The AODA Alliance Sends a Detailed Brief with 53 Recommendations to the Post-Secondary Education Standards Development Committee to Make Post-Secondary Education Accessible to Students with Disabilities

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

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The AODA Alliance Sends a Detailed Brief with 53 Recommendations to the Post-Secondary Education Standards Development Committee to Make Post-Secondary Education Accessible to Students with Disabilities

November 1, 2021

            SUMMARY

Today is the final day for the public to send feedback to the Post-Secondary Education Standards Development Committee on the measures needed to make colleges and universities in Ontario accessible for students with disabilities. The AODA Alliance has sent that Government-appointed Committee a detailed brief, set out below. It makes 53 recommendations.

Overall, our brief supports the Initial Report that the Post-Secondary Education Standards Development Committee submitted to the Ford Government last March, and which the Government made public on June 25, 2021 for public comment. Our brief points out a few areas where we disagree with that Initial Report, and several areas where we urge the Committee to add more detail to its recommendations to the Government. We congratulate the Post-Secondary Education Standards Development Committee on its efforts and are eager to meet with that Committee to discuss our recommendations in this brief.

We thank everyone who has shared their feedback with the AODA Alliance on this topic, including your thoughts on the draft Framework for the Post-Secondary Education Accessibility Standard, which the AODA Alliance created and made public on March 11, 2020. Your input makes a huge difference.

While today is set as the final deadline for giving the Standards Development Committee your feedback, we encourage you to send a short email to them, supporting the AODA Alliance’s November 1, 2021 brief which we here make public. You can write the Post-Secondary Education Standards Development Committee at: postsecondarySDC@ontario.ca

Today is also the final day to send your feedback to the K-12 Education Standards Development Committee on its Initial Report that recommends measures to make K-12 education in Ontario schools accessible to students with disabilities. You can write that Standards Development Committee at educationsdc@ontario.ca

AODA Alliance Brief to the Post-Secondary Standards Development Committee on Its Initial Recommendations for the Contents of the Promised Post-Secondary Education Accessibility Standard

November 1, 2021

Via email to: postsecondarySDC@ontario.ca

 1. Introduction

The Accessibility for Ontarians with Disabilities Act (AODA) requires the Ontario Government to lead Ontario to become accessible to people with disabilities by 2025. The Government is required to do so by enacting and effectively enforcing accessibility standards. These are enforceable regulations. An accessibility standard is required to specifically spell out in detail the barriers that are to be removed or prevented, what specifically must be done to remove or prevent them, and the timelines required for these actions.

The Ontario Government has committed to develop an Education Accessibility Standard under the AODA. In 2017, the Ontario Government appointed two Standards Development Committees, the Post-Secondary Education Standards Development Committee and the K-12 Education Standards Development Committee. These Committees are mandated to make recommendations on what the Education Accessibility Standard should include.

On June 25, 2021, the Ontario Government publicly posted the initial or draft report of the Post-Secondary Standards Development Committee, three and a half months after the Government received it. The public’s feedback has been invited on that Initial Report. That Initial Report sets out recommendations on what the promised Education Accessibility Standard should include in so far as Ontario colleges and universities are concerned. The public has been given up to November 1, 2021 to submit its feedback.

This brief sets out the AODA Alliance’s detailed feedback on the Post-Secondary Education Standards Development Committee’s Initial Report. Our recommendations are listed in Appendix 2 at the end of this brief. In summary, we congratulate the Post-Secondary Education Standards Development Committee for a strong report with very helpful recommendations. In this brief, we recommend ways to fine-tune and strengthen them. With only a few exceptions, we do not disagree with anything the Standards Development Committee recommended.

The Post-Secondary Education Standards Development Committee’s Initial Report demonstrates over and over how Ontario desperately needs a strong and effective Education Accessibility Standard to be enacted as soon as possible. It shows that Ontario’s post-secondary education system is replete with far too many disability barriers. These barriers hurt students with disabilities and hand-cuff post-secondary educators who want them fully included in their post-secondary educational offerings.

It is especially important for the post-secondary education sector to become accessible to students with disabilities. A good post-secondary education is very important for getting a good job, or indeed getting a job at all. This is even more important for people with disabilities. People with disabilities chronically face a substantially higher unemployment rate than the public does as a whole. Barriers in the post-secondary education system can only make this situation worse. A strong and effective post-secondary Education Accessibility Standard is therefore an important measure for increasing employment opportunities for people with disabilities.

 2. Who Are We?

The AODA Alliance is a voluntary non-partisan coalition of individuals and organizations. Our 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: https://www.aodaalliance.org.

Our coalition is the successor to the Ontarians with Disabilities Act Committee. The ODA Committee advocated for more than ten years for the enactment of strong, effective disability accessibility legislation. Our coalition builds on the ODA Committee’s work. We draw our supporters from the ODA Committee’s broad, grassroots base. To learn about the ODA Committee’s history, visit: http://www.odacommittee.net.

We have been widely recognized by the Ontario Government, by all political parties in the Ontario Legislature, within the disability community, and by the media, as a key voice leading the non-partisan campaign for accessibility in Ontario. In every provincial election since 2005, parties that made election commitments on accessibility did so in letters to the AODA Alliance.

Our efforts and expertise on accessibility for people with disabilities have been recognized in MPPs’ speeches on the floor of the Ontario Legislature, and beyond. Our website and Twitter feed are widely consulted as helpful sources of information on accessibility efforts in Ontario and elsewhere. We have achieved this as an unfunded volunteer community coalition.

Among other things, we led the campaign in Ontario from 2009 to the present to get the Ontario Government to agree to develop an Education Accessibility Standard. Our efforts on the education front are documented on the AODA Alliance website’s education page.

Beyond our work at the provincial level in Ontario, over the past several years, the AODA Alliance has been active in advocating for strong and effective national accessibility legislation for Canada. Our efforts influenced the development of the Accessible Canada Act. We have been formally and informally consulted by the Federal Government and some federal opposition parties on this issue.

The AODA Alliance has spoken to or been consulted by disability organizations, individuals, and governments from various parts of Canada on disability accessibility issues. We have also been consulted outside Canada on this topic, most particularly, by parties from Israel and New Zealand.

 3. Our Big Message to the Post-Secondary Education Standards Development Committee

Before going into details, we offer six high-level themes and over-arching recommendations for the Post-Secondary Education Standards Development Committee, to help it finalize its report on what the Education Accessibility Standard should include regarding colleges and universities.

First, we heartily congratulate the Post-Secondary Education Standards Development Committee on its thorough, thoughtful Initial Report. It reflects mountains of very hard work.

The AODA Alliance strongly supports everything in that Initial Report except in the specific instances where the contrary is explicitly indicated in this brief. In each case, we show how the Initial Report can be refined to address the issues we identify. To address our concerns is eminently feasible. Our recommendations fit very well with the Post-Secondary Education Standards Development Committee’s overall approach.

Second, at several points in the Initial Report, the Standards Development Committee correctly recognizes a need for standards to be created, but subsequently recommends that their creation be delegated to others, such as the Ministry of Colleges and Universities and/or the Council of Ontario Universities (COU). In each such case, we propose that it is more appropriate for that policy, standard, or direction to be set out in the Education Accessibility Standard itself.

In those instances, we agree that a standard needs to be created. However, its creation should not be delegated to the Ministry or the COU. The Ministry has no expertise in such areas as supervision of graduate students. Moreover, the whole idea of an AODA accessibility standard is that Cabinet enacts it. It does not get and indeed cannot be sub-delegated to someone else.

As noted earlier, an AODA accessibility standard is required to set specific accessibility standards that spell out in detail which barriers are to be removed and prevented, and what must be done to remove or prevent them. In the absence of an Education Accessibility Standard in Ontario, individual students with disabilities must each resort to the duty to accommodate their disabilities under human rights laws, because recurring disability barriers too often remain in place. If the Education Accessibility Standard directs the removal and prevention of specific disability barriers in the post-secondary education system, then students with disabilities will not have to resort to asking for many individualized accommodations to get around those barriers.

To illustrate, it is commendable that the 2011 Transportation Accessibility Standard does not tell each municipal transit authority to develop a plan on what to include in buses it procures to ensure that those buses are accessible to passengers with disabilities. Instead, it properly spells out in detail what a bus must include to be accessible.

In contrast, it is inappropriate that the 2011 Employment Accessibility Standard does not spell out measures to remove and prevent many recurring workplace barriers. This is a major failing of that accessibility standard. It wrongly allows employers to leave existing barriers in place, while also allowing employers to erect new barriers. The Employment Accessibility Standard primarily attempts to encourage employers to effectively accommodate individual employees with disabilities. It does little to make workplaces accessible and barrier-free over the long term.

If the Education Accessibility Standard does not include specific and detailed barrier removal and prevention requirements in a particular area where a known recurring disability barrier exists, each college and university is left to determine what accessibility features it should include in its documents, websites, furniture, equipment, buildings, or services. This duplication of effort is wasteful and inefficient. Each college and university must re-invent the wheel. Students with disabilities at each college and university must repeatedly advocate for the mitigation and removal of the same recurring barriers. It leaves each college or university, or Colleges and the Council of Ontario Universities, to decide how much or how little each party will do. This risks accomplishing too little for students with disabilities.

Organizations want and need to know specifically what they must do to comply. Where it is proposed that each of the colleges and universities establishes a “guideline”, this is of little use. A “guideline” is not binding. In contrast, an accessibility standard is binding and enforceable.

For example, the Initial Report’s Recommendation 52 (Graduate supervision) includes:

“a) Ministry of Colleges and Universities, working with the Council of Ontario Universities, shall develop a common set of guidelines and resources for graduate faculty members in accessible and inclusive supervision of graduate students with disabilities, including best practices for virtual supervision.

  1. b) Postsecondary institutions shall mandate that all faculties of graduate studies and graduate departments have explicit policies, practices and guidelines on accessibility and accommodation for graduate students with disabilities, which are developed in a consultative manner. Policies should include consideration of disclosure, accommodation, student supervision and graduate assessments (for example, comprehensive exams and thesis defenses), and take into account the roles of graduate students as academic/research staff and university employees.
  2. c) Review of these policies shall be attached to the graduate program quality assurance process.”

We therefore recommend that:

  1. Wherever the Initial Report recommends the creation of a standard or the development of a policy or guideline, such a standard, policy or guideline should be mandatory and should be spelled out in detail in the Education Accessibility Standard, rather than delegating authority to create it to some organization or department.

Third, it is especially important not to confuse or conflate the separate concepts of accessibility on the one hand, and accommodation of students with disabilities under the human rights duty to accommodate, on the other. The Initial Report appears to focus in significant part on the duty to accommodate, though not exclusively so.

To become accessible, a college or university must identify and remove existing recurring disability barriers and prevent the creation of new ones. On the other hand, the duty to accommodate assumes the inaccessible status quo with all its accessibility barriers. It focuses on creating individual “work-arounds” to get around those barriers, while the barriers themselves tend to remain in place.

It will always be necessary at colleges and universities to have in place effective mechanisms for implementing the duty to accommodate students with disabilities. To that end, it is great that the Committee’s Initial Report makes excellent recommendations to fortify these mechanisms for individual accommodation. This is vital now, while those institutions still have many accessibility barriers. Later, when those recurring barriers are removed, there will be a reduced need for individualized accommodation. However, even then, there will remain some need for the duty to accommodate to come into play.

Fourth, while we support virtually all of the Initial Report, and largely only ask for it to be fine-tuned as identified in this brief, we do flag one significant concern. The Initial Report principally speaks to middle and senior management at colleges and universities. It does so in language and recommendations that reflect and focus that environment. As such, the report may not appear to speak directly to students with disabilities themselves, and to front-line course instructors. We do not for a moment suggest that the Post-Secondary Education Standards Development Committee is not keenly focused on the needs of students with disabilities. The Initial Report is commendably all about meeting their needs. However, such vague notions as “disability lens” are hard if not impossible for students to enforce, and hard if not impossible for front-line instructors to understand what they are now expected to change, and when they are in compliance.

There is the risk that the Initial Report’s recommendations could wrongly be converted into an increase in administrative bureaucracy, even though the Committee is seeking substantially increased direct substantive action on removing and preventing barriers. We encourage the Standards Development Committee, as it finalizes its report, to fine-tune its recommendations to make them more concrete and enforceable, so that students will know what results to expect, and front-line instructors will know what they must do. After all, it is the frontline interaction between students and their instructors where all these measures come to fruition.

Fifth, at several places in the Initial Report, it is recommended that colleges and universities make public a document, report or data, or submit them to the Government. All of these reports, documents and other data should be made widely, accessibly available to the public in each case.

We therefore recommend that:

  1. Wherever the Education Accessibility Standard will require colleges and universities to file a document or data with the Government, or to make public any document, report, or data, it should also require that these be submitted electronically to the Accessibility Directorate of Ontario in an accessible format. The Standard should also require the Accessibility Directorate to make those documents, reports or data public on a publicly searchable database or hub.

Sixth, even if all the Standards Development Committee’s recommendations are adopted, we are deeply concerned that the AODA will continue to be weakly enforced. Stronger enforcement and compliance measures are needed. The K-12 Education Standards Development Committee recommended such actions. With minor adjustments, they would readily fit the post-secondary sector.

For example, there is a pressing need for there to be on-site inspections, and not mere Government review of an obligated organization’s accessibility documents (such as policies and records of staff training). It is not good enough for colleges and universities to have good records on file. They need to deliver accessible education to students with disabilities

We therefore recommend that:

  1. The Post-Secondary Education Standards Development Committee should endorse and echo the K-12 Education Standards Development Committee Initial’ Report’s recommendations on enforcement of the AODA, with necessary changes to tailor them to the context of colleges and universities.

 4. Specific Recommendations

 a) General

Where this brief states that “a post-secondary education organization should …” or similar wording, this means that the Education Accessibility Standard should include a provision that requires the post-secondary education organization to take the step we describe.

The Standards Development Committee’s final report should make it clear that it applies to all disabilities covered by the Ontario Human Rights Code, the Charter of Rights and the AODA

We therefore recommend that:

  1. The Initial Report should be revised to add that where the Education Accessibility Standard refers to “students with disabilities “, this should include any student who has any kind of disability, including, for example, any kind of physical, mental, sensory, learning, intellectual, mental health, communication, neurological, neurobehavioural or other kind of disability within the meaning of the Ontario Human Rights Code, the Accessibility for Ontarians with Disabilities Act or the Canadian Charter of Rights and Freedoms.

 b) Standards Development Committee Chair’s March 12, 2021 Letter Transmitting Its Initial Report to the Accessibility Minister

We agree with the Standards Development Committee chair’s March 12, 2021 cover letter to the Accessibility Minister, where it recommended the following – a point that the report itself should recommend:

“We also propose that the Postsecondary Education Accessibility Standards be applied beyond our mandate to include other educational contexts, such as privately funded colleges and universities and transitional job training programs.”

For example, it makes no sense that the Standard would apply to a law school, but not to the Law Society of Ontario’s Bar Admission course, which must be completed after law school graduation, to qualify for admission to the practice of law.

We therefore recommend that:

  1. The Standards Development Committee’s final report itself and not just the chair’s transmission letter should recommend that the Postsecondary Education Accessibility Standard apply to all other post-secondary educational contexts, such as privately funded colleges and universities and job training programs.

 c) Long Term Objective of the Post-Secondary Education Standard

We agree with the ideas and sentiments in the Initial Report’s discussion of the Standard’s long term objective, and with the Committee’s recommendation that its long term objective should be written right into the Standard itself. We also agree that the objective should be expressed in more focused and specific terms than have earlier AODA accessibility standards.

However, we believe that as written, the Initial Report’s long term objective is not strong or focused enough. The Post-Secondary Education Standards Development Committee Initial Report includes:

” Recommendation 1: The long-term objective of the standards:

With the support of the Ontario government, postsecondary publicly funded colleges and universities in Ontario will implement an intentional strategy:

that actively engages students with disabilities in the ongoing identification, removal and prevention of barriers

that recognizes disability as a critical aspect of the education sector’s commitment to equity, diversity and inclusion that creates policies, procedures and guidelines through an intersectional accessibility lens

where teaching and learning practices take into account the diversity of learning environments and needs throughout the academic journey

Realization of the long-term objective will result in all students with disabilities living and learning in an environment where they will:

  • feel valued, welcomed and a sense of belonging
  • navigate transparent systems without barriers
  • be provided with opportunities to realize their full potential both inside and outside of the classroom
  • have an equal opportunity to contribute, to learn and to demonstrate their knowledge”

The K-12 Education Standards Development Committee’s Initial Report’s proposed objective is preferrable.

We therefore recommend that:

  1. The long term objective of the Post-Secondary Education Accessibility Standard should be to ensure that by 2025, post-secondary education in Ontario will be fully accessible and barrier-free for students with disabilities:
    1. By removing and preventing accessibility barriers impeding students with disabilities from fully participating in, being fully included in, and fully benefitting from all aspects of post-secondary education in Ontario, and
  1. By providing a prompt, accessible, fair, effective and user-friendly process for students with disabilities to learn about and seek programs, services, supports, accommodations and placements tailored to the individual strengths and needs of each student with disabilities.”
  1. Eliminating or substantially reducing the need for students with disabilities to have to fight against post-secondary education accessibility barriers, one at a time, and the need for post-secondary education organizations to have to re-invent the accessibility wheel one education program at a time.

 d) Barrier Area 1: Changing Public Attitudes and Awareness

The Standards Development Committee’s report places emphasis on and trust in public education campaigns, including within colleges and universities, to change attitudes towards people with disabilities, and to reduce or eliminate ablism. For example, the Committee’s Initial Report includes, under its Recommendation 18 (Awareness):

“The government will develop guidance documents for obligated organizations and conduct a sustained, multi-faceted ongoing public education campaign on accessibility.”

Respectfully, we disagree. We have been witness to and participants in more such campaigns and efforts than can be counted. They change very little. They let politicians and government claim to be doing something, and posture to look like they are doing something, when it turns out to be superficial optics at best.

We do not need another Government announcing yet another public education campaign, and to then say they are listening to and acting on the advice of the Post-Secondary Education Standards Development Committee. That risks being an excuse for their not taking action on other important recommendations that the Standards Development Committee is advancing.

Sadly, ample experience shows that such public education campaigns too often do not materially change what people in positions of authority do. It is ineffective to hope to first change attitudes towards people with disabilities in the vain hope that this will sometime later change their actions.

Instead, we must now change actions. The attitudes will change as a result. Put another way, nothing raises awareness and changes attitudes and culture better than a clear, specific, mandatory law such as a strong and effective Education Accessibility Standard, known to be backed by timely and effective enforcement. The detailed requirements, such as we recommend, to be included in that accessibility standard, then become the public education campaign.

An obligated organization may remove and prevent disability barriers because its attitudes have changed. It may do so because it is good for business. It may do so because it fears a Government inspection, enforcement and penalties. It may do so because it fears bad press if it doesn’t fix things. It may do so because it is the right thing to do. It may do so because of a combination of these motivations. We care principally that the obligated organization removes and prevents those barriers, and does so as soon as possible, for whatever reason.

 e) Barrier Area 2: Training

It is good that the Initial Report recommends training for post-secondary staff on AODA standards and the Ontario Human Rights Code. It should be expanded to also include their duties under s. 15 of the Canadian Charter of Rights and Freedoms (equality rights to people with disabilities), which the AODA also aims to implement.

We therefore recommend that:

  1. The Standards Development Committee Initial Report’s Recommendation 20-23 (training) should be amended to include training on the duties of post-secondary institutions to people with disabilities under the Canadian Charter of Rights and Freedoms, and especially s. 15 (equality rights).

The Initial Report Recommendation 20-23 proposes that training should be provided at no cost to post-secondary institutions. The Initial Report’s Recommendation 20 includes:

“Online and in-person components shall be provided at no cost to postsecondary institutions across the province.”

If this means that The Government of Ontario should not charge for training resources, then we agree. If it means that post-secondary institutions should never have to pay anyone for such training, then we disagree. An accessibility standard can and should never purport to direct that an obligated organization never need pay for an accommodating or accessibility measure.

We therefore recommend that:

  1. The Initial Report’s Recommendation 20-23 (Training) should be revised to either remove the statement that post-secondary institutions should not pay for disability accessibility/inclusion training, or to clarify that the Ontario Government should not charge a fee for providing such training to those obligated organizations.

The Initial Report’s recommendations regarding training should specifically include training on the duty to accommodate people with disabilities, both employees and students with disabilities. We recognize that this is implicit in the Initial Report’s recommendations. It would be better to make it explicit.

We have found that there is a thirst for such training, and that training can start right now. In early October, 2021, the AODA Alliance made public a captioned training video on the duty to accommodate people with disabilities, available at https://youtu.be/y32XvjWmDAQ which runs about one and a quarter hours. It is presented by AODA Alliance Chair David Lepofsky, and is posted on a post-secondary institution’s website, the Osgoode Hall Law School.

Within two weeks of being posted and publicized on social media by the AODA Alliance, it has been seen over 1,000 times and has received positive feedback. The Toronto District School Board sent it to all its principals and vice-principals.

With tools such as the video now available, action can start now.

We therefore recommend that:

  1. The Initial Report’s Training recommendations, Recommendations 20 and following, should be revised to explicitly require training on the duty to accommodate students and employees with disabilities, and to direct that this training begin immediately, using resources that are now readily available for free.

We support the need for training of college and university facility management officials on universal design. Colleges and universities have been the venue of some of the troubling new buildings with serious accessibility problems.

This training should include direct presentations by users with disabilities who have suffered as a result. It should also require the viewing of projects that have gone wrong.

For example, the AODA Alliance widely-viewed video about serious accessibility problems at the Ryerson University Student Learning Centre, available at https://youtu.be/4oe4xiKknt0, is now being used for training in some design professional circles. The David Onley AODA Independent Review references that video. We encourage its use. We emphasize that we do not hold out Ryerson as an especially problematic place. Rather, that video illustrates problems that we find to be generally typical and troubling around Ontario.

We therefore recommend that:

  1. “Recommendation 29: Facilities Management/Design/Construction staff” Should be amended to require that training of those responsible for facilities at post-secondary institutions and those who design such facilities should be required to include direct live training from people with disabilities who have suffered from post-secondary institutions’ built environment barriers, and should include video depictions of such barriers, such as the AODA Alliance’s videos available at https://youtu.be/4oe4xiKknt0 and https://www.youtube.com/watch?v=Dgfrum7e-_0&t=87s

Training for all post-secondary employees, and especially for course instructors and other creators of electronic content (such as web site content) should be required to have up-to-date training on accessibility barriers in the area of documents and information and communication generally. For example, they need to be trained that if a document is posted in pdf, it MUST simultaneously be posted in html and/or MS Word. Too many still believe that pdf is or can be an accessible format. This is simply erroneous.

We therefore recommend that:

  1. The Initial Report’s Training recommendations 20 and following should be expanded to require up-to-date training on the creation of accessible digital content, such as in online posts and electronic documents, especially for course instructors and anyone else who creates digital content for use by students and others in the post-secondary community. This training should make it clear that if a document is posted or circulated in pdf, it must also be posted or circulated in MS Word and/or html.

Those involved in the procurement of technology for use in the college or university should be required to get training on procuring accessible technology. Though hard to believe, York University procured an entirely new phone system replete with new accessibility barriers, during the time that the Post-Secondary Education Standards Development Committee was doing its work. This no doubt cost thousands of dollars to implement across the university. Those overseeing this were unaware of its obvious barriers, that became evident within moments of looking at the new phones.

We therefore recommend that:

  1. The Initial Report’s Training recommendations 20 and following should be expanded to require that college or university staff involved in the procurement of any technology or equipment be required to be trained on technology accessibility needs and requirements.

We offer additional proposals to supplement the Initial Report’s Training recommendations.

We therefore recommend that:

  1. The Education Accessibility Standard should require that:
  1. Each post-secondary education organization should provide teaching coaches with expertise in universal design in learning and differential instruction to support instructional staff.
  1. The Ontario Government should create templates or models for the training of college and university instructors on universal design in learning and differential instruction, so that each post-secondary education organization does not have to reinvent the wheel in this context.

 f) Barrier Group 3: Assessment, curriculum and instruction

The Initial Report correctly identifies the serious barrier here facing college and university students with disabilities. It is important for the Final Report to directly identify the cause of this problem. If we do not isolate the cause, we will not find the right cure.

Here is a cause that needs to be openly identified. The key product or service that colleges and universities provide to their students is education, through courses, classes and other supports. The direct provider of this product or service is the course instructor.

To be hired as a post-secondary course instructor, a person does not have to have any knowledge or training in universal design in learning (UDl), i.e. how to effectively teach all students with disabilities in their classes. To be hired as a professor or course instructor at a college or university, a candidate does generally not need to have any training, skill or background in how to teach.

This systemic barrier is deeply embedded in the college and university system. It differs markedly from K-12 schools. To be hired as a teacher, a person must have qualified as a teacher, through designated post-secondary training. The K-12 Education Standards Development Committee has pointed out that even there, there is no requirement for teachers to know how to teach students with disabilities in order to get hired as a teacher. The K-12 Education Standards Development Committee makes several recommendations to address that major shortcoming.

The solution is twofold. First, those already teaching in colleges and universities will need to receive substantial training on how to teach in a way that embeds UDL, so that all students with disabilities can learn in their courses. Second, the hiring, promotion and recruitment processes at Ontario colleges and universities must in future include requirements in this area, so that as new recruits join their teaching faculties, they will be better equipped from the beginning. Since getting a job teaching at Ontario colleges and universities is so competitive, there should be ample capacity to thereby make progress.

We therefore recommend that:

  1. The Initial Report’s recommendations on curriculum, assessment and instruction (Recommendations 31 and following) should be expanded
  1. to identify that a key systemic barrier is the fact that course instructors need not be able to teach, or to teach students with disabilities, to be hired, and to make recommendations for training existing instructor in this area, and
  1. to require such qualifications in the future for recruiting and promoting future faculty.

The Initial report calls for specific Government funding for colleges and universities to hire subject matter experts in the creation of accessible instruction materials. Recommendation 38 of the report includes:

“In consideration of the costs involved in hiring subject matter experts in accessible and inclusive pedagogy/andragogy, and creating accessible materials, the Ontario government should provide dedicated funding to the universities and colleges to support these standards.”

We understand the motivation underlying this recommendation, and other similar recommendations. However, it is critical that the Education Accessibility Standard does not itself perpetuate systemic discriminatory conduct. It would be unacceptable for any colleges and universities to refuse to meet a human rights obligation until and unless the Ontario Government specifically pays for new job posts to do this work. The Ontario Human Rights Code and Charter of Rights have included equality rights for students with disabilities for decades. This is not a new mandate, and should not be treated as such.

Of course, if the Government provides additional financing, that can be a positive step. However, there must be no linkage or precondition that the Government must first fund compliance by colleges and universities with their human rights obligations to students with disabilities.

We therefore recommend that:

  1. The Initial Report, including recommendations such as Recommendation 38, should be revised to make it clear that whether or not the Ontario Government supplements their funding, they must fulfil their decades-old obligations to students with disabilities under the Ontario Human Rights Code and the Charter of Rights.

We supplement the Initial Report’s recommendations in the area of Curriculum, Instruction and Assessment to help make those recommendations fully effective.

We therefore recommend that:

  1. To ensure that instructional materials are fully accessible on a timely basis to students with disabilities such as vision loss and those with learning disabilities that affect reading, each post-secondary education organization should:
  1. Promptly survey students with disabilities who need accessible instructional materials, and their instructional staff, to get their front-line experiences on whether they get timely access to accessible instructional materials, and to get specifics on where this has been most lacking.
  1. Establish a dedicated office or resource within the post-secondary education organization, or shared among post-secondary education organizations, to convert instructional materials to an accessible format, where needed, on a timely basis. A student should not be required to show proof that they own a hard copy of an item to be able to get it in an accessible format.
  1. The Education Accessibility Standard should require the Ontario Government to implement, monitor and publicly report on province-wide strategies to ensure the procurement of and use of accessible instructional materials across post-secondary education organizations.

We do not know what is meant by the Initial Report’s Recommendation 57. It states:

“Recommendation 57: Jurisdiction of accessibility supports in work integrated learning settings (non-regulatory)

Ministry for Seniors and Accessibility should provide guidance to postsecondary institutions and employers with respect to the division of responsibilities and applicability of the act’s standards and accommodations (Ontario Human Rights Commission) for students with disabilities in required work integrated learning settings.”

We therefore recommend that:

  1. The Initial Report’s Recommendation 57 should be explained and clarified, or removed.

It is important for each college and university to ensure barrier-free post-secondary program admission requirements. There is now a risk that admission requirements to a post-secondary program that unintentionally or inadvertently impede access to the program for otherwise-qualified students with disabilities. It is important to ensure that students with disabilities can have their eligibility for admission to a post-secondary program fairly and accurately assessed.

We therefore recommend that:

  1. Every post-secondary education organization should be required to review its admission criteria for gaining admission to any of its post-secondary education programs, to identify any barriers that would impede otherwise-qualified students with disabilities from admission, and shall adjust those criteria to either:
  1. Remove the admission criteria that constitute a barrier to admission, or
  1. Provide an alternative method for assessing students with disabilities for admission to the program.
g)  Barrier area 4: Digital learning and technology

The Initial Report calls for definitions certain terms regarding accessible technology to be established by the Ministry of Colleges and Universities. This is not within that Ministry’s knowledge or expertise. Moreover, under the AODA, it is the accessibility standard that should set this definition to be enforceable. The Initial Report’s Recommendation 65 states:

“Recommendation 65: Accessible technology definitions

The Ministry of Colleges and Universities to provide and adopt clear and consistent definitions across the education sector for key terms relating to digital learning and technology.”

We therefore recommend that:

  1. The Initial Report’s Recommendation 65 should be amended to provide that the Education Accessibility Standard, and not the Ministry of Colleges and Universities, should adopt clear and consistent definitions across the education sector for key terms relating to digital learning and technology.

The Initial Report’s Recommendation 68 (Digital learning and technology plan) proposes that all colleges and universities:

“must develop and make publicly available a plan to seamlessly include accessibility in the digital learning and technology used throughout the academic journey of all students with disabilities.”

The Initial Report’s Recommendation 70 would require colleges and universities to each consult with people with disabilities, including students with disabilities, on this plan.

This might at first all appear to be helpful. However, in the end, it requires all colleges and universities to undertake duplicative work, and to ask people with disabilities, including students with disabilities, the same questions about the same barriers, one institution after the next. The AODA is meant to avoid such duplication of efforts. The Education Accessibility Standard should set the detailed requirements for such a plan. All the plan needs to do is to implement the detailed accessibility requirements that the Education Accessibility Standard should itself set. The same goes for school boards under the K-12 Education Accessibility Standard.

If such plans are to be required, the Education Accessibility Standard should require that they be submitted to the Accessibility Directorate of Ontario, and that they be centrally posted on a searchable online hub.

We therefore recommend that:

  1. The Initial Report’s Recommendations 68 and following, regarding accessible technology, should be revised to:
  1. require that the Education Accessibility Standard itself set specific requirements for accessible technology, and
  1. require that each obligated organization submit its accessibility plan to the Accessibility Directorate of Ontario, which the Accessibility Directorate of Ontario would then be required to post online in a searchable accessible public online hub.

An excellent example of a meritorious recommendation in the Standards Development Committee’s Initial Report which is unfortunately listed as “non-regulatory” is Recommendation 76, regarding the establishment of a the accessible digital technology lead in all colleges and universities. We agree with the substance of this recommendation. However, it should not be “non-regulatory” and hence, voluntary and unenforceable. It should instead be included in the Education Accessibility Standard and be mandatory and enforceable.

We therefore recommend that:

  1. The Initial Report’s Recommendation 76 should be revised to make it mandatory for each college and university to appoint an accessible digital technology lead.

We respectfully but profoundly object to a key part of the Standards Development Committee’s Recommendation regarding so-called “Accessible PDFs”. We fully agree with the Standards Development Committee’s recommendation, where it would require alternative accessible formatted documents to be made available when a pdf is provided or posted. However, we disagree with the Initial Report’s proposal that colleges and universities should invest time, energy and resources into training their staff and instructors to create so-called “accessible pdfs” with a view to their becoming a long term option.

The Initial Report includes:

“Recommendation 87: Accessible PDFs

Postsecondary institutions shall provide all documents in an accessible format. In the case of a PDF, this committee is recommending a phased approach:

phase 1: postsecondary institutions shall use a PDF document only if an accessible alternative format is also simultaneously available

phase 2: postsecondary institutions shall provide suitable software and training for the creation of accessible PDFs to the PDF/UA 1 /ISO 14289 standard. Following this date, any document provided as a PDF must meet this international standard. However, to phase in this requirement it is expected that postsecondary institutions continue to publish PDF-based digital content to be as accessible as their training and applications permit, even if an accessible alternative is provided. This will lessen any remediation costs if there is a need to go back and ensure that currently produced PDFs meet the PDF/UA 1/ISO 14289 standard. This will also demonstrate the postsecondary institutions’ commitment and progress towards creating accessible PDFs.

Timeline: Phase 1: within six months of regulation being enacted. Phase 2: within two years of the regulation being enacted

Recommendation 88: Software and training for accessible PDFs

Postsecondary institutions shall provide suitable software and training for creation of accessible PDFs.

Timeline: Within six months of regulation being enacted

Recommendation 88: Software and training for accessible PDFs

Postsecondary institutions shall provide suitable software and training for creation of accessible PDFs.”

We strongly disagree that colleges and universities should invest any time, resources and energy into training themselves to be able to provide “accessible pdfs.” These resources can be far better used promoting accessibility in other areas. Here’s why:

First, the term “accessible pdf” is a misnomer. Even if the document’s creator spends a great deal of time trying to make their pdf accessible, it still is harder to use than formats such as MS Word.

The Initial Report’s recommendation relies on an ISO standard that we do not endorse or accept. It should not be the legislated standard.

Second, when a person with a disability receives a pdf, they have no idea before they open it whether it has any accessibility at all built into it. Users with disabilities should not be left wondering every time they get a pdf whether it has any accessibility features built into it.

Third, when an author types a document in a format such as MS Word, the starting point is that it is generally accessible unless the author starts doing things to the document that creates barriers. When they convert it to a pdf, its accessibility is thereby destroyed. The author then must spend time trying to rebuild its accessibility. It is better not to create the new barriers in the first place.

Fourth, the pdf software is still evolving. Right now, it is reported to have accessibility bugs. See e.g. https://acrobat.uservoice.com/forums/590923-acrobat-for-windows-and-mac/suggestions/44183082-accessibility-errors-with-pdf-maker-update-sept-20

Fifth, the Initial Repport’s recommendations here will not only require training now for existing staff. It will require ongoing training as new staff join. The risk that in the interim, someone will continue creating problematic pdfs is a substantial one. The message “don’t use pdf, or if you do, also share an accessible MS Word or html document” is far easier to convey, and is far more likely to stick.

Sixth, even if a course instructor is trained on steps to try to insert some accessibility into a pdf, and even if these current accessibility problems were eliminated from the software, which is all speculative, there is no assurance that this training will remain relevant by the time they must use it, and that it will remain relevant in the future.

In sum, it is wasteful to invest time and effort into an effort to get people to make so-called “accessible pdfs”, when they are not assured to be accessible, when there are much easier and no-cost alternatives to such training, and when there are so many other pressing needs for the training resources that would be invested into pdfs. It would be a far better use of such resources to spend the money on training staff and faculty on creating accessible content in the native application such as Word, PowerPoint and Google Docs.

We therefore recommend that:

  1. The Initial Report’s Recommendation 87 should be revised to eliminate “phase two”, which now provides:

“phase 2: postsecondary institutions shall provide suitable software and training for the creation of accessible PDFs to the PDF/UA 1 /ISO 14289 standard. Following this date, any document provided as a PDF must meet this international standard. However, to phase in this requirement it is expected that postsecondary institutions continue to publish PDF-based digital content to be as accessible as their training and applications permit, even if an accessible alternative is provided. This will lessen any remediation costs if there is a need to go back and ensure that currently produced PDFs meet the PDF/UA 1/ISO 14289 standard. This will also demonstrate the postsecondary institutions’ commitment and progress towards creating accessible PDFs.”

  1. The Initial Report’s Recommendation 88 should be removed.

We ask the Standards Development Committee to add some additional recommendations that will help make the Digital Barriers recommendations as effective as possible.

We therefore recommend that:

  1. The Initial Report should be expanded to recommend that the Education Accessibility Standard will require each post-secondary education organization to ensure that its information technology support and help staff includes specialists in access technology, and that students with disabilities get prompt access to IT support when needed.

With the advent of the COVID-19 pandemic, people with disabilities have come to experience that different remote classroom and conference platforms are much more accessible than others. When the pandemic is finally behind us, colleges and universities should benefit from lessons learned. Accessible virtual classroom and conference platforms should be available for students who, because of disability, are more effectively accommodated by attending virtually. This should take place even if the course is being taught in person.

We therefore recommend that:

  1. The Initial Report should be revised to require that
  1. Only accessible conference and remote class platforms may be used.
  1. the Ontario Government should be required to report semi-annually to the public and to colleges and universities on the comparative accessibility of different virtual meeting and teaching platforms, so that colleges and universities do not have to repeat the same investigations.
  1. Even when classes are taught in person, students with disabilities should have the option of attending virtually via an accessible virtual meeting platform, where this accommodation would be helpful to them because of their disability.

It is essential for any learning management system to be accessible, and for all its accessibility features to remained turned on.

We therefore recommend that:

  1. The Initial Report should be expanded to require that any learning management system only be procured and used if it is accessible, and for all its accessibility features to be locked in the “on” position so that they cannot be turned off.

Increasingly, electronic kiosks are being used, as well as inaccessible point-of-sale devices restaurant tablet ordering procedures. The 2011 Integrated Accessibility Standards Regulation provisions regarding electronic kiosks have not been effective. They are too vague and are not effectively enforced.

We therefore recommend that:

  1. The Initial Report should be expanded to ban the use of inaccessible electronic kiosks, electronic point-of-sale devices and restaurant tablet ordering technology at any colleges and universities.

 h) Barrier area 5: Organizational barriers

We support the Initial Report’s Recommendation 91 (Access to Disability Accommodation Information), calling for all students to be notified about availability of disability supports. We encourage the Standards Development Committee to add some more specifics, to help ensure that this is as effective as possible.

We therefore recommend that:

  1. The Initial Report’s Recommendation 91 (Access to Disability Accommodation Information) should be expanded to ensure that the Education Accessibility Standard requires:
  1. The post-secondary education organization’s interactive voice response system for receiving incoming phone calls should announce to all callers the organization’s commitment to accommodate students with disabilities and the number to press to get introductory information about how to seek such.
  1. Programming handouts and broadcast email communications to incoming students should include similar general information.
  1. the post-secondary education organization’s broadcast email announcements and other communications to the student population should include summary information to this effect with relevant links.
  1. Classroom instructors should make announcements in their first week of classes to this effect.

The Initial Report’s Recommendation 92 addresses Documentation policies for academic accommodations. We agree that the Education Accessibility Standard should set standards in this area. We also agree that this process must comply with human rights requirements. However, we do not agree that the Initial Report where it recommends:

“Based on these requirements, postsecondary institutions shall develop in a collaborative manner, a consistent and clear set of policies and practices about the nature and extent of documentation required to establish eligibility for academic accommodation.”

The Education Accessibility Standard should set the standard, not colleges and universities. That is what an accessibility standard is for. It should, for example, set some base line requirements.

For example, we understand that some colleges or universities may ask students with disabilities to re-document their disability each academic year. This is entirely unjustified and an unfair burden on students with disabilities, in cases where their disability is a permanent one. If a student is deaf or blind or has autism, for example, that condition is obviously permanent.

We therefore recommend that:

  1. The Initial Report’s Recommendation 92 should be revised to provide that the Education Accessibility Standard itself should set a clear set of barrier-free requirements regarding a student’s documenting an academic accommodation need. For example, a student should not be required to re-document their disability each year, where it is a permanent or long term disability.

We support the Initial Report’s Recommendation 94 (Full participation). It requires colleges and universities to inform students “…as early as possible in a readily accessible and understandable way, of the institution’s recognition of its duty to ensure that all academically qualified students with disabilities have the right to full participation and full inclusion in all the postsecondary institution’s programming, events, orientations and academic life.”

To make this as clear as possible, it would be helpful if this explicitly includes a reference to the duty to accommodate students with disabilities.

We therefore recommend that:

  1. The Initial Report’s Recommendation 94 should be amended to explicitly require that colleges and universities tell students with disabilities, as soon as possible, about the institution’s duty to accommodate students with disabilities.

In the Initial Report’s Recommendation 95: (Clear policies and procedures) the Standards Development Committee recommends that policies and procedures be adopted in colleges and universities:

“… outlining the process by which students with disabilities can access accommodations for academically related learning activities, including, but not limited to:

classroom

libraries

common areas

online learning tools including accessible software

tests/examinations

internships

practica

co-ops

field placements

apprenticeships

work integrated learning

other experiential learning that are part of their academic program of study”.

This is what the Education Accessibility Standard itself is supposed to specifically detail. Best practices, policies, guidelines and the like are not mandatory or enforceable. They can change on a whim.

Moreover, as noted earlier, the sooner colleges and universities have detailed and specific requirements to meet for barrier identification, barrier removal, and barrier prevention for recurring disability barriers, the fewer accommodations that students with disabilities will need.

We therefore recommend that:

  1. The Initial Report’s Recommendation 94-95 be revised to set out specific accessibility requirements for colleges and universities in such areas as classrooms, libraries, common areas, online learning tools including accessible software, tests/examinations, internships, practica, co-ops, field placements, apprenticeships, work-integrated learning, other experiential learning that are part of their academic program of study, request for priority enrollment in a course, and accessible housing placement. For example, to ensure that students with disabilities can fully participate in a post-secondary education organization’s experiential learning programs, each such organization should:
  1. Review its experiential learning programs to identify and remove any accessibility barriers;
  1. Put in place a process to affirmatively reach out to potential placement organizations in order to ensure that a range of accessible placement opportunities in which students with disabilities can participate are available;
  1. Ensure that its partner organizations that accept students for experiential learning placements are effectively informed of their duty to accommodate the learning needs of students with disabilities;
  1. Create and share supports and advice for placement organizations who need assistance to ensure that students with disabilities can fully participate in their experiential learning placements;
  1. Monitor placement organizations to ensure they have someone in place to ensure that students with disabilities are effectively accommodated, and to ensure that effective accommodation was provided during each placement of a student with a disability who needed accommodation; and
  1. Survey students with disabilities and experiential learning placement organizations at the end of any experiential learning placements to see if their disability-related needs were effectively accommodated.

We also support the Initial Report’s Recommendation 96 (Disability Accommodation Plans). However, it is especially important that the accommodation application and planning process for a student be made swift, simple, and de-bureaucratized. We have received feedback that at some post-secondary institutions, the procedure is overly bureaucratic.

Moreover, to succeed, colleges and universities must remove policies that create clear and obvious barriers. For example, the University of Toronto’s Faculty of Law has a policy forbidding the recording of classes. If students with disabilities need a class recorded, they must go through the process of applying for a disability accommodation. This is an unnecessary and inappropriate step.

In sharp contrast, the Osgoode Hall Law School commendably does not ban the recording of classes at all. To the contrary, it has for several years followed the practice of having all lecture classes automatically recorded, explicitly to be available as an accommodation. Law students at that law school do not have to go through any bureaucracy to access such recordings.

We therefore recommend that:

  1. The Initial Report’s Recommendation 94 and following should be revised to:
  1. Require obligated organizations to review their accommodation procedures for systemic barriers, such as a ban on recording classes to which an exception must be sought through the accommodation process; and
  1. Require that those disability barriers be removed and prevented.

It is a positive step that the Initial Report urges that annual reports be made by colleges and universities about their disability accommodation caseload in Recommendation 98 (Disability Accommodation Caseload – Reporting). We add that these figures should be required to be submitted to The Government and that The Government be required to make them publicly available on an institution-by-institution basis, and as provincial aggregations or averages.

We therefore recommend that:

  1. The Initial Report’s Recommendation 98 (Disability Accommodation Caseload – Reporting) be revised to require that each college or university disability accommodation caseloads be reported to The Government, with The Government being required to publish these online annually on an institution-by-institution basis, and as provincial aggregations or averages.

We share the goal in Recommendation 99 (Accessibility Lens), but not how the Standards Development Committee proposes to address that goal. The Initial Report delegates to the Accessibility Ministry responsibility to consult with key stakeholders to create an accessibility lens for colleges and universities to use in major decisions. That is in effect assigning them to create a de facto Education Accessibility Standard, but calling it a “disability lens”. Instead, it is the Standards Development Committee that through its consultation should set out the specific recurring disability barriers and the corrective measures to avoid them.

We therefore recommend that:

  1. The Initial Report’s Recommendation 99 (Accessibility Lens) be removed and replaced with specific recommendations on the recurring disability barriers to be removed and prevented, and what must be done to remove and prevent them.

We agree with Recommendations 104-106 (Accessible Procurement Policies and Procedures), but we ask that these be refined to clarify that these procurement standards must be detailed and specific, both on the procurement process and the kinds of barriers to be avoided (a non-exhaustive specification of barriers). The extremely vague wording in the Integrated Accessibility Standards Regulation for the past decade has been ineffective. For example, section 5 of the Integrated Accessibility Standards Regulation now provides:

“Procuring or acquiring goods, services or facilities

  1. (1) The Government of Ontario, Legislative Assembly and designated public sector organizations shall incorporate accessibility design, criteria and features when procuring or acquiring goods, services or facilities, except where it is not practicable to do so. O. Reg. 191/11, s. 5 (1); O. Reg. 413/12, s. 4 (1).

(2) If the Government of Ontario, Legislative Assembly or a designated public sector organization determines that it is not practicable to incorporate accessibility design, criteria and features when procuring or acquiring goods, services or facilities, it shall provide, upon request, an explanation.”

The IASR’s “not practicable” standard wrongly falls short of the mandatory human rights standard of “undue hardship”. Moreover, the vague requirement of incorporating accessible features does not ensure that no new barriers are created.

There is no effective monitoring or enforcement of the current vague requirements. As noted above, York University purchased a new telephone system replete with accessibility barriers under that regime.

We therefore recommend that:

  1. The Initial Report’s Recommendations 104-16 ((Accessible Procurement Policies and Procedures) should be revised to require that the accessible procurement standards are mandatory, include detailed specifics, are more robust than the current section 5 of the Integrated Accessibility Standards Regulation, and require public accountability/reporting to ensure that they can be effectively monitored and enforced.

We commend Recommendations 108-110 (Handling Accommodation Requests). We would add that at present, from feedback received, some of these processes are too slow and bureaucratic. There should be a simplified process required. Where the request is for a routine accommodation, it should go through a rapid process. Those which may be more unusual or complex and require more effort should be routed into a process designed to effectively address their greater complexity.

We therefore recommend that:

  1. The Initial Report’s Recommendations 108-110 (Handling Accommodation Requests) should be expanded to spell out mandatory baseline requirements for student accommodation request procedures, so that each college or university does not have to re-design their own procedures, and which:
  1. Require the de-bureaucratizing of the handling of accommodation requests by students;
  1. Require a fast-track process for routine accommodation requests which are suitable for such a process;
  1. Require a separate track for more unusual or complex requests to be addressed in an effective and time-sensitive way; and
  1. Ensure that if the student had an Individual Education Plan (IEP) from an Ontario school, or a finding by an Ontario school board’s Identification and Placement Review Committee (IPRC) that identified them as having a disability (exceptionality), or a comparable form of documentation from another jurisdiction, then the post-secondary education organization should treat that as sufficient proof that the student has a disability, without requiring further assessments or proof, unless the post-secondary education organization has independent proof showing that the student no longer has that disability. In that case, the post-secondary education organization shall provide the student with that proof and shall provide the student with an opportunity to demonstrate that they have a disability-related accommodation need. The student’s IEP should not be treated as a ceiling on what a person can request, since a person’s accommodations needs may be different in the postsecondary environment.

In the Initial Report’s Recommendations 111 –113 (Service Animals), there are separate references to service animals and support animals. This incorrectly implies that a support animal is not a service animal. We doubt that this is the Standards Development Committee’s intention.

We therefore recommend that:

  1. The Initial Report’s Recommendations 111-113 (Service Animals) should be revised to replace the term “service animals and support animals” with the more accurate term “service animals, including support animals.”

We support the Standards Development Committees various university governance recommendations, but add one more to make them as effective as possible.

We therefore recommend that:

  1. Each post-secondary education organization should be required to establish a permanent committee of its governing board of directors or trustees to be called the “Accessibility Committee”. This Accessibility Committee should have responsibility and authority to oversee the organization’s compliance with the Accessibility for Ontarians with Disabilities Act and with the requirements of the Ontario Human Rights Code and the Canadian Charter of Rights and Freedoms as far as they guarantee the right of students with disabilities to fully participate in and fully benefit from the education programs and opportunities that the organization provides.

It is very commendable that the Standards Development Committee made equity, diversity, and inclusion a core principle for its work. The Initial Report states:

“Therefore the principles of equity, diversity, and inclusion underlie all aspects of the committee’s work.”

In recent years, there has been a commendable and growing recognition that it is important for an effective education system to focus at all levels on equity, diversity, and inclusion. Equity, diversity, and inclusion efforts have, for example, expanded curriculum content and course offerings to address the needs and circumstances of women, racialized peoples, Indigenous communities, and the LGBTQ population.

Such equity, diversity, and inclusion efforts need to fully and equally include people with disabilities and effectively address their issues and needs. This is not an isolated concern. Across the broader K-12 and post-secondary education systems as well as in some other contexts, equity, diversity, and inclusion initiatives have excluded disability altogether or have included but substantially underserved people with disabilities. In those instances, equity for some creates equity for none. An old hierarchy replaces a new hierarchy, in which people with disabilities remain in a position of chronic disadvantage.

We therefore recommend that:

  1. The Standards Development Committee should recommend that any equity, diversity, and inclusion strategy at any college or university should be reviewed and, where needed, revised to ensure that disability is a full and equal target and focus of that strategy.

People with disabilities working in post-secondary education organizations often face accessibility barriers in the workplace that also hurt students with disabilities. The experience and expertise of people with disabilities working in post-secondary education organizations should be effectively harnessed to help root out the accessibility barriers that impede students with disabilities. This is because workplace disability barriers and education service disability barriers are often the same or substantially overlap.

We therefore recommend that:

  1. Each post-secondary education organization should be required to establish a committee of those employees and volunteers with disabilities who wish to join, to give the organization’s senior management feedback on the barriers in the organization that could impede employees or students with disabilities.

 i) Barrier area 7: Physical and architectural barriers Recommendations

The Initial Report’s Recommendations 127 proposes adoption of the Brock University technical requirements for accessible built environment design. We propose instead that the Facility Accessibility Design Standards (FADS) established at the Ontario College of Art and Design University (OCAD University) be adopted: https://www.ocadu.ca/sites/default/files/2021-06/OCADU_FADS_21-05-26.pdf

This version of FADS has been updated to include or remove any conflicts with the 2020 and 2022 changes to the Ontario Building Code. It also has improved details for some elements and for some facility types making it a more up-to-date standard for built environment design for education facilities, including the types of facilities that might be found at post-secondary education institutions.

This can be enriched by the built environment proposals set out in the K-12 Education Standards Development Committee’ Initial Report, which are set out below in Appendix 1.

These standards must govern not only the buildings and structures, but the furniture as well.

We therefore recommend that:

  1. The Initial Report’s Recommendations 127-128 should be revised to recommend
  1. The adoption of the Education Accessibility Standards of the OCAD University Facility Accessibility Design Standards (FADS) https://www.ocadu.ca/sites/default/files/2021-06/OCADU_FADS_21-05-26.pdf enriched by the K-12 Education Standards Development Committee Initial Report’s built environment recommendations; and
  1. Set standards for accessibility of the furniture in the premises of colleges and universities.

The Initial Report’s Recommendation 139 (Identify Barriers and Provide Accommodations) states:

“Postsecondary institutions shall proactively identify barriers in the built environment that cannot be removed or avoided through alternative access due to legal or geographic barriers, such as heritage designation or zoning restrictions.”

This recommendation is incorrect. The Ontario Human Rights Code and Canadian Charter of Rights and Freedoms prevail over other regulatory and statutory instruments, such as zoning bylaws. Moreover, heritage is not itself an “undue hardship” that overrides the duty to accommodate. At most, when a heritage building is involved, an organization can first seek ways to add accessibility, with the least impact on the building’s heritage features.

We therefore recommend that:

  1. The Initial Report’s Recommendation 139 (Identify Barriers and Provide Accommodations) should be revised to remove an incorrect suggestion that zoning bylaws or heritage designation are a legal bar to implementing accessibility in a building.

The Initial Report’s Recommendation 153 (Signage and Wayfinding) contains some measures to address way-finding. We add that there is a need for each campus to be reviewed to ensure that there is effective cane-detectable way-finding both indoors and outside. As one example, York University’s Downsview campus can be extremely challenging for a person with vision loss to navigate because, among other barriers, outdoor paved paths curve into each other rather than having clearly defined cane-detectable intersections.

Here again, the OCAD University FADS should be adopted, not Brock University’s standard.

We therefore recommend that:

  1. The Initial Report’s Recommendation 153 (Signage and Wayfinding) should be revised to:
  1. Invoke the OCAD University FADS standard for signage and way-finding, instead of those by Brock University; and
  1. Require that each campus review its indoor and outdoor property for effective cane-detectable way-finding, and institute such way-finding if inadequate or non-existent.

It is important not to exacerbate existing barriers in the built environment at any colleges or universities.

We therefore recommend that:

  1. The Initial Report’s recommendations regarding the built environment should be expanded to require that, where possible, a post-secondary education organization should not renovate an existing facility that lacks disability accessibility, unless the organization has a plan to also make that facility accessible. For example, a post-secondary education organization should not spend public money to renovate the second storey of a facility which is inaccessible, if the organization does not have a plan to make that second storey disability-accessible. Very pressing health and safety concerns should be the only reason for any exception to this.

Part of the built environment at a post-secondary institution is its gym facilities and equipment.

We therefore recommend that:

  1. The Initial Report’s built environment recommendations should be expanded to require that each post-secondary education organization:
  1. Take inventory of the accessibility of its existing indoor and outdoor gym, sports, athletic and like equipment and spaces, and make this public, including posting this information online;
  1. Adopt a plan to remediate the accessibility of existing gym, sports, athletic or other like equipment or spaces, in consultation with students with disabilities; and
  1. Ensure that a qualified accessibility expert is engaged to ensure that the purchase of new equipment or remediation of existing equipment or spaces is properly conducted, with their advice being given directly to the post-secondary education organization.

The Initial Report does not set out specific recommendations regarding the shoveling of snow. Each winter, every campus implements some sort of snow removal to ensure that the campus community can get around and into its buildings. However, this may not ensure that people with disabilities can also safely navigate the campus. Snow can be piled up along accessible paths of travel.

A few years ago, one law student’s video went viral and gained media attention. The video showed that snow was shoveled in a way that enabled walking people to use paths on one campus, but which did not enable safe passage by a person using a wheelchair. We include the February 2, 2019 CBC News report on this, as it fully illustrates this issue.

Originally posted at https://www.cbc.ca/news/canada/toronto/watch-this-york-student-struggle-to-get-to-class-in-a-wheelchair-due-to-uncleared-snow-1.5003306

“Ali Imrie’s Twitter video shows her struggling on a snow-covered path on university campus

Kelda Yuen

Osgoode Hall Law School student Ali Imrie says she missed one class and was late for another this week due to snow-covered sidewalks on the York University campus. (Ali Imrie/ Twitter)

Ali Imrie says it’s only 500 metres from her student apartment to Osgoode Hall Law School on the York University campus in Toronto, but even so, she wasn’t able to make it to all her classes this week due to uncleared snow.

“Honestly, this week hasn’t been any different than any other week in the snow,” she said.

But this time, she took a video and posted it on Twitter. The 17-second clip posted Thursday evening shows a friend struggling to push her home from class along a snowy path. At one point, they appear to get stuck. Within a day, the post garnered over 20,000 views and was shared almost 500 times.

The video is raising the issue of a lack of accessibility for students with mobility issues during weather events like the snowstorm the Toronto area experienced this week.

Imrie is quick to note she understands it is difficult to keep pathways clear with the “crazy amounts of snow” that fell, but she is frustrated at what she believes is a lack of initiative from the school to keep on top of snow clearing.

Barbara Joy, the spokesperson for York, told CBC Toronto Friday the university has reached out to Imrie and has since done checks to ensure all paths on campus are clear.

The specific path in Imrie’s video, Joy said, “was actually cleared several times since the snow began, but unfortunately it wasn’t adequate.”

Hoping for a permanent solution

Imrie says she has been flagging the problem for some time now, and she wants a more permanent solution.

This is her third year using a wheelchair since being diagnosed with myalgic encephalomyelitis, also known as chronic fatigue syndrome, and her second year living on campus as a part-time law student.

When she first arrived, her mobility issues made it “difficult and isolating,” she said.

“It got to the point, last January, where I had a rotating schedule of which friend could meet me before or after class to help me get there,” she told CBC Toronto.

She says she contacted the school about it repeatedly, but the problem of uncleared snow persisted.

“The reaction will be reactive and in the moment — it’s fixed. But given it’s been a year and I keep needing to bring it up every time it snows, what’s missing is the proactive piece. There’s not really been any lasting change.”

Imrie says she understands York ‘is a really big campus and it’s difficult to keep it clear all the time,’ but she hopes the university can be more proactive in making sure paths remain clear.

Joy admits York needs to “do better.”

One thing she says the university will do is ensure employees perform more checks to make sure all pathways remain clear.

“With storms, there is blowing snow and other things that impact the way the path is covered in snow, so even if it was cleared in the morning, doesn’t mean we shouldn’t check it in the afternoon,” she said.

“We are going to keep on top of it to make sure it’s maintained.”

Joy also points out there is a shuttle that’s offered to students with mobility issues.

But Imrie says the shuttle can take up to an hour to arrive after being booked.

“For me, because (my illness) is so fatiguing, if I’m in a three-hour class, I can’t add another hour on either end to wait for a van.”

Joy says the school is looking into ways the shuttle can accommodate her better.

Not just a York University problem

Imrie, meanwhile, has another suggestion.

While it would be ideal to have the paths clear at all times, she says the ones heavily used by students with mobility issues should perhaps get priority when it comes to snow clearing.

“There’s different implications for me versus someone who’s walking.”

She is also quick to note that lack of accessibility is not just a problem her school needs to fix.

She says on her route to class, she has to travel on a sidewalk partially owned by the city.

She says it’s rarely cleared after a snowstorm.

“It’s an issue everywhere.””

We therefore recommend that:

  1. The Initial Report should be expanded to include, in its built environment recommendations, specific mandatory requirements at all colleges and universities to ensure that snow-shoveling creates no disability barriers and is sufficient to enable people with disabilities to navigate the campus.

It is important for the Education Accessibility Standard to include protections regarding the Indoor air/environment quality to ensure accessibility for those with environmentally linked disabilities, such as Environmental Sensitivities (which includes Multiple Chemical Sensitivities, EMF Sensitivities, etc.), Fibromyalgia, Asthma, Cancer, Diabetes, Chemical Pneumonitis, Migraines, Chronic Fatigue, Lyme Disease, etc.

We therefore recommend that:

  1. The Initial Report’s built environment recommendations should be expanded to include indoor air quality requirements for persons for whom this can create disability barriers.

It is important for students with disabilities and other people with disabilities to know where accessibility features are included in the campus, so they can plan their route of travel.

We therefore recommend that:

  1. The Initial Report should be revised to require each college or university to create and make available an up-to-date guide on the accessibility features in its built environment, such as electric door openers and ramps.

Since college and university campuses now have many accessibility barriers in their built environment, it is important for students with disabilities to be assured that courses they wish to take will be offered in an accessible classroom.

We therefore recommend that:

  1. The Initial Report should be revised to:
  1. Ensure that students with disabilities have available an earlier or accelerated process for getting their course selections confirmed; and
  1. Have in place a mandatory process for the college or university to make priority re-assignment of any classes from inaccessible classrooms to accessible classrooms, where needed.

Campuses can have paths of travel blocked due to construction. Without centralized control, students and others can encounter unpredictable barriers.

We therefore recommend that:

  1. The Initial Report should be expanded to require each college and university to:
  2. Ensure to the extent possible that construction projects on campus do not block accessible paths of travel, and accessibility features such as ramps and accessible doors; and
  1. Maintain a publicly-accessible up-to-date web page or other easily-accessed public announcement of the location and expected timing of construction projects that may impede accessible travel.

Graduation ceremonies should always be accessible to students, family members, friends, and staff with disabilities.

We therefore recommend that:

  1. The Initial Report should be expanded to specifically require that the venue of graduation ceremonies be accessible to students, family members, friends and staff members with disabilities, including the graduation platform.

The Ontario Government funds some building projects at colleges or universities. It must ensure that any such projects will be fully accessible before agreeing to that funding. In 2017, the Ontario Government agreed to invest $125 million in a new Markham campus for York University that had several serious accessibility barriers in its design.

We therefore recommend that:

  1. The Education Accessibility Standard require that the Ontario Government ensure that public funds are never used to create or perpetuate disability barriers in the built environment.
  1. The Ontario Government be required to revise its funding criteria for construction of facilities at a post-secondary education organization to ensure that it requires, and does not obstruct, the inclusion of all needed accessibility features in that construction project.

 Appendix 1. Initial Recommendations of the K-12 Education Standards Development Committee on Ensuring Physical Accessibility of the Built Environment in Education Settings

(Note: Even though these recommendations are written to address the school setting, they can easily apply to a very wide range of other buildings)

Specific Accessibility Requirements Recommendations

Recommendation Part Three: Usable Accessible Design for Exterior Site Elements

The following should be required:

  1. Access to the site for pedestrians
  2. a) Clear, intuitive connection to the accessible entrance
  3. b) A tactile raised line map shall be provided at the main entry points adjacent to the accessible path of travel but with enough space to ensure users do not block the path for others
  4. c) Path of travel from each sidewalk connects to an accessible entrance with few to no joints to avoid bumps. The primary paths shall be wide enough to allow two-way traffic with a clear width that allows two people using wheelchairs or guide dogs to pass each other. For secondary paths where a single path is used, passing spaces shall be provided at regular intervals and at all decision points. The height difference from the sidewalk to the entrance will not require a ramp or stairs. The path will provide drainage slopes only and ensure no puddles form on the path. Paths will be heated during winter months using heat from the school or other renewable energy sources.
  5. d) Bike parking shall be adjacent to the entry path. Riders shall be required to dismount and not ride on the pedestrian routes. Bike parking shall provide horizontal storage with enough space to ensure users and parked bikes do not block the path for others. The ground surface below the bikes shall be colour contrasted and textured to be distinct from the pedestrian path.
  6. e) Rest areas and benches with clear floor space for at least two assistive mobility devices or strollers or a mix of both shall be provided. Benches shall be colour contrasted, have back and arm rests and provide transfer seating options at both ends of the bench. These shall be provided every 30m along the path placed adjoining. The bench and space for assistive devices are not to block the path. If the path to the main entrance is less than 30m at least one rest area shall be provided along the route. If the drop-off area is in a different location than the pedestrian route from the sidewalk, an interior rest area shall be provided with clear sightlines to the drop-off area. If the drop-off area is more than 20m from the closest accessible entrance an exterior accessible heated shelter shall be provided for those awaiting pick-up. The ground surface below the rest areas shall be colour contrasted and textured to be distinct from the pedestrian path it abuts
  7. f) Tactile directional indicators shall be provided where large open paved areas happen along the route
  8. g) Accessible pedestrian directional signage at decision points
  9. h) Lighting levels shall be bright and even enough to avoid shadows and ensure it’s easy to see the features and to keep people safe.
  10. i) Accessible duress stations (Emergency safety zones in public spaces)
  11. j) Heated walkways shall be used where possible to ensure the path is always clear of snow and ice
  1. Access to the site for vehicles
  2. a) Clear, intuitive connection to the drop-off and accessible parking
  3. b) Passenger drop-off shall include space for driveway, layby, access aisle (painted with non slip paint), and a drop curb (to provide a smooth transition) for the full length of the drop off. This edge shall be identified and protected with high colour contrasted tactile attention indicators and bollards to stop cars, so people with vision loss or those not paying attention get a warning before walking into the car area. Sidewalk slopes shall provide drainage in all directions for the full length of the dropped curb
  4. c) Overhead protection shall be provided by a canopy that allows for a clearance for raised vans or buses and shall provide as much overhead protection as possible for people who may need more time to load or off-load
  5. d) Heated walkways from the drop-off and parking shall be used to ensure the path is always clear of snow and ice
  6. e) A tactile walking directional indicator path shall lead from the drop-off area to the closest accessible entrance to the building (typically the main entrance)
  7. f) A parking surface will only be steep enough to provide drainage in all directions. The drainage will be designed to prevent puddles from forming at the parking or along the pedestrian route from the parking
  8. g) Parking design should include potential expansion plans for future growth and/or to address increased need for accessible parking
  9. h) Parking access aisles shall connect to the sidewalk with a curb cut that leads to the closest accessible entrance to the building. (so that no one needs to travel along the driveway behind parked cars or in the path of car traffic)
  10. i) Lighting levels shall be bright and even enough to avoid shadows and to ensure it’s easy to see obstacles and to keep people safe.
  11. j) If there is more than one parking lot, each site shall have a distinctive colour and shape symbol associated with it that will be used on all directional signage especially along pedestrian routes.
  12. Parking
  13. a) The provision of parking spaces near the entrance to a facility is important to accommodate persons with a varying range of abilities as well as persons with limited mobility. Medical conditions, such as anemia, arthritis or heart conditions, using crutches or the physical act of pushing a wheelchair, all can make it difficult to travel long distances. Minimizing travel distances is particularly important outdoors, where weather conditions and ground surfaces can make travel difficult and hazardous.
  14. b) The sizes of accessible parking stalls are important. A person using a mobility aid such as a wheelchair requires a wider parking space to accommodate the manoeuvring of the wheelchair beside the car or van. A van may also require additional space to deploy a lift or ramp out the side or back door. An individual would require space for the deployment of the lift itself as well as additional space to manoeuvre on/off the lift.
  15. c) Heights of passage along the driving routes to accessible parking is a factor. Accessible vans may have a raised roof resulting in the need for additional overhead clearance. Alternatively, the floor of the van may be lowered, resulting in lower capacity to travel over for speed bumps and pavement slope transitions.
  16. d) Wherever possible, parking signs shall be located away from pedestrian routes, because they can constitute an overhead and/or protruding hazard. All parking signage shall be placed at the end of the parking space in a bollard barricade to stop cars, trucks or vans from parking over and blocking the sidewalk.
  1. A Building’s Exterior doors
  2. a) Level areas on both sides of a building’s exterior door shall allow the clear floor space for a large scooter or mobility device or several strollers to be at the door. Exterior surface slope shall only provide drainage away from the building.
  3. b) 100% of a building’s exterior doors will be accessible with level thresholds, colour contrast, accessible door hardware and in-door windows or side windows (where security allows) so those approaching the door can see if someone is on the other side of the door
  4. c) Main entry doors at the front of the building and the door closest to the parking lot (if not the same) to be obvious, prominent and will have automatic sliders with overhead sensors. Placing power door operator buttons correctly is difficult and often creates barriers especially within the vestibule
  5. d) Accessible security access for after hours or if used all day with 2-way video for those who are deaf and/or scrolling voice to text messaging
  6. e) All exit doors shall be accessible with a level threshold and clear floor space on either side of the door. The exterior shall include a paved accessible path leading away from the building

Accessible Design for Interior Building Elements – General Requirements Recommendations

The following should be required:

85. Entrances:

  1. a) All entrances used by staff and/or the public shall be accessible and comply with this section. In a retrofit situation where it is technically infeasible to make all staff and public entrances accessible, at least 50% of all staff and public entrances shall be accessible and comply with this section. In a retrofit situation where it is technically infeasible to make all public entrances accessible, the primary entrances used by staff and the public shall be accessible.

86. Door:

  1. a) Doors shall be sufficiently wide enough to accommodate stretchers, wheelchairs or assistive scooters, pushing strollers, or making a delivery
  2. b) Threshold at the door’s base shall be level to allow a trip free and wheel friendly passage.
  3. c) Heavy doors and those with auto closers shall provide automatic door openers.
  4. d) Room entrances shall have doors.
  5. e) Direction of door swing shall be chosen to enhance the usability and limit the hazard to others of the door opening.
  6. f) Sliding doors can be easier for some individuals to operate and can also require less wheelchair manoeuvring space.
  7. g) Doors that require two hands to operate will not be used.
  8. h) Revolving doors are not accessible.
  9. i) Full glass doors are not to be used as they represent a hazard.
  10. j) Colour-contrasting will be provided on door frames, door handles as well as the door edges.
  11. k) Door handles and locks will be operable by using a closed fist, and not require fine finger control, tight grasping, pinching, or twisting of the wrist to operate

87. Gates, Turnstiles and Openings:

  1. a) Gates and turnstiles should be designed to accommodate the full range of users that may pass through them. Single-bar gates designed to be at a convenient waist height for ambulatory persons are at neck and face height for children and chest height for persons who use wheelchairs or scooters.
  2. b) Revolving turnstiles should not be used as they are a physical impossibility for a person in a wheelchair to negotiate. They are also difficult for persons using canes or crutches, or persons with poor balance.
  3. c) All controlled entry points will provide an accessible width to allow passage of wheelchairs, other mobility devices, strollers, walkers or delivery carts.

88. Windows, Glazed Screens and Sidelights

  1. a) Broad expanses of glass should not be used for walls, beside doors and as doors can be difficult to detect. This may be a particular concern to persons with vision loss/no vision. It is also possible for anyone to walk into a clear sheet of glazing especially if they are distracted or in a hurry.
  2. b) Windowsill heights and operating controls for opening windows or closing blinds should be accessible…located on a path of travel, with clear floor space, within reach of a shorter or seated user, colour contrasted and not require punching or twisting to operate.

89. Drinking Fountains

  1. a) Drinking fountain height should accommodate children and that of a person using a wheelchair or scooter. Potentially conflicting with this, the height should strive to attempt to accommodate individuals who have difficulty bending and who would require a higher fountain. Where feasible, this may require more than one fountain, at different heights. The operating system shall account for limited hand strength or dexterity. Fountains will be recessed, to avoid protruding into the path of travel. Angled recessed alcove designs allow more flexibility and require less precision by a person using a wheelchair or scooter. Providing accessible signage with a tactile attention indicator tile will help those who with vision loss to find the fountain.

90. Layout

  1. a) The main office where visitors and others need to report to upon entering the building shall always be located on the same level as the entrance, as close to the entrance as possible. If the path of travel to the office crosses a large open area, a tactile directional indicator path shall lead from the main entrance(s) to the office ID signage next to the office door.
  2. b) All classrooms and or public destinations shall be on the ground floor. Where this is not possible, at least 2 elevators should be provided to access all other levels. Where the building is long and spread out, travel distance to elevators should be considered to reduce extra time needed for students and staff or others who use the elevators instead of the stairs. If feature stairs (staircases included in whole or in part for design aesthetics) are included, elevators shall be co-located and just as prominent as the stairs
  3. c) Corridors should meet at 90-degree angles. Floor layouts from floor to floor should be consistent and predictable so the room number line up and are the same with the floors above and below along with the washrooms
  4. d) Multi-stall washrooms shall always place the women’s washroom on the right and the men’s washroom on the left. No labyrinth entrances shall be used. Universal washrooms shall be co-located immediately adjacent to the stall washrooms, in a location that is consistent and predictable throughout the building

91. Facilities

  1. a) The entry doors to each type of facility within a building should be accessible, colour contrasted, obvious and prominent and designed as part of the wayfinding system including accessible signage that is co-located with power door openers controls.
  2. b) Tactile attention indicator tile will be placed on the floor in front of the accessible ID signage at each room or facility type. Where a room or facility entrance is placed off of a large interior open area

Accessible Design for Interior Building Elements – Circulation Recommendations

The following should be required:

92. Elevators

  1. a) Elevator Doors will provide a clear width to allow a stretcher and larger mobility devices to get in and out
  2. b) Doors will have sensors so doors will auto open if the doorway is blocked
  3. c) Elevators will be installed in pairs so that when one is out of service for repair or maintenance, there is an alternative available.
  4. d) Elevators will be sized at allow at least two mobility device users and two non-mobility devices users to be in the elevator at the same time. This should also allow for a wide stretcher in case of emergency.
  5. e) Assistive listening will be available in each elevator to help make the audible announcements heard by those using hearing aids
  6. f) Emergency button on the elevator’s control panel will also provide 2-way communication with video and scrolling text and a keyboard for people who are deaf or who have other communication disabilities
  7. g) Inside the elevators will be additional horizontal buttons on the side wall in case there is not enough room for a person using a mobility aid to push the typical vertical buttons along the wall beside the door. If there are only two floors the elevator will only provide the door open, close and emergency call buttons and the elevator will automatically move to the floor it is not on.
  8. h) The words spoken in the elevator’s voice announcement of the floor will be the same as the braille and print floor markings, so the button shows 1 as a number, 1 in braille and the voice says first floor not G for Ground with M in braille and voice says first floor.)
  9. i) Ensure the star symbol for each elevator matches ground level appropriate to the elevator. The star symbol indicates the floor the elevator will return to in an emergency. This means users in the elevator will open closest to the available accessible exit. If the entrance on the north side is on the second floor, the star symbol in that elevator will be next to the button that says 2. If the entrance on the south side of the building is on the 1st floor, the star symbol will be next to the button that says 1.
  10. j) The voice on the elevator shall be set at a volume that is audible above typical noise levels while the elevator is in use, so that people on the elevator can easily hear the audible floor announcements.
  11. k) Lighting levels inside the elevator will match the lighting at the elevator lobbies. Lighting will be measured at the ground level
  12. l) Elevators will provide colour contrast between the floor and the walls inside the cab and between the frame of the door or the doors with the wall surrounding in the elevator lobbies. Vinyl peel and stick sheets or paint will be used to cover the shiny metal which creates glare. Vinyl sheets will be plain to ensure the door looks like a door, and not like advertising
  13. m) In a retrofit situation where adding 2 elevators is not technically possible without undue hardship, platform lifts may be considered. Elevators that are used by all facility users are preferred to platform lifts which tend to segregate persons with disabilities and which limit space at entrance and stair locations. Furthermore, independent access is often compromised by such platform lifts, because platform lifts are often requiring a key to operate. Whenever possible, integrated elevator access should be incorporated to avoid the use of lifts.

93. Ramps

  1. a) A properly designed ramp can provide wait-free access for those using wheelchairs or scooters, pushing strollers or moving packages on a trolley or those who are using sign language to communicate and don’t want to stop talking as they climb stairs.
  2. b) A ramp’s textured surfaces, edge protection and handrails all provide important safety features.
  3. c) On outdoor ramps, heated surfaces shall be provided to address the safety concerns associated with snow and ice.
  4. d) Ramps shall only be used where the height difference between levels is no more than 1m (4ft). Longer ramps take up too much space and are too tiring for many users. Where a height difference is more than 1m in height, elevators will be provided instead.
  5. e) Landings will be sized to allow a large mobility device or scooter to make a 360 degree turn and/or for two people with mobility assistive devices or guide dogs to pass
  6. f) Slopes inside the building will be no higher than is permitted for exterior ramps in the Accessibility for Ontarians with Disabilities Act’s Design of Public Spaces Standard, to ensure usability without making the ramp too long.
  7. g) Curved ramps will not be used, because the cross slope at the turn is hard to navigate and a tipping hazard for many people.
  8. h) Colour and texture contrast will be provided to differentiate the full slope from any level landings. Tactile attention domes shall not be used at ramps, because they are meant only for stairs and for drop-off edges like at stages

94. Stairs

  1. a) Stairs that are comfortable for many adults may be challenging for children, seniors or persons of short stature.
  2. b) The leading edge of each step (aka nosing) shall not present tripping hazards, particularly to persons with prosthetic devices or those using canes and will have a bright colour contrast to the rest of the horizontal step surface.
  3. c) Each stair in a staircase will use the same height and depth, to avoid creating tripping hazards
  4. d) The rise between stairs will always be smooth, so that shoes will not catch on an abrupt edge causing a tripping hazard. These spaces will always be closed as open stairs create a tripping hazard.

The top of all stair entry points will have a tactile attention indicator surface, to ensure the drop-off is identified for those who are blind or distracted.

  1. e) Handrails will aid all users navigating stairways safely. Handrails will be provided on both sides of all stairs and will be provided at both the traditional height as well as a second lower rail for children or people who are shorter. These will be in a high colour contrasting colour and round in shape, without sharp edges or interruptions.

Accessible Design for Interior Building Elements – Washroom Facilities Recommendations

The following should be required:

95. General Washroom Requirements

  1. a) Washroom facilities will accommodate the range of people that will use the space. Although many persons with disabilities use toilet facilities independently, some may require assistance. Where the individual providing assistance is of the opposite gender then typical gender-specific washrooms are awkward, and so an individual washroom is required.
  2. b) Parents and caregivers with small children and strollers also benefit from a large, individual washroom with toilet and change facilities contained within the same space.
  3. c) Circumstances such as wet surfaces and the act of transferring between toilet and wheelchair or scooter can make toilet facilities accident-prone areas. An individual falling in a washroom with a door that swings inward could prevent his or her own rescuers from opening the door. Due to the risk of accidents, emergency call buttons are vital in all washrooms.
  4. d) The appropriate design of all features will ensure the usability and safety of all toilet facilities.
  5. e) The identification of washrooms will include pictograms for children or people who cannot read. All signage will include braille that translates the text on the print sign, and not only the room number.
  6. f) There are three types of washrooms. Single use accessible washrooms, single use universal washrooms, and multi-use stalled washrooms. The number and types of washrooms used in a facility will be determined by the number of users. There will always at least be one universal washroom on each floor.
  7. g) All washrooms will have doors with power door opening buttons. No door washrooms will be hard to identify for people who have vision loss.
  8. h) Stall washrooms accessible sized stalls – At least 2 accessible stalls shall be provided in each washroom to avoid long wait times. Schools with accessible education programs that include a large percentage of people with mobility disabilities should to have all stalls sized to accommodate a turn circle and the transfer space beside the toilet.
  9. i) All washrooms near rooms that will be used for public events shall include a baby change table that is accessible to all users, not placed inside a stall. It shall be colour contrasted with the surroundings and usable for those in a seated mobility device and or of shorter stature.
  10. j) At least one universal washroom will include an adult sized change table, with the washroom located near appropriate facilities in the school and any public event spaces. These are important for some adults with disabilities and for children with disabilities who are too large for the baby change tables. This helps prevent anyone from needing to be changed lying on a bathroom floor.
  11. k) Where shower stalls are provided, these shall include accessible sized stalls.
  12. l) Portable Toilets at Special Events shall all be accessible. At least one will include an adult sized change table.
  1. Washroom Stalls
  2. a) Size: Manoeuvrability of a wheelchair or scooter is the principal consideration in the design of an accessible stall. The increased size of the stall is required to ensure there is sufficient space to facilitate proper placement of a wheelchair or scooter to accommodate a person transferring transfer onto the toilet from their mobility device. There may also be instances where an individual requires assistance. Thus, the stall will have to accommodate a second person.
  3. b) Stall Door swings are normally outward for safety reasons and space considerations. However, this makes it difficult to close the door once inside. A handle mounted part way along the door makes it easier for someone inside the stall to close the door behind them.
  4. c) Minimum requirements for non-accessible toilet stalls are included to ensure that persons who do not use wheelchairs or scooters can be adequately accommodated within any toilet stall.
  5. d) Universal features include accessible hardware and a minimum stall width to accommodate persons of large stature or parents with small children.
  6. Toilets
  7. a) Automatic flush controls are preferred. If flushing mechanisms are not automated, flushing controls shall be on the transfer side of the toilet, with colour contrasted and lever style handles.
  8. b) Children sized toilets and accessible child sized toilets will be required in kindergarten areas either within the classroom or immediately adjacent to the facilities.
  9. Sinks
  10. a) Each accessible sink shall be on an accessible path of travel that other people, using other sinks or features (like hand-dryers), are not positioned to block.
  11. b) The sink, sink controls, soap dispenser and towel dispenser should all be at an accessible height and location and should all be automatic controls that do not require physical contact.
  12. c) While faucets with remote-eye technology may initially confuse some individuals, their ease of use is notable. Individuals with hand strength or dexterity difficulties can use lever-style handles.
  13. d) For an individual in a wheelchair and younger children, a lower counter height and clearance for knees under the counter are required.
  14. e) The insulating of hot water pipes shall be assured to protect the legs of an individual using a wheelchair. This is particularly important when a disability impairs sensation such that the individual would not sense that their legs were being burned.
  15. f) The combination of shallow sinks and higher water pressures can cause unacceptable splashing at lavatories.
  1. Urinals
  2. a) Each urinal needs to be on an accessible path of travel with clear floor space in front of each accessible urinal to provide the manoeuvring space for a mobility device.
  3. b) Urinal grab bars shall be provided to assist individuals rising from a seated position and others to steady themselves.
  4. c) Floor-mounted urinals accommodate children and persons of short stature as well as enabling easier access to drain personal care devices.
  5. d) Flush controls, where used, will be automatic preferred. Strong colour contrasts shall be provided between the urinal, the wall and the floor to assist persons with vision loss/no vision.
  6. e) In stall washrooms with Urinals, all urinals will be accessible with lower rim heights. For primary schools the urinal should be full height from floor to upper rim to accommodate children. Stalled washrooms with urinals will have an upper rim at the same height as typical non-accessible urinals to avoid the mess taller users can make. All urinals will provide vertical grab bars which are colour contrasted to the walls. Where dividers between urinals are used, the dividers will be colour contrasted to the walls as well.
  1. Showers
  2. a) Roll-in or curb less shower stalls shall be provided to eliminate the hazard of stepping over a threshold and are essential for persons with disabilities who use wheelchairs or other mobility devices in the shower.
  3. b) Grab bars and non-slip materials shall be included as safety measures that will support any individual.
  4. c) Colour contrasted hand-held shower head and a water-resistant folding bench shall be included to assist persons with disabilities. These are also convenient for others.
  5. d) Other equipment that has contrasting colour from the shower stall shall be included to assist individuals with vision loss/no vision.
  6. e) Shower floor drain locations will be located to avoid room flooding when they may get blocked
  7. f) Colour contrast will be provided between the floor and the walls in the shower to assist with wayfinding
  8. g) Shower curtains will be used for individual showers instead of doors as much as possible as it
  9. h) Where showers are provided in locker rooms each locker room will include at least one accessible shower, but an additional individual shower room will be provided immediately adjacent to allow for those with opposite sex attendants to assist them with the appropriate privacy.

Accessible Design for Interior Building Elements – Specific Room Requirements Recommendations

101. Performance stages

The following should be required:

  1. a) Elevated platforms, such as stage areas, speaker podiums, etc., shall be accessible to all.
  2. b) A clear accessible route will be provided along the same path of access for those who are not using mobility assistive devices as those who do. Lifts will not be used to access stage or raised platforms, unless the facility is retrofitting an existing stage and it is not technically possible to provide access by other means.
  3. c) The stage shall include safety features to assist persons with vision loss or those momentarily blinded by stage lights from falling off the edge of a raised stage, such as a colour contrasted raised lip along the edge of the stage.
  4. d) Lecterns shall be accessible with an adjustable height surface, knee space and accessible audio visual (AV) and information technology (IT) equipment. Lecterns shall have a microphone that is connected to an assistive listening system, such as a hearing loop. The office and/or presentation area will have assistive listening units available for those who may request them, for example people who are hard of hearing but not yet wearing hearing aids.
  5. e) Lighting shall be adjustable to allow for a minimum of lighting in the public seating area and backstage to allow those who need to move or leave with sufficient lighting at floor level to be safe

102. Sensory Rooms

The following should be required:

  1. a) Sensory rooms will be provided in a central location on each floor where there are classrooms or public meeting spaces
  2. b) They will be soundproof and identified with accessible signage
  3. c) The interior walls and floor will be darker in colour, but colour contrast will be used to distinctly differentiate the floor from the wall and the furniture
  4. d) Lighting will be provided on a dimmer to allow for the room to be darkened
  5. e) Weighted blankets will be available along with a variety of different seating options including beanbag chairs or bouncy seat balls
  6. f) They will provide a phone or other 2-way communication to call for assistance if needed

103. Offices, Work Areas, and Meeting Rooms

The following should be required:

  1. a) Offices providing services or programs to the public will be accessible to all, regardless of mobility or functional needs. Offices and related support areas shall be accessible to staff and visitors with disabilities.
  2. b) All people, but particularly those with hearing loss/persons who are hard-of-hearing, will benefit from having a quiet acoustic environment – background noise from mechanical equipment such as fans, shall be designed to be minimal. Telephone equipment that supports the needs of individuals with hearing and vision loss shall be available.
  3. c) The provision of assistive speaking devices is important for the range of individuals who may have difficulty with low vocal volume thus affecting production of normal audible levels of sound. Where offices and work areas and small meeting rooms do not have assistive listening, such as hearing loops permanently installed, portable assistive hearing loops shall be available at the office
  4. d) Tables and workstations shall provide the knee space requirements of an individual in a mobility assistive device. Adjustable height tables allow for a full range of user needs. Circulation areas shall accommodate the spatial needs of mobility equipment as large as scooters to ensure all areas and facilities in the space can be reached with appropriate manoeuvring and turning spaces.
  5. e) Natural coloured task lighting, such as that provided through halogen bulbs, shall be used wherever possible to facilitate use by all, especially persons with low vision.
  6. f) In locations where reflective glare may be problematic, such as large expanses of glass with reflective flooring, blinds that can be louvered upwards shall be provided. Controls for blinds shall be accessible to all and usable with a closed fist without pinching or twisting

104. Outdoor Athletic and Recreational Facilities

The following should be required:

  1. a) Areas for outdoor recreation, leisure and active sport participation shall be designed to be available to all members of the school community.
  2. b) Outdoor spaces will allow persons with a disability to be active participants, as well as spectators, volunteers and members of staff. Spaces will be accessible including boardwalks, trails and footbridges, pathways, parks, parkettes and playgrounds, parks, parkettes and playgrounds, grandstand and other viewing areas, and playing fields
  3. c) Assistive listening will be provided where game or other announcements will be made for all areas including the change room, player, coach and public areas.
  4. d) Noise cancelling headphones shall be available to those with sensory disabilities.
  5. e) Outdoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities undergoing rehabilitation.
  6. f) Seating and like facilities shall be inclusive and allow for all members of a disabled sports team to sit together in an integrated way that does not segregate anyone.
  7. g) Seating and facilities will be inclusive and allow for all members of a sports team of persons with disabilities to sit together in an integrated way that does not segregate anyone.

105. Arenas, Halls and Other Indoor Recreational Facilities

The following should be required:

  1. a) Areas for recreation, leisure and active sport participation will be accessible to all members of the community.
  2. b) Assistive listening will be provided where game or other announcements will be made for all areas including the change room, player, coach and public areas.
  3. c) Noise cancelling headphones will be available to those with sensory disabilities.
  4. d) Access will be provided throughout outdoor facilities including to; playing fields and other sports facilities, all activity areas, outdoor trails, swimming areas, play spaces, lockers, dressing/change rooms and showers.
  5. e) Interior access will be provided to halls, arenas, and other sports facilities, including access to the site, all activity spaces, gymnasia, fitness facilities, lockers, dressing/change rooms and showers.
  6. f) Spaces will allow persons with disabilities to be active participants, as well as spectators, volunteers and members of staff.
  7. g) Indoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities who are undergoing rehabilitation.
  8. h) Seating and facilities will be inclusive and allow for all members of a sports team of persons with disabilities to sit together in an integrated way that does not segregate or stigmatize anyone.

106. Swimming Pools

The following should be required:

  1. a) Primary considerations for accommodating persons who have mobility impairments include accessible change facilities and a means of access into the water. Ramped access into the water is preferred over lift access, as it promotes integration (everyone will use the ramp) and independence.
  2. b) Persons with low vision benefit from colour and textural surfaces that are detectable and safe for both bare feet or those wearing water shoes. These surfaces will be provided along primary routes of travel leading to access points such as pool access ladders and ramps.
  3. c) Tactile surface markings and other barriers will be provided at potentially dangerous locations, such as the edge of the pool, at steps into the pool and at railings.
  4. d) Floors will be slip resistant to help those who are unsteady on their feet and everyone even in wet conditions.

107. Cafeterias

The following should be required:

  1. a) Cafeteria serving lines and seating area designs shall reflect the lower sight lines, reduced reach, knee-space and manoeuvring requirements of a person using a wheelchair or scooter. Patrons using mobility devices may not be able to hold a tray or food items while supporting themselves on canes or while manoeuvring a wheelchair.
  2. b) If tray slides are provided, they will be designed to move trays with minimal effort.
  3. c) Food signage will be accessible.
  4. d) All areas where food is ordered and picked up will be designed to meet accessible service counter requirements
  5. e) Self serve food will be within the reach of people who are shorter or using seated mobility assistive devices
  6. f) Where trays are provided, a tray cart that can be attached to seated assistive mobility devices or a staff assistant solution that is readily available shall be available on demand, because carrying trays and pushing a chair or operating a motorized assistive device can be difficult or impossible.

108. Libraries

The following should be required:

  1. a) All service counters shall provide accessibility features
  2. b) Study carrels will accommodate the knee-space and armrest requirements of a person using a mobility device.
  3. c) Computer catalogues, carrels and workstations will be provided at a range of heights, to accommodate persons who are standing or sitting, as well as children of different ages and sizes.
  4. d) Workstations shall be equipped with assistive technology such as large displays, screen readers, to increase the accessibility of a library.
  5. e) Book drop-off slots shall be at different heights for standing and seated use with accessible signage, to enhance usability.

109. Teaching Spaces and Classrooms

The following should be required:

  1. a) Students, teachers and staff with disabilities will have accessibility to teaching and classroom facilities, including teaching computer labs.
  2. b) All teaching spaces and classrooms will provide power door operators and assistive listening systems such as hearing loops
  3. c) Additional considerations may be necessary for spaces and/or features specifically designated for use by students with disabilities, such as accessibility standard accommodations for complex personal care needs.
  4. d) Students, teachers and staff with disabilities will be accommodated in all teaching spaces throughout the school.
  5. e) This accessibility will include the ability to enter and move freely throughout the space, as well as to use the various built-in elements within (i.e. blackboards and/or whiteboards, switches, computer stations, sinks, etc.). Classroom and meeting rooms must be designed with enough room for people with mobility devices to comfortably move around.
  6. f) Individuals with disabilities frequently use learning aids and other assistive devices that require a power supply. Additional electrical outlets shall be provided throughout teaching spaces to -accommodate the use of such equipment.
  7. g) Except where it is impossible, fixtures, fittings, furniture and equipment will be specified for teaching spaces, which is usable by students, faculty, teaching assistants and staff with disabilities.
  8. h) Providing only one size of seating does not reflect the diversity of body types of our society. Offering seats with an increased width and weight capacity is helpful for persons of large stature. Seating with increased legroom will better suit individuals that are taller. Removable armrests can be helpful for persons of larger stature as well as individuals using wheelchairs that prefer to transfer to the seat.
  1. Laboratories will provide, in addition to the requirements for classrooms, additional accessibility considerations may be necessary for spaces and/or features in laboratories.

111. Waiting and Queuing Areas

The following should be required:

  1. a) Queuing areas for information, tickets or services will permit persons who use wheelchairs, scooters and other mobility devices as well as for persons with a varying range of user ability to easily move through the line safely.
  2. b) All lines shall be accessible.
  3. c) Waiting and queuing areas will provide space for mobility devices, such as wheelchairs and scooters.
  4. d) Queuing lines that turn corners or double back on themselves will provide adequate space to manoeuvre mobility devices.
  5. e) Handrails, not flexible guidelines, with high colour contrast will be provided along queuing lines, because they are a useful support for individuals and guidance for those with vision loss.
  6. f) Benches in waiting areas shall be provided for individuals who may have difficulty with standing for extended periods.
  7. g) Assistive listening systems will be provided, such as hearing loops, will be provided along with accessible signage indicating this service is available.

112. Information, Reception and Service Counters

The following should be required:

  1. a) All information, reception and service counters will be accessible to the full range of visitors. Where adjustable height furniture is not used, a choice of fixed counter heights will provide a range of options for a variety of persons. Lowered sections will serve children, persons of short stature and persons using mobility devices such as a wheelchair or scooter. The choice of heights will also extend to any speaking ports and writing surfaces.
  2. b) Counters will provide knee space under the counter to accommodate a person using a wheelchair or a scooter.
  3. c) The provision of assistive speaking and listening devices is important for the range of individuals who may have difficulty with low vocal volume thus affecting production of normal audible levels of sound. The space where people are speaking will have appropriate acoustic treatment to ensure the best possible conditions for communication. Both the public and staff sides of the counter will have good lighting for the faces to help facilitate lip reading.
  4. d) Colour contrast will be provided to delineate the public service counters and speaking ports for people with low vision.

Accessible Design for Interior Building Elements – Other Features Recommendations

113. Lockers

The following should be required:

  1. a) Lockers will be accessible with colour contrast and accessible signage
  2. b) In change rooms an accessible bench will be provided in close proximity to lockers.
  3. c) Lockers at lower heights serve the reach of children or a person using a wheelchair or scooter.
  4. d) The locker operating mechanisms will be at an appropriate height and operable by individuals with restrictions in hand dexterity (i.e. operable with a closed fist).

114. Storage, Shelving and Display Units

The following should be required:

  1. a) The heights of storage, shelving and display units will address a full range of vantage points including the lower sightlines of children or a person using a wheelchair or scooter. The lower heights also serve the lower reach of these individuals.
  2. b) Displays and storage along a path of travel that are too low can be problematic for individuals that have difficulty bending down or who are blind. If these protrude too much into the path of travel, each will protect people with the use of a trip free cane detectable guard.
  3. c) Appropriate lighting and colour contrast are particularly important for persons with vision loss.
  4. d) Signage provided will be accessible with braille, text, colour contrast and tactile features.

115. Public Address Systems

The following should be required:

  1. a) Public address systems will be designed to best accommodate all users, especially those that may be hard of hearing. They will be easy to hear above the ambient background noise of the environment with no distortion or feedback. Background noise or music will be minimized.
  2. b) Technology for visual equivalents of information being broadcast will be available for individuals with hearing loss/persons who are hard-of-hearing who may not hear an audible public address system.
  3. c) Classrooms, library, hallways, and other areas will have assistive listening equipment that is tied into the general public address system.

116. Emergency Exits, Fire Evacuation and Areas of Rescue Assistance

The following should be required:

116.1 In order to be accessible to all individuals, emergency exits will include the same accessibility features as other doors. The doors and routes will be marked in a way that is accessible to all individuals, including those who may have difficulty with literacy, such as children or persons speaking a different language.

116.2 Persons with vision loss/no vision will be provided a means to quickly locate exits – audio or talking signs could assist.

116.3 Areas of Rescue Assistance

  1. a) In the event of fire when elevators cannot be used, areas of rescue assistance shall be provided especially for anyone who has difficulty traversing sets of stairs.
  2. b) Areas of rescue assistance will be provided on all floors above or below the ground floor.
  3. c) Exit stairs will provide an area of rescue assistance on the landing with at least two spaces for people with mobility assistive devices sized to ensure those spaces do not block the exit route for those using the stairs.
  4. d) The number of spaces necessary on each floor that does not have a at grade exit should be sized by the number of people on each floor.
  5. e) Each area of refuge will provide a 2-way communication system with both 2-way video and audio to allow those using these spaces to communicate that they are waiting there and to communicate with fire safety services and or security.
  6. f) All signage associated with the area of rescue assistance will be accessible and include braille for all controls and information.

117. Other Features

The following should be required:

117.1 Space and Reach Requirements

  1. a) The dimensions and manoeuvring characteristics of wheelchairs, scooters and other mobility devices will allow for a full array of equipment that is used by individuals to access and use facilities, as well as the diverse range of user ability.

117.2 Ground and Floor Surfaces

  1. a) Irregular surfaces, such as cobblestones or pea-gravel finished concrete, shall be avoided because they are difficult for both walking and pushing a wheelchair. Slippery surfaces are to be avoided because they are hazardous to all individuals and especially hazardous for seniors and others who may not be sure-footed.
  2. b) Glare from polished floor surfaces is to be avoided because it can be uncomfortable for all users and can be a particular obstacle to persons with vision loss by obscuring important orientation and safety features. Pronounced colour contrast between walls and floor finishes are helpful for persons with vision loss, as are changes in colour/texture where a change in level or function occurs.
  3. c) Patterned floors should be avoided, as they can create visual confusion.
  4. d) Thick pile carpeting is to be avoided as it makes pushing a wheelchair very difficult. Small and uneven changes in floor level represent a further barrier to using a wheelchair and present a tripping hazard to ambulatory persons.
  5. e) Openings in any ground or floor surface such as grates or grilles are to be avoided because they can catch canes or wheelchair wheels.

118. Universal Design Practices beyond Typical Accessibility Requirements

The following should be required:

118.1 Areas of refuge should be provided even when a building has a sprinkler system.

118.2 No hangout steps* should ever be included in the building or facility.

* Hangout steps are a socializing area that is sometimes used for presentations. It looks similar to bleachers. Each seating level is further away from the front and higher up but here people sit on the floor rather than on seats. Each seating level is about as deep as four stairs and about 3 stairs high. There is typically a regular staircase provided on one side that leads from the front or stage area to the back at the top. The stairs allow ambulatory people access to all levels of the seating areas, but the only seating spaces for those who use mobility assistive devices are at the front or at the top at the back, but these are not integrated in any way with the other seating options.

118.3 There should never be “stramps”. A stramp is a staircase that someone has built a ramp running back and forth across. These create accessibility problems rather than solving them

118.4 Rest areas should be differentiated from walking surfaces or paths by texture- and colour-contrast

118.5 Keypads angled to be usable from both a standing and a seated position

118.6 Finishes

  1. a) No floor-to-ceiling mirrors
  2. b) Colour luminance contrast will be provided at least between:
  3. Floor to wall
  4. Door or door frame to wall

iii. Door hardware to door

  1. Controls to wall surfaces

118.7 Furniture – Arrange seating in square or round arrangement so all participants can see each other for those who are lip reading or using sign language

118.8 No sharp corners especially near turn circles or under surfaces where people will be sitting

119. Requirements for Public Playgrounds on or Adjacent to School Property

The following should be required:

119.1 Accessible path of travel from sidewalk and entry points to and throughout the play space. Tactile directional indicators would help as integrated path through large open spaces

119.2 Accessible controlled access routes into and out of the play space

119.3 Multiple ways to use and access play equipment

119.4 A mix of ground-level equipment integrated with elevated equipment accessible by a ramp or transfer platform

119.5 Where stairs are provided, ramps to same area

119.6 No overhead hazards

119.7 Ramp landings, elevated decks and other areas should provide sufficient turning space for mobility devices and include fun plan activities not just a view

119.8 Space to park wheelchairs and mobility devices beside transfer platforms

119.9 Space for a caregiver to sit beside a child on a slide or other play element

119.10 Provide elements that can be manipulated with limited exertion

119.11 Avoid recurring scraping or sharp clanging sounds such as the sound of dropping stones and gravel

119.12 Avoid shiny surfaces as they produce a glare

119.13 Colour luminance contrast will be provided at least at:

  1. a) Different spaces throughout the play area
  2. b) Differentiate the rise and run on steps. Include colour contrasting on the edge of each step
  3. c) Play space boundaries and areas where children should be cautious, such as around high traffic areas e.g. slide exits
  4. d) Entry to play areas with shorter doors to help avoid hitting heads
  5. e) Tactile edges where there is a level change like at the top of the stairs or at a drop-off
  6. f) Transfer platforms
  7. g) Railings and handrails contrasted to the supports to make them easier to find
  8. h) Tripping hazards should be avoided but if they exist, providing colour contrast, to improve safety for all. This is more likely in an older playground
  9. i) Safe zones around swings, slide exits and other play areas where people are moving, that might not be noticed when people are moving around the playground

119.14 Play Surfacing Materials Under Foot will be pour-in-place rubber surfacing that should be made of either

  1. a) Rubber Tile
  2. b) Engineered wood fiber
  3. c) Engineered carpet, artificial turf, and crushed rubber products
  4. d) Sand

119.15 Accessible Parking and Curbs, where provided, at least one clearly marked accessible space positioned as close as possible to the playground on a safe, accessible route to the play space

119.16 Accessible Signage

  1. a) Accessible signage and raised line map at each entrance to the park
  2. b) Provide large colour contrasted text, pictograms, braille
  3. c) provide signage at each play element with ID text and braille, marked with a Tactile attention paver to make it easier to find
  4. d) Identify the types of disability included at each play equipment/area

119.17 For Caregivers

  1. a) Junior and senior play equipment within easy viewing of each other
  2. b) Sitting areas that offer a clear line of sight to play areas and equipment
  3. c) Clear lines of sight throughout the play space
  4. d) Access to all play areas in order to provide assistance
  5. e) Sitting areas with back support, arm rests and shade
  6. f) Benches and other sitting areas should be placed on a firm stable area for people using assistive devices such as wheelchairs.

119.18 For Service Animals

  1. a) Nearby safe, shady places at rest area benches where service animals can wait with a caregiver with a clear view of their handlers when they are not assisting them
  2. b) Spaces where dogs can relive themselves – dog relief area with nearby garbage can

119.19 Tips for Swings

  1. a) Providing a safe boundary area around swings which is identified by surface material colour and texture
  2. b) Swings in a variety of sizes
  3. c) Accessible seat swings or basket swings that require transfer. If size and space allow provide two accessible swings for friends with disabilities to swing together

Platform swings eliminate the need to transfer should be integrated

119.20 Tips for Slides

  1. a) Double Slides (side by side) allow caregivers to accompany and, if needed, to offer support
  2. b) Slide exits should not be directed into busy play areas
  3. c) Transfer platforms at the base of slide exits
  4. d) Seating spaces with back support adjacent to the slide exit where children/caregivers can wait for their mobility device to be retrieved
  5. e) Metal versus Plastic Slides (Metal slides avoid static electricity which damaged cochlear implants, while sun exposure can leave metal slide hot, so shade devices are vital)
  6. f) Roller slides are usually gentler in slope and provide both a tactile and sliding experience or an Avalanche Inclusive Slide

Appendix 2: List of the AODA Alliance’s Recommendations to the Post-Secondary Education Standards Development Committee

  1. Wherever the Initial Report recommends the creation of a standard or the development of a policy or guideline, such a standard, policy or guideline should be mandatory and should be spelled out in detail in the Education Accessibility Standard, rather than delegating authority to create it to some organization or department.
  1. Wherever the Education Accessibility Standard will require colleges and universities to file a document or data with the Government, or to make public any document, report, or data, it should also require that these be submitted electronically to the Accessibility Directorate of Ontario in an accessible format. The Standard should also require the Accessibility Directorate to make those documents, reports or data public on a publicly searchable database or hub.
  2. The Post-Secondary Education Standards Development Committee should endorse and echo the K-12 Education Standards Development Committee Initial’ Report’s recommendations on enforcement of the AODA, with necessary changes to tailor them to the context of colleges and universities.
  1. The Initial Report should be revised to add that where the Education Accessibility Standard refers to “students with disabilities “, this should include any student who has any kind of disability, including, for example, any kind of physical, mental, sensory, learning, intellectual, mental health, communication, neurological, neurobehavioural or other kind of disability within the meaning of the Ontario Human Rights Code, the Accessibility for Ontarians with Disabilities Act or the Canadian Charter of Rights and Freedoms.
  2. The Standards Development Committee’s final report itself and not just the chair’s transmission letter should recommend that the Postsecondary Education Accessibility Standard apply to all other post-secondary educational contexts, such as privately funded colleges and universities and job training programs.
  3. The long term objective of the Post-Secondary Education Accessibility Standard should be to ensure that by 2025, post-secondary education in Ontario will be fully accessible and barrier-free for students with disabilities:
  1. By removing and preventing accessibility barriers impeding students with disabilities from fully participating in, being fully included in, and fully benefitting from all aspects of post-secondary education in Ontario, and
  2. By providing a prompt, accessible, fair, effective and user-friendly process for students with disabilities to learn about and seek programs, services, supports, accommodations and placements tailored to the individual strengths and needs of each student with disabilities.”
  3. Eliminating or substantially reducing the need for students with disabilities to have to fight against post-secondary education accessibility barriers, one at a time, and the need for post-secondary education organizations to have to re-invent the accessibility wheel one education program at a time.
  1. The Standards Development Committee Initial Report’s Recommendation 20-23 (training) should be amended to include training on the duties of post-secondary institutions to people with disabilities under the Canadian Charter of Rights and Freedoms, and especially s. 15 (equality rights).
  2. The Initial Report’s Recommendation 20-23 (Training) should be revised to either remove the statement that post-secondary institutions should not pay for disability accessibility/inclusion training, or to clarify that the Ontario Government should not charge a fee for providing such training to those obligated organizations.
  3.  The Initial Report’s Training recommendations, Recommendations 20 and following, should be revised to explicitly require training on the duty to accommodate students and employees with disabilities, and to direct that this training begin immediately, using resources that are now readily available for free.
  4.             “Recommendation 29: Facilities Management/Design/Construction staff” Should be amended to require that training of those responsible for facilities at post-secondary institutions and those who design such facilities should be required to include direct live training from people with disabilities who have suffered from post-secondary institutions’ built environment barriers, and should include video depictions of such barriers, such as the AODA Alliance’s videos available at https://youtu.be/4oe4xiKknt0 and https://www.youtube.com/watch?v=Dgfrum7e-_0&t=87s
  5. The Initial Report’s Training recommendations 20 and following should be expanded to require up-to-date training on the creation of accessible digital content, such as in online posts and electronic documents, especially for course instructors and anyone else who creates digital content for use by students and others in the post-secondary community. This training should make it clear that if a document is posted or circulated in pdf, it must also be posted or circulated in MS Word and/or html.
  6.  The Initial Report’s Training recommendations 20 and following should be expanded to require that college or university staff involved in the procurement of any technology or equipment be required to be trained on technology accessibility needs and requirements.
  7. The Education Accessibility Standard should require that:
  1. Each post-secondary education organization should provide teaching coaches with expertise in universal design in learning and differential instruction to support instructional staff.
  2. The Ontario Government should create templates or models for the training of college and university instructors on universal design in learning and differential instruction, so that each post-secondary education organization does not have to reinvent the wheel in this context.
  1. The Initial Report’s recommendations on curriculum, assessment and instruction (Recommendations 31 and following) should be expanded
  1. to identify that a key systemic barrier is the fact that course instructors need not be able to teach, or to teach students with disabilities, to be hired, and to make recommendations for training existing instructor in this area, and
  2. to require such qualifications in the future for recruiting and promoting future faculty.
  1. The Initial Report, including recommendations such as Recommendation 38, should be revised to make it clear that whether or not the Ontario Government supplements their funding, they must fulfil their decades-old obligations to students with disabilities under the Ontario Human Rights Code and the Charter of Rights.
  2. To ensure that instructional materials are fully accessible on a timely basis to students with disabilities such as vision loss and those with learning disabilities that affect reading, each post-secondary education organization should:
  1. Promptly survey students with disabilities who need accessible instructional materials, and their instructional staff, to get their front-line experiences on whether they get timely access to accessible instructional materials, and to get specifics on where this has been most lacking.
  2. Establish a dedicated office or resource within the post-secondary education organization, or shared among post-secondary education organizations, to convert instructional materials to an accessible format, where needed, on a timely basis. A student should not be required to show proof that they own a hard copy of an item to be able to get it in an accessible format.
  3. The Education Accessibility Standard should require the Ontario Government to implement, monitor and publicly report on province-wide strategies to ensure the procurement of and use of accessible instructional materials across post-secondary education organizations.
  1. The Initial Report’s Recommendation 57 should be explained and clarified, or removed.
  2. Every post-secondary education organization should be required to review its admission criteria for gaining admission to any of its post-secondary education programs, to identify any barriers that would impede otherwise-qualified students with disabilities from admission, and shall adjust those criteria to either:
  1. Remove the admission criteria that constitute a barrier to admission, or
  2. Provide an alternative method for assessing students with disabilities for admission to the program.
  1. The Initial Report’s Recommendation 65 should be amended to provide that the Education Accessibility Standard, and not the Ministry of Colleges and Universities, should adopt clear and consistent definitions across the education sector for key terms relating to digital learning and technology.
  2. The Initial Report’s Recommendations 68 and following, regarding accessible technology, should be revised to:
  1. require that the Education Accessibility Standard itself set specific requirements for accessible technology, and
  2. require that each obligated organization submit its accessibility plan to the Accessibility Directorate of Ontario, which the Accessibility Directorate of Ontario would then be required to post online in a searchable accessible public online hub.
  1. The Initial Report’s Recommendation 76 should be revised to make it mandatory for each college and university to appoint an accessible digital technology lead.
  2. The Initial Report’s Recommendation 87 should be revised to eliminate “phase two”, which now provides:

“phase 2: postsecondary institutions shall provide suitable software and training for the creation of accessible PDFs to the PDF/UA 1 /ISO 14289 standard. Following this date, any document provided as a PDF must meet this international standard. However, to phase in this requirement it is expected that postsecondary institutions continue to publish PDF-based digital content to be as accessible as their training and applications permit, even if an accessible alternative is provided. This will lessen any remediation costs if there is a need to go back and ensure that currently produced PDFs meet the PDF/UA 1/ISO 14289 standard. This will also demonstrate the postsecondary institutions’ commitment and progress towards creating accessible PDFs.”

  1. The Initial Report’s Recommendation 88 should be removed.
  2. The Initial Report should be expanded to recommend that the Education Accessibility Standard will require each post-secondary education organization to ensure that its information technology support and help staff includes specialists in access technology, and that students with disabilities get prompt access to IT support when needed.
  3. The Initial Report should be revised to require that
  1. Only accessible conference and remote class platforms may be used.
  2. the Ontario Government should be required to report semi-annually to the public and to colleges and universities on the comparative accessibility of different virtual meeting and teaching platforms, so that colleges and universities do not have to repeat the same investigations.
  3. Even when classes are taught in person, students with disabilities should have the option of attending virtually via an accessible virtual meeting platform, where this accommodation would be helpful to them because of their disability.
  1. The Initial Report should be expanded to require that any learning management system only be procured and used if it is accessible, and for all its accessibility features to be locked in the “on” position so that they cannot be turned off.
  2. The Initial Report should be expanded to ban the use of inaccessible electronic kiosks, electronic point-of-sale devices and restaurant tablet ordering technology at any colleges and universities.
  3. The Initial Report’s Recommendation 91 (Access to Disability Accommodation Information) should be expanded to ensure that the Education Accessibility Standard requires:
  1. The post-secondary education organization’s interactive voice response system for receiving incoming phone calls should announce to all callers the organization’s commitment to accommodate students with disabilities and the number to press to get introductory information about how to seek such.
  2. Programming handouts and broadcast email communications to incoming students should include similar general information.
  3. the post-secondary education organization’s broadcast email announcements and other communications to the student population should include summary information to this effect with relevant links.
  4. Classroom instructors should make announcements in their first week of classes to this effect.
  1. The Initial Report’s Recommendation 92 should be revised to provide that the Education Accessibility Standard itself should set a clear set of barrier-free requirements regarding a student’s documenting an academic accommodation need. For example, a student should not be required to re-document their disability each year, where it is a permanent or long term disability.
  2. The Initial Report’s Recommendation 94 should be amended to explicitly require that colleges and universities tell students with disabilities, as soon as possible, about the institution’s duty to accommodate students with disabilities.
  3. The Initial Report’s Recommendation 94-95 be revised to set out specific accessibility requirements for colleges and universities in such areas as classrooms, libraries, common areas, online learning tools including accessible software, tests/examinations, internships, practica, co-ops, field placements, apprenticeships, work-integrated learning, other experiential learning that are part of their academic program of study, request for priority enrollment in a course, and accessible housing placement. For example, to ensure that students with disabilities can fully participate in a post-secondary education organization’s experiential learning programs, each such organization should:
  1. Review its experiential learning programs to identify and remove any accessibility barriers;
  2. Put in place a process to affirmatively reach out to potential placement organizations in order to ensure that a range of accessible placement opportunities in which students with disabilities can participate are available;
  3. Ensure that its partner organizations that accept students for experiential learning placements are effectively informed of their duty to accommodate the learning needs of students with disabilities;
  4. Create and share supports and advice for placement organizations who need assistance to ensure that students with disabilities can fully participate in their experiential learning placements;
  5. Monitor placement organizations to ensure they have someone in place to ensure that students with disabilities are effectively accommodated, and to ensure that effective accommodation was provided during each placement of a student with a disability who needed accommodation; and
  6. Survey students with disabilities and experiential learning placement organizations at the end of any experiential learning placements to see if their disability-related needs were effectively accommodated.
  1. The Initial Report’s Recommendation 94 and following should be revised to:
  1. Require obligated organizations to review their accommodation procedures for systemic barriers, such as a ban on recording classes to which an exception must be sought through the accommodation process; and
  2. Require that those disability barriers be removed and prevented.
  1. The Initial Report’s Recommendation 98 (Disability Accommodation Caseload – Reporting) be revised to require that each college or university disability accommodation caseloads be reported to The Government, with The Government being required to publish these online annually on an institution-by-institution basis, and as provincial aggregations or averages.
  2. The Initial Report’s Recommendation 99 (Accessibility Lens) be removed and replaced with specific recommendations on the recurring disability barriers to be removed and prevented, and what must be done to remove and prevent them.
  3. The Initial Report’s Recommendations 104-16 ((Accessible Procurement Policies and Procedures) should be revised to require that the accessible procurement standards are mandatory, include detailed specifics, are more robust than the current section 5 of the Integrated Accessibility Standards Regulation, and require public accountability/reporting to ensure that they can be effectively monitored and enforced.
  4. The Initial Report’s Recommendations 108-110 (Handling Accommodation Requests) should be expanded to spell out mandatory baseline requirements for student accommodation request procedures, so that each college or university does not have to re-design their own procedures, and which:
  1. Require the de-bureaucratizing of the handling of accommodation requests by students;
  2. Require a fast-track process for routine accommodation requests which are suitable for such a process;
  3. Require a separate track for more unusual or complex requests to be addressed in an effective and time-sensitive way; and
  4. Ensure that if the student had an Individual Education Plan (IEP) from an Ontario school, or a finding by an Ontario school board’s Identification and Placement Review Committee (IPRC) that identified them as having a disability (exceptionality), or a comparable form of documentation from another jurisdiction, then the post-secondary education organization should treat that as sufficient proof that the student has a disability, without requiring further assessments or proof, unless the post-secondary education organization has independent proof showing that the student no longer has that disability. In that case, the post-secondary education organization shall provide the student with that proof and shall provide the student with an opportunity to demonstrate that they have a disability-related accommodation need. The student’s IEP should not be treated as a ceiling on what a person can request, since a person’s accommodations needs may be different in the postsecondary environment.
  1. The Initial Report’s Recommendations 111-113 (Service Animals) should be revised to replace the term “service animals and support animals” with the more accurate term “service animals, including support animals.”
  2. Each post-secondary education organization should be required to establish a permanent committee of its governing board of directors or trustees to be called the “Accessibility Committee”. This Accessibility Committee should have responsibility and authority to oversee the organization’s compliance with the Accessibility for Ontarians with Disabilities Act and with the requirements of the Ontario Human Rights Code and the Canadian Charter of Rights and Freedoms as far as they guarantee the right of students with disabilities to fully participate in and fully benefit from the education programs and opportunities that the organization provides.
  3. The Standards Development Committee should recommend that any equity, diversity, and inclusion strategy at any college or university should be reviewed and, where needed, revised to ensure that disability is a full and equal target and focus of that strategy.
  4. Each post-secondary education organization should be required to establish a committee of those employees and volunteers with disabilities who wish to join, to give the organization’s senior management feedback on the barriers in the organization that could impede employees or students with disabilities.
  5. The Initial Report’s Recommendations 127-128 should be revised to recommend
  1. The adoption of the Education Accessibility Standards of the OCAD University Facility Accessibility Design Standards (FADS) https://www.ocadu.ca/sites/default/files/2021-06/OCADU_FADS_21-05-26.pdf enriched by the K-12 Education Standards Development Committee Initial Report’s built environment recommendations; and
  2. Set standards for accessibility of the furniture in the premises of colleges and universities.
  1. The Initial Report’s Recommendation 139 (Identify Barriers and Provide Accommodations) should be revised to remove an incorrect suggestion that zoning bylaws or heritage designation are a legal bar to implementing accessibility in a building.
  2. The Initial Report’s Recommendation 153 (Signage and Wayfinding) should be revised to:
  1. Invoke the OCAD University FADS standard for signage and way-finding, instead of those by Brock University; and
  2. Require that each campus review its indoor and outdoor property for effective cane-detectable way-finding, and institute such way-finding if inadequate or non-existent.
  1. The Initial Report’s recommendations regarding the built environment should be expanded to require that, where possible, a post-secondary education organization should not renovate an existing facility that lacks disability accessibility, unless the organization has a plan to also make that facility accessible. For example, a post-secondary education organization should not spend public money to renovate the second storey of a facility which is inaccessible, if the organization does not have a plan to make that second storey disability-accessible. Very pressing health and safety concerns should be the only reason for any exception to this.
  2. The Initial Report’s built environment recommendations should be expanded to require that each post-secondary education organization:
  1. Take inventory of the accessibility of its existing indoor and outdoor gym, sports, athletic and like equipment and spaces, and make this public, including posting this information online;
  2. Adopt a plan to remediate the accessibility of existing gym, sports, athletic or other like equipment or spaces, in consultation with students with disabilities; and
  3. Ensure that a qualified accessibility expert is engaged to ensure that the purchase of new equipment or remediation of existing equipment or spaces is properly conducted, with their advice being given directly to the post-secondary education organization.
  1. The Initial Report should be expanded to include, in its built environment recommendations, specific mandatory requirements at all colleges and universities to ensure that snow-shoveling creates no disability barriers and is sufficient to enable people with disabilities to navigate the campus.
  2. The Initial Report’s built environment recommendations should be expanded to include indoor air quality requirements for persons for whom this can create disability barriers.
  3. The Initial Report should be revised to require each college or university to create and make available an up-to-date guide on the accessibility features in its built environment, such as electric door openers and ramps.
  4. The Initial Report should be revised to:
  1. Ensure that students with disabilities have available an earlier or accelerated process for getting their course selections confirmed; and
  2. Have in place a mandatory process for the college or university to make priority re-assignment of any classes from inaccessible classrooms to accessible classrooms, where needed.
  1. The Initial Report should be expanded to require each college and university to:
  1. Ensure to the extent possible that construction projects on campus do not block accessible paths of travel, and accessibility features such as ramps and accessible doors; and
  2. Maintain a publicly-accessible up-to-date web page or other easily-accessed public announcement of the location and expected timing of construction projects that may impede accessible travel.
  1. The Initial Report should be expanded to specifically require that the venue of graduation ceremonies be accessible to students, family members, friends and staff members with disabilities, including the graduation platform.
  2. The Education Accessibility Standard require that the Ontario Government ensure that public funds are never used to create or perpetuate disability barriers in the built environment.
  3. The Ontario Government be required to revise its funding criteria for construction of facilities at a post-secondary education organization to ensure that it requires, and does not obstruct, the inclusion of all needed accessibility features in that construction project.