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Presentation to University of NSW

Disability Disability Rights

Presentation to University of NSW DDA Standards Briefing

December 1, 2005

Bruce Maguire
Policy Officer, HREOC

Good afternoon to you all. I begin by acknowledging the traditional owners of the land on which we're meeting today.

To set the scene for my presentation this afternoon, I want to share two autobiographical fragments with you, both of them having to do with my experience at university.

In 1974, when I was in my final year at high school, I decided that I wanted to study mathematics, psychology and linguistics at university. This was a source of much consternation to my various vocational counsellors and careers advisors, who had concluded with a unanimity that brooked no dissent, that I would study law. Which, as everyone knows, is what blind people study. But I was Irish and stubborn, and so I arranged to have interviews with the various professors in the subjects I was interested in. The mathematics discussion went well, as did linguistics, and so it came time for me to see the professor of psychology. He began by asking me if I dreamt in colour, and whether I fell down stairs. He then explained that, as everyone knows, blind people don't study psychology - they study philosophy. This is because they can't participate in the practical components of the course. I wasn't entirely convinced, but when you're 16 you think that professors know a lot, so I hastily arranged an interview with the head of the philosophy school. He rode a motorbike, drank my favourite brand of beer, and assured me that there are no practical components in philosophy, so I enrolled in that, along with the maths and linguistics, and a bit of education for good measure.

Back then there were few students with disabilities at the university, and there were certainly no established concepts or guidelines to assist us. Reasonable accommodation referred to the college dormitories, and unjustifiable hardship was how we described the early closing times of the Union bar. I remember having some robust discussions with one particular lecturer about the need for extra time during an exam. He would not allow extra time. On the other hand, the philosophy lecturer said I could have as much extra time as I needed, and did I want him to bring me lunch and afternoon tea, but if I hadn't finished by 5pm then perhaps I should give it away and study psychology. In other words, there were no guidelines, no best practice models, and one's success as a student with a disability depended very much on one's negotiating skills and the attitude of individual staff.

Fast forward to 2002: same person, same university, different era (but still no technicolour dreams). I was finishing another degree and thanks to computers, I could now browse library catalogues, do online searches, and for the first time in my life enjoy some of the independence that sighted students take for granted in pursuing interests and research topics. But when I tried to use the resources in electronic reserve, I found that many of the articles had been poorly copied and scanned, so not even the latest software could make sense of them. The problem here wasn't technological, it was rather that there were no accessibility guidelines that library staff could use when preparing electronic resources.

The past 30 years have certainly seen many developments in the disability field. The social model of disability has replaced the biomedical one, and now disability is seen as a complex construction born out of the interaction between society and individual. Notions of access, equity, and reasonable adjustment are mature and accepted. Disability discrimination legislation has been enacted to help address the disadvantage that people with disabilities face every day in almost every aspect of life. Technology has brought tremendous opportunities for many people with disabilities. But, at the same time, the importance of having guidelines that reflect collective expectations has, if anything, increased. The possibilities for customising the university environment to meet the needs of individual students with disabilities are almost endless. But I'm reminded of one of those enigmatic Zen aphorisms: "I'm open to all possibilities, but not all possibilities are open to me". And, we might add, not all possibilities are equally enriching, and not all possibilities reflect our society's and government's view that students with disabilities have the right to expect equality in learning experiences and options. Perhaps one of the most significant changes over the past 30 years is that people with disabilities now expect to be regarded as in every way part of society. Disability is not a segregated backwater, but part of the vibrant mainstream. This leads to an emphasis on the development of inclusive strategies and practices. Both the AVCC guidelines and the DDA Education Standards need to be studied and applied with these principles of inclusion and equal participation firmly in mind.

Early in 2002, the Human Rights and EquaL Opportunity Commission was asked by Blind Citizens Australia (BCA) and students themselves to investigate why there was a growing number of informal and formal complaints relating to access to curricular materials at the university level, and to develop strategies for improving the situation. We felt that the most effective way forward was to convene a forum that all Australian universities would be invited to attend, to initiate the development of strategies for providing curricular materials in accessible formats in a cost-effective, efficient, and needs-appropriate way.

The forum was held on May 29 2002; approximately 90 people participated, representing 35 of Australia's 39 universities, university librarians, government departments, publishers, and students. Prior to the forum, on May 28, a session was held to clarify and discuss copyright legislation and regimes as they impact on students with a print disability. Most participants in the forum also attended this session on copyright. In organising the forum, the Commission received strong support from the Australian Vice-Chancellors' Committee, and I want to acknowledge their contribution to the forum itself and also to the work that has taken place as a result - in particular, the development of the guidelines.

The forum included the presentation of a number of "perspective papers" that examined relevant issues from a variety of standpoints, including student, academic, disability support staff, and government. These papers are on the HREOC website, along with other background material, including the discussion paper that the Commission wrote to provide an overview of the issues to be raised during the forum. Anyone unfamiliar with the issues would probably find it useful to begin by reading this discussion paper, and then move on to the perspective papers and other materials. Even though three years have gone by since the forum, many of the issues are still topical and the background is useful in gaining an understanding of the current context.

Shortly after the forum, the Commission held discussions with AVCC to decide how best to go about the task of implementing the various recommendations that were developed at the forum. We decided to establish a Steering Committee on Accessible Curricular Materials for Universities. This Committee established several working groups to look at specific areas, such as production and copyright, and it was one of these working groups that was responsible for writing the Guidelines on Information Access for Students with Print Disabilities. The guidelines were endorsed and released by the aVCC in November 2004 following extensive consultation with all stakeholders, including the higher education sector. The guidelines provide universities with a useful and flexible framework for ensuring that students with a print disability can access curricular materials to the fullest extent possible.

Before I discuss the specific aspects of the Guidelines, I want to offer a few general comments.

Firstly, I'll try and answer a question that I'm often asked: why do information access issues need their own set of guidelines? Or, putting it in a slightly different way: what is it about information access that makes the issues so challenging to conceptualise and deal with?

A couple of years ago I enrolled in the program of study that I'm currently undertaking. I filled in the online form, and ticked the box that I have a vision disability. I learned that I would be sent a form asking for some more specific information about what my needs might be. I telephoned the admissions centre to ask whether the form would be sent in braille, since I can't read print. "No," was the answer. "can't you get a friend to fill in the form for you?" I pointed out that I'm a policy advisor, and therefore don't have friends. Here was a catch-22 situation: they wanted to know what formats I wanted for my study materials, but the only way of telling them was to complete a form that, because I can't read print, I couldn't complete.

When computers were first being widely introduced about 25 years ago, the information prophets told us that we were about to witness the advent of the paperless office. Like most prophets, they were wrong, and we seem to be using more printed paper now than ever before. Having a print disability affects almost every aspect of life in a "print-centric" society like ours, and providing viable alternatives requires careful planning and attention to detail.

Large bureaucracies often find it difficult to respond to individual needs that may themselves vary over time and across contexts: macro-responses are often easier to deliver than nuances. Yet, it is precisely this nuanced approach that is necessary when addressing the needs of students who have a print disability. For example, a person with a vision impairment may be able to use large print, but only if it is produced using a particular font and on a paper of a particular colour; they may only be able to read it for short periods of time without causing eye fatigue and severe headaches, and they may not be able to see writing on the blackboard in a classroom situation. Such a person will need a variety of formats depending on the particular subject and the location and context in which the material is being used. We can't simply say, as has certainly been said in the past, "this person needs large-print, so we'll only provide large print". Meeting the information access needs of students with a print disability requires approaches and strategies that are as dynamic as the information environment itself.

I can't remember the last day when I didn't have cause to reflect on Arthur C Clark's famous observation that any smoothly-functioning technology is indistinguishable from magic. Information access is very much linked with technology, and developing an understanding of the complexities and vagaries of this technology can be difficult: there are screen readers and screen magnifiers; refreshable braille displays and portable notetaking devices; some document formats are accessible, some aren't, and some are provided they have been prepared in accordance with certain procedures. I recall the experience of a blind student friend of mine who was sent a CD containing all the course outlines and readings, but no-one had consulted with him to see if he had the technology to access it (needless to say, he didn't, so the CD was to all intents and purposes completely useless to him). Having guidelines in this area can help avoid situations such as this and make service provision much easier and more effective.

The AVCC Guidelines, then, are a response to a challenging but extremely important aspect of service provision by universities as they assist students with a print disability. They are not a replacement for the DDA Education Standards, but, rather, they complement them. They do not have the legal status of the DDA Standards, but they do reflect the collective views of the sector and students with disabilities about what constitutes good practice. Our view is that universities that implement these guidelines will significantly reduce the risk of a DDA complaint in the area of information access and, more importantly, they will maximize the opportunities for students with a print disability to benefit from the richness and diversity of university life.

The Guidelines, then, are not a prescriptive or exhaustive list, but are an indicative tool that universities can use as they provide support for the increasing number of students who require curricular material in alternative formats to print. The most common alternative (or accessible) formats are braille, large print, electronic, and audio. The boundaries between formats that were traditionally regarded as separate are rapidly blurring: refreshable braille displays allow braille to be displayed electronically; new standards allow structured navigation of audio documents, and so on. But the general principles remain the same.

The Guidelines are applicable to 7 areas:

  • Provision of student assistance (administrative and academic aspects of student participation);
  • Teaching materials;
  • Internet access;
  • Encouraging inclusivity;
  • Equipment and technology;
  • Practical classes and practicum placement;
  • Policy implementation.

There are 4 general principles identified by the Guidelines as underlying effective service provision across these areas:

1. Universities should aim to provide students with print disabilities with the opportunity to realise their individual capabilities and to gain access to and participate in University life, taking into account their obligations under anti-discrimination legislation to provide reasonable accommodations. It cannot be assumed that because something is hard, it is therefore unreasonable.

2. Universities should ensure that all their interactions with students with print disabilities are characterised by respect of their rights to dignity, privacy, confidentiality and substantive equality.

3. Universities should seek to provide support services to students with print disabilities in the interests of equality of educational opportunity. Services may include alternative ways of accessing information and expressing knowledge and general support services. Universities would normally require students to obtain an expert assessment of the functional implications of their disability on their academic access, so that appropriate support provisions can be negotiated.

4. Universities should give attention to the resources needed to provide the appropriate environment and support services to students with print disabilities. Universities are encouraged to pursue cooperative links with other educational institutions in their region and with community service providers in order to enhance access to highly specialised and expensive services.

Each of the seven areas is discussed in detail. Each specific guideline is illustrated by examples of good practice. I don't have time this afternoon to analyse each guideline and example, but I will select a number that seem particularly important, and about which I'm often asked for comment.

Guideline 3.2 reads as follows:

"The University has guidelines for the provision of administrative information in an accessible format: general university information, enrolment information, email procedures, timetables, academic calendar, faculty course descriptions and handbooks. (This information is also available to Student Union staff and student organisations)."

An example of good practice is given as:

"Any University websites identified as inaccessible by a student or staff member are made accessible according to identified priorities and in compliance with the World-Wide Web Consortium Guidelines on Web Accessibility. (W3C). Where this is not possible, alternative formats are provided.

One of the trends we've observed over the past couple of years is that universities are moving away from the provision of information such as handbooks in hardcopy form to a reliance on the website. Of course, this can benefit students with a print disability, but these benefits do not flow automatically. In particular, the exclusive use of pdf as a format for the delivery of information is making it difficult or impossible for many students with a print disability to access it. While pdf is not specifically mentioned in the AVCC guidelines, I thought it would be useful to spend a couple of minutes discussing it, because it's one of the areas I'm most often asked about, and it's probably one of the most confusing.

Adobe's Portable Document Format (PDF) has become widely used for making documents available on web pages. Despite considerable work done by Adobe, PDF remains a relatively inaccessible format to people who are blind or vision-impaired. Software does exist to provide some access to the text of some PDF documents, but for a PDF document to be accessible to this software, it must be prepared in accordance with the guidelines that Adobe have developed. Even when these guidelines are scrupulously followed), the resulting document will only be accessible to those people who have the required software and the skills to use it. Many blind or vision-impaired people do not have the financial freedom to spend the $1,000+ typically required to upgrade their screen-reader software to take advantage of the latest accessibility features. Requiring a user to upgrade to this extent in order to read a standard document is like designing web content presentation in such a way that most people will have to buy a new computer in order to read it. in any case, some of the PDAs used by blind people have no facilities for accessing PDF files.

We feel that it is most regrettable that some very basic information such as university handbooks, course guides and graduation information is being published only in PDF format, because what this means is that prospective and current students are being denied access to resources that other students take for granted. In our view, universities who rely on PDF without providing accessible alternatives are liable for complaint under the DDA - in fact, some complaints have already been made, and it is likely that the number will increase unless universities take steps to bring their information content management strategies into line with the objects of the DDA.

I thought you might like a first-hand experience of the problems that can arise when trying to access a pdf file. The school that my son attends produces a weekly parent bulletin that it distributes electronically as a pdf file. Recently, they announced a sale of second-hand textbooks. Here's what I read when I tried to read this part of the pdf file with my screen-reading software (please pay attention because there'll be a quiz at the end):

"The Second Hand Book Sale Day will be held on Saturday 26th November from 11:00 am until 2:00 pm in rooms adjacent to the College Shop. In the column to the right are the books that can be bought and sold. The figures after the books will be the maximum Buy/Sell prices that the College Shop will apply. Please note that the Sell price includes a GST component. Carol Service Rehearsals

. Combined Choir

Sun 20th 1:30 - 4:30 pm The Space

. All participants


King Of Shadows The Honey Spot Boy

Connections Maths 7 inc CD-Rom

Year 8

Goodnight Mister Tom


Two Weeks with the Queen


Connections Maths 8

inc CD-Rom

Core Science 1 2nd Edition Core Science 2 2nd Edition Geography for Global

Citizens - 2nd Edition Artwise 1 2nd Edition (to be kept by continuing Art Students) Technology By Design- Stage 4 Retroactive 1 - 2nd Edition

Year 9

Of Mice and Men Red Scarf Girl Merchant of Venice Connections Maths 9 (5.2/5.1)

Year 10


$3.50 $3.50 $3.50





$5.00 $5.00 $5.00

















$15.00 $21.00

$11.50 $16.00

$15.00 $21.00

$5.00 $7.50

OK, here are the comprehension questions:

  • What's the maximum price the school will pay for Of Mice and Men?
  • What's the selling price of The Honey Spot
  • Would I be able to sell my copy of King of Shadows if I wanted $12 for it?

The print version of this section was neatly laid out in a table with rows and columns, but because no structural or navigation tags had been included, the screen-reading software could not make much sense of the layout. And, in case you're wondering why I suddenly started reading about the Carol service, this was in a textbox, but the column boundaries had not been defined, so the screen-reading software assumed it was part of the book list.

We do need to recognise, however, that not all content can be made accessible online to people who are blind or vision-impaired.

This is particularly the case with pictorial material such as maps, graphs and 3-D drawings as well as symbolic content such as mathematics and chemistry. If you need to make such content available, especially if it is a component of a course, then you'll want to develop strategies for making it accessible, for example, by using qualified contractors to produce tactual maps and diagrams on request.

I also know that at least some universities make extensive use of PDF files to provide online reading materials, typically by scanning pages from books or journals, saving the images as PDFs, and putting them on the website. From an accessibility perspective, this isn't ideal, and we would encourage course developers to look for alternatives. Nonetheless, such readings can be made much more accessible if the scanning is done with care (for example, the ends of lines are not chopped off) and students are provided with suitable software to convert the images. These points are actually covered in the AVCC Guideline 4.3.

Section 7 of the Guidelines deals with the provision of adaptive equipment and technology. Guideline 7.1 reads:

"The university provides appropriate adaptive equipment and software for students with print disabilities."

This guideline reflects the reality that much of this equipment and software is very expensive, and often beyond the capacity of individuals to purchase. For example, a typical refreshable braille display is $10,000, and even the basic software needed by blind or vision-impaired students to read the computer screen costs about $1,500. These costs are in addition to the cost of purchasing a standard computer. From talking with many students over the past few years, I have formed the view that a significant number arrive at university without the necessary technology that they will need. This guideline is therefore important, and is supported by several examples of good practice, one of which is:

"The university has committed funds to purchase equipment which is generally considered to be beyond the reach of individual students. For example, high-quality scanners, braille printers, speech synthesiser ."

I would add one important note, however. I have heard of cases where students have been provided with equipment, and then expected to use it to do all their own production of curricular materials. This would be like expecting a student without a print disability to collate and print their own reading packs. The provision of adaptive technology is not a substitute for the provision of appropriate curricular materials in formats that meet the needs of students.

One of the complaints I hear most often from students with a print disabilities is that they do not receive materials on time. Several students have told me recently about how they have only received the braille textbook a week before their final exams. Other students tell me of the constant stress and anxiety they experience because they are always behind with assignments as a result of not having the readings on time. For them, university is a battle not a benefit. For this reason, Guideline 4.2 is one of the most important in the set:

"The university has clear timelines for the production and provision of materials". A supporting example of good practice is:

"University deadlines for the receipt of reading lists allow time for alternative format materials to be prepared prior to the commencement of semester".


"Any additional materials introduced after the course has commenced are made available to the student 4 weeks prior to when the material is to be taught".

The guidelines recognise that sometimes and despite best efforts, these benchmarks cannot always be met, for example, where a lecturer wants to discuss a newspaper article that has appeared the previous day. In such cases, the responsibility is on the lecturer to negotiate alternative strategies beforehand that are acceptable to the student. I remember a case from my own university career a few years ago where a lecturer distributed a newspaper article, and then selected a student and told her she had to read it to me. Unfortunately, English was far from this student's first language, and the more she struggled, the more stressed she became, and it was almost impossible to make any sense of the article. A little prior consultation would have been useful here: I could have downloaded the article from the paper's website, and read it independently at the same time as the other students. The lecturer was not aware that I could do this, which highlights the need for discussion between lecturers and individual students. I've yet to meet a student with a print disability who is inflexible and uncompromising, but I am also yet to meet one who does not want to be consulted and actively involved in decision-making about how their needs can be appropriately met.

Recalling that autobiographical vignette that I offered at the start of my presentation, I want to draw your attention to Guideline 9.1:

"The University has developed procedures which facilitate participation in the practical sessions or placements which form an integral part of many courses."

Reiterating the importance of consultation, one of the supporting good-practice examples is:

"Where a student has a pre-existing print disability, consideration as to how the student will participate in practicums/practical sessions or placements (such as in Education, Nursing or Social Work) is undertaken with the course co-ordinators prior to admission, in consultation with the student concerned."

Recently, I was reviewing some of the comments that have been made since the release of the AVCC Guidelines. One of them was:

"My guess is no-one would bother reading the guidelines except the staff who already do all the right things."

It's very encouraging to have the opportunity to participate in events such as this afternoon's briefing, because they prove that this guess is wrong and that, in fact, the AVCC Guidelines are being taken seriously. Implementation of the Guidelines is, however, the beginning of a process, not the endpoint. The Guidelines themselves anticipate in section 10, where they provide for policy reviews and audits.

The forum that the Commission organized back in 2002 provided a unique opportunity for the higher education sector and the disability community to share their expertise by initiating a process of achieving systemic change through consensus. The Guidelines on Information Access for Students with Print Disabilities are directed towards bringing about greater access through the improvement of current procedures, and by opening up mainstream channels of dialogue and consultation.

Universities are perhaps the greatest bulwark of civilisation and enlightenment that we have in these troubled and troubling times. Some of us dream in colour, some of us dream in black and white, and some us - well, just dream. When it comes to information access, the best dreams are those that become reality. I commend the AVCC Guidelines to you as a tool for bringing about that reality, and I look forward to hearing of your success in implementing them.