does, of course, cover products and services which are to be used internally by employees of public bodies as well as those which are used by the public. Public bodies should be required to produce policy statements regarding accessibility. These should include timescales for the implementation of the actions included in them. Although it is not a legal instrument, the forthcoming communication should also refer to the commitments to which Local Authorities agree when signing up to the Barcelona declaration.
Employment and Access to Work
There is an above average rate of unemployment amongst blind and partially sighted people of working age, and eAccessibility should also mean better ICT and support for this group. In the UK for example, a recent RNIB report
[2] on employment demonstrates that three out of four blind and partially sighted people of working age in the UK are not in employment. Yet sight loss is in itself no barrier to employment. Across the EU, hundreds of thousands of blind and partially sighted people could join the workforce tomorrow, given better support from Member States and employers alike.
However, in 2005, very few jobs do not involve a certain level of IT use. Whilst the Lisbon Agenda intends to increase participation in the workforce, a large number of blind and partially sighted EU citizens are excluded from working as accessible ICT systems are not generally in use. This discrimination is unacceptable. Inclusive software design practices within employment need to be promoted for development of a systematic approach for testing. Existing accessibility standards and guidelines in the public domain should be analysed and applied as best practice where necessary.
The Lisbon Agenda also requires that 'every citizen must be equipped with the skills needed to live and work in this new information society'; and this equates to equal and dependable access to ICT for all citizens. Accessible IT procurement is a key factor to improving employment prospects within the Member States, and the Commission should promote this - particularly by fully utilising the Procurement Directive. Other legislative tools that could also be used are underway in some Member States. In the UK for example, the public sector duty will place a statutory duty on public authorities to promote equality of opportunity for people with disabilities, with the intention of achieving a society in which all people have equal rights and opportunities.
Assistive schemes do exist in some Member States, such as Access to Work in the UK, and these are to be encouraged and promoted to employers and potential users. Given the Lisbon Agenda requirement that a higher priority must be given to life-long learning as a basic component of the European social model, more emphasis should be placed on obtaining good IT skills, especially as this is often a pre-cursor to other learning and employment.
Yet where access technology does exist, workplace IT training and support is often ineffectual or missing. Many employers have inflexible IT systems with remote IT support services, where non-standard individual adjustments are difficult to manage. Attitudes, policies and IT-related processes should change to meet the non-standard requirements of people who use assistive technologies. The Commission should lead on developing effective ways to work with and influence governments and employers so that they are more willing and able to develop systems that will enable blind and partially sighted people and other hitherto excluded sections of the community - such as older people - to be employed. Again, extending procurement provision could solve this. The Commission should also consider providing specific support for people with disabilities in obtaining IT skills. This should consist of a mix of specialised training, basic use and assistive technology and, after this, the inclusion of people with disabilities in mainstream training such as ECDL classes.
Visually impaired people face added barriers when seeking employment. These can range from inaccessible websites and application forms or the fact that access technology is not available to allow them to take tests at interview. Websites must be accessible - particularly those geared at job seekers. Again, the Commission must promote the implementation of guidelines on web accessibility, as discussed by telecom ministers at the Crete symposium.
Broadcasting and Digital Television
Broadcast issues should also be borne in mind whilst considering eAccessibility. Whilst the Television Without Frontiers directive should partly address the issue, as outlined in paragraph 34 of the European Parliament resolution (A5-0251/2003)
[3] , broadcasting also remains an ICT issue. EBU welcomes progressive developments in the world of broadcasting - new services such as Audio Description on digital television, a better quality reception and a wider choice of programming.
Audio Description is an additional narration that fits in between dialogue to describe body language, facial expression, scenery, action, costumes - anything that will help a person with a sight problem follow what is happening.
In some Member States an additional system is also used. Audio Subtitling is a service used when foreign language television programmes are transmitted in their original language, where speech synthesis brings the subtitles to the blind or partially sighted viewer via a special decoder.
Yet although digital technology can make the provision of high quality assistive services available, and not at a great cost, many blind and partially sighted people are unable to take advantage of the benefits offered as this provision is not available automatically. Broadcasters therefore need to be encouraged to provide access services like Audio Description, subtitling and signing. Although solutions such as Audio Description exist for blind and partially sighted people to enjoy television programmes and films, the user may need to navigate several electronic programme guides or screens in order to reach the Audio Description option. Whilst this would not be a problem for a sighted viewer, it can be impossible for those with a visual impairment. To make society aware of the possibilities that ICT offers people with disabilities, in Spain, FUNDOSA Teleservicios (an ONCE Foundation company), produced a DVD which includes menu accessibility, Audio Description and subtitles. The Commission might consider a similar information provision project.
The performance of different countries in this area should be regularly benchmarked - as called for by the European Parliament. The aim of this is to ensure that member states report back, on a regular basis, on measures they are taking to improve access to television for people with sensory impairments. In addition, equipment manufacturers should be encouraged to build the technology to provide Audio Description into their digital reception boxes. They should also be encouraged to develop further access solutions such as talking Electronic Programme Guides. Should progress not be made, EU citizens should have a means of redress. An Ombudsman function with a clear mandate in the eAccessibility field would be one way of ensuring this and to ensure that Member States were adhering to their responsibilities in this field.
The Commission's eEurope 2005 document on challenges for the Information Society notes that not all EU citizens will have a PC. Yet with the best intentions, plans to ensure that services - such as online public services - are available through different terminals e.g. TV sets or mobile phones will exclude people where these terminals are not accessible.
This accessibility issue must therefore be high on the European agenda to prevent further information exclusion of citizens. Manufacturers must also include Design for All features, and open standards should be used to guarantee their connectivity to access technology. Equal access to digital television in the broadest and fullest of contexts must be ensured - and this includes access for people with sight problems - to electronic programme guides, digital teletext and interactive services.
Affordability
The digital divide is often spoken of as being a divide between richer and poorer regions of the EU. Yet this divide could also be that between people with disabilities and non-disabled people and their different experiences of the technological advances that the EU has witnessed over the past twenty years.
For example, the technology to give voice access to mobile phone displays exists, yet acquiring this requires much more money and greater computer literacy than the equivalent for a person who can read the display.
The Commission should include affordability as an essential component of any policy on eAccessibility it produces. It is no good having accessible ICT if this is beyond the means of those it is intended for. As mentioned in the Employment and Access to Work section above, there is an above average rate of unemployment amongst blind and partially sighted people of working age. In the UK, most blind and partially sighted people who have accessible computers at home have purchased the equipment themselves, yet many people are excluded as they are unable to afford to do this.
Digital Rights Management
The Commission has undertaken some work on digital rights management, and whilst EBU welcomes that the issue is being addressed, it feels that no concrete conclusions that would benefit blind and partially sighted people have been reached. The Commission should readdress the issue so that any developments do not exclude people with disabilities.
1 : Law no 34/2002 on the Information and Electronic Trade Society Services, which must be fully implemented by 31/12/2005
2 : Beyond the Stereotypes: blind and partially sighted people and work, RNIB 2004
3 : Notes that levels of sub-titling and sign language interpretation and presentation of programmes in sign language for those with hearing difficulties, and of audio-visual description for the visually impaired, vary quite widely from Member State to Member State ; recalls the Commission's commitment to the European Parliament in June 2002 to raise this issue in the present report; notes that the Commission has not done so ; calls once again on the Commission to address the problem of improving access to the broadcast media for those suffering from sensory impairment; calls on the Commission, in its work programme, to include an annual benchmarking report on the progress in all Member States on making digital TV accessible for people with disabilities ; believes that this report should be based on National Action Plans on 'Improving disabled people's access to digital TV' submitted to the Commission by each of the Member States.
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