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Disproportionate Burden Assessment – Accessible PDFs

Cwm Taf Morgannwg University Health Board is committed to making its website accessible, in accordance with the Public Sector Bodies (Websites and Mobile Applications) (No. 2) Accessibility Regulations 2018.

Providing accessible information is important to us. We are committed to making documents relating to patient care and the provision of our services accessible and have established process for this.

We will always make information and documents that are essential to providing patient care accessible and have made most of the content on this website accessible. Our covers the issues that currently exist on and our planned intention to fix them.

We at CTM believe our approach to carrying out accessibility checks is reasonable. However, the accessibility regulations state that if we believe that a process to comply would impose a disproportionate burden on us, we can negate that element of accessibility.

We have assessed that it would be a disproportionate burden to fix all PDF documents published on the website since September 23, 2018.


This assessment applies to several sections of the website that hold repositories of PDF documents. These sections exist as we have a legal obligation to publish all our board papers, committee papers, reports, disclosure logs, policies and procedures.

These sections contain hundreds of PDF documents produced between September 23, 2018 and September 28, 2023. We have been publishing these as they are presented to our board or relevant committees.

These files do not consistently meet accessibility standards such as:

  • Page titled
  • Headings and labels
  • Non-text content
  • Info and Relationships
  • Table headers
  • Contrast (Minimum)
  • Focus order
  • Meaningful sequence

We are making improvements to newly produced documents and are working towards making all newly produced pdf accessible. This includes:

  • Working with colleagues to improve awareness and to ensure they understand what they need to do to reach the requirements.
  • Creating a checklist to ensure all content is accessible
  • Procuring software such as Adobe Acrobat where necessary to ensure that accessible PDFs are created and checked at production.
  • Testing uploaded documents with accessibility software such as Axe to ensure compliance.

Out of scope

The accessibility regulations do not require us to fix PDFs or other documents published before September 23rd, 2018 if they are not essential to providing our services. We do not plan to fix any PDFs or other documents published before September 23rd, 2018, for example board and committee papers, health board policies and procedure documentation or statutory documentation such as annual reports. However, we will endeavour to make any new PDFs or Word documents accessible wherever possible.

We occasionally publish PDFs which contain ‘transcripts/scanned manuscripts or handwritten notes’ for example in FOIA requests - these are outside of scope and will not be fixed.


The benefit to making these documents into accessible formats are:

  • The information would be accessible to all
  • Possibility of better search engine indexing


We have conducted an objective assessment of resource required to retroactively convert the non-compliant PDF that are in scope to accessible versions. We would do this by using Adobe Acrobat Pro or conversion to a word processor and accessibility corrections completed before reconversion to PDF.

Our assessment found:

  • There are more than a thousand pdf documents that have been uploaded within the area outlined in scope.
  • Over the six months prior to August 31, 2023 those sections of the website have only received 2,507 hits. Of those hits we had only 233 file download events and 83 PDF open hits which combined makes 316 hits. (We cannot give specifics on which documents have been opened or downloaded due to the limitations of Google Analytics). We can assume that many of those hits are from our staff uploading and checking that information. This leaves very small numbers who access the information.
  • Since the website has been active, we have never received a complaint about not being able to open an accessible PDF. In addition, we have recently introduced a request form should anyone want to request a pdf that hasn’t been made accessible so we can service that request on a case by case basis. That feature is yet to be utilised.
  • Most of the content would have very limited use as the position of the Health Board is likely to have changed since the publication of the documents. They would provide only a historical snapshot of our position at that time.
  • We performed a limited test on documents for conversion to an accessible standard to gauge the duration of time that each conversion would take in order to estimate the total duration of the ask. We did this by downloading the pdf and converting it to an accessible pdf in one of two ways. Using Adobe Acrobat to add the missing accessibility items or converting to a Microsoft Word document and performing the accessibility updates there. Most of the documents processed took between one and two hours. The exception was our board and committee papers that took even longer due to the complexity and size of the document of the three documents we converted these took over three hours to convert. Both methods tried produced similar results. We would envisage but cannot guarantee with more familiarity the process the times would reduce by at least a quarter. On an estimated basis of each document taking a duration of two hours and there being over 1000 documents to convert that would give us a conservative estimation of 2000 hours plus to conduct the work.
  • The two teams who produce these documents are very small in nature and have limited resource. Based on the individual teams budget constraints and general work duties the impact to process this, ask would seem an unsustainable burden on those teams in terms of human resource, cost and time. The other option to carry out this work would require the usage of agency staff on short term contracts but due to the financial constraints this option is also extremely unfeasible.

Additional Factors

  • We will provide accessible versions of documents on request whenever possible. To make a request please make a note of the document you wish to request and contact us via the comments section of our web form.
  • We will work towards providing all content in an accessible format and ensure that a process is put in place to do so at the earliest possible time. Where appropriate, we will ensure any current use documentation is converted.


Based on the assessment we performed, we would consider the conversion of documents that have low usage and limited worth to be a poor use of the time of health board staff. There is little to no evidence of demand and would therefore be deemed a disproportionate burden on the health board in terms of staffing and its associated costs.

Due to financial constraints, the usage of an external agency would also seem an unjustifiable cost over the essential service needs and requirements of the area.

Preparation of this assessment

This assessment was prepared in September 2023


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