Disability Advocacy Coalition Calls for Strong Action by Governments At All Levels to Address the Emergency Needs of People with Disabilities during the Covid Crisis

Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Society for All People with Disabilities

Web: www.aodaalliance.org Email: aodafeedback@gmail.com Twitter: @aodaalliance Facebook: www.facebook.com/aodaalliance/

Disability Advocacy Coalition Calls for Strong Action by Governments At All Levels to Address the Emergency Needs of People with Disabilities during the Covid Crisis

March 20, 2020

          SUMMARY

The Covid-19 virus crisis has serious implications for people with disabilities in our community. This cries out for immediate and major action by all levels of government. We call on our federal, provincial and municipal governments and other major public institutions to ensure that planning for the most vulnerable in our society, including people with disabilities, is a key part of all emergency planning in this area. We urge one and all to do what they can to stay isolated and safe.

We here offer concrete ideas. We are ready to help in any way we can. In this Update, we:

* outline some of the serious additional hardships that this Covid crisis is inflicting on over 2.6 million Ontarians with disabilities.

* Offer concrete proposals for immediate action by all levels of government and

* Outline some important lessons that our government must learn after this crisis is behind us all.

We recognize that our governments at all levels are rushing to address an unbelievable crisis. They have many huge pressures on them. They are working around the clock.

We deeply appreciate all the efforts made to date to help protect the public. We here offer constructive suggestions on how to ensure that their efforts include the pressing needs of people with disabilities in this crisis. In offering these ideas, we don’t want to leave any impression whatsoever that no one is doing anything for people with disabilities. We just want to ensure that our public institutions are collectively doing all we and they can on this front. It may well be that more is going on than we have seen. Whatever be the case, we hope the following ideas will help.

          MORE DETAILS

1. The Covid Pandemic’s Serious Impact on People with Disabilities

Of the great many people whom the Covid virus will affect, the 2.6 million Ontarians who have a disability will disproportionately feel its harmful effects. We offer a few important reflections on the particular needs of people with disabilities as our society copes with the Covid-19 virus crisis that has so swiftly engulfed us all.

Specific Government Planning for the Needs of People with Disabilities Is especially vital, for several reasons. Here are the ones we’ve identified on short notice. There are, no doubt, many other similar impacts on people with disabilities beyond those listed here.

First, those who are most vulnerable to the dangers of the Covid virus are seniors and people with disabilities. Disproportionately, seniors have disabilities. Whether or not one is a senior, those with fragile or compromised medical conditions are especially at risk. While not all people with disabilities are medically fragile or compromised, there are a higher proportion of medically vulnerable people among our population of people with disabilities.

Second, the media has reported that the virus has had an especially serious impact on some living in care homes. Of course, those living in such facilities are typically (if not entirely) people with disabilities.

Third, self-imposed isolation at home is vital for everyone at this dangerous time, in order to contain this virus. This self-isolation at home can present additional hardships for some people with disabilities. For them, eliminating all close contact with other people may not be possible.

Fourth, the much-needed cancellation of school and day care programs is hard on all kids. For children with certain disabilities, this can be even harder.

For example, for children with disabilities like autism, the need for a structured and predictable day is important. That structured and predictable day has been blown away by the closure of schools and many programs for children with disabilities. Some children with disabilities get critically important services at school, beyond the school’s education program. Their families must now struggle to find those services elsewhere, and try to get them brought into the home, lest they have to venture out into the community. Some of those services will be closed now, due to the economic shutdown that is hitting so much of our economy.

Some of the important support workers and service providers will face serious economic peril as they are closed or laid off during these closures. Their economic survival may be in jeopardy.

Fifth, effective self-isolation requires a person or family to dig into their savings. A disproportionate number of people with disabilities live at or below the poverty line. They won’t have the savings one needs for this.

Sixth, the homeless too often include people with addiction and/or other mental health conditions. For them, self-isolation at home to avoid this virus is not even an option.

Seventh, we have all been told that frequent hand-washing is extremely important to protect ourselves from getting this virus. As one person with a disability pointed out on Twitter, this is hard to do in washrooms where the soap dispenser is not in an accessible location.

Eighth, for those who were away from home as this crisis escalated, and who have to travel to get home, the many disability barriers in our transportation sector will feel even more amplified now. It has at times been hard to get through on the phone to an airline. Now it is even worse. Long waits at airports are hard on everyone. On passengers with disabilities with frail medical conditions or fatiguing conditions, this is much harder.

Ninth, as the spread of this virus gets worse, we are going to need to rely more and more on our health care system. Our governments are expected to plan for a major surge in demand for hospital services.

Yet patients with disabilities now still face far too many barriers in the health care system. After years and years of our advocacy, the Ontario Government is belatedly working on developing a Health Care Accessibility Standard under the Accessibility for Ontarians with Disabilities Act.

However, at the rate at which the Ontario Government has been going on this issue, a new regulation to set standards for accessibility in the health care system is likely still years away from being enacted and implemented. Last month we made public our detailed Framework that lists what needs to be done to make our health care system truly and fully accessible to patients with disabilities.

Tenth, as schools are closed and post-secondary education organizations such as colleges and universities move their teaching to online platforms, the recurring barriers in education facing students with disabilities become all the more hurtful.

For example, if any colleges and universities have not ensured the full accessibility of their digital learning environment, the move to online learning risks becoming the move to a world of even more education barriers. In that regard, last week the AODA Alliance made public a draft Framework for the promised Post-Secondary Education Accessibility Standard. We seek your input on that draft before we finalize it. Given the crisis facing us all, it is all the more important for post-secondary education organizations to move very fast now to ensure that their digital learning environments are barrier-free for students with disabilities.

Eleventh, the additional burdens of this virus can be felt differently in different disability contexts. For example:

  1. a) We are all warned to avoid touching surfaces if they have not been recently sanitized. Yet for many people with vision loss, their hands can either intentionally or accidentally contact surfaces around them as they navigate.
  2. b) For people with balance issues or fatiguing conditions, they have an increased need to hold on to railings on staircases or other public places.
  3. c) This Covid crisis is happening as the Ontario Government continues its months of delay in deciding and announcing how it is going to fix the chaos it created last year in its Ontario Autism Program. The Ford Government has left parents of children with autism hanging for months, wondering what services their children will receive. As well, for children with other disabilities that have similar needs but do not get similar provincially-supported services, the situation is also very troubling.

2. What Should We As a Society DO?

Today, the maxim “It takes a village” rings loud and clear. As individuals, we can each reach out to others to see what assistance we can rally. Many are doing so. The business sector can also do a great deal to help, by planning measures to ensure that people with disabilities are accommodated during this crisis.

We commend everyone who is trying to help others, on a one-to-one basis, or through more collective efforts. We applaud those retail stores like grocery stores and drug stores that have announced plans to allocate special shopping hours for customers who are seniors or people with disabilities. We encourage the entire business community, and especially those in the food, restaurant, banking, and other retail and service areas, to implement and announce similarly creative strategies to ensure that customers with disabilities are effectively served.

Such commendable localized and individualized volunteer measures are only one part of the picture. it is absolutely essential for our governments at all levels to take a strong lead and to show decisive leadership on these disability concerns. They need to quickly plan and implement specific strategies to ensure that people with disabilities are safe, are fully protected from the community spread of the Covid-19 virus and are able to live in the isolation to which we all must commit ourselves. Our governments at all levels need to proactively build strong and effective disability considerations into all aspects of their emergency planning.

This makes good policy sense. It is so obvious to Ontarians with disabilities. However, over the years, we have found over and over that our governments too often fail to effectively take into account the needs of people with disabilities in their policy planning. This is so even though government after government congratulates itself on supposedly leading by example on disability accessibility and inclusion.

Multiple reports have told the Ontario Government about this serious unmet need and the lack of effective provincial leadership. This has continued even years after enactment of the Accessibility for Ontarians with Disabilities Act.

What we seek is a sensible thing to do. It is also an obligation on the part of our government.

The Canadian Charter of Rights and Freedoms guarantees to people with disabilities the constitutional right to equality before and under to the law, and to the equal protection and equal benefit of the law without discrimination based on disability. The Supreme Court of Canada made this obligation clear almost a quarter century ago in the landmark case of Eldridge v. British Columbia. It held that governments have a strong duty to take into account and accommodate the needs of people with disabilities when they design and implement public programs, including, most notably, health care. The AODA itself is a law which the grassroots disability community fought for over a decade, to turn Eldridge’s powerful language into a reality in the lives of people with disabilities. However, since the AODA was enacted in 2005, Government after Government has achieved progress on accessibility and inclusion for people with disabilities at a glacial pace, according to the 2019 report of the Third Independent Review of the AODA’s implementation conducted by former Lieutenant Governor David Onley.

The accessibility standards enacted to date under the AODA include some requirements regarding emergency planning for people with disabilities. We set these out at the end of this Update. They only cover a small part of what people with disabilities now need in Ontario from their governments and leading public sector organizations like hospitals and public transit providers.

The AODA Alliance has repeatedly revealed that successive governments have done a poor job of enforcing the AODA. In this crisis, the harm to people with disabilities from that failure is even more harmful.

We offer a list of actions that governments should immediately take. This is not the last word on this issue. This list is only the first word. Proper planning and feedback from people with disabilities will reveal other important actions to add to this list.

  1. All emergency announcements and supports must be communicated to the public through multiple fully accessible means. Governments must ensure that people with disabilities can learn about them and find them. The public is desperate to know the latest official news, as things keep changing hour by hour.

For example, announcements by the Prime Minister of Canada or Ontario’s Premier should be simultaneously available with captioning and Sign Language interpretation. Public websites where emergency information is posted should be fully barrier-free. Plain language options should be available for persons with intellectual or cognitive disabilities.

  1. It is good that there are some government efforts underway to assist people with the serious financial hardships that this crisis is causing. Specific targeted measures need to be announced to address the added needs and vulnerabilities facing people with disabilities as they deal with this crisis.

This could include emergency supplements to social assistance like ODSP, the Disability Tax Credit and other financial supports. Emergency expedited procedures to process those claims should be implemented. There should be a moratorium on Government efforts to cut off such social assistance supports as ODSP. Protections against credit card penalties during this crisis should also be on the agenda. Those who lead the advocacy efforts for income security for people with disabilities should be at the forefront of discussions on this issue.

  1. It is good that our health care system is trying to gear up for the anticipated onslaught of patients with the Covid virus. This planning must include emergency efforts to ensure that patients with disabilities will be able to get needed health care services, and to eliminate the barriers that they now must endure throughout the health care system.

As but one example, the Covid testing centres that governments are rushing to open should be designed to be fully barrier-free for patients with disabilities. The AODA Alliance’s Framework for barrier-free health care services is a good starting point for this.

  1. It is essential that people with disabilities who need health care services can get prompt accessible transportation to those services. If those services can be delivered at home through new measures, that would avoid this issue. To the extent that patients with disabilities need to use para-transit services to get to our health care system, e.g. for Covid testing, there should now be put in place an expedited process to call into para-transit services and book such urgently-needed transportation. This is all the more urgent since the Ford Government has been sitting on recommendations to strengthen the 2011 Transportation Accessibility Standard since it took office, with no reforms having been announced. See further our long term efforts to ensure accessible public transit in Ontario.
  1. While schools are closed, some efforts are underway to provide parents with educational activities for their kids at home. At the same time, specific and dedicated resources need to be provided for parents of students with disabilities who may not be able to benefit from educational resources that too often are only designed to meet the learning needs of students who have no disabilities. For ideas on what is needed to make education accessible in Ontario, consult the AODA Alliance’s Framework for accessible K-12 education.
  1. Our health care providers in the community must now cope with an inexcusable shortage of safety health supplies such as masks and gloves. Our governments must now rush to get these mass-produced in huge quantities.

However, these safety masks and gloves must also be made available widely to people with disabilities who need them to be used by care-givers, attendant care providers, group home staff, and other like people with whom they must closely deal.

  1. Governments must immediately deploy emergency strategies to protect homeless people from the devastating impact of this health crisis. It must take into account that disproportionately, homeless people have disabilities. This should include an emergency strategy to protect people with disabilities from becoming homeless during this crisis, because they live in a rental apartment but are on the verge of eviction.
  1. Emergency strategies must be put in place to assure needed supports to people with disabilities who are self-isolating, such as needed attendant care and other in-home services.
  1. From the experience in other countries where the pandemic has quickly spread, we know that horrible decisions may be made about rationing scarce health care services, when the demand for those services out-strips the supply. It is essential that people with disabilities not get the short end of that stick, based on harmful stereotypes about the quality of life when one is living with a disability. Such stereotypes too often have been present in our health care system. We cannot afford for them to surface now, and be used to justify denying needed medical services because a patient has a disability.
  1. Our governments should now undertake a quick multi-level coordinated outreach to people with disabilities to ensure that they know what impacts can make a more informed decisions on how to ensure that disability needs are taken into account in this emergency planning. That should include, among other things, establishing and publicizing a hotline for people with disabilities to report hardships they face during this crisis.
  1. Government disability or accessibility offices should be immediately included in all emergency planning.
  1. Governments should immediately survey readily-available online resources in this area. For example, we set out below a list of recommendations available online from the International Disability Alliance. While we are not familiar with that organization, it offers good ideas.

Governments are scrambling to deal quickly with this Covid crisis. It is vital to ensure that the needs of people with disabilities are not again left out of the policy planning process, where the stakes for everyone are so high.

3. Long Term Disability-Related Lessons that Our Society Can Learn from the Covid Crisis

When we get this crisis behind us, there will be much-needed efforts to figure out what went wrong, and how we can learn from the events that are now unfolding. Our governments, public institutions and private sector organizations must learn some key lessons from the experience of people with disabilities.

One big lesson to be learned is that we are now all suffering the consequences of grossly-inadequate past government efforts at making our society fully accessible to people with disabilities. As one example, for years, the disability community has faced far too much resistance when seeking to get requirements enacted to install such helpful accessibility features as automatic water faucets, soap dispensers and paper towel dispensers in public bathrooms. The same goes for requiring automatic power doors, so that one does not have to either physically open the door or press a button to get the door to open. Yet in the face of the Covid crisis, these basic accessibility features are now vital to protect everyone from the dangerous spread of the Covid virus when we use a public washroom.

Similarly, in the past, some employees with disabilities have encountered resistance when they have asked some employers to let them work from home. Other employers were supportive. With this virus, employers have rapidly made this accommodation widely available to many of their employees, as a good public health measure to prevent the spread of the virus. ` We need to more effectively ensure that no employees with disabilities ever have to face such resistance to such workplace accommodations in the future.

One can imagine many more such illustrations of this broader lesson to be learned. These examples help show that the failure of government after government in Ontario to effectively implement and enforce the AODA must dramatically change in the future. Three successive Government-appointed Independent Reviews of the AODA’s implementation and enforcement have called for major reforms and strong new provincial leadership. The current Ontario Government has had 414 days since it received the most recent of these reports, and still has no effective plan to implement it.

4. Toward a Disability-Inclusive COVID19 Response: 10 recommendations from the International Disability Alliance

March 19, 2020

)Note: The  AODA Alliance encourages all governments to consider the following recommendations which one of our supporters brought to our attention.)

In the light of the COVID19 pandemic and its disproportionate impact on persons with disabilities, the International Disability Alliance (IDA) has compiled the following list of the main barriers that persons with disabilities face in this emergency situation along with some practical solutions and recommendations. This document is based on inputs received from our members around the world aiming to assist global, regional, national and local advocacy to more efficiently address the range of risks persons with disabilities face.

If you have any updates on how COVID 19 is affecting persons with disabilities in your area of work, or want to share any good practices or lessons learnt, please contact IDA Inclusive Humanitarian Adviser Ms Elham Youssefian via emailing eyoussefian@ida-secretariat.org

  1. People with disabilities are at higher risk of contracting COVID19 due to barriers accessing preventive information and hygiene, reliance on physical contact with the environment or support persons, as well as respiratory conditions caused by certain impairments.

Recommendation 1: Persons with disabilities must receive information about infection mitigating tips, public restriction plans, and the services offered, in a diversity of accessible formats

  • Mass media communication should include captioning, national sign language, high contrast, large print information.
  • Digital media should include accessible formats to blind persons and other persons facing restrictions in accessing print.
  • All communication should be in plain language.
  • In case the public communications are yet to become accessible, alternative phone lines for blind persons and email address for deaf and hard of hearing may be a temporary option.
  • Sign language interpreters who work in emergency and health settings should be given the same health and safety protections as other health care workers dealing with COVID19.
  • There may be appropriate alternatives for optimum access, such as interpreters wearing a transparent mask, so that facial expressions and lip movement is still visible,
  • Alternatives are particularly important as remote interpretation is not accessible for everyone, including people with deaf-blindness. Solutions should be explored with concerned people and organizations representing them.
  • Assistive technologies should be used such as FM systems for communicating with hard of hearing persons especially important when face masks make lipreading impossible.

Recommendation 2: Additional protective measures must be taken for people with certain types of impairment.

  • Disinfection of entrance doors reserved for persons with disabilities, handrails of ramps or staircases, accessibility knobs for doors reserved for people with reduced mobility.
  • Introducing proactive testing and more strict preventive measures for groups of persons with disabilities who are more susceptible to infection due to the respiratory or other health complications caused by their impairment.
  • The COVID19 crisis and confinement measures may generate fear and anxiety; demonstrating solidarity and community support is important for all, and may be critical for persons with psychosocial disabilities

Recommendation 3: Rapid awareness raising and training of personnel involved in the response are essential

  • Government officials and service providers, including emergency responders must be trained on the rights of persons with disabilities, and on risks associated to respiratory complications for people who have specific impairments (e.g. whose health may be jeopardized by coughing).
  • Awareness raising on support to persons with disabilities should be part of all protection campaigns.

Recommendation 4: All preparedness and response plans must be inclusive of and accessible to women with disabilities

  • Any plans to support women should be inclusive of and accessible to women with disabilities
  • Programs to support persons with disabilities should include a gender perspective.
  1. Implementing quarantines or similar restrictive programs may entail disruptions in services vital for many persons with disabilities and undermine basic rights such as food, health care, wash and sanitation, and communications, leading to abandonment, isolation and institutionalization.

Recommendation 5: No disability-based institutionalization and abandonment is acceptable

  • Persons with disabilities should not be institutionalized as a consequence of quarantine procedures beyond the minimum necessary to overcome the sickness stage and on an equal basis with others.
  • Any disruptions in social services should have the least impact possible on persons with disabilities and should not entail abandonment.
  • Support family and social networks, in case of being quarantined, should be replaced by other networks or services.

Recommendation 6: During quarantine, support services, personal assistance, physical and communication accessibility must be ensured

  • Quarantined persons with disabilities must have access to interpretation and support services, either through externally provided services or through their family and social network;
  • Personal assistants, support workers or interpreters shall accompany them in quarantine, upon both parties agreement and subject to adoption of all protective measures;
  • Personal assistants, support workers or interpreters should be proactively tested for COVID 19 to minimize the risk of spreading the virus to persons with disabilities
  • Remote work or education services must be equally accessible for employees/students with disabilities.

Recommendation 7: Measures of public restrictions must consider persons with disabilities on an equal basis with others

  • In case of public restriction measures, persons with disabilities must be supported to meet their daily living requirements, including access to food (as needed with specific dietary requirements), housing, healthcare, in-home, school and community support, as well as maintaining employment and access to accessible transportation.
  • Government planners must consider that mobility and business restrictions disproportionately impact persons with reduced mobility and other persons with disabilities and allow for adaptations. For example, Australia has reserved specific opening hours in supermarket for persons with disabilities and older persons
  • Providers of support services must have the personal protective equipment and instructions needed to minimize exposure and spread of infection, as well as should be proactively tested for the virus.
  • In case of food or hygienic products shortage, immediate measures must be taken to ensure that people with disabilities are not left out as they will be the first group to experience lack of access to such items.
  • Any program to provide support to the marginalized groups should be disability-inclusive, e.g. distribution of cash may not be a good option for many people with disabilities as they may not be able to find items they need due to accessibility barriers.
  • When ill with COVID19, persons with disabilities may face additional barriers in seeking health care and also experience discrimination and negligence by health care personnel.

Recommendation 8: Persons with disabilities in need of health services due to COVID19 cannot be deprioritized on the ground of their disability

  • Public health communication messages must be respectful and non-discriminatory.
  • Instructions to health care personnel should highlight equal dignity for people with disabilities and include safeguards against disability-based discrimination.
  • While we appreciate that the urgency is to deal with the fast-rising number of people infected and in need of hospitalization, rapid awareness-raising of key medical personnel is essential to ensure that persons with disabilities are not left behind or systematically deprioritized in the response to the crisis.
  • Communications about the stage of the disease and any procedures must be to the person themselves and through accessible means and modes of communication.
  1. Organizations of Persons with Disabilities (OPDs) particularly at national and local levels may not be prepared to take immediate action and may not be fully aware how to approach the situation. Some measures OPDs can take include:

Recommendation 9: OPDs can and should play a key role in raising awareness of persons with disabilities and their families.

 

  • Prepare COVID19 instructions and guidance in various accessible formats in local languages; please see existing resources produced by IDA members and their members, which we will keep updating
  • Help establish peer-support networks to facilitate support in case of quarantine;
  • Organize trainings on disability inclusion for responders
  • Compile an updated list of accessible health care and other essential service providers in each area

Recommendation 10: OPDs can and should play a key role in advocating for disability-inclusive response to the COVID19 crisis

  • Proactively reach to all related authorities including the health system, the national media, the crisis response headquarters and education authorities to:
  • Sensitize authorities on how the pandemic as well as the response plans may disproportionally impact persons with disabilities;
  • Offer tailored practical tips on how to address accessibility barriers or specific measures required by persons with disabilities
  • Based on available resources and capacity, contribute to the national or local emergency response.

*For updated resources on inclusion of persons with disabilities in Covid19 prevention and response, please regularly check the webpage dedicated by the International Disability Alliance at http://www.internationaldisabilityalliance.org/covid-19

5. Key Emergency Provisions in the Integrated Accessibility Standards Regulation 2011 Enacted Under the Accessibility for Ontarians with Disabilities Act

The Integrated Accessibility Standards Regulation, enacted in 2011 under the Accessibility for Ontarians with Disabilities Act, includes the following emergency-related provisions.

Emergency procedure, plans or public safety information

  1. (1) In addition to its obligations under section 12, if an obligated organization prepares emergency procedures, plans or public safety information and makes the information available to the public, the obligated organization shall provide the information in an accessible format or with appropriate communication supports, as soon as practicable, upon request.

(2) Obligated organizations that prepare emergency procedures, plans or public safety information and make the information available to the public shall meet the requirements of this section by January 1, 2012.

Workplace emergency response information

  1. (1) Every employer shall provide individualized workplace emergency response information to employees who have a disability, if the disability is such that the individualized information is necessary and the employer is aware of the need for accommodation due to the employee’s disability. O. Reg. 191/11, s. 27 (1).

(2) If an employee who receives individualized workplace emergency response information requires assistance and with the employee’s consent, the employer shall provide the workplace emergency response information to the person designated by the employer to provide assistance to the employee. O. Reg. 191/11, s. 27 (2).

(3) Employers shall provide the information required under this section as soon as practicable after the employer becomes aware of the need for accommodation due to the employee’s disability.

(4) Every employer shall review the individualized workplace emergency response information,

(a) when the employee moves to a different location in the organization;

(b) when the employee’s overall accommodations needs or plans are reviewed; and

(c) when the employer reviews its general emergency response policies.

(5) Every employer shall meet the requirements of this section by January 1, 2012.

  1. (1) Employers, other than employers that are small organizations, shall develop and have in place a written process for the development of documented individual accommodation plans for employees with disabilities. O. Reg. 191/11, s. 28 (1).

(2) The process for the development of documented individual accommodation plans shall include the following elements:

  1. The manner in which an employee requesting accommodation can participate in the development of the individual accommodation plan.
  1. The means by which the employee is assessed on an individual basis.
  1. The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer’s expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
  1. The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
  1. The steps taken to protect the privacy of the employee’s personal information.
  1. The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
  1. If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
  1. The means of providing the individual accommodation plan in a format that takes into account the employee’s accessibility needs due to disability. O. Reg. 191/11, s. 28 (2).

(3) Individual accommodation plans shall,

(a) if requested, include any information regarding accessible formats and communications supports provided, as described in section 26;

(b) if required, include individualized workplace emergency response information, as described in section 27; and

(c) identify any other accommodation that is to be provided.

Emergency preparedness and response policies

  1. (1) In addition to any obligations that a conventional transportation service provider or a specialized transportation service provider has under section 13, conventional transportation service providers and specialized transportation service providers,

(a) shall establish, implement, maintain and document emergency preparedness and response policies that provide for the safety of persons with disabilities; and

(b) shall make those policies available to the public. O. Reg. 191/11, s. 37 (1).

(2) Conventional transportation service providers and specialized transportation service providers shall, upon request, provide the policies described in subsection (1) in an accessible format. O. Reg. 191/11, s. 37 (2).

(3) Conventional transportation service providers and specialized transportation service providers shall meet the requirements of this section by January 1, 2012.

Regarding para-transit services, the Integrated Accessibility Standards Regulation requires:

Emergency or compassionate grounds

  1. (1) Specialized transportation service providers shall develop procedures respecting the provision of temporary specialized transportation services earlier than in the 14 calendar days referred to in subsection 64 (1),

(a) where the services are required because of an emergency or on compassionate grounds; and

(b) where there are no other accessible transportation services to meet the person’s needs. O. Reg. 191/11, s. 65 (1).

(2) A person shall apply for the services described in subsection (1) in the manner determined by the specialized transportation service provider. O. Reg. 191/11, s. 65 (2).

(3) Specialized transportation service providers shall meet the requirements of this section by January 1, 2014.

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