Explainer
Section 508 and Accessible Manuals
The Short Answer
WCAG 2.0 A and AA, Applied to a Manual
Section 508 of the Rehabilitation Act (29 U.S.C. 794d) requires federal agencies, when they develop, procure, maintain, or use electronic and information technology, to give people with disabilities access comparable to everyone else's, unless that would be an undue burden. The technical rules are the Revised 508 Standards in 36 CFR Part 1194. For electronic content, which includes documents, they require conformance to Level A and Level AA of WCAG 2.0.
A manual is an electronic document. When one is delivered to an agency, the question is not whether accessibility matters but whether the standard is in scope for that contract, and how the customer will check it.
When It Applies
Does It Reach Your Manual?
The Federal Acquisition Regulation puts the rule into contracts. FAR subpart 39.2 implements Section 508, and 39.203 says that unless an exception or exemption applies, ICT acquisitions shall meet the applicable standards at 36 CFR 1194.1. The defense supplement, DFARS, has no separate subpart on this in part 239. The text that matters is whichever accessibility language your contract or statement of work carries.
Inside the standards, the scoping for electronic content is in E205. Content that is public facing is covered. Content that is not public facing is covered when it is official business communicated by the agency in one of the listed ways, which include educational or training materials and templates or forms. Separate from that, E208 and section 602.3 say that when an agency provides electronic support documentation for ICT, the documentation must meet the same WCAG 2.0 level. There are exceptions, among them national security systems and ICT a contractor acquires incidentally to a contract. Which of these fit your manual is a reading of the contract, not a rule of thumb.
Practical advice: look for an accessibility clause, a CDRL or data item description that mentions it, or a statement of work paragraph on electronic documents. Our guides to DFARS technical data delivery clauses and what a CDRL is explain where delivery requirements live. If the contract is silent, ask.
What It Takes
An Accessible PDF or HTML Manual
- Structure that software can read
- Headings, lists, tables, and figures are marked up as what they are, not drawn to look like them. In a PDF that means a tag tree; in HTML it means real heading, list, and table elements (WCAG 1.3.1).
- A reading order that matches the meaning
- A screen reader follows the tag order or the source order, not the visual layout. Multi-column pages, callout boxes, and figures with captions are where the two drift apart (WCAG 1.3.2).
- Alternative text for every illustration that carries information
- Text that serves the same purpose as the picture (WCAG 1.1.1). An exploded view or wiring diagram needs more than a one-line description: pair it with a longer text description, and keep the figure and callout numbers readable as text. Purely decorative graphics are marked so a reader skips them.
- Table headers
- Header cells identified as headers, so a reader announces the column and row for each data cell (WCAG 1.3.1). Merged and nested cells make this hard; simple tables survive every output.
- Document language and title
- The default language set in the file (WCAG 3.1.1) and a title that describes the document (WCAG 2.4.2). Passages in another language are marked separately.
- Real text and enough contrast
- Text, not pictures of text (WCAG 1.4.5). A contrast ratio of at least 4.5:1 for normal text and 3:1 for large text (WCAG 1.4.3). Color is never the only carrier of meaning (WCAG 1.4.1).
The two formats differ in one important way. Non-Web documents such as PDFs are excused from four WCAG 2.0 success criteria (bypass blocks, multiple ways, consistent navigation, and consistent identification). HTML is Web content and must meet them, which in a large manual means a working table of contents, search or an index, and consistent navigation. Section508.gov's guidance for PDFs tells agencies to prioritize HTML and use PDF only when necessary. Long PDFs still benefit from bookmarks even though the standard does not demand them.
PDF/UA, ISO 14289-1, is the ISO standard for accessible PDF files. The Revised 508 Standards reference it for authoring tools that export PDF; the delivered file is tested against WCAG 2.0.
Warnings
Color Cannot Carry the Message
Warnings and cautions are the part of a manual most likely to depend on color: a red or yellow band, an icon, a bold box. For accessibility the signal word must be real text, the symbol needs a text alternative, and the text must have enough contrast against the band. A warning set as a picture of text fails twice, once for text in an image and once for being invisible to a screen reader. The warning also still has to sit directly before the step it governs in the reading order. See warnings, cautions, and notes for the content rules, and technical illustration for the figures that need descriptions.
Structured Source
Why DITA and S1000D Help
Retrofitting a finished PDF means fixing every file one at a time. Fixing the source means fixing it once. A structured source such as DITA or S1000D already records headings, lists, tables, figures, warnings, and the language of the content as data. A rendering pipeline that is built to carry that data through can emit tags and real HTML elements every time, and the same alt text and header definitions reach every output.
That only works if authors supply the data. Alternative text is written by a person, per figure, in a field the schema provides; tables must be modeled with header rows; a business rule or style check can make the missing ones visible. Our guides to how XML becomes a PDF and S1000D to PDF describe the pipeline where the structure is kept or lost. For the European equivalent, see EN 301 549 V4.1.1 and the European Accessibility Act and your manuals.
How to Test
Manual Checks Plus Tools
- Run an automated checker on every PDF and every HTML page. Treat the result as a screen for obvious failures; automated tools cannot judge whether alt text is meaningful or the reading order makes sense.
- Open the tag tree of a sample of PDFs and compare it with the page: headings nested correctly, figures tagged with alt text, table header cells tagged as headers, nothing important left untagged.
- Read a sample aloud with a screen reader, starting from a procedure with a warning, a table, and a figure. If you cannot do the task by ear, the file is not accessible whatever the checker says.
- Navigate the HTML with the keyboard only. Focus must be visible, the order logical, and no control reachable only by mouse.
- Zoom the HTML to 200 percent and check nothing is cut off or overlaps. Check contrast on the actual rendered colors, including warning bands and table shading.
- Record what was tested, on which sample, and with what result, and deliver that record if the contract asks for an accessibility statement.
Delivery
Building It In
Shakewell produces Section 508 accessible PDF and HTML outputs for technical publications. The practical way to get there is to decide the accessibility requirement when the output formats are decided, not after the first review, so the pipeline and the authoring rules carry it from the start.
FAQ
Questions We Hear
Does Section 508 apply to technical manuals delivered under a federal contract?
It can. The Revised 508 Standards cover information and communication technology that agencies procure, develop, maintain, or use, and the definition lists electronic documents. FAR 39.203 says ICT acquisitions shall meet the applicable standards unless an exception or exemption applies. Whether a particular manual is covered depends on the contract, who reads it, and the exceptions (national security systems are one). Read the contract text and ask the contracting officer; this page is not legal advice.
Which WCAG version does Section 508 use?
WCAG 2.0 at Level A and Level AA, incorporated by reference in 36 CFR Part 1194. Later WCAG versions are not what the rule names, though a contract can ask for more. For non-Web documents such as PDFs, four success criteria are excused: 2.4.1, 2.4.5, 3.2.3, and 3.2.4. HTML manuals are Web content and do not get that relief.
Is a tagged PDF the same as PDF/UA?
No. Tagging is what makes a PDF readable by assistive technology. PDF/UA is the ISO 14289-1 standard that defines what an accessible PDF file must contain. The Revised 508 Standards name it for authoring tools that export PDF, not as the test for a delivered file; the delivered file is measured against WCAG 2.0. A contract may still call for PDF/UA, so check.
Should we deliver HTML or PDF?
Section508.gov tells agencies to prioritize HTML and use PDF only when necessary. For manuals, many programs need both: PDF for print and archive, HTML or an interactive viewer for the field. Both come from the same source, so the work is in the pipeline, not in doing it twice. Our guide to how XML becomes a PDF shows where the structure is carried through.
Do warnings and cautions need special handling?
They need the same rules, applied carefully. The signal word and its meaning must be text, not only a colored band or an icon; any symbol needs alt text; and the contrast between band and text must pass. Our guide to warnings, cautions, and notes covers the content side.
Get In Touch
Settle Accessibility Before You Deliver
Send us the contract language and a sample of your current PDF or HTML output. We will tell you what the requirement covers and what has to change.