Skip to Main Content

Disproportionate burden statement: Home

Disproportionate burden statement – Library and Knowledge Services at Buckinghamshire Healthcare NHS Trust

We believe that our approach to carrying out accessibility checks is reasonable but means that we will not do detailed accessibility checks on all of our libguides pages.  This might mean accessibility issues on some of websites are not fixed.

However, the accessibility regulations say that we do not need to make a website accessible if doing so would impose a disproportionate burden on us.  We believe that carrying out more detailed checks and fixing documents, beyond what is set out above, would be a disproportionate burden.

You can read why we consider this to be a disproportionate burden.

Checking websites

Our most important content and transactions are provided on our main Libguides page. We're doing detailed checks of these. 

However, we do not believe the benefit of paying an auditor for detailed checks of our other sites would justify the impact on us except where those sites are specifically aimed at people with a disability.  

Checking documents 

We've also assessed that it would be a disproportionate burden to fix all documents published on these websites since 23 September 2018. 

The majority of these documents are rarely viewed, therefore they are unlikely to be negatively impacting users with disabilities or impairments. For this reason, we don't believe the cost of time, effort and resource to fix all the documents is justified. 

We will focus on fixing the most-viewed documents on these sites, and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities. 

Types of website and documents 


Our Libguides site has more than 18 separate websites. It is aimed at signposting healthcare staff to useful resources grouped around topics of interest. As a predominantly signposting service, most of the documents are not owned by the Library Service.

These websites vary in purpose, size and content. They do not provide essential services or specifically address the needs of, or are meant for, persons with disabilities.


As of 2 September 2020, there were almost 5000 links documents on our main websites published since 23 September 2018. The majority of these documents are not owned by the Library Service.

Estimated costs

Paying for detailed audits

We have estimated the costs for an external expert to do a detailed check (and later re-audit) on our Libguides site.

We estimate the cost to our small library service overall for detailed audits for all of our websites would be in the region of £30,000. 

These costs are based on estimates from GOV.UK's guidance on deciding how to check your website and getting an accessibility audit. These include:

  • a third-party day rate of £1,300
  • about 1 to 3 days to audit a small website
  • about 5 to 20 days to audit a large website

Cost of fixing documents

It's difficult to know how long it would take to make every document accessible without first reviewing each one.  

Potentially each document would require several hours of work to be recreated in a fully accessible version. 

If we use a conservative estimate of two hours to review and fix each document within scope, fixing all 5000 documents would take 1330 working days (based on a 7.5-hour working day).  

Assessment of costs and benefits

We believe that:

  • The size (6WTE), resources and nature of our service mean that there are limited public resources available which must be managed appropriately and in the public interest to prioritise the delivery of essential services.
  • The costs of paying for detailed checks for all our websites and fixing all of the documents on our main websites would be a substantial burden on us and the public resources we manage
  • The benefit to users would be limited and their needs can be met in other ways
  • Therefore, doing detailed checks on all of our websites and fixing all documents on our main website would impose a disproportionate burden on us.

In reaching this decision, we have considered the following:

Our organisation’s size, resources, and nature

The service we provide is primarily for the provision of library services to staff working for Buckinghamshire Healthcare NHS Trust. We have 6WTE members of staff providing services to 6000 staff. To comply with our service obligations and maintain the quality assurance of our services, as required by Health Education England we must provide a wide range of services including

Staffing the library, enquiry services, user and stock circulation, interlibrary loans, e-resource management, current awareness bulletins, outreach services, literature searches, training, survey development, knowledge management. We do not have a dedicated Comms or website team.

During 2020 we have also been forced to re-prioritise resources owing to the coronavirus (COVID-19) pandemic, ensuring business continuity of essential services. 

We do not provide services that specifically address the needs of, or are meant for, persons with disabilities.  However, where appropriate we make reasonable adjustments for people who use our services.

The estimated costs and benefits for our organisation: accessibility checks

We believe the potential of paying the substantial costs set out above on audits (before we've actually fixed anything) is unreasonable and not a good use of valuable public resources.  It could also have an impact of the delivery of the services themselves that the websites relate to.

Many of the teams that maintain sites independent of our main websites provide services to the NHS workforce, e.g. training and education programmes and resources.

We believe that:

  • maintaining these essential public services should be prioritised over paying for audits of our websites
  • it would be reasonable  for our services to carry out basic checks of their independent websites, and use any available budget to fix the main issues found on their sites

The estimated benefits to users

Our users with disabilities will benefit from us making our websites and online documents accessible.

For our main Libguides page, we already undertaking detailed accessibility checks, fixing the most accessed documents, and ensuring that new documents are accessible where they are required for essential services or specifically address the needs of, or are meant for, persons with disabilities.  This focuses our accessibility improvements where they will provide the most benefits to people with disabilities.

However, for the majority of our websites, we do not believe that the limited additional improvements that could be gained from detailed checks or more document fixes would justify the substantial costs of doing so. 

How to request content in an accessible format

If you need information in a different format email us at and tell us: 

  • the web address (URL) of the content 
  • your name and email address 
  • the format you need, for example, audio CD, braille, BSL or large print, accessible PDF 

We’ll consider your request and get back to you as soon as possible. 

Last updated

This assessment was last updated on 23 September 2020