In Ontario, under the Accessibility Standards for Customer Service, as of January 1, 2012, organizations are required to publicly notify customers of temporary disruptions of services or facilities or if they are expected to be temporarily unavailable in the near future, including the steps to take to access alternative methods. This includes planned as well as unplanned service disruptions. Any disruption of services or facilities that people with disabilities need to access your products or services requires proper notification. You will provide a description of alternative facilities or services if they are available. This notice is important to people with disabilities because they often go to a lot of trouble to access your goods or services. For example, they may book accessible transit, or arrange for someone to drive them.
First you want to identify the services you offer that people with disabilities rely on. Examples of services people with disabilities rely on are elevators and escalators. Notification must include reasons for the disruption and the estimated duration. You will provide a description of alternative facilities or services if they are available. Notice may be provided in easily seen places on the organization’s premises, on a website if any, or by any reasonable method. When posting your notice on the premises choose places that rapidly provide information to the public.
One area you might not have considered is an accessible washroom or any washroom. If you provide this amenity and customers rely on it, include this on the list of things that require notification when disrupted. Feel free to take this policy and extend it to benefit the general population. The notifications you will post in an appropriate public place should not target people with disabilities. You would just use words like Dear guest, patron, customer, etc. Perhaps a notification for the general bathroom will also please all your customers. Anyone who counts on this amenity can attest to the fact that a disruption can be a huge inconvenience.
A best practice is to prepare the templates in advance and decide where you want to post the notification. You may want specific templates prepared for chronic problems or anything with a regular scheduled maintenance shutdown. Allocate the responsibility to specific staff or departments and let them know the notification has to answer all of these questions:
- What is the reason for the disruption?
- How long do you anticipate the disruption will last?
- What alternative facilities, if any, are available?
If the disruption means the customer cannot access your services, you may also inform them on your website, if you have one, and perhaps on the telephone. Some organizations may decide to post the disruption notice on the pole by the parking spots for people with disabilities. This tells a person with a disability not to bother disembarking and proceed to find what they need elsewhere. Do what you reasonably can to provide information that can reach your customer as efficiently as possible.
Since you are obliged to provide a reason for the disruption you may want to train staff to use specific words that do not cause alarm or provide unnecessary visual details. Some reasons may just be regular maintenance or upgrades causing a temporary disruption of service. Sometimes the problem is so simple you may want to use words like “a broken pipe”.
Example: A staff person discovers a disruption and informs the staff person in charge of calling maintenance. The second staff person is in charge of placing the notice signs in conspicuous (public) places and informing the persons in charge of websites and the main telephone switchboard about the service disruption. The person at the switchboard may be taught to include a message about the disruption on the automated telephone customer service system. If you are aware the customer cannot gain access to your facilities, and you expect the disruption to last a long time, you will want other methods to continue to provide customer service. Prepare staff to offer alternatives and be creative to keep customers satisfied.
Make your policy and procedures clear to everyone
Example: The only elevator to reach your organization is under repair for the expected duration of three days. You post the notice of disruption of service on your website, post a sign at the site of the disruption and post a notice at the entrances. You offer a different method to reach the customer. You may offer appointments to meet the customer at a mutually agreeable and accessible location.
If you are an organization obligated to keep documentation, you will:
- Record who is responsible for what action
- Decide what level of detail about your organization you want to provide the public and government
- State in your policy that you will provide a notice of disruption of services, and include the legal obligations
- Decide if you want to include the departments responsible for providing notification; you may not want to provide a specific name of a person responsible, but you may want to include the title of the person or the department in charge
Assess all the assistive devices and services you provide people with disabilities and come up with a plausible case scenario in the event there is a disruption of service. You know your minimum legal obligations and what work needs to be done.
You may choose to provide more detail, for example, so when a disruption occurs, the customer with a disability is aware you have a telephone sales system or you are offering to meet the person with their order in another location. You may want to communicate in your public policy what your general alternatives are, to inform people with disabilities, reduce the number of questions on simple topics and advance your customer service. If you are an obligated organization with 20 or more employees, make legal documentation requirements work in your favour to increase your effectiveness.
What if all of your services are disrupted?
Generally, disruptions to all of your services, such as during a power outage or during a labour dispute, do not require this special notice. However, if the disruption has a significant impact on people with disabilities, you should provide notice of the disruption of service.
Why is this regulation just for people with disabilities?
People with disabilities need this information in order to proceed with their daily plans and change them when necessary. On the other hand, this is just good customer service that really benefits everyone. Your clients will likely appreciate the additional information. A parent with a baby carriage or anyone using a cart benefits when they are informed the elevator or escalator is not functioning. A person with a baby carriage or a few children has become used to using the accessible washroom that often has a dual purpose of acting as a family room. There are so many benefits everyone enjoys now because of laws originally intended to aid people with disabilities. Thumbs up on the Accessibility for Ontarians with Disabilities Act, a great way to say people with disabilities need something in order to have equal access, when in reality we all benefit.
Suzanne Cohen Share, M.A., CEO
Access (SCS) Consulting Services o/b 623921 Ont. Ltd.
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