January 1, 2012, is the date to complete all actions required under the Accessibility Standards for Customer Service and emergency preparedness requirements in the Integrated Accessibility Standards. The good news is, if your organization is obligated to report, you do not have to file with the government until December 31, 2012.
Why is this good news? Because many organizations are still making decisions and rushing to train staff. Some organizations are just learning about their obligations now. I am not advocating finishing the work late, but if you are late, there are resources—accessibility experts, e-learning courses, the Accessibility Directorate website and webinars—ready to be of service. Better yet, take the 30-day trial option on Accessibility Standards PolicyPro to provide guidance.
If you are cutting corners now to meet compliance, schedule a proper awareness program about persons with disabilities as soon as possible. Changing attitudes is the most difficult part of this agenda. Most people believe their efforts to remove barriers will burden them financially, when the reality is that historical attitudes have burdened persons with disabilities and placed them in this position to recognize and remove barriers ASAP.
Depending on the size of your organization, a coordinated effort between staff responsible for AODA compliance and experts can rapidly help your organization meet its obligations. By preparing your policies, practices and procedures prior to staff training, you can save time and money when disseminating the necessary information. Combining the generic legal portion of staff training about the customer service standards with your actual policies, practices and procedures provides practical experience for the attendee.
There are concerns about the emergency preparedness requirements under the Integrated Accessibility Standards. I would advise all organizations to comply on time. Since the law will be in effect as of January 1, 2012, one can imagine if a disaster should strike, whether your insurer will use these requirements against you if procedures are not in place.
Let us quickly recap the obligatory actions to complete. Under the customer service standards, if you have one employee or more, your obligations are to:
- Establish policies, practices and procedures on providing goods or services to people with disabilities
- Use reasonable efforts to ensure that your policies, practices and procedures are consistent with the core principles of independence, dignity, integration and equal opportunity
- Set a policy to allow people to use their personal assistive devices on your premises and about any other measures your organization offers (assistive devices, services, methods) to help people to access your goods and services
- Communicate with persons with a disability in a manner that takes into account the person’s disability
- Allow people with disabilities to be accompanied by their service animal in those areas of your premises that are open to the public, unless the animal is excluded by another law
- If the service animal is excluded by law, then have an alternative method to provide services
- Allow customers with disabilities to be accompanied by a support person in premises open to the public
- Provide notice ahead of time on what admission, if any, you will charge for the support person of a person with a disability
- Provide notice when facilities or services on which customers with disabilities rely are temporarily disrupted.
- Train staff, volunteers, contractors and other third parties who interact with the public on your behalf on topics outlined in the customer service standard
- Train staff, volunteers, contractors and third parties who are involved in developing your policies, practices and procedures on topics outlined in the customer service standard
- Establish a process for people to provide feedback on how you provide goods or services to people with disabilities
- Include in this feedback process how you will respond and take action on complaints
- The information about your feedback process must be readily available to the public
There are additional requirements for designated public sector organizations or other providers with 20 or more employees. Employers must:
- Document policies, practices and procedures for providing accessible customer service, and meet other document requirements in the standard.
- Notify customers that required documents are available upon request.
- When providing the required documents to a person with a disability, provide the information in a format that takes into account the person’s disability.
Employers with 20 or more employees must include the following in their documentation:
- General information on policies, practices and procedures
- Policies, practices and procedures on service animals and support persons
- Notice of temporary disruption of services or facilities including the steps to take
- A training policy
- A description of the feedback process
With respect to the emergency preparedness provisions of the Integrated Accessibility Standards:
- Under the information and communication standard, if your organization provides emergency procedures, plans or public safety information that is available to the public, then you will provide the plan in an accessible format upon request
- Under the employment standard, if the employer is aware that an employee has a disability that requires accommodation in an emergency, the employer must provide the employee with individualized emergency response information in an accessible format; employers must also designate someone to provide assistance during the emergency
- In the transportation standard, all conventional and specialized service providers will make available to the public information on accessibility equipment, features of their vehicles, routes and services, and provide this information in an accessible format upon request
What is the carrot the province is offering for early filing? Your organization may be showcased in a video so that others can learn from your experience. Free advertising!
I do have one question for the government that will not likely receive a response. Why did you pick New Year’s Day for compliance in action and New Year’s Eve for filing? This is like getting a bill for your driver’s licence on your birthday. Who comes up with these dates? No wonder people complain!
Happy New Year everyone! We will chat again next year. I look forward to hearing about your experiences and any questions.
Suzanne Cohen Share
Access (SCS) Consulting Services