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Section 508 Reference Guide E-Learning and Multimedia


While there is not a Section 508 category on e-Learning, it is still a critical area for both Section 508 compliance awareness and planning accessibility.

E-Learning (also known as online training, distributed learning, CBT, and multimedia courses) has seen tremendous growth over the past decade for many reasons including security, travel expenses, and the need to provide consistent training to associates that are sometimes located in multiple locations.

Faced with tighter budgets, government agencies have turned to online training to cut costs, which makes e-Learning an increasingly essential component of many professional development programs.

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The Internet has brought learning "online" and offers many advantages. It is convenient, available at any time of the day, and can be accessed nearly anywhere in the world. E-Learning offers tremendous potential to increase the availability and convenience of education. When e-Learning is made accessible and Section 508 compliant, it enables employees with disabilities to receive equivalent access to training materials used by their peers.

As with many types of products and technologies, including those used in e-Learning, people with disabilities may inadvertently be excluded if accessibility is not considered and incorporated into products and technologies. However, accessibility is not only of concern to those with disabilities. The potential for e-Learning expands when developers embrace the widest possible range of individual learning styles, preferences, and abilities.

Today, online content is varied and can include: text on a website, digital audio, digital video, animated images, and virtual reality environments. This content can be created in a variety of ways by utilizing a variety of authoring tools.

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EIT educational materials are delivered in many forms: audio, videotape, CD, DVD, broadcast TV, and over the Internet. Online education has become the preferred means of retrieving up-to-date information. With its advantages of speed and flexibility, online learning makes use of a variety of technologies to facilitate learning and interaction between participants. Online education technologies include:

  • Synchronous and asynchronous communication and collaboration tools such as e-mail, listservs, bulletin boards, whiteboards, chat rooms, videoconferencing, and teleconferencing
  • Interactive environments, such as simulations, immersive experiences, and games
  • Testing and evaluation tools, including self-assessment and multiple-choice testing


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Remember that…

  • E-Learning products consist primarily of software, web-based information and applications, and multimedia productions. Therefore, these standards will often apply. Determine which categories apply to your environment.
  • Based on your analysis from the previous point, follow the "Determining Compliance" sections for the appropriate standards.
  • Further discussion on designing applications for the disabled is located in Appendix B of this guide.


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Each technical section includes sources for additional information on that category. Below are other general information sources.


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Equivalent Access vs. Alternative Access

When considering accessibility of learning applications, it is important to understand the differences between two types of access: equivalent and alternative.


  • Equivalent access: Provides disabled users with content identical to that used by a non-disabled user. For the disabled user, however, that content is presented using a different modality (e.g., providing a course textbook in Braille format, on audiotape, or in digital format).
  • Alternative access: Provides a disabled user with a learning activity that differs from the activity used by non-disabled users. However, the alternative activity is designed to achieve the same learning objectives (e.g., a mobility-impaired student might be given the option of conducting a science experiment in a virtual laboratory, where the levels of dexterity, strength, and physical access are different from those required in a physical laboratory).

Note: Equivalent access should be provided whenever possible. Alternative access should be provided only if equivalent access is not possible.

Determining Compliance


Examples of equivalent access on webpages:

  • If an image or graphic is used as decoration, all that is necessary is a null description. E.g., <IMG SRC="spacer.bmp" ALT="">
  • When an image or graphic is important to the content, be sure to describe the purpose of the graphic, not necessarily a description of the image or graphic. E.g., if the image were a stick figure holding a pointer, you would use alternative text "trainer", rather than describing the stick figure holding a pointer.


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Customization Based on User Preference

Allowing users to customize elements of e-Learning environments is essential for accessibility. Hard-coding presentation elements such as fonts may make access impossible for some users. When applications present information in a versatile manner, the content becomes more accessible and reaches a wider variety of users.

Customizable display elements include:

  • Font, font style, font color, and font size
  • Cursor size, style, and blink rate
  • Size of text and images, including video
  • Screen layout, colors, and backgrounds

Customizable interface features include:

  • Timing of events
  • Keyboard settings

Depending on users' abilities and preferences, they may seek to change settings for presentation style, size, or timing. For example, a user with low-vision may want to change the style of a font and enlarge the size of text. The user should also be able to change other application features, such as the timing of events. For example, dialog boxes and alerts should remain on the screen until the user closes them.

Programmed activities that require several actions to be performed within a fixed time limit can create problems for a user whose AT provides a less efficient way (compared to non-disabled users) of interacting with the software. Those timing requirements should be customizable by the user.

Determining Compliance


The programmer locks down the fonts and blocks the user preferences by hard-coding these elements. In this case, the user would not be able to enlarge the fonts and the application would be inaccessible to individuals with visual impairments who do not have AT.

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Equivalent Access to Auditory and Visual Content

Under standards 1194.24(c) and (d), training and informational video or multimedia productions that contain speech or other audio information must contain open captions or closed captions. All training and informational video and multimedia productions shall contain audio descriptions.

To be fully accessible to deaf or hearing-impaired users, productions should provide equivalent access to all auditory information and content. To make products that are accessible to those with hearing impairments, developers can:

  • Caption all auditory content.
  • Provide a text transcription of auditory content.

For blind or visually impaired users, productions should provide equivalent access to all visual aspects of learning technologies and content. Specifically, developers should:

  • Add text descriptions (e.g., ALT text) to all images (e.g., pictures, logos, charts) so that a screen reader or Braille display can output the text.
  • Provide audio description tracks for multimedia, describing visual aspects of the content.

For users who are deaf, hearing-impaired, blind, visually impaired, or deaf-blind, productions should combine equivalent access, as detailed above, for all auditory and visual aspects of learning technologies and content. In particular, deaf-blind users need text equivalents for all audio and visual material.

  • Provide compatibility with AT (e.g., screen readers, screen magnifiers, adaptive keyboards, voice recognition software, single switches).
  • Developers should provide complete keyboard access to all elements of an application and its content, including menus, help directories, toolbars, dialog boxes, and presentations.

Applications that implement these features will help disabled users work more efficiently. In addition, these features benefit all users by increasing usability and minimizing the learning curve. Adhering to a consistent design between pages makes information generally easier to find for all users.

Determining Compliance

Inspect e-Learning productions and ensure:

  • Each training and informational video or multimedia production is in support of the agency's mission.
  • The captions in each production accurately capture spoken narrative and other sounds.
  • In each non-narrative segment (e.g., a picture of a building or a group of people), there are audio references to the reason or importance for the scene.
  • Multimedia productions in software applications or web-based applications (e.g., PowerPoint or Flash) meet the applicable standards.


  • This requirement specifically applies to video and multimedia productions. Audio-only productions are not subject to the requirements of this provision. Typically, captions are used for audio that is presented with visual information.
  • The Media Access Group at WGBH publishes a series of consumer guides to issues related to media access. MAG Guide Volume 3 offers guidance to the somewhat complex mandates governing the provision and availability of closed captions and audio descriptions on television.
  • Satisfying this requirement does not involve interoperability with AT. Open or closed captions are built into the video and multimedia training productions.


For examples of text equivalents of images in a web application, see standard 1194.22(a).

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Guidelines for Accessible Delivery of Presentations

Under standard 1194.24(e), presentation of alternate text or audio descriptions shall be user-selectable unless the alternate text or audio descriptions are a permanent part of the production (e.g., open captions).

Determining Compliance

Inspect the user manual or consult the manufacturer for captions and descriptive audio track support. Note whether manuals have instructions on how to activate these features.

  • As a guide, acquire a sample video/multimedia production that has alternate text and captions. Attempt to play it in the product.
  • If controls for alternate text or audio description are available, view the production for captions:
    • If the presentation or production has open captions, this is not a problem since open captions are permanent.
    • If it has closed captions, determine if the caption display is user selectable (e.g., by pressing the CC button on a remote).
  • View the sample production for audio descriptions. If audio descriptions are available, a user should be able to activate or deactivate each choice. Descriptions might be provided in different languages or voices.


  • The phrase 'unless permanent' was appended to this provision with the intended meaning 'unless a permanent part of the production.' In the case that alternate text or audio description is a permanent part of the multimedia production, display or presentation of this information will not be user selectable, regardless of whether the EIT equipment provides user controls for their presentation.
  • DVD content and menus should be designed to turn the audio description on and off with accessibility in mind. This is often not the case today; currently most audio description requires vision to turn it on/off.
  • Satisfying this requirement does not involve interoperability with AT. Open or closed captions and audio descriptions are built in to the video and multimedia productions.
  • Every person learns differently. At its best, online learning allows users to interact with lesson material in their preferred way, relying on their individual strengths while discounting as much as possible their weaknesses.
  • The principles of excellent software design call on developers to work in full knowledge of the range of human skills and limitations. Software designers of teaching materials and activities, in particular, should strive to achieve this high standard.
  • When a user has a disability, access to learning software may depend entirely on how that product can deliver its content. Some users may need only to access features in media that is presented; other users may require entirely different media. Developers who achieve the kind of flexibility that diversity requires will enhance the accessibility of their product.
  • At a minimum, developers should provide text equivalents for all media types. This suggested baseline would help address access for many users.
  • It is important to note that users with learning disabilities can benefit from graphical presentations. Therefore, the practice of providing text-only content as an alternative to inaccessible multimedia content may not be an effective solution for users with cognitive disabilities.


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Guidelines for Accessible Delivery of Text

When text is correctly structured and formatted in e-Learning products, it can be the most flexible way to present content. To make distributed online learning accessible, developers of learning platforms must provide a means to render digital text in alternative formats. Specifically, it should be possible to render text as:

  • Visual information. Text can be displayed on computer screens or other electronic devices (e.g., PDAs, cell phones, e-book readers).
  • Audio information. Text can be translated into speech using recordings or via synthesized speech provided by a computer.
  • Tactile information. Text can be displayed on refreshable Braille displays or printed using a Braille embosser.

Common text accessibility problems include:

  • Hard-coded fonts that prevent users from changing style, size, or color
  • Text presented with background images or poor contrast colors that hinder readability
  • Text presented in an image format that screen readers and Braille displays cannot access
  • Multi-column formats (including some tables) that screen readers cannot process in the correct order

Learning system developers may enhance the accessibility of text for all users by following these practices:

  • Offer features that allow the user to customize fonts and backgrounds.
  • Allow AT designers to have access to an API or the source code.
  • Use validated HTML for dynamic content.

Content creators or educators may enhance the accessibility of text for all users by following these practices:

  • Choose text formats that offer the most accessibility (e.g., HTML, plain text).
  • Use true text and not graphical representations of text.
  • Structure the text appropriately, identifying headings and other structural elements (e.g., using HTML's header tags, such as <H1>).
  • Use styles or style sheets to enhance a flexible display. However, standard 1194.22(d) stipulates that web applications and information must be readable without style sheets, so do not make e-Learning environments dependent.

Determining Compliance


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Guidelines for Accessible Delivery of Audio

Audio elements can add to the general effectiveness of online learning materials while making them more accessible to those who are print-impaired learners (e.g., visually impaired or dyslexic). However, developers should provide alternatives to ensure that learners who are deaf or hard-of-hearing are not disadvantaged.

Common audio accessibility problems include:

  • Lack of captions and/or transcripts
  • Poor sound quality
  • Inability to control volume

Learning system developers may enhance the accessibility of audio for all users by following these practices:

  • Provide a means to include captions and/or transcripts, if no captions or transcripts are included in the original product.
  • Provide volume controls to raise sound above the default level.
  • Provide visual equivalents to audio alerts (e.g., show a text alert on the screen whenever an error beep is played).

Content creators or educators may enhance the accessibility of audio for all users by following these practices:

  • Provide transcripts and captions for all essential audio.
  • Consider providing other forms such as ASL or captions with images.

Determining Compliance


Here is an example of a text transcript from a production:

[phone rings]
Person 1: Please answer the phone.
[phone rings] [phone rings] [phone rings]
Person 2: You get it. I don't want to talk to anyone.
[answering machine picks up in the background]

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Guidelines for Accessible Delivery of Images

Images can provide essential information. But without text support, images are not accessible for users who are blind or have low-vision. Developers must provide users with a way to access visual information. Providing text identification, or alternative text, will also benefit users of text-only browsers, such as mobile phones. Developers should ensure that images are scalable so that users can enlarge them for better clarity.

Common image accessibility problems include:

  • Failure to provide alternate text
  • Poor image resolution that restricts the ability of low-vision users to enlarge images

Learning system developers may enhance the accessibility of images for all users by following these practices:

  • Provide a means to include equivalent text alternatives of images.
  • Provide a zoom feature.

Content creators or educators may enhance the accessibility of images for all users by following these practices:

  • Provide text alternatives for images.
  • Use the highest practical resolution for bitmap graphics (e.g., photographs) when use of vector graphics is not possible. Vector images scale and do not lose resolution whereas bitmap images do.

Determining Compliance


For examples of text equivalents of images in a web application, see standard 1194.22(a).

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Guidelines for Accessible Delivery of Multimedia

Multimedia is the combination of text, graphics, video, animation, and/or sound. Thus, a given piece of multimedia content combines the access needs of each media type represented. Multimedia can be useful for many groups of learners, since a multi-modal presentation of information can be easier to understand. In general, users benefit when alternatives are available for each media type.

Common multimedia accessibility problems include:

Learning system developers may enhance the accessibility of multimedia for all users by providing accessibility features within the multimedia format provided by the application, including captions, transcripts, or audio descriptions.

Content creators or educators may enhance the accessibility of multimedia for all users by following these practices:

  • Comply with all relevant suggestions for enhancing accessibility for text, audio, and images, since multimedia can combine all of these elements.
  • Provide audio descriptions of essential visual elements for video content.
  • Consider the importance of the timing of media delivery.

In addition to the guidelines above, it is good practice to adhere to the following:

  • Never blur pictures to indicate unavailability. If a graphic is used, always choose crisp and clear images.
  • When graphics contain useful information, provide information in text.
  • Always refer users to alternative ways to obtain information contained in graphics.
  • Do not shrink a picture of an actual page and use it as a graphic or button on another page.
  • Avoid creating a text-only version of your website.

For example, a "talking head" video may need only a stand-alone transcript of the audio, but a documentary including graphics and other important visuals may require captions in order to maintain the link between visuals and narration.

Determining Compliance


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Guidelines for Accessible Interface Navigation

Many users of AT encounter difficulty trying to use features normally accessed only by a mouse. Making the interface or e-Learning course overly mouse dependant will surely cause difficulties for AT users, especially when navigating through content and other elements such as menu bars, tables of contents, and frames.

Common interface navigation accessibility problems include:

  • Indexing or navigation systems that use complex frames where the title and name attributes are absent.
  • Tables of contents with expand/collapse features (e.g., blue triangles, plus-minus signs) that lack text labels.
  • Menu bars built using scripting languages that AT cannot understand (e.g., proprietary user interface element design that is not accessible).

Learning system developers may enhance the accessibility of interface navigation for all users by following these practices:

  • Provide names, titles, or associated text labels for each element of the interface.
  • Ensure that keyboard users can access all parts of the interface. Clearly document all appropriate keystrokes.

E-Learning environments with multimedia productions are more usable when developers provide context and orientation information to users. Products should be designed to:

  • Teach users how to navigate.
  • Inform the user of the length of each document. For example, page numbers can be expressed as "page X of Y pages".
  • Provide a way for users to skip standard page headers and navigation links. Users who are already familiar with the page layout should be able to skip directly to the primary content.
  • Use consistent page design. Content becomes more accessible when users can depend on consistency of layout, presentation and navigation.
  • Provide a text warning/alert whenever a new browser window will open automatically.
  • Choose a simple informative web address for your site and keep the URL in the address field after the page has loaded.
  • Minimize the need for scrolling.

Determining Compliance


For web-based applications:

  • Regarding titles for frames, see standard 1194.22(i).
  • Regarding labels for fields in an electronic form, see standard 1194.22(n).
  • Regarding "skip navigation" links, see standard 1194.22(o).


Major portions of this page were reproduced with the permission of IMS Global Learning Consortium. "IMS Guidelines for Developing Accessible Learning Applications, Version 0.6 White Paper", copyright 2004 by IMS Global Learning Consortium, Inc. Exceptions are some of the Introduction and Overview, Determining Compliance, and Example sections.

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Questions to Improve Understanding

1. When determining Section 508 compliance for e-Learning, one of the first things you must determine is what type of course it is: web-based, software, multi-media based, or a combination of these.

  1. True
  2. False


Answer 1.

2. What categories of the Section 508 standards may apply to e-Learning?

  1. Software standards
  2. Web standards
  3. Multi-media standards
  4. All of the above


Answer 2.

3. Highly interactive and engaging web-based e-Learning may fail to meet all of the applicable Section 508 standards.

  1. True
  2. False


Answer 3.

4. There is a conflict between robust, interactive web-based training courses and conformance with the Section 508 standards.

  1. True
  2. False


Answer 4.

5. Which e-Learning components must be Section 508 compliant?

  1. Help and installation portions
  2. Learning Management System (LMS)
  3. Content
  4. All of the above


Answer 5.

6. It is possible to launch an e-Learning training course using which means?

  1. Learning Management System (LMS)
  2. Internet
  3. Intranet
  4. CD or DVD
  5. All of the above


Answer 6.

7. All videos must be captioned for deaf and hard-of-hearing viewers.

  1. True
  2. False


Answer 7.

8. Is it okay to include a time-out option in tests?

  1. Yes
  2. No


Answer 8.

9. Which is a good Internet site to find many free training courses on Section 508 compliance?



Answer 9.

10. When is the best time to consider Section 508 compliance?

  1. After the course is completed.
  2. In the planning and development stage, before the course has been designed, even before the "storyboard" phase.
  3. At the second major development milestone.
  4. At the programming stage.


Answer 10.

Answer Key

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Last Modified: 02/05/2015 17:06:57