Accessibility at. Halton Region
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1 Accessibility at Halton Region
2 Table of Contents About this Booklet...3 Halton Region s Statement of Commitment to Accessibility...4 About the Accessibility for Ontarians with Disabilities Act, How the Ontario Human Rights Code and the AODA Work Together...5 Understanding disability Understanding accommodation Accessible Customer Service...6 Examples of accessible customer service Keep in mind the following when assisting customers with disabilities What to do if you cannot serve a person with a disability Ontario Regulation 191/11- Integrated Accessibility Standards...8 General Requirements...8 Information and Communications Standards...9 o Accessible Formats and Communications Supports o Accessible Feedback Processes o Emergency Plans and Public Safety Information o Accessible Websites and Web Content Employment Standards...10 o Accommodation during Recruitment and Selection o Accommodation Planning o Accessible Formats and Communication Supports for Employees o Workplace Emergency Response Information o Return to Work Process o Performance Management, Career Development and Redeployment o Changes to Policies and Procedures Design of Public Spaces Standards...12 Resources...13 Additional Resources More Tips on Providing Accessible Customer Service 2
3 About this Booklet This booklet provides an overview of: Accessibility for Ontarians with Disabilities Act, 2005 (AODA), Ontario Regulation 429/07- Accessibility Standards for Customer Service (Accessible Customer Service Standards) and Ontario Regulation 191/11 - Integrated Accessibility Standards (IAS) Information on the Ontario Human Rights Code as it relates to persons with disabilities This resource is intended to assist Halton Region staff, volunteers and others who provide goods, services or facilities on behalf of the Region to comply with the Accessible Customer Service Standards and the IAS. There are references in this booklet to additional resources that are available on Halton s intranet site. Anyone who does not have access to Halton s intranet site but wishes to access these documents is asked to contact: Gabrielle Baldazzi Senior Policy Advisor , ext gabrielle.baldazzi@halton.ca 3
4 Halton Region s Statement of Commitment to Accessibility Halton Region is committed to meeting: The objectives and requirements of the Accessible Customer Service Standards and the Integrated Accessibility Standards. The accessibility needs of persons with disabilities with respect to Halton Region s programs, services and facilities. About the Accessibility for Ontarians with Disabilities Act, 2005 The AODA is the first law of its kind in Canada. Its goal is the development of standards to improve accessibility for people with disabilities across Ontario. Standards are rules organizations like Halton Region must follow to identify, remove, and prevent barriers to people with disabilities. Accessible Customer Service Standards were the first accessibility standards enacted by the Ontario Government. The standards set out a number of requirements on how to deliver customer service to people with disabilities. The Integrated Accessibility Standards were enacted in 2011 and include standards in the areas of: Information and Communications Employment Transportation (As Halton does not provide public transit this booklet does not cover this part of the regulation) Design of Public Spaces Additional standards may be developed by the Ontario Government. 4
5 How the Ontario Human Rights Code and the AODA work together The Ontario Human Rights Code (Code) works together with the AODA to promote equality and accessibility. The Code requires that people with disabilities be free from discrimination where they work, live and receive services and that their needs be accommodated. The AODA establishes accessibility standards. The human rights principles of the Code help to guide how AODA standards are to be met. Understanding disability The term disability covers a broad range and degree of permanent and temporary conditions, some visible and some not visible. A disability may have been present from birth, caused by an accident or developed over time. There are physical, intellectual and learning disabilities, mental health, hearing or vision disabilities, epilepsy, diabetes and other conditions. The Code protects people from discrimination based on past, present and perceived disabilities. Understanding accommodation The Code requires employers and service providers like Halton Region to accommodate people with disabilities and to bear the costs of this accommodation. Accommodation is the necessary and appropriate modification that may be needed to allow people with disabilities to access services or contribute equally in the workplace. The only exception is if an accommodation would cause undue hardship. There is no set formula for accommodating people with disabilities. For example, accommodation might include providing documents in an alternate format, using sign language interpreters, or changing a person s job duties. Accommodation is a shared responsibility. Everyone involved, including the person requiring the accommodation, should have a role in finding the solution. 5
6 Accessible Customer Service Delivering customer service to a person with a disability can mean many things, including understanding that individuals may need different types of accommodation to access programs and services. Halton Region is committed to providing customer service to people with disabilities in a manner that: Respects their dignity and independence and is sensitive to individual needs Ensures reasonable efforts are made to provide an opportunity equal to that offered to other customers to obtain and use our goods or services Allows people with disabilities to benefit from the same services in a similar way as other customers Is timely, considering the nature of the service and accommodation required Examples of accessible customer service A person who has low vision may need to have information read aloud to them. An individual with a learning disability may need to have instructions written down for them. To respond to the Accessible Customer Service Standards, Halton developed an Accessible Customer Service Policy and procedures to help staff deliver accessible customer service to people with disabilities. These documents are available on Halton s intranet site. Keep in mind the following when assisting customers with disabilities Assistive Devices Assistive devices are tools, technology or other mechanisms that help a person with a disability do day-to-day activities or tasks. They can include wheelchairs, walkers, white canes, portable magnifiers, assistive listening devices and personal oxygen tanks. Remember: Allow customers to use the device as needed, unless excluded by law Do not handle or move the device without the user s permission 6
7 Service Animals People who are blind or have vision loss may use a guide dog but there are other types of service animals as well. Service animals can assist people with other types of disabilities and can be trained to open doors, pick up items, predict seizures or alert someone to sounds such as doorbells or telephone rings. Remember: People with disabilities are permitted to be accompanied by their service animal and keep the animal with them in areas that are open to the public Do not touch, talk to or make eye contact with the service animal Support Persons A person with a disability may have a support person accompany them to help with communication, mobility, personal care or to access services. A support person may be a family member, friend, volunteer or paid personnel. Remember: Allow customers to be accompanied by their support person Speak directly to the customer, not the support person Do not discuss confidential matters in the presence of the support person without first getting consent from the customer Do not charge support persons an admission fee when a fee has already been paid by the attendee What to do if you cannot serve a person with a disability It is possible that from time to time there will be disruptions in service, such as elevators under repair, renovations that limit access to an area or technology that is temporarily unavailable. If a disruption in service is planned and expected, it is important to provide reasonable notice. Notice can be provided by several methods, such as on Halton s website, by telephone or in writing. In the event of an unexpected disruption in service, provide notice quickly and in as many ways as possible. Contact Access Halton by dialing 311 or and advise them of the following: Location and nature of the disruption Expected duration Alternate services that may be available Post signs in prominent locations advising of the disruption. 7
8 Ontario Regulation 191/11- Integrated Accessibility Standards (IAS) IAS - General Requirements The general requirements in the IAS are focused on the development of a multi-year accessibility plan, accessibility policies, training and how to consider accessibility in purchasing processes and when designing or purchasing self-service kiosks 1. To respond to these requirements Halton Region has developed: The Halton Region Multi-year Accessibility Plan, that outlines the actions Halton will take to meet the requirements of the IAS (available on Halton.ca) An Integrated Accessibility Standards Policy that provides direction on how Halton Region will comply with the IAS requirements (available on Halton.ca) A training program for Halton staff on the IAS and how the Ontario Human Rights Code relates to people with disabilities The Accessibility Obligations in Procurement Procedure to assist staff in meeting the purchasing requirements in the IAS (available on Halton s intranet site) 1 Halton Region does not have any self-service kiosks. Any future kiosks must incorporate accessibility features. These features could include Braille or large print numbers, high colour contrasting buttons, or adequate clearance space under the kiosk for wheelchairs and scooters. 8
9 Information and Communications Standards For people with disabilities, communicating and receiving information can be difficult if information is not provided in an accessible format or if an appropriate communication support is not in place. The IAS sets out what organizations need to do to create, provide and receive information and communication in ways that are accessible for people with disabilities. Accessible Formats and Communication Supports Alternatives to standard print are often referred to as accessible formats. Tools to help communication are referred to as communication supports. Examples of accessible formats and communication supports include an electronic document formatted to be accessible for use with a screen reader, reading written information to a person directly, and American Sign Language interpretation. When requested, you must provide information and communications in an accessible manner to people with disabilities. Remember to: Consult with the people making the request to determine their accessibility needs and the most appropriate format or communication support Provide the accessible format and/or communication support in a timely manner and at a cost that is not more than the regular cost charged to other people When it is not possible to convert the requested material, you need to provide the individual making the request with an explanation as to why the information is unconvertible and a summary of the information. For more information on how to respond to requests, see the Accessible Formats and Communication Supports Procedure which is available on Halton s intranet site. Accessible Feedback Processes Upon request, Halton Region must ensure that its feedback processes are accessible. Feedback can include information received through online surveys, or telephone questionnaires, comment cards or at public information centres and public consultation meetings. Remember when asking people for feedback, be prepared to receive and respond to this feedback in a format that works for them. This can include: Notifying the public about the availability of accessible formats and communication supports Arranging for accessible formats and communication supports on request 9
10 To help meet these requirements, Halton has already taken the following steps: Newspaper ads for public meetings and other events ask residents to let us know if they need any specific accommodation Alternate formats like Braille and large print as well as communication supports are provided, on request For more information on this requirement, see the Accessible Feedback Procedure on Halton s intranet site. Emergency Plans and Public Safety Information When providing emergency procedures, plans or public safety information to the public, organizations must be prepared to do so in an accessible format, upon request. Realtime emergency information (such as announcements and alarms) is not included in this requirement. For more information on this requirement, see the Providing Emergency Information in Accessible Formats Procedure on Halton s intranet site. Accessible Websites and Web Content The IAS requires that organizations conform to the World Wide Web Consortium s Web Content Accessibility Guidelines (WCAG) 2.0, initially at Level A and then increasing to Level AA. WCAG is an international standard for making websites and web content accessible to a broader range of users with disabilities. Halton s Social and Digital Media team has placed a high priority on website accessibility. This team continuously assesses and improves the accessibility of Halton.ca. Although this group is working toward the longer-term compliance requirements in the IAS, staff who create Word or PDF files may also have a role to play in ensuring the documents they upload are formatted to be accessible. Employment Standards The IAS requires employers like Halton Region to ensure accessibility is considered throughout the entire employment cycle, including recruitment and selection, performance management, career development, redeployment and return to work. The requirements help to create workplaces that are accessible and help employees reach their full potential. The Code requires employers to meet the accommodation needs of employees with disabilities to the point of undue hardship. The Employment Standards build on this and require employers to have processes in place to determine and address an employee s accommodation needs. The requirements: Apply to paid employees Do not apply to volunteers and other non-paid individuals 10
11 Accommodation during Recruitment and Selection Employers must notify employees and the public that accommodation can be provided to assist people with disabilities to participate in the recruitment process. Examples of accommodation can include documents in large print or a wheelchair accessible room. Halton s job posting web page includes a statement advising that accommodation for people with disabilities is available, on request. Also, when making offers of employment, Halton informs the successful candidates that disability-related accommodation is available. Accommodation Planning Employers must have a written process to develop documented individual accommodation plans for employees with disabilities. An accommodation plan is a formal way of recording and reviewing the workplace accommodations that will be provided to an employee with a disability. Halton Region s Work Accommodation Policy outlines a process to develop individual accommodation plans. This policy is available on Halton s intranet site. Accessible Formats and Communication Supports for Employees Employees with disabilities may request accessible formats and communication supports. Employers must consult with an employee to determine his or her accessibility needs and how best to accommodate them. Examples of this type of accommodation could include access to software like a screen reader or documents in an electronic format. If Halton Region employees require this type of accommodation, they are to discuss this need with their supervisor to determine the appropriate format or support to be put in place. Workplace Emergency Response Information Employers must provide individualized assistance and information for employees with a disability to assist them in a workplace emergency, if their disability makes assistance necessary and the employer is aware of the need. At Halton Region, a process has been put into place to address this requirement. Employees who may need assistance, because of a temporary or permanent disability, are asked to Asset Management (security@halton.ca) to begin a discussion on the assistance required by the employee in the event of a workplace emergency. Return to Work Process Employers are to develop a process for employees who have been absent because of a disability and who may need disability-related accommodation to return to work. If Halton employees need a disability-related accommodation to return to work, they are to partner with their supervisor, Human Resource Services and, if applicable, their union to develop a return-to-work plan. Halton s Workplace Safety and Insurance Board (WSIB) Policy and Short-term Disability Plan address Halton s return to work processes. Both documents are available on Halton s intranet site. 11
12 Performance Management, Career Development and Redeployment Employers must consider the accessibility needs and accommodation plans of employees with disabilities in performance management, career development and redeployment. When evaluating or giving feedback, this could mean providing performance management plans in alternate formats or providing feedback in a way that considers an employee s disability. An employee may have accommodation needs in order to succeed elsewhere in the organization or to take on new responsibilities in his or her current role. If so, the employee s accommodation needs will be taken into account. Under Halton s Redeployment and Job Change Policy, when employees are redeployed to a different position, department or facility, their accessibility needs, along with their individualized accommodation plan, will be taken into consideration. Changes to Policies and Procedures If there is a change to an existing policy or procedure on accommodating employees with disabilities, this information will be posted on Halton Region s intranet site and will also be communicated to staff by Managers. Design of Public Spaces Standards The Design of Public Spaces Standards focus on making it easier for people with disabilities to move through and use public spaces in their communities. 12 These standards include technical and public consultation requirements for the following public spaces: Recreational trails and beach access routes Outdoor public use eating areas Outdoor play spaces Exterior paths of travel, i.e., sidewalks or walkways, ramps, pedestrian curb ramps, accessible pedestrian signals, rest areas Accessible parking Service counters, fixed queuing guides, waiting areas The requirements apply when: Building new public spaces, or Planning significant alterations to existing public spaces Organizations will not have to retrofit public spaces to meet the requirements. Additional information on the specific requirements in the Design of Public Spaces Standards is available at In December 2013, the Ontario Government introduced a number of accessibility amendments to the Building Code. More information on these changes is available at
13 Additional Resources Resources A number of resources are available to assist you on Halton Region s intranet site and on Halton.ca. Ontario government resources can be found on the websites of: The Accessibility Directorate of Ontario Ontario Human Rights Commission More Tips on Providing Accessible Customer Service People with disabilities are people first individuals who happen to have a disability. Use person-first language which means saying a person with a disability rather than a disabled person. Make no assumptions about the type of disability your customer may have. Start by asking How can I help you? Never touch your customer without asking, unless it is an emergency. Physical Mobility Physical mobility may restrict a person s control or speed of movement, coordination and balance, ability to walk long distances, grasp some objects or sit or stand for long periods of time. Ask before you help. Respect personal space. If you are having a lengthy conversation with someone who uses a wheelchair or scooter, consider sitting so you are at eye level. 13
14 Deafness or Hearing Loss Hearing loss can range from mild to profound. Deafened and hard of hearing individuals may use hearing aids or other assistive listening and communication devices. A deaf person may use an American Sign Language interpreter. Before you speak, attract the customer s attention. Use eye contact or a wave to connect. Speak directly to the person who is deaf and not the interpreter. Look directly at the person, speak clearly and do not cover your mouth when speaking. Reduce background noise or move to a quieter location. If writing back and forth, keep sentences short. Blindness and Vision Loss There are varying degrees of vision loss. Many people who live with vision loss have some vision. Vision loss can reduce a person s ability to read text or signs, locate landmarks, recognize faces or see hazards. Some people with vision loss may use a guide dog or a white cane. Do not assume the customer cannot see you. Identify yourself when you approach a customer. Offer your elbow to guide. If accepted, walk slowly and identify obstacles before you come to them. Do not leave the customer without advising that you are leaving them. Be precise and descriptive with information like behind you on your left or the cup is by your right hand. Avoid phrases like over here. Deaf-Blindness A person who is deaf-blind has some degree of vision and hearing loss. Many people who are deaf-blind will be accompanied by an intervenor, a professional who helps with communication. Speak directly to the customer. Ask the customer how best to communicate. Do not leave the customer without advising that you are leaving them. Speech or Language People with speech disabilities may have problems with verbal communication. Stroke, hearing loss or cerebral palsy may result in difficulties with speech. Do not speak for these individuals or complete their sentences. Consider asking questions that require only short answers or a nod of the head. Give customers the time they need to get their points across. 14
15 Intellectual Disabilities Intellectual disabilities can mildly or more profoundly limit a person s ability to learn, communicate, do everyday activities or live independently. Do not make assumptions about what the customer can or cannot do. Be prepared to repeat or re-phrase your sentences. Be patient. Use plain language, keep sentences short. Give one piece of information at a time. Learning Disabilities Learning disabilities can range from mild to severe and can affect how a person receives, expresses or processes information. Ask your customer how best to accommodate their needs. Minimize distractions so that full attention is on communication. Avoid complex words or jargon. Keep sentences short and clear. Mental Illness Mental illness is not a single disease but a broad classification of many mental health illnesses, including depression, schizophrenia, bipolar, anxiety and eating disorders. Do not make assumptions about a person s abilities. Ask how you may help them. Be patient and reassuring. Speak in a calm manner and present one thought at a time. Use plain, clear language. Avoid complex words or jargon. 15
16 CAO-13053
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