Episode 3

Accessibility by Design: Baking Inclusion Into the System

Stephen Framil, Corporate Global Head of Accessibility at Merck, shares how he embedded accessibility into enterprise digital governance across more than 125 countries. From authoring a global accessibility policy to integrating controls into procurement, SDLC, and clinical trial protocols, Stephen explains how accessibility must be “baked in” rather than bolted on. Drawing from his background as a conductor, musician, and cancer survivor, he describes accessibility leadership as orchestration—guiding experts toward inclusive outcomes while normalizing accessibility across systems and culture.

Transcript
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Well, hello.

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I'm Joe Walensky, and here to bring you another episode of Talking with

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Accessibility Practitioners.

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Today I am pleased to be visiting with

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Steve Fremill. Hello, Steve, how are you today?

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Hi, Joe.

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Uh, so far so good. You know, it's, uh, it's about 11 o'clock here Eastern time,

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where I'm at, uh, in a suburb outside of Philadelphia in my home office.

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And, uh,

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so far we're doing well today. Thank you. How about yourself?

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Well, I am speaking, uh,

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from my home office, which is in Bellingham, Washington, about, uh,

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80 miles north of Seattle.

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And there's a slight break from the, the, uh, river of, uh,

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water we've had over the past week,

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but I'm tucked away inside, so it-it's good to be, uh,

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here chatting with you.

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Uh, thanks again for, uh, offering to participate.

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Uh, looking forward to learning more about you.

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And so maybe a good place to start is if you could just tell us a little bit about your work.

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Yeah, absolutely. Uh, and thank you for the invitation to, to share today.

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And just for a, uh,

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a quick visual description for folks, um,

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I'm today I'm wearing a, uh, sort of an aqua-colored blazer with a black T-shirt.

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Um, I have mostly black hair,

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and I'm of, um,

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Pacific Islander and, uh, Caucasian descent.

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So, um, yes, Steve Fremill, uh, the Corporate Global Head of Accessibility at Merck.

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And also, for the past two years, I have, uh,

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been a co-lead of

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the Internally Facing, uh,

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Global Disability Inclusion Strategy Council, um,

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at Merck.

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And the role of that council, really,

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for the workforce

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was to advance a disability-confident workforce.

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So that has been my work, um, uh,

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the Global Disability Inclusion Strategy Council

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for the past couple of years,

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along with my role as the Corporate Global Head of Accessibility at Merck, um,

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uh, really for the past three years.

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But that work really sort of, um, matured into the what it is today,

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really starting back as far as seven years ago.

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And, um,

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that really started with the

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concept and the framework, uh,

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within Merck of enterprise digital governance.

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What we were finding in our nearly 30,000 websites, what the there was a lot of, um,

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uh, lack of, uh,

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governance or control or accountability with our websites.

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Very often the business would stand up a,

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a website for a product and then just sort of walk away.

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And, uh, when things had evolved through the product lifecycle, then, you know,

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we would have a, uh,

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a website out there that just was outdated

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or causing a cybersecurity risk

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or causing some sort of pharmacovigilance, drug safety risk as well.

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And so what the organization needed globally

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was a framework for managing,

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uh, digital governance, uh, particularly with the externally facing digital assets.

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And so, uh,

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that includes things that are around compliance, such as, I had mentioned, cybersecurity,

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such as pharmacovigilance, drug safety, as well as accessibility, um,

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as accessibility is, uh, in,

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in my view, increasingly becoming a regulatory matter, especially with, uh,

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the laws that are in some countries or regions, uh,

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whether it be Canada,

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whether it be Israel or Japan or Brazil,

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and of course the European Accessibility Act most recently for all 27 member states of

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the EU.

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Um, but, uh, also that enterprise digital governance concept was around optimization.

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So are we using the corporate branding as we should?

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Uh, should the design of sites, uh,

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be following some sort of, uh,

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design system, as it were?

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And so, uh, this enterprise digital governance, really, accessibility was a piece of that.

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And because, as I mentioned,

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accessibility is

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increasingly a regulatory matter,

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it was something that needed to be carved out and really stood up on its own.

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And back in 2020, uh,

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there was consensus company-wide that we needed a company-wide policy for accessibility.

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Uh, you know, we have our, our top-line corporate policies,

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and we positioned our digital accessibility policyright underneath our,

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uh, policy for human resources,

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really wanting to ensure that everyone, not just our workforce,

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but patients and consumers as well, had equal access to our digital content.

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And this policy, which I authored, uh,

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was, uh, company-wide.

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Uh, it applied to all divisions, all countries, all business units, um,

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and so on, both externally facing digital assets as well as internally

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facing assets.

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And so that really, uh,

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creating that policy, getting it approved by our Policy Governance Committee, which is, um,

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you know, is a whole uh,

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takes quite a bit of time, um,

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to convince a very large global multinational organization that they need another policy. Um,

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but they, uh, accepted it.

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And, uh, and we published that policy on April 1,

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no fooling, of 2021,

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and since then have been rolling it out strategically,

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uh, based off of di different digital channels,

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but more importantly,

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really inserting it into the

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processes and the, um, uh, the,

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the systems that we're used within the company

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so that you what you really have is something

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accessibility by design, so that, uh, when people are building digital assets, uh,

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the digital SDLC, Systems Development Lifecycle,

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they get flagged for specific accessibility activities

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while they're planning or creating, designing, coding, building,

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and so forth throughout the lifecycle. And I think that's really important.

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Um, so there's a few areas. I mentioned the digital SDLC.

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We got that accessibility controls into there.

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Uh, we also got it into our procurement language, uh,

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where, uh, our, um, vendors and our suppliers, uh,

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for any digital products or services would,

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uh, need to deliver on accessibility standards according to the latest version of, uh, WCAG,

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Web Content Accessibility Guidelines. So, uh, that's another measure in which we did this.

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Also, getting it into our governance, risk, and compliance.

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So anytime there was a need for an exception made,

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at least our leadership would know and be able to

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accept the risk if we were not

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going to make a particular asset,

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um, accessible, at least at that point in time. So really building it in.

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And some of the things that we recently have, um,

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started is getting accessibility controls into the,

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uh,

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protocols of our clinical trial studies.

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And so what are those digital touchpoints that happen within a clinical trial

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and ensuring that any supplier supporting the clinical trial

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ensures accessibility, whether it be through, uh, recruitment, uh, of, uh, patients? Because,

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of course, patients, as you know,

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they have frailties, they have comorbidities, and they have disabilities. And so absolutely.

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Um, and, uh, you know, often, uh,

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therapies for different,

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uh, uh,

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disease states cause disabilities.

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Chemotherapy causes disabilities with neuropathy and things of that nature.

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So, um, certain disease stages such as diabetes have,

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uh,

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retinopathy or also neuropathy. And so this is where it really makes a lot of sense when you're,

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um, testing new drugs in phase three,

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where you're really designing those studies so that patients who are going to have disabilities, um,

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that your digital, uh,

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touchpoints are accessible. So really baking it in, uh, to the process, the systems,

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the templates, uh, you know,

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depending on what, uh, content management system, uh, you're using,

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making sure that those guardrails are there

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so that the business doesn't have to

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go back and fix it or

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have to suddenly become an accessibility expert.

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You know, not everyone can, you know, be an expert on all these things, um, accessibility, pharmacovigilance,

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cybersecurity, you know, branding, all that.

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You have to put these, um, uh, these controls in place so that they get done and,

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uh, uh, you know, that there's, there's accountability along the way.

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And so that's really the,

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uh, what we've been doing at Merck over the last, uh, you know, six,

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seven years is really baking it into our ways of working, uh,

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so that the business, who always wants to doright by the company, uh,

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and by the patient and the consumer, uh,

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doesn't, um, have to, uh, uh,

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go back and fix things

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or have to, uh,

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suddenly become an expert in this particular aspect of, uh, the work that they're doing. So,

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uh, so yes, that's, that's my current role.

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That's what it's been for the last, uh, few years

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and really, uh, continuing to, um, to, you know, to lead that forward. So.

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Well, yeah, thanks for providing such a,

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a detailed, uh, uh,

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uh, look at all of what, what it sounds like a very robust and progressive, uh, set of, uh,

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accessibility-related activities.

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Uh, you I, I think it was, you know, it was interesting to hear you talk so much about the,

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the governance and policy areas.

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You mentioned that a, you know,

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a very large organization like that doesn't necessarily need another policy,

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but yet you've,

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you've established something very significant.

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And, and I, I it in most of our mainstream conversations, uh,

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you know,

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online and with colleagues about accessibility,

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I would say that at least in my world, most of it surrounds the, uh,

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the bits and bytes, uh,

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of actually executing accessibility. Uh, and, and governance is such a huge part of it.

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But I, uh, I don't think we, uh, you know, we talk about it, uh, as much.

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Maybe it, it, it, it's not quite, uh,

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as interesting to talk about. But, but just on that particular, um, area, uh, you know,

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what was the, you know, the beginnings of that? Or were you involved with that?

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Or has it been that way for a long time where there's actually this,

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uh, uh, significant, uh,

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uh, internal representation in, in policies within the organization? Right.

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Well, uh, at Merck, you know, one of the, uh, the slogans is,

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"Patients are our purpose." And so, uh, for all the reasons I had mentioned around, uh, patients,

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uh, uh,

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often having disabilities, this really resonated, you know, with the, uh, the values,

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the values of the company.

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And so but, you know, I,

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um, you know, having, uh,

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written the policy and, and really, uh, you know, moving it forward company-wide,

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I often, um, you know,

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had to reflect personally, like,

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how did this happen?

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Because it was not a matter of, uh, uh, uh,

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you know,

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something that I was looking to do.

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Something I'm probably a little bit of imposter syndrome when it's like, how, how, how did,

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how did I arrive here?

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Because, you know, I am not a marketeer.

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I'm not a designer.

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I'm not a scientist.

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I'm not a physician. I'm not a lot of things.

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But, uh, you know, one of the things I'm,

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I am is I'm all I am also a patient.

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You know, I'm now a, uh, a two-year cancer survivor and having gone through

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the types of, uh, disabilities that come with therapies.

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And so, um, you know, so far, so good.

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But this is where, uh, it, uh, it, it really, uh, you know, started to resonate with me.

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But then I mentioned, like, all the things that I'm not, uh, professionally.

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In fact, uh, uh,

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my, uh,

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my formal training and is all in music.

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I have a doctorate in music, in cello performance.

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And I have, you know, taught in, in higher ed for 30 years, uh,

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both cello and chamber music and conducted orchestra.

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And so I have had a very, uh, you know,

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uh and I continue to do that, um, with, uh, uh,

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various, uh, performing arts organizations that I've created over the last 20 years. And,

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uh, when I think about that, like, well, how did I arrive here?

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And what I,

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you know, in retrospect observe is that there's always been this thread of accessibility, um,

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in what I've done throughout life.

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I can recall as a, um, as a teenager, uh,

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going on high school mission trips to, uh,

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build greenhouses

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in New Mexico, uh,

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for, um, uh,

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for, uh, Indigenous Native American, um, lands,

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really trying to ensure that there was good,

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uh, uh,

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good food

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accessible in these, uh, very dry environments.

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And I think I go back to building schools in the Dominican Republic, um, as, as part of,

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you know, really creating, um, access to education.

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But what really struck me was that in the early 2000s,

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uh, I was in a, uh, an opportunity in,

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uh, the inner city, West Philadelphia.

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Uh, and I created an inner city conservatory where we provided

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free music lessons to the at-risk youth in the neighborhood,

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making great music accessible to everyone.

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And even today, I'll get stopped by parents whose kids were, um, in the program.

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I'll get stopped in the train station. And I say, "Hey, you know, that was really great.

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It really helped my kid," and so forth.

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And that, of course, is, is really wonderful to hear.

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But the I also mentioned the performing arts organizations, uh,

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Camerata Philadelphia and the Port City Music Festival in Wilmington, North Carolina.

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And for the last 20 years, all of our concerts have been free admission, uh, to the public,

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really making music accessible to everyone,

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breaking down those barriers that can so often, uh,

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limit, uh, people's, uh, ability to experience things.

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And so that has and so when I arrived at Merck and,

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you know, we had, uh, the need for, uh,

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this policy around accessibility and really what that meant to breaking down barriers

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and providing equal access to our digital content,

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it really kind of was just, uh, uh,

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the next step in my journey,

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lifelong journey of making things accessible.

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So, uh, I know, uh,

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you know, everyone's, you know,

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journey through life takes a lot of twists and turns and things like that.

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But that's something that, um, is,

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is really it, uh,

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has followed me in various ways, in various ways, uh, for the last, uh, 20, 30, 40, 50 years.

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Well, as you, uh,

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moved from this, uh, uh,

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sort of, uh, natural, uh, work, uh, natural life experience of, uh,

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doing accessibility activities in communities, um,

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and you,

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you moved into doing things more formally,

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uh, in your, in your current position, um, what,

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what types of things did you need to do, uh, or did you feel you need to do to, you know,

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just build your own knowledge of accessibility as a,

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a professional practice?

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As, as a professional practice. So, uh, you know, I mentioned that I'm,

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I was I think I also mentioned I was not an engineer.

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Um, so when it comes to designing and coding, uh,

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that's not something that, uh, I,

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you know, would necessarily do unless I, you know,

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took on, you know, those, those types of professions and, and studied up on it.

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So I knew that there was always

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folks who were could do that. My wife is a UX designer.

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And so, um,

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and really, as you know, accessibility is just part of UX design.

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It's one of those, uh, principles that, um,

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you know,

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it makes a good user experience.

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Um, and of course, you know, the, the, the coding with that as well.

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So I knew that there really wasn't anything, um,

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that was covered. That space was filled.

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You know, we had people who were designing, you know, using, uh,

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WCAG standards and, and, and developing.

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And that's why we inserted it into our procurement so that

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our suppliers were delivering on that.

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But what we found, what I found was really needed in a large

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global company was the,

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uh,

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orchestration of how we're going to be

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progressing this policy forward.

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Uh, when you have over 125 countries that you're

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working with and you have

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an accessibility steward network

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globally of over 70 people, and you're really getting them all on the same page,

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the same time, and here are the requirements year over year that we're going to try to

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advance accessibility for

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different digital channels,

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that takes a little bit of, um, orchestration,

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conducting.

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And of course, you I mentioned that I have also done a lot of orchestral conducting.

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And I make the comparisons, like,

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I don't play the oboe,

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but I can tell the oboe player

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when to start, when to stop, how loud to play, how soft to play,

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and really

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communicate the, the artistic expression.

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But I'm not I, you know so that's really providing that sort of, um,

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that sort of guidance

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with the experts that you're working with.

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You know, you have

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to have a great respect for

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the oboe player and the bassoon player

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and the clarinet player, maybe not the flute player. No, I'm just kidding.

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Um, but everyone,

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all the professionals who know their craft but be able to provide them that sort of, uh,

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that strategy, how you're, uh,

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going to move things forward, giving them the,

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uh, the, the time to be able to, uh, take on, uh,

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new digital channels that they were going to start to make accessible.

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You know, I'm we were working on websites, uh,

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first with automated testing. And this says, "Okay, the next year,

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we're going to start doing manual testing. You have to do things incrementally.

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We're going to start adding mobile apps.

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We're going to start adding PDFs, um, make sure that all your videos have captioning."

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And so all these things, when you have a global company, um,

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and over 2,000 websites, uh,

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and, and so forth, you have to incrementally roll this out so that

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it can get done, um,

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and not be overwhelming to the business because then they'll just throw their hands up.

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So it's really, uh, leading the strategy of implementation globally.

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And that really I pull and I draw from

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my experience as an orchestral conductor

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and also providing that support

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as a cellist in

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chamber music, string quartets,

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you know, letting the,

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the violins be the star of the show, but really being that foundation, um,

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to be able to, uh, to, to support them.

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And so I really pull heavily from, um, my,

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my, uh, experience as a as a cellist and a conductor and chamber musician,

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as well as teaching. I mentioned I teach for over 30 years.

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And so there's a lot of when you're training, when you're working with stakeholders, uh,

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introducing the concept of accessibility. I've been doing this for a while at Merck.

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And honestly,

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there's always a new group who have never heard of this, never heard of it.

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And of course, they ask, "Why haven't we heard of this before?" Um,

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so it's, uh,

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there's plenty of opportunity to communicate,

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to train, and, and to point them in theright direction.

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So and of course, working with your, your designers, your engineers, your developers, testers,

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uh, on, um, making sure that they have, uh,

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what they need to be able to deliver on accessibility as well.

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Well, uh, your orchestral communication analogy is, is such a grand way of,

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of thinking about your, your work.

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And so I think I'm going to internalize that a little bit because, uh,

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it's kind of a great.

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It's kind of a joyful way of thinking about the work that we do.

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Well, the thing is also,

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what's a successful

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in these days, maybe not, you know,

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100 years ago, um, is that, uh, when you're, you know,

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conducting an orchestra,

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it's really having that

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utmost respect for the professionals that you're working with.

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And I think it's the same way when it comes to

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running accessibility in a global company, really,

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uh, working with your designers and your developers and,

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and respecting their expertise, their craft, and really together, um, uh,

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progressing that forward. And I think that that's what's key.

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The reason why I said, uh, the last 100 years when it comes to conducting,

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because very often the maestro would just be,

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you know, not the nicest person.

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And that was the culture, the orchestral culture, you know,

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in previous times.

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But these days, it's different.

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And I think that's something that

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the business world honestly can really

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learn a lot from.

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Well, you've provided

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an excellent overview of your work and how you've found your way into that.

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I always like to kind of finish things up with a little bit of an open-ended question.

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You could kind of pick what you wanted to, uh, reply to.

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But, you know, one area is just that, uh,

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you know, having been in the accessibility profession for a long time,

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I've seen a lot of cycles.

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I've seen things that where I've thought we were making a huge amount of progress.

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At other times,

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I'm mystified by how little progress it seems, uh, things have been, uh, how,

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how little progress we've made maybe as a profession.

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Uh, so I was wondering if you have any, uh, thoughts on that.

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How does it feel for you in your tenure in terms of, uh, kind of the highs and lows? Right.

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Well,

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I think when you

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when we talk about accessibility,

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whether it's the digital environment or the built environment,

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it's very much

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hand in hand with

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disability inclusion.

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And for the disability community, it's really, you know,

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breaking down those barriers so that they can fully

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experience life.

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And so I think what I,

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you know,

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there's plenty of folks to fix your website

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or design it in such a way.

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But of course,

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we know that accessibility is only a moment in time

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because as soon as you change the content, it can, you know,

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perhaps break accessibility.

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So it's, it's a could be like a little bit like playing whack-a-mole to try to, you know,

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fix everything because it's, it's someone's going to come along, put in some new content,

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and it's going to break it.

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So I think and this kind of leans into what I mentioned about,

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you know, building into your processes.

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And so this notion of accessibility by design,

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how can we normalize

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accessibility so that it is part of everything that we do?

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Remember back in the day when responsive design was new

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and it was something that the business had to really think hard.

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Is this what we're going to invest in?

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You have to make a decision for different viewport sizes.

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Well, today, we don't even think about that,right?

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And so I think this is something where we would,

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we want to be there. We want to normalize accessibility.

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And so as I continue this work

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and also, you know, you know, starting,

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starting something new

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with a,

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a consulting company, AI1Y,

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that's new.

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It's and really

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with the idea of normalizing accessibility and getting it into

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a company's processes,

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their policies,

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their systems so that it becomes normalized

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and so that it is something that

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is you don't necessarily have to fight for all the time.

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And so I think that's perhaps why

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there may be ebbs and flows and ups and downs

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for accessibility professionals.

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It's because perhaps we're just

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going after the digital assets and trying to fix them

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when we need to normalize the whole way of working so that it's part of what we do.

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And so that's what I think, you know, I'll be continuing to focus on,

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particularly with a new consulting firm, AI1Y, and,

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you know,

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going forward in the future here.

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Well, that's a very great,

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excellent way to think about

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the kind of the evolution of

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where things have been going.

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In just in wrapping up,

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I always like to ask if there are just any final things you'd like to talk about

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that you're excited or passionate about, either personal life,

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professional life,

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things related to accessibility, things not related to accessibility.

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Are there what's

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getting you going as we move into the new year? Right.

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Well,

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one of the things that I started doing,

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I think as I

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was approaching the half-century mark

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a few years back,

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was getting into

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endurance sports with marathons,

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half marathons,

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and also triathlons

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and Ironman races.

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I'm a three-time Ironman.

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And, you know, back in 2022, had cancer in 2023, came back in 2024,

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and then again in 2025. So that's something that I really enjoy doing.

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And I often going back to what I mentioned about a little bit of imposter syndrome,

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especially working with the disability community

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and everything.

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And I think it's important that if it's something that we can do

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in life,

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we should definitely do it because we can. And so I often ask myself, "Why do I run?

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Why do I swim?

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Why do I cycle?"

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Because I can.

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I may not be able to do this forever,

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most likely.

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And I think for everyone,

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this is important to really embrace life.

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And if it's something that you enjoy doing and you can do it, do it because things,

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as we know,

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can always change

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in an instant. So yes.

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Well,

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thanks for sharing so much, you know,

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about your health challenges and the

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many details associated with

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your work.

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It's been great hearing about your journey and how accessibility fits into what

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you do.

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So, you know, thank you very much for participating in this. Absolutely.

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And thank you, Joe, for the invitation.

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So very much enjoyed our time.

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Have a great year, Steve. Thank you. You too.

About the Podcast

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Digital Accessibility
The People Behind the Progress

About your host

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Joe Welinske

Joe Welinske provides consulting for organizations needing assistance with digital accessibility.
With over 25 years of experience with accessibility, Joe can help you make sure you are enjoying the benefits of digital products that work for people with all abilities.
Joe has been credentialed as a Certified Professional in Core Competency Accessibility by IAAP and as a Section 508 Trusted Tester.
Joe serves as Accessibility Director at Blink - an evidence-driven design agency. As Director, Joe is responsible for helping Blink's practitioners to build accessibility into everything they do. He also evangelizes the need for accessibility with Blink's clients and partners.
Joe is a co-organizer of the Seattle Inclusive Design and Accessibility meetup group and he has served as the Secretary of the King County Metro Paratransit Advisory Committee.