integrated accessibility standards how-to workshop [read-only]

AODA Integrated Accessibility Standards: How-to Workshop

Leola W. PonNovember 23, 2011

OMHRA November 23, 2011

Today’s Plan…

• In-depth review of each IAS requirement:

• group work and interactive discussions

• Special topics: Information and Communication

Standards

• Special topics: Employment Standards


The Outcome…

• Map out your compliance strategy

• Develop your IAS accessibility policy

• Develop your IAS/human rights training program


Status of the Standards

• Customer Service

• Integrated Accessibility Standard

• Built Environment???

• etc.


Overview: Other Statutes

• AODA sets the floor

• Human Rights Code continues to apply

• If there is a conflict, the provision that provides the

highest level of accessibility for persons with

disabilities…shall prevail

• How determine or enforce?

• No AODA complaint mechanism for individuals

• Grievance? HRTO? Litigation?


Government Oversight & Enforcement

• Accessibility Directorate of Ontario

• Directors

• Licence Appeal Tribunal

• Court

• Fines ($50K/$100k)


“Integrated” Accessibility Standards

• Information and Communication

• Employment

• Transportation


Integrated Accessibility Standards

• Government of Ontario

• Large designated public sector organizations (50+

employees)

• Small designated public sector organizations (<50

employees)

• Large private / not-for-profit sector organizations (50+)

• Small private or not-for-profit sector organizations (<50)


AODA Dictionary: Selected Terms

• “accessible formats” may include, but are not limited

to, large print, recorded audio and electronic formats,

braille and other formats usable by persons with

disabilities;

• “communication supports” may include, but are not

limited to, captioning, alternative and augmentative

communication supports, plain language, sign language

and other supports that facilitate effective

communications



• “conversion ready” means an electronic or digital

format that facilitates conversion into an accessible

format

• “information” includes data, facts and knowledge that

exists in any format, including text, audio, digital or

images, and that conveys meaning



• “kiosk” means an interactive electronic terminal,

including a point-of-sale device, intended for public use

that allows users to access one or more services or

products or both

• “new internet website” means either a website with a

new domain name or a website with an existing domain

name undergoing a significant refresh


Integrated Standards (General) – Accessibility policies

• how the organization (will) achieve(s) accessibility

• statement of organizational commitment to meet needs

in a timely manner

• written policies, publicly available, accessible format

upon request

• January 1, 2013


Integrated Standards (General): Accessibility Plan

• multi-year, post on website and provide in an

accessible format upon request

• review and update at least once every five years in

consultation with persons with disabilities/ accessibility

advisory committee

• annual status report, post on website, provide in an

accessible format upon request

• January 1, 2013


Integrated Standards (General): Procurement of goods, services or facilities

• incorporate accessibility criteria and features

• if not practicable to do so, provide explanation upon

request

• January 1, 2013


Integrated Standards (General): Self-serve kiosks

• incorporate accessibility features when designing,

procuring or acquiring self-service kiosks

• January 1, 2013


Integrated Standards (General): Training

• IAS and Human Rights Code training to:

• all employees, and volunteers;

• all persons who participate in developing the

organization’s policies; and

• all other persons who provide goods, services or

facilities on behalf of the organization


Integrated Standards (General): Training

• appropriate to the duties of the employees, volunteers

and other persons

• as soon as practicable and ongoing (with changes to

policy)

• training records: date of training, number of trainees

• January 1, 2014


Integrated Standards (General): Accessibility reports

• Section 14 AODA

• “annually or at such other times”

• available to the public

• (electronically) signed by a director, senior officer or

other responsible person with authority to bind the

organization


Information and Communication

• exemptions:

• Products and product labels

• Unconvertible information or communications

• Information that the obligated organization does

not control directly or indirectly through a

contractual relationship (with exceptions)


Information and Communication

• If unconvertible, provide requester:

• an explanation as to why the information or

communications are unconvertible; and

• a summary of the unconvertible information or

communications


Information and Communications: FeedbackProcesses

• existing feedback processes must be accessible

• provide or arrange to provide accessible formats and

communications supports, upon request

• notify the public about their availability

• January 1, 2014


Information and Communication: Accessible formats and communication supports

• general obligation to provide or arrange for the

provision of accessible formats and communications

supports, upon request

• In a timely manner and based on specific needs

• At no additional cost (when compared to others)

• Consult with the individual

• Notify public of availability

• January 1, 2015


Information and Communication: Emergency plans/procedures and public safety

• information made available to the public

• Must provide in accessible format or with appropriate

communications supports, upon request

• January 1, 2012


Information and Communication: Websites and Web content

• Websites, web content (published after January 1,

2012), web-based applications, unless not “practicable”

• that an organization controls directly or through a

contractual relationship that allows for modification of

the product

• not “intranets”


Information and Communication: Websites and Web content

• January 1, 2014, new internet websites and web

content on those sites must conform with WCAG 2.0

Level A.

• January 1, 2021, all internet websites and web content

must conform with WCAG 2.0 Level AA (exceptions)


Information and Communication: Public Libraries

• Must provide access or arrange for the provision of

access to accessible materials where they exist

• Information on availability of accessible materials

• Optional for archival materials, special collections, etc.

• January 1, 2013


Employment

• employers and employees;

• does not apply to “volunteers” and other “non-paid”

• who is an “employee”?


Employment

• Compliance timeframes – with 1 exception

• January 1 2013 – Government

• January 1 2014 – Large public sector

• January 1 2015 – Small public sector

• January 1 2016 – Large private/non-profit

• January 1 2017 – Small private/non-profit


Employment

• Recruitment

• Must notify employees and the public about

availability of accommodation for applicants with

disabilities

• Applies to “recruitment processes”

• External advertisements

• Internal job postings

• interviews, etc.


Employment

• Recruitment, assessment or selection process

• notify accommodations are available upon request in

relation to the materials or processes to be used in

the recruitment process

• consult with the selected applicant

• provide or arrange to provide suitable

accommodation - take into account the applicant’s

accessibility needs


Employment

• Notify successful applicants

• the policies for accommodating employees with

disabilities


Employment

• Inform employees on disability policies (e.g.,

accommodation, human rights, return to work)

• provide info to new employees as soon as practicable

after starting job

• update if job accommodation policies change


Employment

• Accessible formats and communication supports for

employees

• consult (re: suitability of) and provide accessible

formats and communication supports for (a)

information that is needed in order to perform the

employee’s job; and (b) information that is generally

available to employees in the workplace.


Employment

• Workplace emergency response information

• individualized workplace emergency response

information

• if individualized information is necessary based on

type of disability

• if employer is aware of the need for accommodation

due to the employee’s disability


Employment


• with the employee’s consent, the employer can

share information to designated person

• as soon as practicable after the employer becomes

aware of the need


Employment


• review the information when:

• employee moves to a different work location;

• employee’s overall accommodations needs or plans are reviewed; and

• employer reviews its general emergency response policies.

• January 1, 2012


Employment

• Documented individual accommodation plans

• written process for the development of documented

individual accommodation, including:

• participation

• means for individualized assessment

• evaluation by an outside medical or other expert, at the employer’s expense


Employment

• written process for the development of documented

individual accommodation, including (…cont’d)

• representative or bargaining agent

• privacy

• frequency of review and updates, and how done

• reasons for denial of plan

• plan in a format that takes into account the employee’s

accessibility needs


Employment

• Documented individual accommodation plans shall,

• if requested, include any information regarding

accessible formats and communications supports

provided,

• if required, include individualized workplace

emergency response information

• identify any other accommodation that is to be

provided


Employment

• Return to work process

• outline the steps the employer will take; and

• use documented individual accommodation plans,

as part of the process


Employment

• Performance Management, Career Development and

Advancement, and Redeployment

• “shall take into account the accessibility needs of

employees with disabilities, as well as individual

accommodation plans”


Transportation

• Wide range of application from urban transit systems to

taxis to school buses

• Will also apply to organizations that provide

transportation on a less formal basis – universities,

colleges, hospitals, etc.

• Very technical specifications – 35 pages of the

regulation plus amended regulations under the HTA

AODA Integrated Accessibility Standards: How-to Workshop

Leola W. PonNovember 23, 2011

integrated accessibility standards how-to workshop [read-only]

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