ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE UPDATE
Send Us Feedback on Our Latest Draft Brief to the Wynne Government on Proposed Revisions to the 2007 Customer Service Accessibility Standard -- and -- On YouTube, You Can Now Watch AODA Alliance Chair David Lepofsky’s March 3, 2016 Interview on The Agenda With Steve Paikin
March 4, 2016
1. We Need Your Feedback Fast!
We eagerly want your feedback on our latest draft brief to the Wynne Government on its weak proposed revisions to the already-weak 2007 Customer Service Accessibility Standard. We set out this draft brief below. It is a joint effort by the AODA Alliance and the ARCH Disability Law Centre. We acknowledge with thanks ARCH’s collaboration on this project.
In this draft brief, we list readily achievable actions that obligated organizations should be required to take to help ensure accessible Customer Service. We need more examples from you, and we need them very quickly.
Please send your feedback and ideas to us at firstname.lastname@example.org no later than noon on Friday, March 11, 2016.
Some examples in this brief focus on all disabilities. Other of the examples proposed in this draft brief focus to some extent more on some disabilities than others. We want to effectively address the needs of all people with all kinds of disabilities.
We welcome your ideas for specific, concrete, readily achievable measures for ensuring accessible customer service that would address all disabilities, or that would address the needs of specific disabilities, whether or not you already see them already reflected here.
In summary this draft brief addresses:
- Ensuring that obligated organizations make a clear commitment to provide barrier-free and accessible customer service and designate an employee within their staff to ensure accessible Customer Service is provided.
- Ensuring that obligated organizations let customers with disabilities know about the nearest available accessible washroom and transit locations.
- Providing accessible public washroom signs.
- Posting scent-free policy signage.
- Establishing accessible parking spots.
- Addressing physical barriers to accessible customer service.
- Ensuring accessibility of “point-of-sale” and immovable debit/credit information transaction machines (ITMs).
- Ensuring accessibility of cash registers or tills with price displays
- Providing accessible drug prescription labels and information.
- Providing accessible restaurant menus.
- Providing visual fire alarms.
- Ensuring accessibility of financial services and of provincially-regulated financial institutions that offer bank-like services.
- Reducing loud music in public spaces where customer service is offered.
Each of these measures is required by the Ontario Human Rights Code. Each would help obligated organizations achieve their organizational goals. In the case of businesses, these measures will help them get more customers and make more money.
The draft brief refers to an Appendix B we are considering including. We do not provide it here, and may end up not including it.
2. On YouTube, Watch AODA Alliance Chair David Lepofsky’s March 3, 2016 Interview on The Agenda With Steve Paikin
If you did not get a chance to watch it live, we encourage you to go to YouTube to watch online the March 3, 2016 interview that AODA Alliance Chair David Lepofsky gave on The Agenda with Steve Paikin. It focused on the many accessibility barriers still facing students with disabilities in Ontario education system.
This interview shows why Ontario needs the Wynne Government to at last agree to develop an Education Accessibility Standard under the Accessibility for Ontarians with Disabilities Act. After more than five years of thinking about it, it is time for the Wynne Government to make a decision, and just say “Yes!”
You can always send your feedback to us on any AODA and accessibility issue at email@example.com
To sign up for, or unsubscribe from AODA Alliance e-mail updates, write to: firstname.lastname@example.org
We encourage you to use the Government’s toll-free number for reporting AODA violations. We fought long and hard to get the Government to promise this, and later to deliver on that promise. If you encounter any accessibility problems at any large retail establishments, it will be especially important to report them to the Government via that toll-free number. Call 1-866-515-2025.
Please pass on our email Updates to your family and friends.
Why not subscribe to the AODA Alliance’s YouTube channel, so you can get immediate alerts when we post new videos on our accessibility campaign.
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Please also join the campaign for a strong and effective Canadians with Disabilities Act, spearheaded by Barrier-Free Canada. The AODA Alliance is the Ontario affiliate of Barrier-Free Canada. Sign up for Barrier-Free Canada updates by emailing info@BarrierFreeCanada.org
ARCH Disability Law Centre
Brief to the Ontario Government on Necessary Revisions to the 2007 Customer Service Accessibility Standard
March 4, 2016
Note: This is only a draft and does not constitute the position of the AODA Alliance or ARCH Disability Law Centre
1. Introduction and Summary
In this brief, the Accessibility for Ontarians with Disabilities Act (AODA) Alliance and ARCH Disability Law Centre (ARCH) present concrete, workable, and much-needed revisions to strengthen the Customer Service Accessibility Standard. These revisions can be easily implemented by the Government without excessive cost or delay.
This brief is a joint effort of the AODA Alliance and the ARCH Disability Law Centre. The AODA Alliance is a voluntary non-partisan coalition of individuals and organizations. Its mission is: "To contribute to the achievement of a barrier-free Ontario for all persons with disabilities, by promoting and supporting the timely, effective, and comprehensive implementation of the Accessibility for Ontarians with Disabilities Act."
To learn about us, visit: http://www.aodaalliance.org.
Our coalition is the successor to the Ontarians with Disabilities Act Committee. The ODA Committee advocated for over ten years for the enactment of strong, effective disability accessibility legislation. Our coalition builds on the ODA Committee’s work. We draw our membership from the ODA Committee's broad, grassroots base. To learn about the ODA Committee's history, visit: http://www.odacommittee.net
ARCH Disability Law Centre is a specialty community legal clinic dedicated to defending and advancing the equality rights of people with disabilities in Ontario. It is a not-for-profit charitable organization whose staff report to a volunteer elected Board of Directors, at least half of whom are people with disabilities. Our goal is to advance and defend the rights of persons with disabilities. To learn more, visit: www.archdisabilitylaw.ca.
On December 3, 2015, after getting input from its supporters, the AODA Alliance sent the Wynne Government a detailed submission on the Government’s proposed revisions to the Customer Service Accessibility Standard and Integrated Accessibility Standards Regulation. Our December 3, 2015 submission showed that the Government’s proposed revisions would not significantly improve the accessibility of Customer Service for people with disabilities in Ontario. In some ways, they would make the weak 2007 Customer Service Accessibility Standard even weaker. They would break Premier Wynne’s promise to never reduce any accessibility protections under the AODA. They would preserve an unlawful provision in the Customer Service Accessibility Standard which impermissibly creates an accessibility barrier. To see the AODA Alliance’s December 3, 2015 submission to the Wynne Government on its proposed revisions to the 2007 Customer Service Accessibility Standard, visit http://www.aodaalliance.org/strong-effective-aoda/12042015.asp
ARCH Disability Law Centre fully endorsed the AODA Alliance submissions and presented some additional submissions to the Government.
As the final report of the Mayo Moran AODA Independent Review showed in 2015, Ontario is now behind schedule for reaching full accessibility by 2025. It has not made a significant difference in the lives of people with disabilities, even ten years after the AODA was passed. The revisions that we propose would go a good way to changing that direction in a positive way, in so far as accessible Customer Service is concerned.
In this new brief, we make specific recommendations for revisions that the Wynne Government should enact to strengthen the Customer Service Accessibility Standard. Our recommendations are readily achievable in a short time, with little or no cost. Where we can, we indicate where comparable measures have been spelled out either in laws in other jurisdictions, or in “best practices” identified by government bodies, or professional/business associations. These revisions, when implemented, will improve organizational or business success and help generate profits for obligated organizations. They reflect the current requirements of the duty to accommodate customers with disabilities which the Ontario Human Rights Code has imposed for one third of a century.
We urge the Ontario Government to assign senior Government officials to sit down jointly with representatives from the disability community, the business sector, and the broader public sector, to discuss our recommendations and work up an agenda for improving the 2007 Customer Service Accessibility Standard. We offer the proposals in this brief as examples of needed revisions. Through that dialogue, others will no doubt emerge.
This brief explores a few examples of low or no cost readily-achievable requirements that will improve the Customer Service Standard and make it more meaningful for persons with disabilities. The Customer Service Accessibility Standard should be revised to include readily-achievable action now, and longer term action as well. The examples of revisions here propose address:
a) Ensuring that obligated organizations make a clear commitment to provide barrier-free and accessible customer service and designated an employee within their staff to ensure accessible customer service is provided.
b) Ensuring that obligated organizations let customers with disabilities know about the nearest available accessible washroom and transit locations.
c) Providing accessible public washroom signs.
d) Posting scent-free policy signage.
e) Establishing accessible parking spots.
f) Addressing physical barriers to accessible customer service.
g) Ensuring accessibility of “point-of-sale” and immovable debit/credit information transaction machines (ITMs).
h) Ensuring accessibility of cash registers or tills with price displays
i) Providing accessible drug prescription labels and information.
j) Providing accessible restaurant menus.
k) Providing visual fire alarms.
l) Ensuring accessibility of financial services and of provincially-regulated financial institutions that offer bank-like services
m) Reducing loud music in public spaces where customer service is offered.
We acknowledge that a number of the recommendations set out here address barriers addressing people with mobility disabilities or vision loss, hearing loss or dyslexia. We urge that revisions to the Customer Service Accessibility Standard ensure that needed accessibility and accommodations are provided to customers with all kinds of disabilities, including those with intellectual or learning disabilities, mental health conditions or communication disabilities. We welcome added ideas that will focus on recurring barriers facing the spectrum of different disabilities.
Appendix A provides the Government with a history of the Customer Service Standard and the Government’s review of it.
Appendix B sets out the Recommendations for Barrier-Removable and Accessibility that were informed by a consumer consultation in 2013.
2. Selected Customer Service Barriers and their Readily-Achievable Solutions
a) Commitment to Barrier-Free customer Service and Designated Accessibility Customer Service Representative
As part of the accessible Customer Service policy that the Customer Service Accessibility Standard requires, obligated organizations should be required to have a commitment to provide accessible, barrier-free Customer Service to customers with disabilities. This should be publicly posted, e.g. on the obligated organization’s website.
All organizations that provide goods, services or facilities to customers should designate an employee, such as an existing employee, to assist persons with disabilities and ensure compliance with customer service standards. This “one-stop-shopping” approach to accessible Customer Service helps organizations ensure accessible Customer Service while helping customers with disabilities know whom to approach. This practice is mandated under the Americans with Disabilities Act (s. 35.107). Moreover, provincially-administered court facilities each have a designated Courts Accessibility and Accommodation Coordinator appointed from among their court services staff.
If an obligated organization has a website, it should be required to clearly identify that there is an accessible Customer Service representative in their organization, and how to contact them. If the obligated organization has other ways of announcing this to the public, such as on a telephone interactive voice response system, it should be required to announce that position on that line from time to time.
b) Letting Customers With Disabilities Know About Nearest Accessible Washroom and Transit Locations
Where obligated organizations have not yet achieved full accessibility, customers with disabilities still need vital information. When persons with disabilities are unable, due to accessibility barriers, to use the washroom in, or park near, an obligated organization that provides goods, services or facilities, those obligated organizations lose customers.
As an interim measure, a customer service accessibility representative could easily tell a customer with a relevant disability the location of the closest accessible washroom, parking or public transit stop. This measure would cost nothing, improve awareness of existing barriers, and would be quite helpful to customers with disabilities.
c) Providing Accessible Public Washroom Signs
When obligated organizations have public washrooms, they should be required to post accessible signage i.e. signs that include Braille, large print and raised letters. These are not expensive. They are important for independent access.
The US Department of Justice requires signage to be acquired under the Americans for Disabilities Act (ADA) even in temporary situations such as emergency shelters. The signs should be installed “with raised characters and Braille on the wall adjacent to the latch side of the door and centered 60 inches above the floor and leave the existing sign in place on the door if removing it will damage the door,” (ADA Checklist for Emergency Shelters, 2007, pg. 42).
d) Posting Signage About Scent-Free Policy
Individuals with invisible disabilities such as Multiple Chemical Sensitivities (MCS), or Idiopathic Environmental Intolerance (IEI), can easily be accommodated through the expanded visibility of no scent/fragrance policies. In addition, offices using cleaners should be required to use the least toxic cleaning products. All benefit from fewer toxins in the air. This signage will serve as a public education tool. Massey Hall and Roy Thompson Hall have signage posted and messages on their phone services while customers wait to purchase tickets, announcing their scent free policies. See also the University of Toronto’s Scent-Free Guidelines and Information Poster (https://www.utm.utoronto.ca/health-safety/information-campaigns/u-t-scent-free-guideline are also excellent an excellent example.
Posting signs in stores, offices, and customer service centers will promote understanding of, and responsiveness to no scent policies. Again, posting these and including them on telephone voice response systems costs little.
e) Accessible Parking
Parking can be the first interaction between customers and an obligated organization. While longer term accessibility measures are incorporated or implemented in the built environment, interim or temporary measures may be necessary and very helpful. If a parking lot does not contain any or enough accessible parking, and when there is an available curb cutout in place, a temporary measure can be put in place to secure more parking.
The Americans with Disabilities Act Checklist for Polling Places, a document produced for comparable temporary accessibility needs by the US Department of Justice, describes the process for adding additional accessible parking spaces:
“Find a relatively level parking area near the accessible entrance and then designate the area for accessible parking spaces and adjacent access aisles. Use three parking spaces to make two accessible parking spaces with an access aisle. Traffic cones or other temporary elements may be used to mark the spaces and access aisles. Provide a sign designating each accessible parking space and make sure the access aisle of each space is connected to the accessible route to the accessible entrance.” (2004, pg. 8).
This parking measure must be accompanied by a curb ramp in order to achieve true accessibility as set out in the Oregon State University Built Environment Best Practices (Part 2: 5C3a, http://oregonstate.edu/accessibility/bestpractices).
Alternatively, when there is no nearby accessible curb cutout and the obligated organization does not have a curb ramp, the organization’s accessible customer service representative should at minimum become aware of and tell customers with disabilities about the nearest accessible parking spots available for that could be use by customers.
A recent example demonstrates this point. Various tribunals were using a local courthouse for their hearings. The police parked in all of the “handicapped” parking spots close to the court house, leaving persons with disabilities to park at the back end of the parking lot. This caused serious difficulties for persons with disabilities, especially in bad weather. They were late for their hearings. Sometimes people could not get to their hearings at all. This was only resolved when ARCH intervened and raised the possibility of a human rights application.
f) Physical Barriers to Accessible Customer Service
Despite promising to do so “promptly” in the 2011 Ontario election, the Ontario Government has not enacted a comprehensive Built Environment Accessibility Standard under the AODA. 2013 amendments to the Ontario Building code did not require accessibility retrofits for existing buildings that are not undergoing a significant renovation, or in parts of those buildings where no significant renovation is underway. Moreover, those Ontario Building code amendments did not ensure that new buildings, or significant renovations, were fully accessible and free of physical barriers. The “Public Spaces” accessibility requirements in the Integrated Accessibility Standards Regulation, enacted under the AODA in 2012, only provide for limited accessibility, free from physical barriers, in a limited range of public spaces.
The 2014 final report of the Mayo Moran AODA Independent Review concluded that there is a pressing need for action on built environment barriers, especially in the context of retrofits to existing buildings. We conclude that built environment barriers must be addressed, where appropriate, in other accessibility standards enacted under the AODA, to fill the huge gaps that remain.
Physical accessibility is an indispensable part of accessible Customer Service. If customers with disabilities cannot even get into an obligated organization where goods, services or facilities are provided to the public, they are already placed in a very disadvantageous position due to their disability.
As such, it is appropriate to address physical barriers to accessible Customer Service through revisions to the Customer Service Accessibility Standard. Nothing prevents the Government from addressing physical accessibility barriers through the Customer Service Accessibility Standard where they impede access to Customer Service.
As a first step, interim measures are immediately needed to address physical barriers that impede accessible Customer Service. We offer examples here:
Many establishments that offer goods, services or facilities to the public have one, two or three steps at their entrance. They should be required to at least provide a movable ramp, except where to do so would cause undue hardship within the meaning of the Ontario Human Rights Code
The provision of transportable ramps is a necessary accommodation for persons with mobility disabilities. A growing number of obligated organizations have accepted this. Ontario’s ground-breaking “Stop Gap” organization offers such temporary ramps at low cost. It has been accepted by many businesses and public sector organizations
While snow is an inevitable reality in Ontario winters, piling it up on accessibility ramps and paths of travel need not be. The Customer Service Accessibility Standard should require that piling snow in those areas should be avoided, except where it is impossible to do so.
Obligated organizations should also be required to remove movable physical obstacles from main paths of travel within an obligated organizations Customer Service areas. For example, where signage can be situated in a place where customers with vision loss or other disabilities won’t collide with it, this should be preferred over placing it in the middle of main traffic halls or aisles. Head-level obstructions should be required to be avoided, especially where the obstacle cannot be safely detected by the use of a white cane.
The Customer Service Accessibility Standard should be revised to designate required widths of aisles and heights of shelves for display of products for sale. These can be varied depending on whether the obligated organization is a large chain store, or a medium-size establishment, or a small “mom and pop” local store. Retail establishments want to know what they need to do to ensure accessibility and don’t want to each have to spend the time and money to reinvent the wheel in this regard.
An obligated organizations which, despite these efforts, cannot assure full physical accessibility of their public areas should be required by the Customer Service Accessibility Standard to create and publicize alternative ways for people with disabilities to access their goods, services, or facilities. This could include a phone number to call for curb-side shopping, offers for a store employee to help a person shop from home using Skype etc.
g) Ensuring Accessibility of “Point-of-Sale” and Immovable Debit/Credit Information Transaction Machines (ITMs)
An increasing number of retail outlets, as well as other businesses that use point-of-sale transaction machines (or ITMs), have shifted from debit/credit mechanisms that were attached to tills with thick, but malleable and movable cords to fixed position ITMs that cannot be adjusted for wheelchair users.
Several US jurisdictions, including those under the Architectural Access Board (AAB) of Massachusetts, stipulate explicit accessible range of motion measurements that must met in all retail locations. Introducing a new point-of-sale device immovable device would not be acceptable in these jurisdictions, where the cord-connected devices would be acceptable.
The Customer Service Accessibility Standard should be required to ensure that such devices be positioned in a way that they are either reachable, or readily adjustable to be reachable. We propose that these new fixed position ITMs be made adjustable by a lowering mechanism, or a return to the cord devices. Since these technologies are rapidly changing, an obligated organization should find it easy to adjust these over a short business cycle.
Point-of-sale devices that have a numeric keypad for keying in a PIN code should have a raised dot on the 5, to assist those with vision loss or dyslexia. If the device does not come with it, the obligated organization can fix this easily, e.g. with a drop of nail polish.
As well, despite the inclusion of Information and Communications Standards in the AODA Integrated Accessibility Standards, point-of-sale devices are increasing using inaccessible touch-screen technology. To introduce new inaccessible point-of-sale devices is a clear violation of the duty not to create new barriers, imposed by the Ontario Human Rights Code. Apple iOS products all include measures to make touch-screen technology accessible. There is no reason why new point-of-sale devices, deployed in Ontario, do not also always include accessibility technologies.
The information and communication provisions of the Integrated Accessibility Standards Regulation have not prevented this problem. People with disabilities cannot wait for years until the Ontario Government completes a revision of those provisions, to solve this problem. The longer the Ontario Government delays addressing it, the more preventable new barriers will be created in the meantime.
h) Ensuring Accessibility of Cash Registers or Tills with price display
While point-of-sale devices continue to incorporate further IT developments, there should be a continued commitment to accessibility. This would include a price display feature on cash registers that will help to satisfy the duty to accommodate hard of hearing and Deaf customers. If the display is in a large font, that will assist clients with low vision.
In addition to tills with large font displays, customers with certain disabilities need the name of products and their price to be in larger font. One person reported that he has to carry a magnifying glass with him and bend close to produce in grocery stores because he is unable to read the signage. Many experience gradual vision loss as they age. For example, drug stores cater to many among the senior population.
i) Accessible Drug Prescription Labels and Information
Large drug store chains or other large chains that have pharmacies should be required to offer accessible prescription labelling services. This technology is now readily available, and would let customers with print disabilities independently read their prescription information. Similarly, those establishments should be required to offer to print prescription labels and information in large font if requested. An American drug store chain was offering this service over a decade ago.
Finally, large retail establishments should have carry to car service for customers with disabilities who may be unable to carry groceries by themselves. This is included in Manitoba’s Discussion Paper on an Initial Proposed Customer Standard, April 17, 2014.
j) Accessibility of Restaurant Menus
There are several low cost options for restaurants to make menus available in an accessible format for those who cannot read print due to such things as vision loss, or dyslexia. Braille menus can be ordered for production for a few dollars. A large print menu can be easily printed for pennies. Posting the menu online in an accessible format allows a person using a smart phone to have its screen-reader read the menu aloud to him or her.
k) Visual Fire Alarms
Having visual fire alarms installed in organizations that offer goods, services or to the public is essential for personal safety for persons who are Deaf, deafened or hard of hearing. Yet despite the irremediable consequences of not having a visual alarm, they are not required in existing or older organizations. See: https://www.orhma.com/Portals/0/PDF%20Files/GovtRelations/AccessibilityHotVisualFireAlarms2007.pdf
l) Accessibility of Services and of Provincially-Regulated Financial Institutions that Offer Bank-Like Services
Organizations that provide financial services should have specific requirements to provide printed financial statements in an accessible format. Such financial records are very important to an individual and contain very private information. A person should not have to ask others to read that private information to them aloud.
Provincially-regulated banking institutions that provide services to their customers should implement technology can allow customers with disabilities to conduct banking transactions at home via webcam. This service has been adopted in the UK by Lloyds Bank of London with success. Provincially-regulated financial institutions that offer bank-like services should be mandated to do the same.
m) Reducing Loud Music in Public Spaces Where Customer Service is Offered
Loud music in public spaces of obligated organizations that provide goods, services or facilities is likely annoying to many if not most customers. For people with certain disabilities, this loud music can go beyond annoyance, and can constitute a real and serious barrier. This is also raised in the Manitoba Discussion Paper on An Initial Proposed Customer Service Standard.
For some people with autism, it can be the same as shining a blinding light in one’s eyes. For a person who is hard of hearing, it can prevent carrying on a conversation. For people with vision loss, it can make it hard or even impossible to navigate independently, since sound is a key part of independent orientation and mobility.
The Customer Service Accessibility Standard should be revised to require obligated organizations to have a policy that they will reduce the music volume or turn it off, when requested based on a disability-related accommodation request. This policy should be posted and periodically announced, where the obligated organization has regular spoken announcements or a telephone interactive voice response system. Where the obligated organization has a website, it should be posted there. The obligated organization should include, in its accessible Customer Service training, a requirement to train Customer Service staff on this policy and on how to turn down the volume. One might be surprised to learn that in some retail establishments, many employees that serve the public have no idea how to turn down or off the music volume.
Appendix A - Background to the Customer Service Accessibility Standard and the Government’s Review of It
On November 9, 2015, the Wynne Government posted online a summary of changes it proposes to make to the 2007 Customer Service Accessibility Standard and to the 2011 Integrated Accessibility Standards Regulation. Both accessibility standards were enacted under the Accessibility for Ontarians with Disabilities Act (AODA). On January ##, 2016, the Government then posted for public comment the text of the proposed amendments to these accessibility standards on which it had invited public input late in 2015. The Government has given the public up to March ##, 2016 to provide feedback.
The Government enacted the Customer Service Accessibility Standard in 2007. It was the first accessibility standard enacted under the AODA. It was enacted just two years after the AODA was passed in 2005.
The Customer Service Accessibility Standard was based on recommendations by the Customer Service Standards Development Committee which the Ontario Government appointed under the AODA. Working as the first AODA Standards Development Committee, that committee did not operate with all the protections for people with disabilities that we later secured in 2007 promises from the Ontario Government. It did not include equal representation by people with disabilities. It did not vote on its proposals clause-by-clause. Disability sector representatives did not have the benefit of dedicated staff from the Accessibility Directorate of Ontario to assist them in their work.
The Ontario government promised all those measures in the 2007 Ontario election. That was too late for the Customer Service Standards Development Committee. It was therefore not surprising that the 2007 Customer Service Accessibility Standard was very weak. The lopsided process by which it was developed tilted against people with disabilities.
Shortly after the 2007 Customer Service Accessibility Standard was enacted, we made public a detailed critique of its deficiencies. That analysis remains valid today. The September 12, 2007 AODA Alliance analysis of the Customer Service Accessibility Standard.
Under the AODA, the Government was obliged to launch a review of the 2007 Customer Service Accessibility Standard by an AODA Standards Development Committee within five years of its enactment. That had to begin by the 2012 summer. The Government did not launch that mandatory review until the second half of 2013. It appointed Ontario’s Accessibility Standards Advisory Council (ASAC) to conduct that review.
In March 2014, the Government made public for public comment ASAC’s initial proposal for making changes to the Customer Service Accessibility Standard. ASAC’s initial proposals for revisions were very weak and inadequate. They were in part counterproductive and harmful to people with disabilities.
On April 4, 2014, the AODA Alliance submitted a detailed 50-page brief to ASAC. It gave our feedback on ASAC’s initial proposals. It showed what was wrong with both the original Customer Service Accessibility Standard and with ASAC’s proposals for revisions to that standard. Our brief made constructive recommendations on what is needed to strengthen the Customer Service Accessibility Standard.
After receiving input from the public, ASAC formulated its final proposals to the Government on proposed revisions to the 2007 Customer Service Accessibility Standard. The Government made ASAC’s final recommendations for revisions public on November 7, 2014. On November 12, 2014, we widely circulated ASAC’s final proposals, in an AODA Alliance Update that strongly criticized them as inadequate. That Update stated:
“We urge the Government to immediately instruct the Accessibility Directorate of Ontario to develop meaningful, strong revisions to the Customer Service Accessibility that are not constrained by the weak and counterproductive proposals that ASAC has submitted. The Accessibility Directorate of Ontario is part of the Ministry of Economic Development, Employment and Infrastructure – the Ontario Government Ministry with lead responsibility to implement and enforce the AODA.
The Government should use the AODA Alliance’s April 4, 2014 brief to ASAC as the basis for these reforms. We would welcome the chance to work with the Government and other stakeholders on this.”
One year later, on November 9, 2015, the Government made public a summary of the changes it proposed to make to the 2007 Customer Service Accessibility Standard and the 2011 Integrated Accessibility Standards Regulation, followed in January ##, 2016 with the actual text of those proposed revisions.