Holistic Approaches to E-Learning Accessibility
JISC TechDis Service
York Science Park
University of Bath
The importance of accessibility to digital e-learning resources is widely
acknowledged. The W3C WAI has played a leading role in promoting the importance
of accessibility and developing guidelines which can help when developing accessible
Web resources. The accessibility of e-learning resources provides additional
challenges. In this paper the authors describe a holistic framework for addressing e-
learning accessibility which takes into account the usability of e-learning, pedagogic
issues and student learning styles in addition to technical and resource issues. The
paper goes onto describe issues surrounding staff development issues and evaluation
of these resources. The paper is adapted from Implementing A Holistic Approach To
E-Learning Accessibility (Kelly, Phipps and Howell, 2005) given at the ALT-
Conference in September 2005).
The importance of universal accessibility to Web resources is widely acknowledged.
W3C’s Web Accessibility Initiative (WAI) has developed guidelines which help to
ensure that Web resources can be accessed by people with disabilities. With the Web
providing the main delivery channel for e-learning resources it would appear that the
WAI guidelines should be a requirement for e-learning development. However, this
paper puts the case for a wider perspective, recognising limitations of WAI guidelines
and implementation and acknowledging that the IT sector has responded to demand
for accessible digital resources by providing accessible versions of proprietary formats
and operating systems.
The Web Accessibility Initiative
The World Wide Web Consortium (W3C) (the body responsible for the coordination of
developments to Web standards) established the Web Accessibility Initiative (WAI)
with a remit to lead the Web to its full potential with a particular reference to
promoting a high degree of accessibility for people with disabilities. WAI has
successfully raised awareness of the importance of Web accessibility and in
developing guidelines which help to ensure that Web resources are accessible, with
the Web Content Accessibility Guidelines, often referred to as WCAG (WAI, 1999)
being of particular relevance to developers of Web resources.
Challenges in Implementing WAI WCAG Guidelines
In 2001 the UK Government introduced the Special Educational Needs and Disability
Act (SENDA, 2001), bringing the previously excluded elements of the education sector
within the remit of existing anti discrimination legislation. In the same year the JISC
the (Joint Information Systems Committee) established the TechDis service with a
remit for all aspects of technology and disability within education. Since 2001 the
service has been working with other intermediaries to try and understand the
ramifications of the legislation on, amongst other things, e-learning.
An excellent overview of the legislation highlighting many of the issues that would be
affected by the legislation is given in (Willder, 2002). However, she concludes that
until the legislation is tested it will be difficult to draw conclusions. (Sloan, 2002)
suggests that there is little doubt that e-learning will be within the scope of UK
“… it can be seen that there is likely to be a duty on higher and further
education institutions to ensure that their online teaching resources and
VLEs are provided in a form accessible to disabled students. Further,
institutions will be expected to make ‘reasonable adjustments’ to
overcome these problems and are unlikely to be able to justify continuing
Over a period of 4 years the authors have been working together with academic staff
and individuals working in the policy area to better understand how standards and
guidelines fit together with UK legislation and how that then transposes onto the
learning experience of a disabled student in the UK. In working with learning
technologists, disability staff and lecturers, the authors and others acknowledged in
this paper have come to some interesting conclusions and challenges to those who
are working in the field of accessibility.
Kelly, Phipps and Howell (2005), describe some of the experiences of staff involved in
e-learning attempting to map their work onto WCAG guidelines. They conclude that
whilst WCAG guidelines have a very important role to play in the creation of more
generic web-based materials, it is difficult to relate the same approach to a rich e-
learning experience that is accessible to all students. They reflect that the
application of guidelines to individual objects can create problems and describe a
more holistice approach.
A Holistic Approach
The Need for a Holistic Approach
Much emphasis is now placed on accessibility in education; generally this has come to
be synonymous with Web accessibility or the accessibility of e-learning. However to
staff who are just starting out in educational development or using technology in a
very iterative way with students the application of these standards and guidelines
can be at best a discouragement or at worst damaging, preventing staff from
exploring the potential of e-learning.
This approach also ignores a major facet of the educational experience: it is holistic.
Students attend an institution and partake of a range of facilities and activities –
some they will not relate to, others they will. Because a disabled student cannot
access one type of assessment that happens to be delivered via a Web browser, it
does not mean they cannot instead do an oral examination in a one-to-one situation.
The current accessibility paradigm places emphasis on total online access, or if
materials cannot be made accessible, then providing an equivalent online
experience. This can be damaging to the educational experience of attending an
institution, ignoring the fact that institutions and their staff deploy a range of
learning methods, some of which will suit all students; others will not. The only way
to judge the accessibility of an institution is to assess it holistically and not judge it
by a single method of delivery.
The components of a proposed holistic framework to support the development of e-
learning resources are outlined below.
The Disability Rights Commission’s report (DRC 2004) highlighted the importance of
Web site usability for people with disabilities. The report pointed out that “45% of
[the 585 accessibility and usability] problems were not a violation of any [WAI WCAG]
Checkpoint and could therefore have been present on any WAI-conformant site
regardless of rating”. This point illustrates a limitation of the WAI WCAG guidelines.
It should be self-evident that quality e-learning Web resources should be usable and
not just accessible. However the strong emphasis given to accessibility, especially
with concerns sometimes expressed that failure to comply with W3C WAI WCAG
guidelines could lead to legal action, can lead to failure to give equal weight to
Although it might appear desirable to include usability alongside accessibility there is
a need to be aware of potential conflicts. This may be partly due to poor support for
Web standards in browsers. In addition users may express preferences for e-learning
resources which have conflict with accessibility guidelines. The proprietary Flash
format is widely used for the development of interactive e-learning resources and on-
line games. Such resources may be accessible. The RNIB (Royal National Institute for
the Blind), for example, has encouraged the development of accessible Flash
resources. The RNIB also provide advice on the development of accessible Flash
resources (RNIB, n.d.). Although resources such as the RNIB Blind Date game may be
usable and accessible, they would not appear to comply with the WAI WCAG
guidelines as they make use of a proprietary file format.
Accessible e-Learning or Accessible Learning?
In the holistic approach to accessible e-learning there is a need to provide accessible
learning experiences, and not necessarily an accessible e-learning experience. This
approach has parallels with the concept of blended learning rather than the more
limited e-learning approach.
As an example, consider an e-learning environment which provides a highly
interactive 3D visualisation of a molecule. Such an environment is likely to be very
difficult to make accessible to a visually impaired student or a student with impaired
motor skills. Rather than seeking to develop an accessible version of such an
environment (which, if possible to do, may prove costly, without any guarantee that
the accessible equivalent will be usable by the student with disabilities). In such a
case the teacher should consider the learning experience provided by the e-learning
resources and seek to develop an alternative which provides an equivalent learning
experience. In many cases it should be possible to find an acceptable equivalent
learning experience, such as the resources used prior to the development of the e-
learning resource (for example, a physical representation of a molecule).
This approach may also be used when a real-world learning experience is not
accessible. For example consider a field course for a geography student, which
requires climbing a mountain or other terrain unsuited for a student in a wheelchair
or with similar physical disabilities (this may include an overweight student or a
heavy smoker who finds physical exertions difficult). A blinkered approach may seek
to make the mountain accessible by using expensive all-terrain vehicles, building
appropriate paths and ramps at key sites or, in the worst case scenario, cancelling
the field trip for all students. A holistic approach allows the teacher to identify the
learning experiences (such as the selection of appropriate sites to take water and soil
samples) and seek equivalent learning experiences (perhaps providing the student
with 3G phone technologies, videos, for use in selecting the sites, followed by
discussion of the test results with other team members at base camp). This holistic
approach to accessible learning has been accepted in a number of academic
disciplines. For example the Virtual Field Course Web site (VFC, n.d.) describes
several approaches to support field studies for students with disabilities.
This holistic approach encourages a more bird’s eye view of the learning experience
encountered by disabled students. The learning path that the student chooses to
follow should be accessible while individual online components or learning objects
may not. To provide another example consider a blind student who wishes to take a
degree in biochemistry. When choosing a course the student should be advised on
course modules which the student’s disability may make it difficult for the student to
pass (such as options which may require a student to peer through a microscope and
describe what they see). Although such courses may not be possible for a blind
student to take, the department could seek to provide accessible alternative course
options which would still allow the student to be awarded a degree.
Adapting to Individual, Local, Political and Cultural Factors
The final components of the holistic framework for e-learning accessibility calls for
an approach which takes into account individual needs and local cultural, political
and social factors. Since accessibility is primarily about people and not about
technologies the authors feel it is inappropriate to seek a universal solution. In
seeking to provide accessible learning experiences it will be necessary to take into
account the individual’s specific needs, institutional factors, the subject discipline
and the broader cultural and political factors.
Instead of aiming to provide an e-learning resource which is accessible to everyone
this paper argues there can be advantages in providing resources which are tailored
for the student’s particular needs. An example of this approach is given in Section 5
of this paper.
The Holistic Framework
The holistic framework for e-learning accessibility, which has been described
elsewhere (Kelly, 2005a) is illustrated in Figure 1.
Figure 1: Holistic Framework for E-Learning Accessibility
Rather than relying purely on the WAI guidelines, the framework incorporates the
guidelines as part of a broader approach to the provision of accessible e-learning
resources. There is a need to address the usability of e-learning resources, the
pedagogic aims of the e-learning resources, infrastructural and resources issues and
to provide solutions which are appropriate to the needs of the framework. The
authors feel that a quality assurance framework is needed to support this approach
which will ensure that documented policies are provided and systematic procedures
for ensuring compliance with the policies are implemented.
It could be argued that this approach has limitations compared with the W3C WAI
guidelines. The WAI guidelines can appear easier to implement as they provides a
series of checklists. However a checklist approach can, in fact, be counter-productive
as it encourages developers to prioritise the objective areas which testing tools can
easily report on.
Another limitation of this approach may be its lack of universality which is implicit in
its inclusion of institutional and local factors. This criticism may, in fact, be regarded
in some quarters as strength of the approach, as it does not seek to mandate a single
global solution, but rather welcomes diversity and a learner-centric approach to e-
Whilst this work has been discussed and revised at length at various workshops and
conferences, there is still a need to develop the framework and to provide examples
of how it could be applied in a variety of circumstances, including differing learning
environments, students with a variety of disabilities, use of various technologies and
in a variety of different organisations.
The Need for a Holistic Approach
An article (Sitemorse, 2005) published by the accessibility auditing software company
Sitemorse has generated heated debate over the relative merits of automated
accessibility checking versus manual testing. The article describes the findings of an
automated analysis carried out by Sitemorse across the Web sites of various disability
organisations within the UK including the RNIB, RNID, the Disability Rights
Commission, etc. The arguments over the relevance of the findings clearly
demonstrates a lack of consensus and illustrates the difficulties that even national
disability organisations find in complying with even basic WAI WCAG guidelines.
However the article failed to provide a solution to these conflicts. In this paper a
framework has been described which does provide a resolution to this impasse. The
framework is applicable to a learning context but is also well-suited to the provision
of informational resources, such as those provided by disability organisations (who
are targeting specific audiences) mentioned in the Sitemorse article.
The Holistic Approach in Development Cycle
In trying to provide pragmatic guidance what emerged was a suggested framework for
developers that could be applied at various points in an e-learning development
cycle. What is demonstrated below is the result of discussions with colleagues in both
the disability and e-learning areas of education. It is also 'work in progress'; we are
not seeking to claim that this is the final answer, but hope that it does help
contribute to the discussion. The final caveat is that this is designed to be applicable
to UK education institutions; we are not trying to create a model that will fit all
areas of e-learning.
In using the framework below it is suggested that developers document in some way
the process as they work through it. This will be useful if challenged, but also as a
means of reflecting on the process when undertaking further developments.
Stage One Stage Two Stage Three Stage Four Stage Five
Awareness Investigation Understanding Implementation Evaluation
Can the student
the macro scale
Stage One - Awareness
Here the developer is asked to consider specific issues relating to the development of
e-learning material and consider the needs of disabled students. For example, it is
suggested that, if an online assessment is being created, the developer should be
aware that there are issues related to how someone with a vision impairment would
Stage Two - Investigation
Here the developer, after becoming aware that there may be some issues with the
resource, investigates what existing guidelines, 'standards' or practices are available
that would support the resource under development in relation to inclusion. For
example, it may be that the use of W3C guidelines are applicable in the creation of
Stage Three - Understanding
This is where the developer must make a value judgement: are the practices they
have identified in stage 2 valid for the resource under development? Furthermore,
they must ensure that the application of the guidelines, 'standards' or practices does
not compromise the learning objective or outcome. For example, in an online
assessment using images, an alt tag (describing the image) must not give away the
Stage Four - Implementation
This is probably the most important stage to document, after working through the
processes and either developing a resource that is 'accessible', or one that may be
inaccessible to some audiences it may be necessary to identify other ways of
achieving the learning objective. For example, a totally inaccessible online
assessment, due to the material or system constraints, may be overcome by holding a
viva voce for the student, or an inaccessible discussion group may result in a small
group discussion with other students. Documenting these areas is important to ensure
that the developer recognised the issues and began the process of identifying
alternatives or adjustments.
Stage Five – Evaluation
Evaluation of practice is key in ensuring that the needs of disabled students are met
in learning environments. Here it is suggested that not only individual learning
outcomes are evaluated, but a wider approach is taken. For example, where a
project is funded to provide individual learning objects, it should be evaluated on the
whole and not on each product.
This paper argues that although the W3C WAI guidelines for content accessibility are
valuable, they should not be regarded as the only set of criteria which developers of
e-learning resources need to consider. Not only is there a need to address a wider set
of issues than those addressed in the WAI guidelines, there are also other factors
which need to be addressed, some of which may conflict with WAI guidelines. In
addition there is a need to place the learner at the centre of development process.
This approach focuses on the broad learning outcomes and recognises that
inaccessible e-learning resources may be deployed provided that disabled learners
are still able to demonstrate the required learning outcomes in a way that does not
disadvantage them or their non-disabled peers.
The authors acknowledge that, in some quarters, these ideas made be regarded as
controversial, especially in organisations which have defined e-learning accessibility
policies solely using the WAI guidelines. It is also recognised that there is still an on-
going debate to be held. The authors welcome comments and input to this debate.
DRC (2004). Formal Investigation Report: Web Accessibility. Retrieved 21 January,
2005, from http://www.drc-gb.org/publicationsandreports/report.asp
Kelly, B, Guy, M and James, H (2003). Developing A Quality Culture For Digital Library Download full-text
Programme, Informatica Vol. 27 No. 3 Oct. 2003. ISSN 0350-5596. Retrieved 18 May,
2005, from http://www.ukoln.ac.uk/qa-focus/documents/papers/eunis-2003/
Kelly, B., Phipps, L. and Howell, C. (2005) Implementing A Holistic Approach To E-
Learning Accessibility, In: Cook, J. and Whitelock, D. (2005) Exploring the frontiers of
e-learning: borders, outposts and migration; ALT-C 2005 12th International
Conference Research Proceedings, ALT Oxford.
Kelly, B, Phipps, L and Swift, E (2005a). Developing A Holistic Approach For E-
Learning Accessibility, Canadian Journal of Learning and Technology Vol. 30, No. 3.
Retrieved 18 May, 2005, from http://www.ukoln.ac.uk/qa-focus/papers/cjtl-2004/
Kelly, B, Sloan, D, Phipps, L, Petrie, H Hamilton, F. (2005b). Forcing Standardization
or Accommodating Diversity? A Framework for Applying the WCAG in the Real World,
Proceedings of the 2005 International Cross-Disciplinary Workshop on Web
Accessibility (W4A). ISBN: 1-59593-036-1. Retrieved 18 May, 2005, from
RNIB (n.d.). Web Access Centre. Retrieved 18 May, 2005, from RNIB Web site:
SENDA (2001). Special Educational Needs and Disability Act 2001, HMSO. Retrieved 18
May, 2005, from http://www.hmso.gov.uk/acts/acts2001/20010010.htm
Sitemorse (2005). Confusion Reigns Over Website Accessibility Compliance. Retrieved
18 May, 2005, from SiteMorse Web site:
Sloan, M. (2002). E-Learning and Legislation. Retrieved 18 May, 2005, from TechDis
Web site: http://www.techdis.ac.uk/resources/msloan02.html
VFC (n.d.). The Virtual Field Course. Retrieved 18 May, 2005, from University of
Leicester Web site: http://www.geog.le.ac.uk/vfc/education/
WAI (1999). Web Content Accessibility Guidelines 1.0, W3C Recommendation 5-May-
1999. Retrieved 18 May, 2005, from W3C Web site: http://www.w3.org/TR/WCAG10/
WAI (2004). Web Content Accessibility Guidelines 2.0. W3C Working Draft 19
November 2004. Retrieved 18 May, 2005, from W3C Web site:
Willder, B. (2002). 'Disability legislation: implications for learning technologists in the
UK'. In: Access All Areas: Disability, Technology and Learning, Phipps, L., Sutherland,
A. & Seale, J. (Ed.) ALT/JISC/TechDis. pp. 6-9