Encountering digital accessibility in the wild
As a digital accessibility agency, we primarily focus on helping businesses and organizations make their websites and mobile apps accessible to users of all abilities. But recently, I encountered digital accessibility issues in a context that was new for me. I took my first flight in several years (#COVID) and settled in to watch a movie on Alaska Airlines’ in-flight entertainment system. Between the noise of the airplane and a screaming baby nearby (yes, it was my baby), I was having a hard time hearing all of the dialog. But the closed caption feature was nowhere to be found. After checking out a number of other titles, I finally found one that had closed captioning as an option and was able to enjoy the film.
This is a great illustration of the ways that digital accessibility can improve the user experience for everyone (and conversely the lack of accessibility makes things difficult for everyone). But it also demonstrates how contingent accessibility can be. Depending on the environment, many users can be in need of accessibility features; for example, many people experience some hearing loss or visual loss (such as presbyopia) as they age but would not generally self-identify as people with disabilities.
Offline digital accessibility
One of the earliest and most prominent examples of digital accessibility is the ATM. The federal Department of Justice (DOJ) has issued detailed requirements to banks for providing accessible versions of ATMs and the types of features required for the device to be considered accessible. (This stands in contrast to the DOJ’s hands-off approach in declining to issue web accessibility requirements as of 2021.) These regulations cover both the physical design of the ATM as well as the software that powers it. For example, the ATM must have sufficient space for a wheelchair, provide a speech enabled mode, and include braille instructions for activating and using the speech mode.
How can inflight entertainment systems be made accessible?
The ATM demonstrates the far-reaching changes that may be necessary to make standalone devices accessible. If we consider the case of the seatback inflight entertainment system, what kinds of features would be necessary to make them accessible? This is a non-exhaustive list, but they would include:
- Audio announcements available as a option on all interfaces to describe the contents of the screen (much as screen readers operate on phones and computers)
- Some form of keyboard accessibility: while ATMs already had touchpads, this is a bit trickier for airlines that have been introducing touchscreens. After all, the point of the touchscreen is to replace the seatrest physical remote control that was used on the previous generation of seatback video screens.
- Of course, the media itself must also be accessible (e.g. closed captions)
The Bring Your Own Device (BYOD) Era
Especially on short haul domestic flights, it is more and more common to see that the seatback entertainment systems have been removed completely. Instead, passengers have the option to use their own computers, tablets or mobile devices to access streaming video entertainment provided by the airline while the plane is in the air. On these flights, the passenger uses an app on their phone or an inflight website to select and view their entertainment.
In many ways, this new trend represents a big win for accessibility. Airlines can sidestep the difficulties inherent in building their own hardware and can instead piggyback on existing infrastructure that the passenger likely already has access to. For example, when using a browser on a phone or computer to select a movie, the passenger can make use of their built-in screen reader software and keyboard inputs. The airline just needs to ensure that the websites and apps used to serve this content are accessible per the Web Content Accessibility Guidelines (WCAG) just like any other website.
Are airlines required to provide accessible inflight entertainment?
Air transportation is not regulated under the Americans with Disabilities Act (ADA), but there is a separate law, the Air Carriers Access Act (ACAA) that prohibits discrimination against air passengers with disabilities. There is no mention of entertainment systems in the law of in the rules issued by the Department of Transportation (DOT) under the law. However, the regulations do stipulate that airlines are required to make all of their websites WCAG 2.0 Level AA compliant; this applies even to websites that are not directly related to reservations, check-in and other critical processes. While the inflight entertainment websites are not available on the open internet, the BYOD trend does raise interesting questions as to whether the new web-based inflight entertainment interfaces are covered under the DOT’s rules.
Lessons: Cover the easy stuff
What was most surprising about my experience is that Alaska Airlines missed the most basic requirement associated with making video content accessible. While I didn’t test the website itself, the media accessibility should be the easy part. After all, closed captioning has been available for years on over-the-air television not to mention streaming services like Netflix or Disney+. Furthermore, airlines (especially those that fly internationally) have invested in caption support in multiple languages.
As site owners, you may not yet have the wherewithal to bring your website into full compliance with WCAG 2.1 Level AA, but that doesn’t mean you should do nothing. There is almost always low hanging fruit that you can address immediately that will make your site more accessible than it currently is. This will improve the user experience for users with disabilities (and potentially the wider audience) and can significantly reduce the likelihood that your site will be targeted in a surf-by lawsuit.