Disproportionate burden assessment for PDF documents

Our website hosts numerous PDFs that were created in previous years. As these documents are no longer being updated, we have decided not to recreate all of them in accessible versions. We’ve assessed the cost required to make these PDFs accessible to WCAG 2.1 standard. We believe that doing so now would be a disproportionate burden within the meaning of the accessibility regulations.

It is worth noting that according to accessibility regulations, there is no obligation for us to address PDFs or other documents published before 23 September 2018 if they are not essential to providing our services. However, as part of our commitment to provide consistency in content format across our site, various large libraries of PDF files that include documents published prior to 23 September 2018 will be converted to accessible versions. A list of these libraries can be seen below.


Benefits of making content accessible

The core local area the Trust covers is Nottingham and Nottinghamshire with a combined population of around 1.1 million people. Ensuring the accessibility of our content or service provides numerous benefits. By converting PDF files to HTML format, we enhance accessibility for everybody, including individuals with disabilities and those visual impairments who rely on screen readers or assistive technologies. Making our content accessible fosters inclusivity, enabling a wider audience to access and engage with information about our services.


Non-accessible content

The content listed below is non-accessible for the following reasons.

  • PDF documents that have been published since September 2018 that are not compliant to the Web Content Accessibility Guidelines version 2.1 AA standard. For example, they may not be structured so they’re accessible to a screen reader. This does not meet WCAG 2.1 success criterion 4.1.2 (name, role value).
  • Images on pages do not always have suitable alternative text and some have incomplete text. This fails WCAG 1.1.1A success criterion (Non-text Content).
  • Videos on pages do not always have suitable captions and audio description. This fails WCAG 2.1A success criteria 1.2.2 (Captions (Pre-recorded)).


Libraries of PDF documents we are actively converting to an accessible format

We recognise that certain libraires of PDF documents are frequently accessed by patients, their carers, our own staff, and other stakeholders. We are actively working to convert these PDF files into accessible HTML versions and hope to have completed each library be the end of March 2024. These include:

  • Patient information library of leaflets - 482 total documents
  • Staff policies and procedures - 271 total documents
  • Board papers for 2023/2024 - Total number to be confirmed
  • Freedom of information request responses for 2023/2024 - Total number to be confirmed


Content that’s not within the scope of the accessibility regulations

The content listed below is non-accessible for the following reasons.

  • PDF documents that have been published since September 2018 that are not compliant to the Web Content Accessibility Guidelines version 2.1 AA standard.
  • Some images do not have a text alternative, so people using a screen reader cannot access the information. This fails WCAG 2.1 success criterion 1.1.1 (non-text content).

When we publish new content, we’ll make sure our use of images meets accessibility standards.

  • Some videos do not have suitable captions and audio description. This fails WCAG 2.1A success criteria 1.2.2 (Captions (Pre-recorded)).
  • When we publish new videos, we’ll make sure our use of captions and audio description meets accessibility standards. 


Burden of making all content accessible

While the benefits of accessibility are significant, we must acknowledge the potential burden imposed on our organisation. The following factors contribute to the burden:

  • Resource Allocation: Converting a large quantity of old and rarely used PDF files to HTML format requires significant resources.
  • Time and labour: The conversion process can be time-consuming and labour-intensive, involving manual effort to ensure accurate conversion of content and formatting. Extensive quality assurance will be required. This testing further increases the burden on our staff.
  • Technical Limitations: Some PDF files may contain advanced features, such as interactive forms, digital signatures, or complex graphical elements. Converting such files to HTML format may result in the loss of certain functionalities or require additional development efforts to replicate these features accurately.


Estimated costs and benefits

According to our accessibility auditing, there are an additional 1,968 PDF files published after 23 September 2018, not included in our libraries listed above, that potentially have one or more accessibility issue. Based on the Trust's estimation, addressing these accessibility issues could take an average of 45 minutes per document, depending on their complexity.

This information has been used to calculate the potential costs and impact on the Trust amending these PDF documents to WCAG 2.1 standard may have.

The calculations indicate that fixing the accessibility issues in all 1,968 PDF files would require approximately 1,476 working hours, equivalent to approximately 40 weeks (around 9.2 months). This is calculated using the Trust's standard employment contractual hours of 37.5 hours per week. This means that Trust employees would need to dedicate this considerable amount of time away from their other duties. These duties may include serving the needs of individuals with website accessibility requirements.

Should this work be completed it would be shared between existing suitably trained and experienced staff members. One of whom is an NHS Band 3 and the other NHS Band 4. Assuming the load is shared equally, we have estimated the cost in salaries plus additional employee costs for the duration of the project would be in excess of £30,000.


How we provide accessible information

While recognising the potential disproportionate burden, we are committed to fulfilling our duty to provide accessible information. To address this, we have taken the following steps:

  • Accessibility requests: We have established a formal process for users to request alternative formats for much of our online content. This includes a dedicated email address, telephone number and video call service for those who use British Sign Language. Information about how to request content in an accessible format can be found here.
  • Completion of requests: Once an accessibility request is received, we prioritise it and ensure a timely response. Our team will work to provide the requested alternative format, such as an accessible HTML version of the PDF file or any other suitable format as per the user's request. Upon receiving a request, we'll consider the request and get back to the user within 10 working days.
  • Communication and support: We communicate the availability of alternative formats and the accessibility request process through our website, and other relevant platforms. Clear instructions are provided to guide users on how to make a request. Information about how to request content in an accessible format can be found here.
  • Ongoing accessibility considerations: We are incorporating accessibility considerations into our content creation and publishing processes. This proactive approach will help minimise the burden associated with accessibility conversions and ensure that accessibility and inclusion is considered from the outset.

While acknowledging the potential burden, we are committed to providing accessible information with the resources available to us. By implementing these steps, we aim to meet the needs of users requiring information in alternative formats.


Contact us

For more information about our commitment to provide information and resources in alternative formats, please contact communications@nottshc.nhs.uk.



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