Enabling Greater Accessibility

Live notes from IET Technical Coffee Morning – Robin Stenham on accessibility.

Accessibility is one of the things I particularly care about so it’s good to have this session.

Robin is Manager – Curriculum Access in Disabled Student Services. Two main areas of responsibility: single enquiry point for students (or their intermediaries) about the interface between their assistive technology and the OU’s products and services – particularly courses. Has a team, has backup from IET staff, but it’s literally one man plus half another one and half of his dog! The other area of responsibility is policy development, again working with IET and LTS, affect and effect policy. Wants to rebalance and embed accessibility in to the mainstream.

Things are changing quite quickly – announcements on Monday folded in to talk at the last minute.

He talked broadly about the issues around accessibility, and specifically for the OU, and then about the new focus on embedding accessibility across the OU, which promises a step-change in the way we manage making our products and services accessible to all.

Why accessibility?

Students’ ethical and legal rights. Fundamental part of OU mission!

Legal requirement is for ‘reasonable adjustment’, which has raised expectations.It’s a technical, pedagogical and service delivery issue. We need a whole-institution approach.

Also business imperative – exempt from ELQ consideration (any student with disabilities gets full funding), and getting it right helps recruitment and retention. Getting it right for disabled students helps other students too. (Access for all.)

It’s part of our own professional armament – keeping ahead of the game. It can also add value to research proposals (certainly has to mine!).

Changes afoot to put the OU in the lead internationally in terms of how it manages accessibility. Organisational dynamics key.

Disabled students at the OU

11,435 disabled students currently registered – about 6% of the student population. 25% of them get Disabled Student’s Allowance.

Fatigue/Pain 5k, Mobility/Physical and Mental Heath both about 3.5k, Manual Skills and Dyslexia about 2.5k, Other about 2k. Sight, Hearing, Personal care about 1k. Unseen about 1.5k. Autistic spectrum lower. Others and things I didn’t capture about 2k total.

Challenges for disabled students

May have difficulty with one or more of many activities. (Some anyone would expect (reading, writing) and some you might not – e.g. sustaining an activity, interacting with others. ) Need to think about how these activities are supported and make reasonable adjustments.

What counts as a reasonable adjustment needs to be a whole-institution consideration – not a retrofit by Disabled Student Services in responsive mode when students encounter problems.

Who’s responsible?

At the moment scattered – changes to University products and services (e.g. move to Moodle) is senior management. Teaching is course teams. Routes for progression – Programme teams/CAUs.  Technical and media – the producers of the materials (LTS, and other units). Support for individuals is Student Services (ALs, Regional/Central Staff, Disabled Student Services). Examinations is Examinations and Assessments. And so on …

So support for embedding accessibility is scattered across many groups, including Disabled Student Services, Accessibility in Educational Media (AEM) team in IET, LTS, Regions, Equality & Diversity Office, and others.

We spend a lot of resource retrofitting materials – e.g. alternative format production, a small industry sending out PDFs, recording in digital format (and analogue, but that phasing out in February), Digital Talking Books – historically developed ReadOut and DREAM, but that being replaced by an international standard – DAISY – so we are producing many DAISY Digital Talking Books for distribution to students. Other things include transcripts, summer school activities, training and development for staff.

Student expectations, when they’re not met, lead to complaints – and there’s a system and organisation for dealing with those.

How charming to pillory a disabled man – article in the Times on 11 November by Melanie Reid. Issue about Gordon Brown’s handwritten letter to relative of soldier killed,   contained ‘Why if the partially sighted can sue the OU for producing inaccessible material […] then this constitutes a grave emergency’. Mr M – late 2007 – sued us in the County Court for failure to provide extensions to TMA deadlines and to provide materials in suitable format; we settled out of court.

Enabling Greater Accessibility

Last April, had a consultant in, led to a workshop – ‘Working together to make accessibility a reality’ – good things came out of this process review. Audience senior managers – Associate Deans, Programme Heads, etc. Sponsored by senior managers – Will Swann, Denise Kirkpatrick.

Had seven objectives to improve things for accessibility – doing better, but also documenting better, and being more visible and organised about it. Trying to step outside silos. That took a morning (!). Now translated to an Implementation Plan, with the ear of the senior managers – previous pushes to do this didn’t have that senior ownership and governance.

Objective to provide accurate and comprehensive information about reasonable adjustments – to students, enquirers, advisors, ALs and Disabled Student Allowance Assessors. Would be great improvement on the current long course descriptions, and would require getting things right upstream in the course production processes. Move away from cottage industries and bolt-ons.

Implementation Plan addresses responsibility. Josie Taylor (Director of IET) and Anne Howells (LTS boss) also bought in, via Denise Kirkpatrick, will also include Deans. Learning and Teaching and Quality, Strategy, Curriculum and Awards. Five sections – policy management and responsibility, process, staff skills, technology, review (plans, targets, reprioritisation).

Faculties will specify an Associate Dean to have special responsibility for accessibility, and will also nominate someone to be supported with training and guidance so they have the high-level skills and expertise too. IET will help assess the knowledge shortfall and help people get up to speed and stay that way. Martyn Cooper reckons it’s a minimum of 10% of someone’s time to track this stuff.

New Code of Practice relating to disabled students coming soon from the QAA – has precepts which institutions need to adhere to.

There is a huge amount of information and guidance – some up to date, some not. Routes in via IET Accessibility Primer and general public-facing info on OU website http://www.open.ac.uk/disability and /diversity

Very much a moving target – technology change very rapid. International standards too.

IET will be producing checklists to help at each stage – what to do, where to get help to do it. Part of IET’s input to Curriculum Management Guide, which is the key document used by Course Teams to make courses.

Also issue with AL-initiated materials, student-generated content (e.g. Elluminate sessions) – accessibility challenges. Some argue that these are additional to producing ‘graduateness’ – but graduate-ness includes encounters with peers, the whole learning experience – so students need to engage with the issues in creating an inclusive society. These should not be barriers for us or our students. If we can harness new technologies in an inclusive and accessible way, it’ll enhance employability for all students. Remote working skills, being inclusive, distributed environment – very transferable skills.

First review in Easter 2010.

What are the benefits?

  1. Increased and sustainable recruitment and retention
  2. Reduced costs and concomitant increased quality of course production, presentation and support (costs hard to define and quantify, though; may require seedcorn funding – but want cost-neutrality where possible)
  3. Reduced costs and concomitant increased quality of complaint management because of an audit trail to be used in the event of DDA challenges (also reputational benefit indirectly)
  4. Meeting our mission


Me: DAISY Digital Talking Books and structured content production.

Robin: Previously, did 1000 flowers bloom approach to technology. Didn’t have understanding of the impact of producing web resources, and implications of multiple stages. Now we have structured content (previously structured authoring) – a single source document (using Word with a fixed stylesheet) delivers a multiplicity of outputs: HTML pages on websites (or complete website), Word-rendition of that material, PDFs to send to printers and go to students. PDFs do help with digitisation and broadly-available content; but PDF still has horrendous accessibility issues. Also outputs MP3 files! And DAISY Digital Talking Books. Disabled Student Services moving on from analogue – we still send out courses on cassettes. 150 cassettes for a 60-point level 1 course! Students spend 20% of time on navigation rather than studying. Also replacing DREAM and ReadOUt with an international standard-based approach: DAISY digital talking books. Will show the advantages of having a digital talking ebook which provides enormous flexibility for non-disabled students to access course texts through the multiplicity of readers.

At the press of a button on Openlearn site – get a Word document, a PDF, a series of MP3s with coherent names, and a digital talking book. Unresolved areas are symbolic fonts and foreign languages, pagination. But we can do a multiplicity of alternative formats at a press of a button – for all students, not just students with declared disabilities.

Project almost finished, but reverberations around for a while.

Q1: Reasonability. To do your job, need to understand what reasonable adjustment means. Is that straight from legislation? Who decides?

Robin: Very interesting question. ‘Reasonable adjustment’ is right from the legislation, and we have to make them, but there’s no case law (yet). We have many best guesses about it. Robin thinks reasonable adjustment is a process, which is influenced by a number of things: the governance and management, international standards, cost, dialogue between student and adviser.

Martyn Cooper: Very pertinent question, highly problematic, has been since it came in. Law sets out the term, Best Practice Guides give some examples of what you have to think about. But everyone settles out of court (as we did) so no case law. And anyway probably wouldn’t transfer very well. General guidelines offered, course teams have prime responsibility. Currently an informal process in the OU. In the new plan, defining the responsibility. Proposal to have a panel in the university so where a course team or a developer decide something isn’t reasonable, they pass it to that panel for review and help. Perhaps your idea about how to meet the situation wasn’t reasonable, but there might be other ideas, so need to check. But some adjustments are in truth unreasonable.

Q1: Only barrier cost?

Martyn: No. If adjustment impairs the study of other students. Or if compromises academic quality. Always say, refer back to learning objectives, or to the assessment adjectives. Is there a reasonable way of achieving those – adjustment might give access to some material but not the learning. Sometimes might say ‘Ok, can’t do that bit, but can reach learning outcomes by going for the other parts’ – so long as the students know. At the moment they don’t get that level of information at course signup.

Q1: There is a legal concept of a reasonable person. Somewhat antiquated. He is a white able-bodied male who gets on the Clapham Omnibus!

Martyn: Disability legislation – back to 1985, 1996 when education came in to scope – so that point probably archaic.

Q1: No legal definition of reasonability, in practice.

Robin: Yes, indeed. We don’t have a coherent process to enable us to have a defendable position about whether our decisions are reasonable. As an institution, the criteria are laid out about academic standards, costs, impact on other students – our processes will enable us to define reasonability, but explicitly and documentation. E.g. from language courses – previously had academic outcomes around about speaking a language, now change to communicating in a language. Change enables e.g. students with hearing or speaking impairments to study.

Martyn: It’s not all doom or gloom! In every case in the last 12 years, usually leads to innovation and better quality for everyone. It’s not a terrible issue of dealing with nasty problems. It’s part of making really good students. So things like virtual microscope or virtual field trips meet the needs of students without disabilities so folded in to mainstream provision to great benefit. Also good news is that this implementation plan exists, with buy-in across the board, rather than being agitated for by the people directly concerned. If it achieves half of its aims it’ll be great.

Robin: Loads of examples where inclusivity improves the content of the course – design, HCI (and mobiles!). New maths & computing course – lots of accessibility review of the new tools, and different ways of assessing work and how groups can work together. Will make the course much richer by considering needs widely.

Jon: Should aim for course team to make a course passable by someone with particular challenge, or to be able to get a Pass 1 (top grade)? E.g. if skip inaccessible part of course, could make it hard to get top marks.

Robin: Raises question of clusters of individual needs. In one sense there’s no such thing as disabled students, there are students with a variety of needs. Structured content allows us to cater to students with a variety of preferences – and requirements – for media to study with. Help students become independent learners. It’s about diversity, and diversity in accessing media. So balance between individualisation and mass personalisation – in course content, learning outcomes, and media.

Martyn: Point raised is valid. Standard illustration: e.g. Arts course talking about development of perspective in Western Art, teaches by asking students to review a series of pictures. Can’t be accessible to students who can’t see – so don’t waste your effort producing endless course descriptions. Course Team then has decision – is there something else we can provide, or can they pass the course without doing that? Is an academic question, tied up with academic objectives.

Robin: Then make it explicit and clear. Students with disabilities not naturally litigious – it’s when they’re led to believe they can do something and then find out they can’t, because the course descriptions don’t help them know whether they can do it or not.

Q2 (visitor from China): In China, have 60m disabled people, but at university level have separate institutions for disabled students. Suggestions for our Chinese universities to be inclusive? Collaborative work?

Robin: Yes, sure! Primary and secondary education in UK has been around special schools for e.g. students who are blind, or who are deaf. But direction of policy here (and societal view), based on cost and inclusivity, is a move to integrate students with learning differences in to the mainstream. At university level, whole thrust of legislation is to create inclusive higher education.

Q2: As developing country, perhaps costs lower for separate institutions.

Martyn: Different perspectives on this globally. In UK, no specialist universities, but some rare specialist colleges. In the US, some universities have special focus on this (incl Rochester). But American model is that the expertise there gets rolled out to other universities as best practice. Different cultures, and huge diversity in this area across Europe. Philosophically in the UK the tendency is towards inclusion. Within the disability community views differ. Many think it’s a good thing, so long as needs are actually met – if not met, it can be a way of avoiding support.

Q3 (MCT course manager): Welcome this. Can be bewildering. Symbol fonts slightly tricky – can we raise that profile of symbolically-rich courses? Will there be particular strand looking at this?

Robin: Working with Science. Did a mystery shopper exercise, keeping a diary, did improvements based on that. Now looking at how we can make science accessible – and where we can’t, and what the difficult areas are. Enormous effort internationally on making symbolic language accessible, but no silver bullet. Tracking that very intently, we don’t know enough about it. Not part of the Implementation Plan but Disabled Student Services working on this. Pathfinder for other faculties too. Timescale – by end of July 2010, project complete, results analysed by Faculty.

Martyn: Every faculty has its own particular challenges – hence need for each Faculty to have a specialist on accessibility in their area.

Robin: Also e.g. deaf students studying music. Similar challenge.

Q4: Where does the increased use of existing, third-party material (online resources, databases, etc) leave us with regards to reasonable adjustments?

Robin: Have done things here. Mary Taylor developed guidelines for referring people to documents and websites – quick and dirty ways to put up flags for further analysis by experts. Having problems with this now. Business school course, co-produced reader – some articles were pictures!, so inaccessible. Had to do fixes. Rights have to be involved here. The simple way of dealing with it is to re-key, but that’s a cost. Or advanced scanning technology for the student themselves. It’s a minefield. Like student-generated content. We have to engage with this. Need to have processes in place, and know the basis on which we’re doing that, and communicate that.

Q4: Embedded in Implementation Plan?

Robin: Yes.

Q5: ELQ exemption – self-declared students?

Robin: Not sure. Definitely students on DSA. Don’t know about self-declaration, though.

Martyn: There is a constraint about the amount of study within an annual period.

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Author: dougclow

Data scientist, tutxor, project leader, researcher, analyst, teacher, developer, educational technologist, online learning expert, and manager. I particularly enjoy rapidly appraising new-to-me contexts, and mediating between highly technical specialisms and others, from ordinary users to senior management. After 20 years at the OU as an academic, I am now a self-employed consultant, building on my skills and experience in working with people, technology, data science, and artificial intelligence, in a wide range of contexts and industries.

7 thoughts on “Enabling Greater Accessibility”

  1. Great post, Doug. Thanks especially for recording the questions – most interesting part.

    I’ve found that creating Large Print in Word has then helped in linearizing text for audio transcriptions, but never gone the whole way to using Word format is the primary document format. Do you do any DTP work? Any heavily graphical work?

    In Scotland there’s been a presumption of mainstreaming pupils since 2000, and the 3 exceptions are explicitly spelled out in legislation.

    Re: deaf students studying music. Have you seen Eveleyn Glennie talking about deaf people learning music (7:51) and student access to Royal Academy of Music (10:19)?

    1. You’re welcome.

      The OU does do a lot of graphical work, where needed, and we have a process for doing audio descriptions for them. The page layout is now done separately from content creation so some of the tricky DTP-type issues are dodged that way – at the expense of losing author control over page layout.

      Hadn’t seen the Glennie clips – ta!

  2. Doug – Thanks for this blog post. Can I just correct dates of the legislation – not sure if I said it wrong or you heard it wrong:

    UK Disability Discrimination Act (DDA) first passed 1995. (Education exclude from obligations under this act.)

    Special Educational Needs Disability Act (SENDA) amended DDA and became DDA part 4 in 2001. This stated the specific rights and responsibilities in education.

    The DDA then went though a further amendment in 2005. It is DDA 2005 that is the current legislation.

    The Code of Practice to accompany the DDA for providers of post-16 education and related services produced by the now defunct Disability Rights Commission is still made available by the Equality and Human Rights Commission:

    Click to access code_of_practice__revised__for_providers_of_post-16_education_and_related_services__dda_.pdf



  3. Hi Doug, I’m the editor of the DAISY Consortium’s monthly newsletter, the DAISY Planet. Content in DAISY format will deal with the problem “Students spend 20% of time on navigation rather than studying.” Can you tell me please how this figure was determined (it does make sense)? I’d like to mention your post, specifically the move to the DAISY Standard for your materials and the amount of time students spend navigating rather than studying. Perhaps you could contact me directly. Many thanks – Lynn

    1. Hi Lynn

      I’m not sure how the 20% figure for navigation time using tapes was determined, but it’s been in casual circulation for a while at the OU. I know that over the year we’ve done a huge amount of evaluation and testing of our materials with students with disabilities, and it may have come out of a fairly serious study. Or it might be a rule of thumb based on observations. I also know that we’ve done some testing of DAISY, in various ways, but I don’t know whether we have robust data about the navigation overhead there for good comparison.

      More than happy for you to mention this in your newsletter.

      Will also email to put you in contact with Robin himself who is right on top of our policy and practice here, and may well be able to give fuller answer than I have here – I just pay attention to what he says!

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