November 22, 2008
On November 17, 2008, the Ontario Government made public the initial proposal for a Information and Communication Accessibility Standard, and has asked for public feedback and input on it. The AODA Alliance has written the McGuinty Government’s minister responsible for this legislation. It asked for further information to assist the public in giving input. ()See below)
Under the Accessibility for Ontarians with Disabilities Act 2005(AODA), the Ontario is required by law to become a fully accessible province for people with physical, mental or sensory disabilities, by 2025. The AODA requires the Government to enact strong, effective accessibility standards that will bring about this result.
Under the AODA, the government appoints Standards Development Committees to develop these accessibility standards. The Government then decides whether to enact the proposed accessibility standard into law, either as proposed, or with changes.
The Government appointed an Information and Communication Standards Development Committee to develop a proposed accessibility standard to deal with access to information and effective communication for persons with disabilities, when seeking to get access to goods, services, facilities or employment in Ontario. The Information and Communication Standards Development Committee has been hard at work. It prepared an initial proposal for an Information and Communication Accessibility Standard, and submitted it to the Ontario Government earlier this fall. On November 17, 2008, the Ontario Government circulated this proposal for public input. It seeks your feedback by January 16, 2009. To see the proposed Information and Communication Accessibility Standard, and to see what you need to do to offer your views on it, visit:
The AODA Alliance commends the Information and Communications Standards Development Committee for its hard work. We are already hard at work preparing feedback for the Government. We welcome any suggestions. Send us your thoughts at:
In our letter to the Government, set out below, we express our concern that the proposed Information and Communication Accessibility Standard is quite hard to read. The Ministry posted a very short plain language summary. However it is not detailed. We asked for a more detailed one to be made available.
We also express a concern that the January 16, 2009 deadline for feedback may present difficulties for community groups, especially since it comes so soon after the holiday season.
The Ministry’s form for giving feedback, asks, among other things, does the Proposed Standard “help to achieve purpose and intent of the AODA by improving accessibility for people with disabilities?” This is far too weak a question. The AODA doesn’t merely require an accessibility standard to “improve” accessibility. That sets the bar far too low.
We urge one and all, when giving feedback to the Government, to ask instead whether the proposed accessibility standard will lead to fully-accessible information and communication, needed for equal enjoyment of goods, services, facilities, and employment in Ontario, by 2025.
To see what the AODA Alliance had to say about the only accessibility standard made so far under the AODA, this one covering access to customer service, visit:
To see what the AODA Alliance has had to say about the initial proposed accessibility standard on transportation, made public in 2007, visit:
Letter – Re: Initial Proposed Information and Communications Accessibility Standard
ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
1929 Bayview Avenue,
Toronto, Ontario M4G 3E8
via facsimile (416) 325-1488
November 21, 2008
The Honourable Madeleine Meilleur,
Minister of Community and Social Services,
6th Floor, Hepburn Block
80 Grosvenor Street
Toronto, Ontario M7A 1E9
Re: Initial Proposed Information and Communications Accessibility Standard
I write on behalf of the Accessibility for Ontarians with Disabilities Act Alliance. We are pleased that the Ministry has released an initial proposal for the Information and Communications Accessibility Standard for public input. We look forward to developing and offering our input on this proposal.
We ask your assistance to best enable the public, including the disability community, to give meaningful input into the proposed Information and Communication Accessibility Standard.
First, from our preliminary review, the proposed standard seems quite hard to read, understand and digest. We expect that others will find it the same way. This barrier makes it harder to give your Ministry meaningful input.
The proposed accessibility standard commendably seeks to promote the use of plain language. The accompanying commentary from the Information and Communication Standards Development Committee states: “The Committee believes that plain language is important – it benefits everyone, not just persons with disabilities.”
Unfortunately, this proposed standard doesn’t use plain language. We ask that your Ministry make public as soon as possible a comprehensive plain language description of what the proposed standard provides. It would be most helpful if it includes, in detail, the steps the proposed standard would require an organization to take, to make information and communication fully accessible to persons with disabilities, and by when each of these steps must be taken.
Your Ministry provides two very short summaries on its website. These are helpful as basic introductions. However they don’t give the reader enough information to give the feedback needed. It is helpful that the annotated text of the proposed accessibility standard identifies areas where the Standards Development Committee wishes input. However, to come up with answers to the issues the Standards Development Committee identified, it is important to have a good understanding of the proposed standard – something the reader can’t get from the proposed standard or the other information the Ministry has released to date.
Second, It would be very helpful if the Ministry could make public a list of any amendments or proposals for this standard which were voted down during discussions at the Standards Development Committee, and any reasons why these were voted down. This would help us and others interested in giving feedback. This would follow from your Government’s commitment to make this standards development process open and transparent, and its election pledge to let each Standards Development Committee vote on each proposal on a clause-by-clause basis. This should be easy to provide. We understand that the Ministry has asked Standards Development Committee members to give their rationales for anything they voted against.
Third, we ask that your Ministry’s public consultations include advertised, accessible public forums, which are open to anyone and not “invitation-only.” As you know, we voiced serious concerns about the Ministry’s 2007 “invitation-only” consultations on the initial proposed Transportation Accessibility Standard.
Fourth, it would be very helpful to us and all interested in input in this area to know what the Ontario Government now does to ensure full accessibility of information and communication within the Ontario Public Service, and for members of the public communicating with the Ontario Government. The Ontarians with Disabilities Act 2001 has imposed specific obligations and duties on the Ontario Government for several years, including the provision of accessible public information and websites. Of course, the Charter of Rights and Human Rights Code have required this for over twenty-five years.
Fifth, we are interested to know what steps your Ministry has taken to educate the affected sectors regarding the issue of accessibility of information and communications, in advance of the public release of this proposed accessibility standard.
Finally, we note that your Ministry has asked for feedback on the proposed Information and Communication Accessibility Standard by January 16, 2009. It may be necessary to extend this deadline, because of both the holiday period in December/January, and the need for the new materials requested in this letter, before organizations and individuals can be expected to prepare meaningful input.
We would welcome the chance to discuss this with you, and would be pleased to do whatever we can to assist.
Catherine Dunphy Tardik
Chair, AODA Alliance
- Premier Dalton McGuinty via facsimile (416) 325-9895
- Lucille Laroche, Deputy Minister, Community and Social Services (416) 325-5240
- Ellen Waxman, Assistant Deputy Minister, Accessibility Directorate (416) 325-5615
- Alf Spencer, Acting Director, Accessibility Directorate of Ontario (416) 326-9725