06 — Alternate Formats (`PRINT-ALT`)
Status: Normative reference. Part of the Print Accessibility knowledge base (Issue #2852). Scope: What the effective-communication regime obliges when standard print does not reach a reader — large print, braille, tactile graphics, audio, electronic alternates, qualified readers — and how a request for one is invited, timed, and priced.
Scope decision (locked). We produce large print (ALT-001/002) and electronic alternates (ALT-006); we do not produce braille, tactile graphics, or audio. ALT-003, ALT-004, and ALT-005 are therefore written as hand-off pointers — when the trigger fires → what to know → route to a specialist vendor — not as embossing/tactile/narration production specs. Do not read them as things our pipeline implements.
The legal spine (auxiliary-aids duty, primary consideration, no-surcharge, undue burden) lives in
00-legal-basis.md(PRINT-LEGAL-001..010). This section cross-references it and does not re-derive it.
PRINT-ALT-001 — Large-print production spec: size / typeface / leading / measure / page-size
Level: SHOULD Applies to: large-print alternates only Source: APH, Research-Based Guidelines for the Development of Documents in Large Print (American Printing House for the Blind); corroborated by CCLVI/ACB Best Practices and Guidelines for Large Print Documents Source strength: consensus standard Machine-checkable: yes Validation: Assert against the large-print artifact: body ≥ 18 pt; subheadings ≥ 20 pt; headings ≥ 22 pt; a sans-serif face from the APH-acceptable set (APHont, Verdana, Tahoma, Helvetica, Antique Olive); line spacing ≥ 1.25; single column; line length 39–43 characters; block paragraphs with a full blank line between (no first-line indent); page size ≤ 9 × 12 in. Point size, leading, columns, page size, and characters-per-line are all measurable in the file.
A large-print alternate MUST set body text at ≥ 18 pt (20 pt subheadings, 22 pt headings) in an approved sans-serif face, at ≥ 1.25 line spacing, in a single column with a measure of 39–43 characters, using block paragraphs. Print between 12 pt and 18 pt is “enlarged print” and does not qualify as large print.
Rationale: Below 18 pt the artifact is not large print by definition and does not discharge a large-print request; multi-column layout forces the return-sweep that is the single hardest reading task for low-vision readers (APH); over-long or too-short measures both cut reading efficiency. Excludes low-vision readers who requested and were promised large print.
Implementation notes: This is a real production target for us, not a hand-off. The reflow/WeasyPrint lane is the natural producer: a large-print profile sets font-size: 18pt; line-height: 1.25; column-count: 1; and constrains measure to ~39–43 ch (≈ a 4.5–5 in text column at 18 pt). Enforce the ≥ 12.7 mm margin from PRINT-SUBSTRATE-008 so print-at-100% preserves the 18 pt. The PDF preserve (“flyer”) lane cannot manufacture conforming large print by scaling — see ALT-002. The audit/ACR can verify a document claiming to be large print against every threshold above (MUST is reserved for the definitional 18 pt floor; the composite spec is SHOULD).
unverifiednote: the numeric spec above is quoted directly from APH’s published PDF and matches CCLVI/ACB best-practice; the only item I could not re-confirm from a second independent issuing body is the exact 39–43 character measure — APH states it explicitly and I treat it as verified-single-source. Nothing here is marked unverified.
PRINT-ALT-002 — Reflow vs enlargement; photocopy-enlargement does NOT conform
Level: MUST
Applies to: large-print alternates only
Source: APH / CCLVI large-print guidance (definitional); effective-communication regime (PRINT-LEGAL-001/002)
Source strength: our-implementation rule
Machine-checkable: partial
Validation: A photocopy/PDF-zoom enlargement is detectable by symptom: line length still runs the original 60–80+ characters, the measure was not re-flowed, margins are proportionally enlarged into the binding zone, and page size exceeds 9×12. A true large-print alternate re-flows text to the 39–43 char measure at 18 pt. Flag “scaled-up original” vs “reflowed.”
Large-print alternates MUST be produced by re-flowing the content to the large-print spec (PRINT-ALT-001), not by photographically or digitally enlarging the standard document. Enlarging the original (bigger paper, photocopy zoom, PDF scale) does not conform, because it enlarges the too-long measure and the margins along with the type and produces an unwieldy, low-efficiency page.
Rationale: Enlargement keeps the original 60–80 character measure — now physically longer — which worsens the return-sweep problem large print exists to solve, and pushes to 11×17 / 2-to-3× page sizes APH explicitly rejects. The reader gets bigger letters and a harder read. Excludes the low-vision reader the alternate was meant to serve. Implementation notes: Direct constraint on our pipelines: do not offer “enlarge to 11×17” as a large-print path. Large print comes from the reflow lane re-composing to the ALT-001 profile. If only a preserve-mode PDF exists and reflow is impossible, we cannot claim large-print conformance — surface that limit honestly rather than shipping a zoomed page. This is why ALT-001 is a reflow feature, not a scale slider in the tag-tree editor.
PRINT-ALT-003 — Braille: contracted vs uncontracted, embossing standards, triggers
Level: SHOULD (hand-off)
Applies to: all documents (trigger + routing, not production)
Source: effective-communication regime (PRINT-LEGAL-001/002/003); braille standard is BANA / Unified English Braille (informational)
Source strength: consensus standard
Machine-checkable: no
Validation: Human/process — confirm that a braille request is recognized, logged, and routed to a qualified braille-transcription vendor within the PRINT-ALT-008 timeframe. We do not validate braille output; the vendor certifies it.
When a reader requests braille (or an assessment identifies a braille-primary reader), the request MUST be recognized and routed to a qualified braille transcription/embossing vendor; we do not produce braille in-house. What to hand off with: source text in a clean, well-tagged electronic form; whether contracted (UEB Grade 2) or uncontracted (Grade 1) is requested (default to contracted for general readers unless told otherwise); and any tables/graphics that will need tactile treatment (PRINT-ALT-004).
Rationale: Braille is the primary literacy medium for many blind readers and cannot be substituted by large print or audio for someone who reads braille; failing to route the request is an effective-communication failure. Excludes braille-reading blind users. Implementation notes: No embossing implementation. Our value is upstream: a clean tagged source (which our remediation produces) is exactly what a braille transcriber needs, so the best thing our pipeline does is emit good structure and route. The product surfaces a “Request braille” path that captures the request and hands it, plus the tagged source, to the vendor queue. Do not build translation tables.
PRINT-ALT-004 — Tactile-graphics problem (images → touch)
Level: SHOULD (hand-off)
Applies to: all documents (trigger + routing, not production)
Source: effective-communication regime; tactile standard is BANA Guidelines and Standards for Tactile Graphics (informational)
Source strength: consensus standard
Machine-checkable: no
Validation: Human/process — confirm that images carrying essential information are identified as candidates for tactile treatment and routed with the braille/tactile vendor, and that a text long-description alternative (PRINT-FIDELITY-005) is provided in the meantime.
When essential information is conveyed by an image, chart, or map and a tactile-graphics-using reader is served, the graphic MUST be flagged for a qualified tactile-graphics producer; we do not produce tactile graphics. A decorative image needs no tactile treatment; an information-bearing one does, and a tactile graphic is a redesign (simplification, key, braille labels) — not an embossed photocopy.
Rationale: A raised-line copy of a dense chart is unreadable by touch; tactile graphics require expert redesign. Without it, information-bearing images are simply lost to blind readers. Excludes tactile-graphics readers.
Implementation notes: No tactile production. Our pipeline’s job is (1) distinguish decorative from information-bearing images (we already do this in tagging), (2) provide the text long description (PRINT-FIDELITY-005) as the immediately available alternative, and (3) route flagged graphics to the tactile vendor with the braille job. Emitting good alt/long-desc is the deliverable; the emboss is someone else’s.
PRINT-ALT-005 — Audio and structured audio alternates
Level: SHOULD (hand-off) Applies to: all documents (trigger + routing, not production) Source: effective-communication regime; structured-audio reference is DAISY / synchronized-audio practice (informational) Source strength: consensus standard Machine-checkable: no Validation: Human/process — confirm an audio request is routed to a qualified narration/DAISY producer, and that a well-structured electronic source (headings, reading order, MathML, alt text) is handed off so the audio can be navigable, not a flat read.
When a reader requests an audio alternate, the request MUST be routed to a qualified human-narration or structured-audio (DAISY) producer; we do not produce audio in-house. What matters for the hand-off: a document with correct heading structure and reading order yields navigable audio (skip by heading, page, section); a flat document yields an unnavigable linear recording. Spoken-math depends on MathML in the source (PRINT-FIDELITY-006).
Rationale: Audio serves readers who use neither print nor braille efficiently; unstructured audio is barely usable for anything longer than a page. The quality of the audio is set by the structure of our source. Excludes print-disabled readers relying on audio. Implementation notes: No TTS/narration pipeline. Again our contribution is upstream structure — the tagged reading order, headings, and MathML our remediation already produces are what make a DAISY book navigable. Route the request; hand off the structured source. Do not ship a raw browser-TTS render as “an audio alternate.”
PRINT-ALT-006 — Electronic alternates as auxiliary aid and their limits
Level: SHOULD
Applies to: all documents
Source: PRINT-LEGAL auxiliary-aids regime (accessible electronic formats are an enumerated auxiliary aid); WCAG for the electronic artifact
Source strength: regulation
Machine-checkable: partial
Validation: The electronic alternate itself is testable to WCAG / PDF-UA (our existing audit path). What is not machine-checkable is whether an electronic file is an acceptable substitute for the requested format — that is a primary-consideration determination (PRINT-LEGAL-003).
An accessible electronic version (tagged PDF-UA or accessible HTML) SHOULD be offered as an auxiliary aid where it meets the reader’s need, but MUST NOT be treated as an automatic substitute for a specifically requested format (braille, large print). Under Title II’s primary-consideration rule, the requested format is honored unless another equally effective format is offered and accepted.
Rationale: An accessible electronic file serves many readers (screen-reader, screen-magnifier, reflow-on-device users) and is the format we produce best — but handing a blind braille reader a PDF instead of the braille they asked for is not effective communication. Excludes readers whose specific request is overridden without agreement. Implementation notes: This is our native strength — tagged PDF-UA and accessible HTML are exactly what the remediation, audit, and ACR tooling deliver. The rule for the product: offer the electronic alternate proactively, but never let it silently close a request for braille/large print/audio. Route those (ALT-001..005) even when an accessible PDF exists.
PRINT-ALT-007 — Qualified readers as an auxiliary aid
Level: MAY
Applies to: all documents
Source: PRINT-LEGAL auxiliary-aids enumeration (qualified readers are a listed aid)
Source strength: regulation
Machine-checkable: no
Validation: Process/human — not a document property. Confirm the servicing entity can offer a qualified reader when format production is infeasible or a stopgap is needed.
A qualified reader (a person who reads printed material aloud effectively and accurately) MAY be offered as an auxiliary aid, particularly as an interim measure while a requested format is produced or where format production is infeasible for a one-off interaction.
Rationale: Sometimes the fastest effective communication is a competent human reader; it can bridge the PRINT-ALT-008 turnaround gap. Not a document-level concern — excludes no one when offered appropriately, but is not a substitute for a standing format request.
Implementation notes: No implementation surface in our pipelines — this is an organizational/service capability, listed here for completeness of the auxiliary-aids menu. Our tooling neither provides nor validates readers.
PRINT-ALT-008 — “Timely manner” turnaround expectations
Level: SHOULD
Applies to: all documents
Source: PRINT-LEGAL effective-communication regime (“in a timely manner” so as not to deny equal access)
Source strength: regulation
Machine-checkable: no
Validation: Process/SLA — confirm alternate-format requests are fulfilled fast enough that the reader is not effectively denied the information (e.g., an alternate that arrives after a benefits deadline has failed even if technically produced).
Alternate formats MUST be provided in a timely manner — soon enough that the reader is not effectively excluded relative to standard-print recipients. There is no single statutory day-count; timeliness is judged against the document’s own deadlines (a form due in 10 days needs its alternate well inside those 10 days).
Rationale: A braille copy of a benefits notice that arrives after the appeal window has closed is a communication failure regardless of production quality. Excludes readers whose alternate arrives too late to act on. See PRINT-LEGAL for the regulatory basis of the timeliness duty.
Implementation notes: For formats we produce (large print, electronic) turnaround is near-instant — that is a selling point, and the pipeline should surface expected turnaround. For routed formats (braille/tactile/audio) the SLA lives with the vendor; the product should timestamp the request so timeliness is auditable.
PRINT-ALT-009 — Request-notice text: required content, placement, no-surcharge
Level: SHOULD
Applies to: all documents
Source: effective-communication regime; no-surcharge rule cross-references PRINT-LEGAL-004; on-form placement cross-references PRINT-FORM-022
Source strength: regulation
Machine-checkable: partial
Validation: Presence/placement is checkable in the artifact: a document SHOULD carry a visible alternate-format request notice; on forms it SHOULD appear at the top (near the title, before the first field) at a legible size (≥ the body minimum). Whether the wording is adequate is a human review against the required elements below.
A print document intended for the public SHOULD carry a visible notice telling readers that alternate formats are available on request, how to request one, and that there is no charge for the alternate. The notice SHOULD state at least: (1) availability of alternate formats, (2) a working request channel (phone/email/relay), and (3) an explicit no-surcharge statement. Do not re-derive the no-surcharge obligation here — it is PRINT-LEGAL-004.
Rationale: A reader who does not know an alternate exists, or fears being charged for it, is functionally denied it; the no-surcharge line removes the deterrent the law already prohibits. Excludes readers who would have requested but were not told, or were deterred by cost fear.
Implementation notes: On forms this is the same notice as PRINT-FORM-022 (top placement, ≥ body size). Our tooling can (a) detect whether a public document carries any alternate-format notice and flag its absence, and (b) emit the default string from PRINT-ALT-010. The no-surcharge clause is mandatory content even though the entry level is SHOULD — its legal force comes from LEGAL-004, not from this entry.
PRINT-ALT-010 — Recommended default request-notice string our products can emit
Level: SHOULD
Applies to: all documents
Source: our-implementation rule (a concrete default satisfying PRINT-ALT-009 content + PRINT-LEGAL-004 no-surcharge)
Source strength: industry practice
Machine-checkable: yes
Validation: When the product inserts the notice, assert it is present, at ≥ body-text size, positioned near the top of the first page (or top of a form), and contains all three required elements (availability, request channel, no-surcharge). The channel placeholders MUST be filled — a notice with {{phone}} unresolved fails.
Where a product emits an alternate-format notice, it SHOULD use the following default string (with the placeholders populated), rendered at ≥ the document’s body-text size and placed prominently near the top of the document:
Need this in another format? This document is available in large print, braille, audio, and accessible electronic formats at no cost to you. To request an alternate format, contact us at {{phone}} (voice), {{tty_or_relay}} (TTY/relay), or {{email}}. There is no charge for alternate formats, and we will provide yours in a timely manner.
Rationale: A ready, correct default removes the two failure modes we see in practice — no notice at all, or a notice that omits the no-surcharge line. Populated placeholders prevent shipping a boilerplate stub. Excludes readers who would otherwise never learn an alternate was available.
Implementation notes: Ship this as a template in the reflow/WeasyPrint lane and the docx→AcroForm lane (top-of-form). The audit/ACR can check for presence + the three required elements + resolved placeholders. Keep the wording aligned with PRINT-ALT-009/PRINT-FORM-022; if legal review revises the copy, revise it here (single source) and let the products pull it.