Accessible documents policy

Accessible documents at Medicines and Healthcare products Regulatory Agency

This policy explains how accessible the documents the Medicines and Healthcare products Regulatory Agency publishes on GOV.UK are. It covers PDFs, spreadsheets, presentations and other types of documents.

It does not cover content published on GOV.UK as HTML: this is covered by the main GOV.UK accessibility statement.

Using our documents

The Medicines and Healthcare products Regulatory Agency publishes documents in a range of formats, including:

  • Word
  • PDF
  • Powerpoint
  • Excel

We want as many people as possible to be able to use those documents. For example, when we produce a document we try to make sure to:

  • provide an HTML option where possible
  • tag headings and other parts of the document properly, so screen readers can understand the page structure
  • make sure we include alt text alongside non-decorative images, so people who cannot see them understand what they’re there for
  • avoid using tables, except when we’re presenting data
  • write in plain English

How accessible our documents are

We know some of our documents on this website aren’t fully accessible. These include:

  • some Adobe PDF documents
  • some Microsoft Word, Excel and PowerPoint documents.

For example, some of them:

  • are not tagged up properly - for example, they do not contain proper headings
  • are not written in plain English
  • are only available in PDF format

Some of our documents published after 23 September 2018 but before 23 September 2020 are not accessible. Wherever possible, we’re changing content from these documents into HTML content because it is more accessible. We are prioritising the most popular documents by viewing figures, and those which are essential to using a service. Work to amend prioritised documents to be accessible will be complete by Spring 2021.

Unfortunately, it will not be possible for all historic documents to be made accessible. We will also not be able to publish all documents from 23 September 2020 onwards in an accessible format.

We have assessed the cost of fixing the issues identified within the documents and believe that doing so would be a disproportionate burden within the meaning of the accessibility regulations.

What to do if you cannot use one of our documents

If you need information on this website in a different format email webupdates@mhra.gov.uk.

We’ll consider your request and get back to you in 18 working days.

Reporting accessibility problems with one of our documents

We’re always looking to improve the accessibility of our documents. If you find any problems not listed on this page or you think we’re not meeting accessibility requirements, contact webupdates@mhra.gov.uk.

Enforcement procedure

The Equality and Human Rights Commission (EHRC) is responsible for enforcing the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018 (the ‘accessibility regulations’). If you’re not happy with how we respond to your complaint, contact the Equality Advisory and Support Service (EASS).

Technical information about the accessibility of our documents

The Medicines and Healthcare products Regulatory Agency is committed to making our documents accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

The documents the Medicines and Healthcare products Regulatory Agency publishes are not compliant with the Web Content Accessibility Guidelines version 2.1 AA standard. The non-accessible sections are listed below.

Non accessible content

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

Non compliance with the accessibility regulations

Diagrams

A few of our documents have diagrams such as graphs. These images do not have a text alternative, so the information in them is not available to people using a screen reader. This does not meet WCAG 2.1 success criterion 1.1.1 (non-text content).

We plan to add text alternatives for all diagrams by December 2020. When we publish new documents we’ll make sure our use of diagrams meets accessibility standards.

Images of text

A few of our documents will have images of text, without a suitable text alternative. The information in them is not available to people using a screen reader. This does not meet WCAG 2.1 success criterion 1.49 (Images of Text).

We plan to add text alternatives for all such images by December 2020.

Scanned images of text

A few of our PDFs include scanned images of text. These do not work for people using screen reading technology as it cannot describe the text in the image. This does not meet WCAG 2.1. success criterion 1.4.5 (Images of text) and 1.4.9 (Images of Text).

We plan to add text alternatives for all such images by December 2020.

PDF format

The majority of our documents are PDFs. These do not work for people using screen readers. This does not meet multiple WCAG 2.1 success criterion including:

  • 1.1.1 (non-text content)
  • 1.3.1 (info and relationships)
  • 2.1.1 (keyboard)
  • 2.4.1 (bypass blocks)
  • 2.4.2 (page titled)
  • 2.4.4 (link purpose (in context))
  • 2.4.9 (link purpose (link only))
  • 3.1.1 (language of page).

We are working to convert priority documents to HTML. This will be complete by Spring 2021.

Colour contrast

A few of our documents do not have the necessary contrast ratio of 4:5:1 between background and text. This is particularly the case with some presentations. This means that people who cannot perceive all colours may not be able to view the text. This does not meet WCAG 2.1 success criterion 1.43 (Contrast).

By converting documents to HTML versions, we will fix this issue for priority documents.

Disproportionate burden

We are claiming disproportionate burden on the following accessibility problems:

  • Converting all PDFs published after 23 September 2018 to HTML
  • Ensuring all documents published from 23 September 2020 are published in HTML format

These will fail the following WCAG 2.1 AA success criteria:

  • 1.4.4 Resize text
  • 4.1.1 Parsing

We have assessed the cost of fixing the issues identified within the documents and believe that doing so would be a disproportionate burden within the meaning of the accessibility regulations.

Content that is not within the scope of the accessibility regulations

Many of our older PDFs and Word documents do not meet accessibility standards - 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).

Some of our PDFs and Word documents are essential to providing our services. For example, we have PDFs with information on how users can access our services, and forms published as Word documents. By December 2020, we plan to either fix these or replace them with accessible HTML pages.

The accessibility regulations do not require us to fix PDFs or other documents published before 23 September 2018 if they’re not essential to providing our services.

For example, we do not plan to fix agendas or minutes from governing councils from this time period.

How we tested our documents

We last tested a sample of our documents on 9 to 11 July 2020. The test was carried out by members of the News, Digital and Content team at the Medicines and Healthcare products Regulatory Agency.

We tested:

  • 10 types of documents used as forms to access our services or provide us with information
  • 30 different static documents, which are mainly reports or guidance

What we’re doing to improve accessibility

This page was prepared from 7 September 2020 to 22 September 2020. It was last updated on 22 September 2020.

We are currently:

  • prioritising our more popular and public-facing content as those we will ensure are published in an accessible way
  • working to make all our existing documents accessible, primarily by converting them into HTML. We are prioritising the most viewed content, and those necessary for using a service.
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