This was reported to me by our accessibility team. I haven't actually asked them why it is an accessibility problem, but it's certainly not ideal if all the help documents are just titled 'Help' (as they are).
The attached patch changes help to work as follows:
1) If you include in your help file, <title>something</title>, then the HTML title becomes 'Help - something'.
2) If your help file has any heading e.g. <h1>Whatever</h1>, then the HTML title becomes 'Help - Whatever' (for the first heading)
3) If your help file has no headings either then the title is still just 'Help'.
This patch could be applied to 1.9 but I'm not particularly recommending that, HEAD would be ok...