- Background.
- Social Model Language of Disability.
- Need to Distinguish Between Reasonable Accommodation and Accessibility.
- Formats and Means.
- Candidate’s Presentation of the Exam Script Paper.
- Special Exam Centres.
- Some Textual Difficulties with RA Document.
- Majoritarian Approach in Physical Exercise Evaluations.
- Link To VVI’s Guide to Accessible Exams.
Preliminary
1. Background
Voice of Vision Impairment (VVI) is Ireland’s Disabled Persons’ Representative Organisation (DPRO) under the UN Convention on the Rights of Disabled People (UNCRDP). In this capacity, in liason with the Irish Human Rights Commission, the Examinations Commission met with VVI on March 12th, 2025, to discuss the Commissions’s “Reasonable Accommodations Scheme” and what improvements VVI would recommend in review.
As preparation, the Commission sent VVI the latest iteration of their reasonable accommodations (RA) document for schools regarding applications for reasonable accommodations in exams (2025).
VVI very much welcomes this opportunity to meet with the Commission and we are hopeful that it is the beginning of a cordial and mutually beneficial relationship in close consultations and active involvement of VVI (the only DPRO specific to blind and partially sighted people in Ireland) in disability-proofing the Commissions systems and policies.
While we appreciate the Commission’s sending us a .rtf version of the 2025 Reasonable Accommodations document, which greatly increased accessibility for screenreader-users, we mention the importance of manually writing page-numbers in screen-reader-accessible versions of documents (e.g., in .rtf or Word formats).
VVIMAC Section 6. Electronic Documents.
https://vvi.ie/our-policies/accessible-communications-policy/6-electronic-documents/
Substantive Points.
2. Social Model Language of Disability.
Traditionally, the medical/charity model of disability has been used. This depicts disability as being intrinsic to an individual, as if the individual is the real problem, and everyone else is just trying to help them overcome this personal challenge or tragedy etc.
On the other hand, the social model of disability, which is the basis ot the Human Rights approach, recognises disability as being a social construct (as a type of discrimination). In this way, it is recognised that society literally disables people by barriers it often inadvertently creates as norms. For example, wheelchair-users are disabled (as a verb) by design when steps are used instead of ramps. When ramps are used, wheelchair-users are no longer disabled in that context.
As such, social model language is compatible with “disabled people,” (with disabled as a verb rather than an identity). Medical model terms incompatible with the social model include: “people with disabilities,” “having a disability,” “visual/physical disabilities,” “visual difficulties,” “visual challenges,” “visual issues,” “of average ability,” in terms of tasks etc.
Visually impaired people or people with a visual impairment (or use of plural etc.), are fine as person-first terminology or as an umbrella term for blind and partially sighted people. , since our impairment is something we have, rather than being a social construct. It is intrinsic to us in the same way as a phenotype is part of us.
VVIMAC Section 3. Language and Terminology.
https://vvi.ie/our-policies/accessible-communications-policy/3-language-and-terminology/
3. Need to Distinguish Between Reasonable Accommodation and Accessibility.
Reasonable accommodation relates to particular needs on an individual basis, whereas accessibility relates to more macro-level policies to minimise the need for individuals to request reasonable accommodations. In other words, accessibility is at the systems level, whereas reasonable accommodation is at the individual level. Reasonable accommodation is generally negotiated or arrived at through dialogue with the individual (e.g., by the school). It is not a no-holes-barred or free-for-all concept, but the agency of the individual in determining what is most suitable for them personally is very much to the fore. Any reasonable accommodations should be feasible once they don’t put an undue burden on the provider, and in this context, for example, that would include meaning that the integrity of the exams process must be maintained, since to do otherwise would put undue burden on the institutions involved.
For reference, see Kalinova vs. PTSB (Workplace Relations Commission, 2022; UN Convention on the Rights of Persons with Disabilities (Articles 5 and 9, and General Comments 2 and 6. In particular, paragraphs 24-7 of General Comment No. 6 give a very straightforward and comprehensive description of the differences between reasonable accommodation and accessibility.
4. Formats and Means.
4.1. Introduction.
4.2. Word Processors.
4.3. Exam Paper Formats
4.4. Application Forms.
4.1 Introduction.
It is commendable that the current Reasonable Accommodations advice mentions “no surprises,” and there is recognition, somewhat, that this should apply to the candidate as well as the school or Commission. The current document recognises that the candidate should, in so far as is possible, use the same communications means or formats as they do throughout the school year, e.g., in the classroom.
4.2 Word Processors.
However, to this end, it should be remembered that a visually impaired candidate using a word processor will have their own preferred settings in terms of screenreading software, colour contrast, text size, and even the keyboard being used. In our experience, it is generally not practical for someone else other than the candidate to know their requirements to the extent that a computer and software can be set independently of the candidate. Ultimately, because the candidate’s settings have evolved over time to suit their individual needs, and they may not be able to remember all of their own settings when setting up a new device; our recommendation is that the candidate be allowed to use their own device when doing exams.
It is not clear from the RA document that third-party software is permitted. Of course, such software is necessary, e.g., NVDA or JAWS as the most popular screenreading software tools. Candidates with low vision may use magnification software such as ZoomText, and other candidates may be more comfortable with speech to text (verbal inputs) by use of software such as Dragon.
It is not clear from the RA document that word processor includes a digital braille note-taker or digital braille display, and this should be clarified.
Devices with which exams can be written should include manual braille machines (on the presumption that some candidates will not have access to a digital braille note-taker and may be used to brailling on paper.
Similar to the need to use their own personal equipment for writing, Many visually impaired candidates will require the use of their own personal time-keeping equipment, e.g., an I-watch. It can be checked before an exam that internet access has been disconnected and the individulator can make inobtrusive checks throughout the exam to make sure that the internet remains disconnected.
We would like to be able to comment further on “parallel motion drawing boards” but our knowledge of these devices is scant.
4.3 Exam Paper Formats.
We welcome that provision of exam papers in .pdf format continues to be tried, particularly for candidates with low vision who can read documents by sight. However, especially for screenreader users, editible .rtf or .doc(x) formats should also be an option.
See VVIMAC Section 6. Electronic Documents.
https://vvi.ie/our-policies/accessible-communications-policy/6-electronic-documents/
We note the Commissions concern that such an exam paper could be inadvertently edited by the candidate with negative consequences. Ultimately, a candidate bears some responsibility of due dilligence in being careful not to impair their own chances. For example, with the physical paper, a candidate might inadvertently obscure letters or numbers when underlining or otherwise putting pen-marks on the exam paper, and if they notice they have done this, they can request another copy of the paper.
With an editible digital copy of the paper, e.g., in .rtf or .doc(x), once a candidate is happy with their preferred settings, with a two-key combination on the keyboard they can turn on a mode for the exam paper that makes it no longer editible. Otherwise, if they think they may have inadvertently altered the paper, they will know (not being word processing novices) that the keyboard command Ctl+Z, kept held down, will bring the document back to as it was before any editing took place. If the candidate is still not sure, as with their sighted candidate, they should be able to request a backup digital copy of the paper.
A braille version of the exam paper should include option for non-capitalised non-UEB (SEB) braille.
VVIMAC Section 8. Braille
https://vvi.ie/our-policies/accessible-communications-policy/8-braille/
The digital booklet formats used for continuous assessment need to be screenreader-friendly.
VVIMAC Section 5. Accessible Websites and Apps
https://vvi.ie/our-policies/accessible-communications-policy/5-accessible-websites-and-apps/
4.4 Application Forms.
For accessibility reasons, eligibility/accommodation forms should be signable by a candidate/guardian by use of email, and other formats should also be explored. Ironically, many visually impaired people would find the current reasonable accommodation application forms to be inaccessible, since they are only paper-based. We should be operating in terms of universal design so that it is possible that even school staff dealing with such an application may themselves be disabled (e.g., have a visual impairment).
5. Candidate’s Presentation of the Exam Script Paper.
In the 2025 RA document there are instructions for candidates using word processors in terms of preparation of their script/written paper to make it acceptable for submission. To avoid indirect indiscrimination of such candidates, it is essential that they not be required to do anything more than their non-disabled comparator (cf. Equal Status Act, 2000, S4).
To this end, for example, printing of a document should be a matter for the school, and not for the candidate. A visually impaired person may not be able to tell whether a script has been properly printed, and may not have the technical skills to print their document. This is not an extra worry they should have to contend with. In Third Level institutions, at least, it has been the norm that members of staff are given the responsibility of printing off scripts.
Once again, though, for a blind examiner (if the Commission should ever wish to encourage such equality), will necessarily find the print version inaccessible. Digital saving of such documents (with strict GDPR, of course), should also be considered.
6. Special Exam Centres.
While the use of screenreading technology in an exam context can usually be facilitated by the use of headphones, other candidates may still be distracted by this limited – albeit reduced – sound. Furthermore, non-neurotypical screenreader-users may find headphones unbearable. For this reason, it could be made clearer in the RA document that users of screenreading technology are more likely to require their own rooms for written examinations.
Similarly, the manual braille machine is quite loud, also requiring that a candidate using this mode of writing be given their own exam room.
7. Some Textual Difficulties with RA Document.
There is occasional Inconsistency in the 2025 RA Document. In section 4.1 it is not clear that a narrative description of the sraith pictiúir in English is to be allowed. A simple tightening up of language should clarify.
The structure of the RA document could be reconsidered to allow for less repetition and a much shorter document (perhaps 20 pages instead of 96), without losing any information and thus increasing accessibility. A suggestion for this approach would be to take normative accessibility options (currently called reasonable accommodations) as primary headings in their own right, grouped under disability constituency – a slight re-working of the current structure, but without the repetition – the application process, of course, being treated in a separate section.
8. Majoritarian Approach in Physical Exercise Evaluations.
We are worried that what might be preferred by the teacher or a majority of candidates in any particular PE class may put a disabled candidate at a disadvantage. While a one-size-fits-all approach is not suited to this area, schools/teachers should be encouraged to see if a universally accessible approach can be decided upon where potential candidates are disabled.
9. Finally.
An overview of VVI’s general guide to exams etc., can be found at:
VVIMAC S10. Exams etc.
https://vvi.ie/our-policies/accessible-communications-policy/10-exams-apps-forms-and-surveys/