Three Worrying Misconceptions About DOT-Mandated User Testing

May 17, 2016

By: Josef Pevsner, Business Development Executive


In late 2013, The US Department of Transportation (DOT) amended the Air Carrier Access Act of 1973 to include a section guaranteeing access for persons with disabilities to carrier websites and on-site kiosks. The amendment gave all air carriers - that fly within, to, or from the US with a 60+ person capacity plane, and market that travel to the public via their primary website – two years to plan and implement an accessibility strategy for their websites. 

One of the key pieces of the DOT’s amendment was a section making all covered carriers seek feedback directly from disabled users from four representative disability groups: visual, auditory, tactile, and cognitive.  This was meant to be completed before the original deadline for Phase 1 of the amendment, December 12th, 2015.

By the original effective date for Phase 1 of the amendment, many carriers had not yet completed the mandated provision, and amidst the confusion, the DOT extended the Phase 1 deadline by 6 months, to June 30th, 2016.  As a result, the testing requirement has also been moved to the new date.  Now, with less than 60 days until the deadline (which is firm), many carriers have moved to make their websites accessible, but many have yet to effectively seek and analyze feedback from disabled users.

Based on conversations with many carrier representatives over the last 11 months, it seems clear that there are three primary misconceptions that have caused carriers to slip on the requirements for testing.  These are:

1. “We only need to conduct one round of testing”

Many carriers believe that they only have to collect feedback for their sites once, either after Phase 1, when the 7 core flows have been made accessible, or after Phase 2, when the full site has been made accessible.  Carriers have to collect this feedback twice at least: once for Phase 1, and once for Phase 2. 

2. “We only have to collect feedback from blind users”

Many carriers believe that because the accessibility changes they have to implement are largely to accommodate persons with visual disabilities, they only need feedback from those individuals.  In fact, the carriers need to collect feedback from all four representative disabled user groups.   

3. “It would be an undue burden to make further changes based on feedback after our redesign”

Some carriers believe that after they collect the necessary feedback, they have to make changes to everything newly addressed on their site, and they choose not to elicit feedback as a result.  The fact is, carriers don’t need to make those additional changes, but they still should. According to sources close to the mandate, “While the consultation requirement does not mandate that carriers modify their Web sites using all the feedback obtained from the consultations, we encourage carriers to make any changes necessary to ensure access by people with these functional limitations to the extent that such changes are not unduly burdensome to implement.”

 

If your organization needs support to meet the User Testing requirements as described by the DOT, please email accessibility@usablenet.com. We can help!

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