Guidance - Official Publications and Extending Availability for Disabled People
Number: 16
First issued: 28 March 2002
(Revised 15 March 2008)
This guidance provides advice on ways in which official publications should be made available in formats that enable disabled users to access them.
Purpose
1. This guidance draws attention to the needs of disabled people when producing official publications. It also advises departments of other sources of information, of the steps that Her Majesty’s Stationery Office (HMSO) is taking to improve accessibility to legislative materials and stresses the need for departments to apply the principles of good practice when providing information to disabled users.
Background
2. Official publications are produced to communicate government policies, initiatives and programmes; for consulting with people about future policy; for communicating new laws and regulations, and as a means of providing a wide range of other information. The Government is committed to providing services which are geared to meeting the needs of all groups in the community and it is important that official publications are produced in a range of formats to ensure accessibility by all groups including disabled people.
3. Where publications are a service to the public there may be a requirement to make them available in alternative formats. In any case, the Disability Discrimination Act 1995 [DDA] makes it unlawful to discriminate against disabled people by refusing them service, providing service on worse terms or providing a lower standard of service. It also requires service providers to make reasonable adjustments to the way they provide their goods, facilities and services to make them accessible to disabled people.
4. Until the courts have ruled on cases of alleged discrimination it is difficult to predict what will be considered reasonable. It is unclear whether information provided by a department is a service to the public. Books are considered to be manufactured products rather than the provision of a service and so are not covered by the Act. Many official publications could be brought within the scope of the Act if it was considered that the document in question was, for example, important in enabling people to comply with the law or generally informs them about procedures they must take. It would therefore be good practice to ensure that such publications are made available in formats that allow disabled users to access them. The responsibility for making the arrangements for publication in formats such as Braille would rest with the originating department.
5. The position is, however expected to change in the future as the government is committed to extend rights under the draft Disability Discrimination Bill currently going through the pre-legislative scrutiny process. The new section 21B to the DDA would extend the provisions of Part 3 of the Act to the functions of public bodies. Where publications produced by departments could be held to be a public function the new section 21D will require departments to produce documents in accessible versions if, having regard to costs and resources, it would be reasonable to do so.
6. Departments should seek legal advice on how the duties in Part III of the Act affect the way they publish material. However, as a matter of good practice, and irrespective of whether the duties in Part III apply or not, departments should adopt a positive approach in arranging for official publications to be made available in formats that meet the needs of disabled users.
7. COI Communications and the then Department for Education and Employment (now the Department for Work and Pensions) published a guide about improving government information for disabled people. Let’s make it accessible was written to help departments and agencies develop a strategy to meet the needs of their disabled customers. It contains guidance covering all information needs including official publications and can be found on the internet at: www.disability.gov.uk/images_of_disability/access.html
8. The guide contains a number of case studies covering a range of documents. It concludes that as a matter of good practice, priority in providing accessible formats should be given to information which:
- is aimed specifically at disabled people;
- is needed to exercise the rights and responsibilities of citizenship (such as voting or paying tax);
- is needed to receive payments or other services;
- is of a personal or confidential nature (e.g. if it relates to medical or financial issues);
- could result in legal consequences or loss of rights if not acted upon (e.g. census or voting information);
- seeks a response from the audience (e.g. consultation documents); or
- is in response to correspondence from a disabled person who has expressed a preference for a particular medium.
Improving accessibility
9. There is one basic step that departments should adopt and which can improve accessibility for a large number of people with impaired vision. This requires the adoption of a clear print standard for all publications. The Royal National Institute for the Blind (RNIB) and COI Communications’ Informability Unit recommend a "clear print standard" of 12 point type for a general audience and a minimum of 14 point for readers with a visual impairment. Similarly, the type should contrast well against the background - ideally contrast dark against light. Black type on a white or yellow background will be legible to many more people than, for instance, red on a green background which provides poor contrast. The font used for the text of this Guidance Note is 12 point Arial. The following are examples of other type sizes:
This is an example of text reproduced using
14 point Arial type
Most users of large print prefer the text to be reproduced
somewhere between 16 point and 22 point
10. Departments should in addition to the standard print versions consider producing publications in alternative formats, especially where these fall within the categories listed at paragraph 7 above. These can include Large print (to the same standard as standard print); Large print (word processed version), Large print for people with learning disabilities, Audio cassette, Braille, Video, British Sign Language video, Disk, CD-ROM and Websites. Let’s make it accessible provides some comparative costs and turn-around times of the various media and a table from the guide is reproduced below. It does not provide actual costs as these will depend on the nature of the publication, the quantity produced, the size of the document, the deadline for delivery and other variables.
The number of £ signs in the chart is intended to give an impression of scale of cost, i.e. £ denotes relative cheapness; ££££££ is expensive. Six £ signs should not be interpreted as six times as expensive as one £ sign.
| Format | Turn-around time | Cost | Notes/comments |
|---|---|---|---|
| Large print to same standard as standard print | Same as for standard print | £££ |
Design stage should run parallel to that of the standard print version. Unit cost will be higher than standard print because the document will be longer. Overall cost should be less as print runs will be much shorter. Alternatively, produce a single version in 14pt or larger type. |
| Large print word processed version | Relatively quick | £ | Systems need to be in place to ensure accurate final text is available electronically. Small quantities can be produced in advance or single copies printed off or photocopied as required. Added advantage: once prepared, text can be transmitted electronically. |
| Large print for people with learning disabilities | Longer than for standard print | ££££ for full colour ££ for black and white |
Text for people with learning disabilities must be short, in very plain English, and have plenty of illustrations to help explain the text. The time taken to prepare the text and illustrations means that it is difficult to produce such versions quickly. |
| Audio cassette professional quality | About 3 weeks | £££ | Where possible, professional scripting and voices are preferable, as low quality recordings are not easy to listen to. Digital recording gives superior quality and can be amended more easily. |
| Audio cassette: budget version | Varies dependent on supplier | £ | Only suitable for one-offs or short runs. Not recommended for long or complicated documents or ones likely to need updating. |
| Braille: 'published' quality | About 4 weeks | ££ | Desirable for longer print runs. Would include printed cover. Should be supplied by professional suppliers. |
| Braille: budget version | Varies | £ | Only suitable for one-offs or short print runs. May be supplied by larger suppliers or by small suppliers such as prison braille units or individuals, or in-house. |
| Video | 6–12 weeks | ££££ | Useful medium for people with low levels of literacy. However, should include subtitles for people with a hearing impairment. |
| British Sign Language (BSL) video | 10–14 weeks | £££££ | Takes a while to assemble necessary contributors. Should also include subtitles and clear, simple voice-over. |
| Disk | Quick | £ | Type of format may depend on end-user. For a general audience, text should be presented as 'text only' and include a 'Readme file' which explains what information is on the disk, in which format and how to access it. |
| CD-ROM | Depends on complexity of information being presented | £££££ to prepare £ to duplicate |
CD Roms can be accessible to a wide range of people who have access to the technology but are useless to many others. A number of aids, such as sound, sign language, text, pictures, etc can be combined in the same medium. |
| Websites | Depends on complexity of information being presented | ££££££ to prepare a site from scratch ££ to add to or maintain an existing site |
Useful source of information for those with the technology. Care should be taken to ensure websites adhere to Cabinet Office guidelines on accessibility: www.cabinetoffice.gov.uk/e-government/webguidelines |
11. Decisions about which media to use should not be based on cost alone. Questions to take into account when planning your information strategy should include:
- Who is the target audience?
- Which media will be most effective in providing the information?
- What is the subject matter and how much of it is there?
- Are there legal or other reasons for ensuring who your message reaches?
- And, most importantly, are your decisions likely to be viewed as reasonable?
12. In considering which media to use it should be noted that approx. 5 times more people rely on the use of British Sign Language (BSL) than those who rely on Braille. However, whereas a blind person cannot access print and may need Braille, or possibly audio cassette to access the information, there is a proportion of BSL users who are able to read. Departments should, therefore, seek to ensure that wherever it is practical to do so, the needs of those deaf users who rely on BSL can be met .
13. A point to remember is that disabled people should not be discriminated against in terms of the cost of provision. It follows that a disabled person should not be expected to pay more for a Braille version of a publication for example than for a standard publication.
What HMSO is doing to meet its obligations
14. HMSO has long established relationships with the RNIB and other similar charitable bodies which allows these bodies to respond to requests which they may receive, to reproduce Official Publications in Braille, Moon, Audio and other formats.
15. The type sizes for new Acts of Parliament were increased in 2001 and HMSO is currently considering alternatives which will result in the 12 point standard type size being adopted for statutory instruments.
16. All statutory publications are now published on the OPSI website at www.opsi.gov.uklegislation/. Versions of legislation can also be provided to individual disabled users for their own use on Disk in ASCII, HTML encoded, XML encoded and SGML encoded formats. Arrangements have also been made with our contractor, TSO (The Stationery Office Limited) for them to fulfil requests from individuals for the supply of legislation in Braille. The user will pay the same price as the standard printed version, and the additional cost of converting it into Braille will be met by HMSO from the Public Access Scheme budgets.
Other sources of information
17. Further advice about the production of official publications in alternative formats can be obtained from
The Informability Unit, COI Communications
The Informability Unit advises COI Communications and its public sector clients on how to communicate effectively with special needs’ audiences.
Contact:
Wendy Gregory
Head of Informability
COI Communications
Hercules Road
London SE1 7DU
Telephone: 020 7620 3441
Fax: 020 7261 8832
e-mail: wendy.gregory@coi.gsi.gov.uk
In addition RNIB have produced their own pack of booklets see it right which offers practical help and advice to help you to meet the information needs of blind or partially sighted people. Further information can be obtained from the RNIB website at: www.rnib.org.uk/seeitright/#order
Information for disabled people in areas such as employment, health and education can be found on the Directgov website at: www.direct.gov.uk/Audiences/DisabledPeople/fs/en
Conclusion
18. If you have any queries regarding this guidance please contact:
The Publishing Services Team
Office of Public Sector Information
Admiralty Arch
The Mall
London
SW1A 2WH
e-mail: hmsopublishing@opsi.x.gsi.gov.uk
CAROL TULLO
Controller HMSO
Queen’s Printer