Website accessibility implementation plan

1. Background

1.1. About this plan

This plan describes the APVMA’s response to meeting the mandatory requirements of the Web Accessibility National Transition Strategy (AGIMO, June 2010).

This strategy sets out the web and online accessibility requirements that all FMA Act agencies must achieve by the end of 2014, in order to deliver a more accessible and useable web environment for all people within our society.

The strategy is based on a set of world-wide standards known as the Web Content Accessibility Guidelines 2.0 (or WCAG 2.0) produced by the World Wide Web Consortium (W3C). WCAG 2.0 has a number of different levels of possible conformance, the highest being triple A.

Australian Government agencies must meet a minimum double A conformance level by the end of 2014 and were expected to have achieved single A conformance by the end of 2012. As a matter of policy, the APVMA has chosen to move directly to double A conformance as part of the redevelopment of our website and intranet in 2013-14.

WCAG is the internationally recognised benchmark for website accessibility and WCAG 2.0 sets an improved level of accessibility to cater to the needs of a constantly evolving and increasingly dynamic web environment.

Related to WCAG standards are a set of standards known as WAI-ARIA (for accessible rich internet applications). While these standards are not specifically mandated by the National Transition Strategy and are still under development by W3C, it would be prudent to consider these evolving requirements when new applications and systems are being developed by the APVMA. It is technically much more difficult to ‘retro-fit’ accessibility requirements to existing systems than it is to build accessibility in from the ground up.

1.2. Requirements under the National Transition Strategy

The National Transition Strategy describes three key phases for agency implementation:

  1. Preparation (July–December 2010). During this period, agencies were expected to conduct a systematic assessment of their websites (including intranets) and website infrastructure to assess their readiness for application of the new WCAG 2.0 requirements. Key activities were to include: website stocktake; conformance check; infrastructure assessment; capability assessment; and risk assessment.
  2. Transition (January–December 2011). This period was designed for agencies to acquire the skills and foundations that would be required to underpin the implementation of WCAG 2.0 requirements. Key activities were to include: training and education; procurement review; infrastructure and capability upgrades; and progress reporting.
  3. Implementation (two target dates—December 2012 and December 2014). Implementation is expected to proceed as soon as the all enabling requirements (infrastructure, capability and training) have been completed. The key activities are to implement the requirements described in an agency implementation plan (such as this plan) and undertake suitable conformance testing.

1.3. Current status of APVMA web accessibility transition

The main APVMA corporate website and intranet have not been assessed for WCAG 2.0 conformance, because they are shortly to be replaced by new sites based on a new web content management system. This new system will be compliant and the new sites tested for WCAG2.0 double A conformance.

In the short term, the APVMA has focused on creating all new website content in accessible formats, preferring HTML publication to document downloads wherever feasible based on the content.

Where content is being developed or designed by third parties for deployment on the APVMA website, we have developed suitable contracting mechanisms (request for proposal requirements and contract deliverables specified with accessibility standards) to ensure longer-term conformance.

Our work to date has not included any formal consideration of sites owned or operated on the APVMA’s behalf by third parties. These issues will be addressed by this action plan.

1.4. The APVMA’s commitment to web accessibility

The APVMA is committed to making our online services and information accessible to as many people as possible regardless of ability. We are in the process of implementing the Australian Government’s Web Accessibility National Transition Strategy.

Over time, all our internal and external web-based sites and systems will be upgraded to conform to the WCAG 2.0 Level AA standard, or will be replaced with new systems that meet this level of WCAG conformance.

Where possible, we will also meet related accessibility standards such as WAI-ARIA for online applications.

Accessibility will be built into our procurement processes for new technologies, systems and content prepared by third parties at our request and which is destined for online publication.

2. Scope

This plan deals specifically with accessibility of content in websites and web applications of the Australian Pesticides and Veterinary Medicines Authority.

Under the National Transition Strategy a ‘government website’ is defined as one that:

  • is either fully or partly owned and/or operated by a government agency
  • is registered on a domain name, sub-domain or sub-directory
  • has a distinct look and feel (design), audience and purpose.

This definition has the effect of bringing the APVMA’s branded presence on third-party sites, including social media networks, into scope.

2.1. Websites

The current APVMA websites included in this action plan are:

2.2. Web applications

The APVMA’s external business applications are hosted through the domain and include:

  • PUBCRIS database of registered agricultural and veterinary chemicals
  • Permits database
  • Online payments system (OLAF)

A further external facing site is the recruitment site, hosted by a third party provider at

The APVMA’s internal applications (personnel and training sites) are hosted through third party providers and include:

  • APVMA employee self-service site
  • Online training portal

In 2013-14 the APVMA is developing additional online applications and systems including:

  • A registration self-assessment tool
  • A new online reporting form for adverse experiences
  • A registrants’ extranet that allows a single authentication (sign-on) to a variety of APVMA business applications and systems.

We are also redeveloping the PUBCRIS and Permits database search systems.

3. Goals and strategies

This plan has six key areas of action:

3.1. A. Management responsibilities

  1. Champion, develop and monitor action plan
    1. Responsibilities are established and documented.
    2. The implementation plan is periodically reviewed and updated.
    3. Accessibility is monitored by the APVMA’s Executive Director, Corporate Services (who has responsibility for APVMA information and technology management).

3.2. B. System/platform

The APVMA will consider accessibility in future development work.

  1. Building new web sites and web applications
    1. All new websites will conform with WCAG2.0 double A guidelines; web-based applications will also consider the applicability of the WAI-ARIA guidelines as well as WCAG2.0 conformance.
    2. Accessibility requirements are identified early in the design process.
    3. All new websites and applications are checked for accessibility as part of their development.
    4. Errors found in audits are addressed.
    5. Users of assistive technology are involved in accessibility evaluations for high profile sites and applications.
    6. External developers address and implement WCAG2.0 AA or WAI-ARIA guidelines as appropriate.
  2. Procuring new products for the online environment
    1. Procurement actions relating to websites or web applications include web accessibility criteria.

3.3. C. Content

All new or revised content will be accessible within the limitations of the particular web-based system or platform where possible. This will include a focus on text alternatives, keyboard access, readability and input assistance.

  1. Fixing accessibility problems in current web content
    1. All new content meets minimum conformance levels
    2. Limited updates to existing web content, pending migration to a new site that will set AA conformance as the overall objective.
  2. Developing content with a content management system
    1. Content management system produces accessible web content.
    2. Templates for web content conform with WCAG 2.0 AA guidelines.
    3. Templates for web content are checked for accessibility as part of their development.
  3. Maintaining accessibility of web content
    1. Accessibility level of web content is maintained.
    2. Developers and content authors produce accessible web content.
  4. Managing accessibility of web content in third party products
    1. Web-based applications are reviewed at a suitable point in the service agreement with the third party provider.
    2. Web developers understand how to implement WCAG guidelines for third-party or commercial products (eg developing the new intranet in Drupal content management system)
    3. Development of social media channels includes consideration of alternatives where necessary.

3.4. D. Documents

All new or revised documents will be provided in multiple formats where possible, with enhanced accessibility.

  1. Publishing documents online
    1. Where content is not published in HTML, documents published on the web are provided in multiple formats.
    2. All PDFs are correctly tagged.

3.5. E. Media

This includes videos, sound recordings, or other multimedia presentations.

Within each of these categories we will focus on the four principles of WCAG 2.0 (text alternatives, keyboard access, readability and input assistance).

  1. Publishing audio-visual content online
    1. Audio content is accessible to users with hearing impairments.
    2. Video content is accessible to users with hearing and visual impairments.
    3. Audio-visual content is accessible to users with other disabilities.

3.6. F. Awareness and support

  1. Raising awareness of web accessibility
    1. Staff members with web responsibilities have a thorough understanding of the importance of accessibility.
    2. Web accessibility is included in all relevant policies and procedures relating to the online environment.
    3. The APVMA web publishing guidelines are consistent with WCAG2.0
  1. Training developers and content authors
    1. Web developers are assessed for capability in developing accessible code before given access to APVMA web services.
    2. Content authors are trained in producing accessible content before given access to APVMA web sites.
    3. Content creators understand the need to develop content in line with accessibility standards.
  2. Addressing accessibility feedback, requests and complaints
    1. All web content can be used by people with disabilities.
    2. Users can request an accessible format of a PDF (Word, MP3 or text).
    3. Users can request alternative forms of access (eg read out loud).
    4. Users know who to contact for an accessibility issue.
    5. Users receive a prompt response on accessibility-related user complaints, requests and questions.
  3. Promoting the APVMA’s commitment to online accessibility
    1. The action plan is available on the APVMA website
    2. The action plan is available in multiple formats.

4. Implementation process

The APVMA will achieve these goals and strategies in the following manner.

4.1. Step 1—APVMA accessibility policy updated

  • Obtain management agreement to an updated APVMA web and online accessibility policy.

    STATUS: completed. Policy was agreed in June 2012 and website accessibility statement has been subsequently amended.
  • Policy to be reviewed regularly

    STATUS: ongoing.

4.2. Step 2—legacy content

  • Identify high-priority/current documents that do not have an accessible format and convert to an accessible document format.

    STATUS: partly achieved. Conversion of approximately 300 documents is complete and documents are awaiting publication.
  • Remaining legacy content will be considered as part of step 5 (redevelopment of main agency website).

4.3. Step 3—infrastructure

  • Develop and deploy suitable web infrastructure:

    STATUS: achieved. Drupal selected as the APVMA’s new content management system for website and intranet development.
  • Redevelop agency website and intranet in Drupal

    STATUS: Intranet redevelopment will be completed by 30 June 2013.

    Website redevelopment will be completed by 1 July 2014.

4.4. Step 4—intranet redevelopment

  • Test WCAG2.0 conformance prior to full release.
  • Document accessibility requirements and planned improvements.

STATUS: Pending.

4.5. Step 5—website redevelopment

  • Audit conformance issues for current website that may impact content migration strategy.
  • Test WCAG2.0 conformance at key stages during development.
  • Confirm site conformance prior to release.
  • Document accessibility requirements and planned improvements.

STATUS: Pending.

4.6. Step 6—new content development

  • Amend web and intranet publishing procedures to incorporate accessibility requirements and responsibilities.
  • Review and update templates used for web/online content development.

STATUS: Pending.

4.7. Step 7—monitor and improve

  • Conduct routine conformance testing across all in-scope sites and applications on an annual basis.
  • Identify opportunities to improve accessibility with all new content, application or channel development.

STATUS: Pending/ongoing.

4.8. Step 8—staff awareness

  • Content creators and authors are provided with suitable training in creating and developing accessible content.
  • Purchasers of third party content development services include relevant APVMA accessibility standards and requirements in all procurements.

STATUS: Pending/ongoing.

4.9. Step 9—user awareness

  • All users are aware of the APVMA’s commitment and options for access to all information on an equitable basis.
  • Contact information and response times are clearly identified and discoverable on all APVMA online sites and systems.

STATUS: commenced. Updated accessibility statement loaded to main corporate website.

5. Document version control and amendment record

Document title

APVMA Website accessibility implementation plan

Document owner

Director, Public Affairs and Communication

Document authorised by:

Executive Director, Corporate Services


April 2013

Last updated

1 July 2014

Version number

V 1.1





1.1 1 July 2014 Minor date updates


6 April 2013

Approved version for release to AGIMO and APVMA website


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