Disproportionate Burden Assessment

What is in scope

The scope of this assessment covers a total of 770 PDF and Microsoft Office documents created and uploaded to our website.

We are committed to either removing these documents from our website completely or converting them into fully accessible HTML web pages. We hope to have completed this process by 31 December 2024.

To help us with this process, we will be looking at analytics and prioritising the documents which are accessed the most frequently.

What is not in scope

We are not required to fix documents published before 23 September 2018 if they are not essential to providing our services.


There are several benefits of either removing or converting these documents:

  • The documents would be fully accessible to all of our website users
  • The documents would be easier to search
  • Outdated documents would be removed, reducing clutter and potential confusion


Our assessment of the burden of either removing or converting these documents is:

  • Our yearly budget for the website is £2,600. This covers web hosting, security certificates and software.
  • There are 770 documents created by Hull University Teaching Hospitals NHS Trust and published on our website
  • Each document would require a significant number of hours of work to be put into a fully accessible format, depending on complexity and length
  • Many of the documents have multiple authors and significant ratification processes
  • Many of the documents contain complex tables, graphics, charts, diagrams and embedded multimedia
  • Very few people access these documents, particularly the older ones – reports show these are accessed approximately 1-2 times per month
  • Requests for accessible versions will always be met on an ad hoc basis, if required
  • The estimated cost of converting these documents into an accessible HTML format is £40,306.99.
  • We estimate that the burden will end at the point where older versions of documents are succeeded by newer, more accessible versions. We aim to have this complete by 31 December 2024.

How we worked out the estimated cost of the burden

  • There are 770 documents to be converted
  • We estimated each document would take an average of 2.34 hours to convert, with some taking less time and some taking more time
  • This totals 1,801.8 working hours
  • The hourly rate for the employee is £22.37
  • 1801.8 x 22.3704 = £40,306.99


In the case of the many documents which are infrequently accessed, the number of employee hours required to convert them into an accessible HTML format would be very high. Additionally, ad hoc requests for accessible versions of documents will always be met.

We consider there is a significant disproportionate burden on the organisation in terms of cost, as it relates to employee hours, particularly where there is no evidence of these documents being accessed regularly.

Assessment Date: 19 September 2023