Many libraries have established formal or informal policies to ensure the accessibility of licensed and library-created digital content, but libraries also report uncertainty regarding the responsibilities for auditing and enforcing such policies, according to the “LYRASIS 2019 Accessibility Survey Report,” by Hannah Rosen, Licensing Specialist and Digitization Program Coordinator, and Jill Grogg, Licensing Program Strategist, for LYRASIS. Published in July, the survey included 155 responses primarily from academic libraries, along with a small number of public libraries, government archives, independent archives, museums, and primary education schools.

“Accommodating users with disabilities and/or learning impairment is not a new endeavor for libraries,” the report explains. “However, the evolving landscape of content digitization and the shifting nature of the scholarly communication ecosystem present new challenges for libraries attempting to adhere to institutional policies and meet legal requirements regarding online accessibility for those users.”

Thirty-eight percent of respondents had some type of policy in place for vendors, but only 14 percent described a formal accessibility policy, such as a written policy approved by relevant administrators. Almost a quarter of respondents (24 percent) said that they adhere to an informal or “rule of thumb” policy for vendors. An additional 13 percent wrote in that their institution was either currently researching or working on a policy, or that they expected vendors to comply with recognized standards, but had no policy. Thirty-nine percent simply answered “no.”

A much higher percentage of respondents said that their libraries had accessibility policies in place for content created by the institution and made available on the World Wide Web, with 28 percent having a formal policy in place, and 29 percent describing an informal policy. Fourteen percent wrote in “other” responses, with several noting that their institution had accessibility policies that did not include specific provisions for digital content. Less than one-third (29%) of respondents said that their institution had no accessibility policy in place for content creation.

Libraries that had policies in place were asked what mandates informed these policies. For both licensed content and content created at the institution, most respondents said that the Americans with Disabilities Act had been used to craft their policies, followed by the World Wide Web Consortium’s Web Content Accessibility Guidelines, Section 508 of the Rehabilitation Act of 1973, institution-wide mandates, a library’s own  internal mandate, and state laws.

Open-ended questions about who was responsible for accessibility policies, and how policies are updated, generated a variety of answers. About one third of respondents said the library was responsible for the policy, another third cited various external task forces or councils at their institution, and another third said they were unsure. Most respondents said their institution had no specific plan in place for ongoing evaluation or updating.

“The lack of cohesion regarding this question makes sense,” the report notes. “Since only 14 percent of respondents have formal policies at all, the landscape is still fairly in flux. Auditing and/or updating an accessibility policy appears to be a much lower priority than simply having a policy in the first place.”

Uncertainty about policy enforcement was expressed as well. Thirty-two respondents answered an open-ended question about how their institution ensures that vendors follow accessibility policies, and seven said they were unsure, while six said there was no enforcement protocol. By contrast, seven respondents described strict enforcement policies, such as requiring all digital content, software, and hardware to undergo an internal review before purchase. Six respondents said their staff made sure that licensing agreements signed by their library include commitments to accessibility, and vendors are then responsible for keeping those promises. And the remaining six described informal, case-by-case enforcement. Voluntary Product Accessibility Template was the most cited documentation required from vendors, followed by accessibility language within the content license, or an accessibility statement.

In the report’s conclusion, Rosen and Grogg note that “Policies, whether formal or informal, are clearly in place, but uncertainty remains, particularly regarding responsibilities for auditing and enforcing such policies. Most respondents indicated that content or systems must conform immediately to any policies, yet mechanisms and personnel charged with compliance are distributed internally and externally and are not standardized…. Accessibility as a concept is very straightforward; the successful implementation of accessibility mandates is much less so. Libraries are moving forward without a map, in part due to legal imperatives or parent organization pressures to do so, which tells us there is an urgent need for greater collaboration amongst the community.”

The full 42-page report includes separate sections on accessibility and content acquisition, content creation, and systems, as well as information about policy implementation timelines, staff training, accessibility mandates for open source software, a detailed breakdown of the types of content respondents are creating at their institutions, and much more. It can be downloaded for free here, along with Excel and CSV files of the raw response data.