Accessibility training guide for employees, volunteers and contractors

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Alternate accessible formats will be provided on request.

Accessibility for Ontarians with Disability Act (AODA)

In 2005, Ontario passed into law the Accessibility for Ontarians with Disability Act (AODA).  Under the AODA, businesses and organizations that provide good and services will have to meet accessibility standards with the goal of making Ontario fully accessible by 2025.

The Act obliges organizations in the public and private sectors to remove and prevent barriers for people with disabilities in five areas: customer service, information and communications, transportation, employment and the built environment.   

Disabilities can be visible, invisible, temporary or permanent.

What is Accessibility?

Giving people of all abilities opportunities to participate fully in everyday life without any barriers.

The AODA and the Human Rights Code

The Ontario Human Rights Code (the Code) and the AODA work together to promote equality and accessibility. The Code states that people with disabilities must be free from discrimination where they work, live and receive services, and that their needs must be accommodated.   The AODA has accessibility standards that organizations in Ontario must meet. The Code helps guide how these standards are met.

The Customer Service Standard, O. Reg. 429/07 was the first of five standards to become law as a regulation.  Training must be provided to new employees, volunteers, anyone who deals with the public and third parties.  

The Integrated Accessibility Standards Regulation (IASR), enacted in 2011, builds on the Accessibility Standard for Customer Service to help create a barrier-free Ontario.  The IASR addresses barriers to people with disabilities in the following four areas:

• Employment
• Information and Communications
• Transportation
• Design of Public Spaces

Who needs to be trained?

• All existing and new employees and volunteers.
• All persons who participate in developing the organization’s policies.
• All others who provide goods, services or facilities on behalf the organization.

Principles of Accessible Customer Service

Services, policies, practices and procedures will be provided in such a manner that they promote:

• Dignity and Respect
• Independence
• Integration
• Equal Opportunity

The Definition of Disability in the Ontario Human Rights Code   

Any degree of physical disability, infirmity, malformation or disfigurement caused by bodily injury, birth defect or illness.

• A condition of mental impairment or a developmental disability.
• A learning disability or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.
• A mental disorder.
• An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety & Insurance Act, 1997.

Communicating and Interacting with Persons with Disabilities

Now that you are familiar with AODA and the Accessibility Standards for Customer Service, we

need to look at a big part of accessible customer service, knowing how to communicate with

people with different disabilities.  Some of the best practices for communicating and interacting

with persons with disabilities are:

Terminology is important! When referring to someone with a disability it is extremely important that you put the person FIRST!

When interacting with the PUBLIC remember the acronym TALK

T – Take the TIME to ask – May I help you?                          

A– ASK – don’t assume – never assist unless asked

L– LISTEN attentively and speak directly to the customer.

K– KNOW the accommodations and special services that are available

Being able to interact and communicate with people with disabilities is a big part of providing accessible customer service. Sometimes the best approach is to ask a person with a disability how you can best communicate with them.

Training tips

Here are a few tips for interacting with people who have various disabilities.

People with physical disabilities

Only some people with physical disabilities use a wheelchair. Someone with a spinal cord injury may use crutches while someone with severe arthritis or a heart condition may have difficulty walking longer distances.

Tips:

• if you need to have a lengthy conversation with someone who uses a wheelchair or scooter, consider sitting so you can make eye contact at the same level
• don’t touch items or equipment (e.g., canes, wheelchairs) without permission
• if you have permission to move a person’s wheelchair, don’t leave them in an awkward, dangerous or undignified position, such as facing a wall or in the path of opening doors

People with vision loss

Vision loss can restrict someone’s ability to read, locate landmarks or see hazards. Some customers may use a guide dog or a white cane, while others may not.

Tips:

• when you know someone has vision loss, don’t assume the individual can’t see you; many people who have low vision still have some sight
• identify yourself when you approach and speak directly to the customer
• ask if they would like you to read any printed material out loud to them (e.g., a menu or schedule of fees)
• when providing directions or instructions, be precise and descriptive
• offer your elbow to guide them if needed

People with hearing loss

People who have hearing loss may be deaf, deafened or hard of hearing. They may also be oral deaf – unable to hear, but prefer to talk instead of using sign language. These terms are used to describe different levels of hearing and/or the way a person’s hearing was diminished or lost.

Tips:

• once a customer has identified themselves as having hearing loss, make sure you are in a well-lit area where they can see your face and read your lips
• as needed, attract the customer’s attention before speaking; try a gentle touch on the shoulder or wave of your hand
• if your customer uses a hearing aid, reduce background noise or move to a quieter area
• if necessary, ask if another method of communicating would be easier (e.g., using a pen and paper)

People who are deafblind

A person who is deafblind may have some degree of both hearing and vision loss. Many people who are deafblind will be accompanied by an intervenor, a professional support person who helps with communication.

Tips:

• a customer who is deafblind is likely to explain to you how to communicate with them, perhaps with an assistance card or a note
• speak directly to your customer, not to the intervenor

People with speech or language impairments

Cerebral palsy, hearing loss or other conditions may make it difficult for a person to pronounce words or may cause slurring. Some people who have severe difficulties may use a communication board or other assistive devices.

Tips:

• don’t assume that a person with a speech impairment also has another disability
• whenever possible, ask questions that can be answered with “yes” or a “no”
• be patient; don’t interrupt or finish your customer’s sentences

People who have learning disabilities

The term “learning disabilities” refers to a variety of disorders. One example is dyslexia, which affects how a person takes in or retains information. This disability may become apparent when a person has difficulty reading material or understanding the information you are providing.

Tips:

• be patient – people with some learning disabilities may take a little longer to process information, to understand and to respond, try to provide information in a way that takes into account the customer’s disability; for example, some people with learning disabilities find written words difficult to understand, while others may have problems with numbers and math

People who have intellectual/developmental disabilities

Developmental or intellectual disabilities, such as Down Syndrome, can limit a person’s ability to learn, communicate, do every day physical activities and live independently. You may not know that someone has this disability unless you are told.

Tips:

• don’t make assumptions about what a person can do
• use plain language
• provide one piece of information at a time

People who have mental health disabilities

Mental health issues can affect a person’s ability to think clearly, concentrate or remember things. Mental health disability is a broad term for many disorders that can range in severity. For example, some customers may experience anxiety due to mood swings, phobias or panic disorder.

Tips:

• if you sense or know that a customer has a mental health disability be sure to treat them with the same respect and consideration you have for everyone else
• be confident, calm and reassuring
• if a customer appears to be in crisis, ask them to tell you the best way to help

People who use assistive devices

An assistive device is a piece of equipment a person with a disability uses to help them with daily living (e.g., a wheelchair, screen reader, hearing aid, cane or walker, an oxygen tank).

Tips:

• don’t touch or handle any assistive device without permission
• don’t move assistive devices or equipment (e.g., canes, walkers) out of your customer’s reach
• let your customers know about accessible features in the immediate environment that are appropriate to their needs (e.g. public phones with TTY service, accessible washrooms)

Some examples of assistive devices that your organization might offer include:

• lift, which raises or lowers people who use mobility devices
• accessible interactive kiosk, which might offer information or services in braille or through audio headsets, wheelchairs

People who use service animals

There are various types of service animals who support people with various types of disabilities. People with vision loss may use a guide dog. Hearing alert animals help people who are deaf, deafened, oral deaf, or hard of hearing. Other service animals are trained to alert an individual to an oncoming seizure.

The law requires employers to allow service animals on the parts of your premises that are open to the public. In cases where the law prohibits them (e.g.: a service animal would not be allowed in the kitchen), provide another way for the person to access your goods and services.

Tips:

• avoid touching or addressing a service animal (it is not a pet, it is a working animal)
• if you’re not sure if the animal is a pet or a service animal, ask your customer

People with a support person

A support person, such as an intervenor, may accompany some people with disabilities. A support person can be a personal support worker, a volunteer, a family member or a friend. A support person might help a customer with a variety of things, such as communication, mobility, personal care or medical needs. Welcome support people to your workplace or business. They are permitted in any part of your premises that is open to the public.

Tips:

• if you’re not sure which person is the customer, take your lead from the person using or requesting your goods or services, or simply ask
• speak directly to your customer, not to their support person

Additional Requirements

Communication and Feedback – the Standard requires organizations in Ontario to establish and implement a process for receiving and responding to feedback about the way we provide goods or services to persons with disabilities.

People with disabilities should be able to provide feedback on services in person, by telephone, in writing or by mail, by e-mail, or by other electronic means ensuring that we take into account the varying communication needs of persons with disabilities.

An important part of giving feedback is knowing what will happen afterwards. The standard requires stating a specific course of action that IAG will take if a complaint is received.

General Requirements of the Integrated Accessibility Standards Regulation (IASR)

The Integrated Accessibility Standards Regulation (IASR), enacted in 2011, builds on the

Accessibility Standard for Customer Service to help create a barrier-free Ontario.  The IASR

addresses barriers to people with disabilities in the 4 areas listed:

• Transportation

• Information and Communications
• Employment
• The Building Environment – Interior / Exterior of buildings

The IASR requires organizations in Ontario to:

• Write an accessibility policy on how we will govern and achieve accessibility.   
• Incorporate accessibility criteria when procuring or acquiring goods, services or facilities. 
• Incorporate or consider accessibility features for self-service kiosks

Human Rights Code

The Ontario Human Rights Code provides for equal rights and opportunities and freedom from discrimination. The Code recognizes the dignity and worth of every person in Ontario and prohibits discrimination in employment on the grounds of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sexual orientation, gender identity, gender expression, age, record of offences, marital status, family status or disability.   

The Code protects people from discrimination because of past, present and perceived disabilities.  Customers, clients and tenants with disabilities also have the right to equal treatment and equal access to facilities and services. 

Human Rights in the Workplace

All employees are entitled to a harassment and discrimination free environment based on the human rights grounds named above.

In the workplace, employees with disabilities are entitled to the same opportunities and benefits as people without disabilities. This may include special arrangements or “accommodations” to enable them to fulfill their job duties.

Understanding The Duty to Accommodate

In the workplace employees are entitled to be accommodated based on all of the human right grounds named above.

Even when facilities and services are designed as inclusively as possible, you may still need to accommodate the individual needs of some persons with disabilities. Under the Code, the employer has a legal “duty to accommodate” persons with disabilities. The goal of accommodation is to allow persons with disabilities to equally benefit from and take part in services, housing, or the workplace. 

Accommodation means not denying people jobs or services in the first place if they can be accommodated. Accommodation is to be provided short of undue hardship.

Accommodating the individual needs of people with disabilities is a legal duty under the Code. This allows people to benefit equally and take part fully in the workplace, housing, and other services.

Determining appropriate accommodations for a person with a disability should be individualized and tailored to the needs of the person with a disability. There is no set formula for accommodation. Examples of accommodation include: providing printed material in alternative formats, modifying job duties, retraining.

The ultimate goal of accommodation should be full participation in society for people with disabilities. The accommodation process is a shared responsibility between the person with a disability and, in our situation, the employer. Parties have an obligation to engage cooperatively, share information and be open to possible accommodation solutions.

Undue Hardship

Accommodation is to be provided “short of undue hardship”. Accommodation doesn’t have to be provided if it causes undue hardship. Undue hardship is the legal limit of the duty to accommodate. It refers to situations where severe negative effects outweigh the benefit of providing accommodation.  Three factors are used to determine undue hardship: cost, outside sources of funding, and health and safety requirements.

If you need an accommodation:

• 1) Tell your employer about any needs related to your disability and your job duties, tenancy, or the services being provided.
• 2) Provide supporting information about your disability-related needs, including medical or other expert opinions where required.
• 3)  Get involved in seeking accommodation solutions to the best of your ability.
• 4) Accept requests for accommodation in good faith.

Applying Human Rights Principles

Employers should involve those who need accommodations in exploring solutions: They often know what works best for them. Make sure the process and solutions meet the individuals’ needs and promote privacy, dignity, and respect.

The Code and AODA accessibility standards are laws that work together to promote equality and accessibility in Ontario. Under the Code, employers must consider disability-related accommodation requests and provide timely accommodation, from recruiting and hiring through to retirement or dismissal.

Employment Standards

The Employment Standard assists companies in Ontario in removing and preventing barriers to persons with disabilities when posting jobs, during its recruitment and selection process, when implementing occupational health and safety programs, and during the rehabilitation and placement of employees with disabilities returning to work. 

IAG is committed to fair and accessible employment practices:

• IAG will accommodate people with disabilities during the recruitment and assessment processes and when people are hired.
• Our job advertisements will include a statement about the availability of accessibility accommodations upon request;
• When arranging an interview, accommodations will be offered and made available upon request;
• When making a job offer, we will again include a statement about the availability of accessibility accommodations upon request.

Moving Forward

Remember, accessibility is everyone’s responsibility and we all play a role in making IAG an accessible and welcoming place to work.

Customer Service, Integrated Accessibility Standards Regulations and Ontario Human Rights Code