Human Resources Committee Report BH.05.JUN0816.R04

June 8, 2016

Report to: Human Resources Committee, Board of Health

Submitted by: Elizabeth Bowden, (Interim) Director, Human Resources and Corporate Services

Subject: ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT (AODA) UPDATE

Recommendations

(a) That the Human Resources Committee makes recommendation to the Board of Health to receive this report for information.

Background

The Accessibility for Ontarians with Disabilities Act (AODA) is a complex and evolving multi-year piece of legislation.1 The goal of the Act and the standards is to make the province accessible for all people with disabilities by 2025 2.

The AODA sets out the roadmap for an accessible Ontario by 2025. It currently contains standards in the following areas that are relevant at WDGPH:

Customer Service
Information and Communications
Employment

Wellington-Dufferin-Guelph Public Health (WDGPH) is committed to meeting the needs of everyone in our community and complying with our AODA requirements. WDGPH will deliver programs and services in a manner that respects the dignity and independence of persons with disabilities.

WDGPH will make every reasonable effort to ensure that:

Persons with disabilities are provided equal opportunity to obtain, use and benefit from our programs and services.
Programs and services provided to persons with disabilities are the same, or similar, to those offered to others, unless an alternate measure is necessary to enable a person with a disability to benefit from them.
Persons with disabilities may use a personal assistive device to access our programs and services. Personal assistive devices may include, but are not limited to: service animals, support person, communication, cognition, mobility and medical aids.
Persons with disabilities will be offered alternative communication and information formats, where necessary.

ACTIONS TAKEN BY WDGPH

What is a disability?

The term “disability” covers a broad range and degree of conditions, some visible and some not visible. A disability may have been present from birth, caused by an accident, or perhaps may have developed over time.3 Section 10(1) of the Ontario Human Rights Code defines “disability” as follows4:

“Because of disability” means for the reason that the person has, or has had, or is believed to have or have had:

any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
a condition of mental impairment or a developmental disability;
a learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
a mental disorder; or
an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

What actions has WDGPH taken in order to comply with AODA?

WDGPH is classified as a non-profit employer in the 50+ employee category. So far, the Agency has focused on the following areas:

Policies, processes and practices
Communications and awareness
Technology
Infrastructure
People
Procurement

Key outcomes under AODA at WDGPH:

People with disabilities have access to the services of WDGPH in a timely manner.
People with disabilities have access to information and communications in alternate formats upon request.
People with disabilities can participate fully in services and employment at WDGPH.
People with disabilities experience greater accessibility in WDGPH facilities.

WDGPH’s approach (2013-2015) has been:

WDGPH completed a comprehensive environmental scan of other public health agencies and public sector organizations to identify and implement AODA best practices. Wellington County was identified as a best practice organization.5
WDGPH developed purchasing and human resources policies and procedures that include accessibility requirements.
WDGPH implemented the training of current and new staff.
WDGPH identified and removed barriers to employment.
WDGPH ensured access to information and communications.
WDGPH continued to identify and remove and prevent barriers.

WDGPH’s approach (2015-2021) will be:

Where appropriate, review and revise policies, procedures and processes to confirm they support accessibility considerations.
Redevelop our website to comply with WCAG 2.0 Level AA accessibility requirements.
Continue to include accessibility training in new hire orientation and update training for existing staff where required.
Encourage ongoing requests for public feedback through feedback mechanisms.
Update the WDGPH multi-year accessibility plan a minimum of once every five years and post the plan on the WDGPH website.
Continue to identify, remove and prevent barriers.

Regulatory Requirements and Proposed and Completed Actions – Accessible Customer Service

WDGPH is committed to providing programs and services in a way that respects the dignity and independence of people with disabilities. Wherever possible, persons with disabilities will benefit from the same services, in the same place and in the same or similar way as other clients.

WDGPH shall use reasonable efforts to ensure that its policies, practices and procedures are consistent with the following principles:

Programs or services will be provided in a manner that respects the dignity and independence of persons with disabilities.
Persons with disabilities will be given an opportunity equal to that given to others to obtain, use and benefit from the program or services.
Persons with disabilities may use assistive devices and/or support persons in the access of programs and services.
When communicating with a person with a disability, employees shall do so in a manner that takes into account the person’s disability in a respectful manner.

1. Develop accessible customer service policies

Required compliance date: January 1, 2012
Status: Completed
Planned Action: Review and revise policy as required.

2. Provide accessible customer service training

Required compliance date: January 1, 2012
Status: Completed
Action: Training provided for all existing employees and new employees.

Integrated Accessibility Standards Regulation (IASR)

IASR Part I - General Requirements

The Information and Communications, Employment, and Transportation Standards requirements under AODA, were combined under O. Reg. 191/11: Integrated Accessibility Standards 6. This regulation requires WDGPH to develop accessibility policies, incorporate accessibility into procurement, train staff, and create a multi-year accessibility plan.

1. Develop accessibility policies

Develop accessibility policies, including a statement of organizational commitment and make the policies publically available.

Required compliance date: January 1, 2014
Status: Completed
Action: Revised and simplified accessibility policies and our statement of commitment.

2. Develop multi-year accessibility plans

Develop multi-year accessibility plan that outlines what will be done to implement the requirements of the IASR.

Post the plan on the Agency’s website and provide it in an accessible format, upon request.

Required compliance date: January 1, 2014
Status: Completed
Planned Action: Review and revise the multi-year accessibility plan as required.

3. Incorporate accessibility in procuring goods, services or facilities

Incorporate accessibility criteria and features when procuring goods, services or facilities, except where it is not practicable to do so.

Required compliance date: January 1, 2014
Status: Completed
Action: Incorporated into existing RFP process as well as WDGPH procurement policy.

4. Training as required under the ISAR for employees

All current and new employees will additionally be required to take additional training on Accommodation in Employment (ISAR) as required by the standard.

Required compliance date: January 1, 2015
Status: Completed
Action: Training provided for all existing employees and new employees.

IASR Part II – Information and Communications

WDGPH is committed to meeting the communication needs of people with disabilities. When asked, information and communication materials will be provided in accessible formats or with communication supports. This includes publicly available information about Agency goods, services and facilities, as well as publicly available emergency and safety information.

1. Feedback processes

WDGPH will provide opportunities for people with disabilities to provide feedback in order to address concerns and improve the level of service provided to people with disabilities.

Required compliance date: January 1, 2015
Status: Completed
Action: Information on feedback options is available on the Agency website and upon request. Individuals can provide feedback through paper forms, e-mail, mail and phone.

2. Accessible formats and communication supports

WDGPH will consult with people with disabilities to determine their information and communication needs.

Required compliance date: January 1, 2016
Status: Completed
Action: Information on different communication medium options is available on the Agency website and upon request. Individuals can request accessible formats and communication support through paper forms, e-mail, mail and phone. The Agency will review and refine public forms into the website redevelopment project.

3. Emergency procedures, plans or public safety information

Provide emergency procedures, plans or public safety information that is publicly available in an accessible format or with appropriate communication supports, upon request.

Required compliance date: January 1, 2012
Status: Completed

Accessible websites and web content (January 1, 2021)

WDGPH is committed to ensuring that the website and online content conforms with the World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 in order to make content accessible for the public.

Required compliance date: January 1, 2014 – WCAG 2.0 Level A for new Internet websites and web content
Status: Completed

Required compliance date: January 1, 2021 – WCAG 2.0 Level AA for all Internet websites and web content
Status: In Progress
Planned Action: WDGPH is currently developing a new website in 2016-2017 that will meet WCAG 2.0 level AA technical requirements.

IASR Part III – Employment

WDGPH is committed to making sure the process of finding, obtaining and keeping a job is as inclusive as possible in order to build an effective workforce.

1. Recruitment – general, selection process, notification to successful applicants
WDGPH will notify employees and the public of the availability of accommodation for applicants with disabilities in the recruitment process.

Recruitment, Assessment and Selection
When job applicants are individually selected to participate in an assessment or selection process, they will be notified that accommodations are available upon request in relation to the materials or processes to be used in the assessment/selection process.

Notice to Successful Applicants
When making offers of employment, WDGPH will notify the successful applicant of Agency policies for accommodating employees with disabilities.

Required compliance date: January 1, 2016
Status: Completed

2. Informing employees of supports
Inform employees of policies to support employees with disabilities.

Required compliance date: January 1, 2016
Status: Completed
Planned Action: Develop and implement revised new hire orientation program in 2016 to reinforce available employee supports that are available at WDGPH.

3. Accessible formats and communication supports for employees
Provide or arrange for accessible formats and communication supports when it is requested by an employee with a disability and the information is needed to perform the employee’s job and is generally available to employees in the workplace.

4. Workplace emergency response information
Provide individualized workplace emergency response information to employees who have a disability, as required.

Required compliance date: January 1, 2012
Status: Completed
Planned Action: During the review of the 2016 Emergency Preparedness Response Plan, ensure ongoing compliance.

5. Documented individual accommodation plans
Develop and have in place a written process for development of documented individual accommodation plans for employees with disabilities (where required).

Required compliance date: January 1, 2016
Status: Completed

6. Return to work process
Develop a return to work process for employees who have been absent from work due to a disability and require disability-related accommodations to return to work.

Required compliance date: January 1, 2016
Status: Completed

7. Performance management, career development and advancement, redeployment

WDGPH will take into account the accessibility needs of employees with disabilities, as well as individual accommodation plans:

when using its performance management process in respect of employees with disabilities;
when providing career development and advancement to its employees with disabilities; and
when reassigning employees with disabilities.

WDGPH will:

review, assess and as necessary, modify existing policies, procedures, practices and templates to ensure compliance with the AODA; and
take the accessibility needs of employees with disabilities and, as applicable, their individualized accommodation plans, into account when assessing performance; managing career development and advancement; and reassigning as required.

Required compliance date: January 1, 2016
Status: Completed

WDGPH STRATEGIC COMMITMENT

Service-Centred Approach
We are committed to providing excellent service to anyone interacting with Public Health.

Health Equity
Our programs and services use health equity principles to reduce or eliminate health differences in our communities.

Organizational Capacity
We will improve our capacity to effectively deliver public health programs and services.

Public Health and/or Financial Implications

WDGPH recognizes that further steps need to be taken to become barrier-free. Therefore, the Agency has completed a multi-year plan which reflects a commitment to engage in initiatives that will help WDGPH be free of physical, attitudinal and social barriers by the year 2021 in accordance with AODA legislation.7

References

Accessibility for Ontarians with Disabilities Act, 2005, S.O.2005, c. 11. [Online]. [cited 2016 04 28]. Available from https://www.ontario.ca/laws/statute/05a11?search=Accessibility.
County of Wellington. Wellington County. [Online]; 2016 [cited 2016 04 29]. Available from: http://www.wellington.ca/en/government/legislation.asp.
Ontario Human Rights Commission. Ontario Human Rights Commission - Disability. [Online]. [cited 2016 04 26]. Available from: http://www.ohrc.on.ca/en/code_grounds/disability.
Ontario Human Rights Commission. Ontario Human Rights Commission - 2.1 The definition in the Human Rights Code. [Online].; 2016 [cited 2016 04 27]. Available from: http://www.ohrc.on.ca/en/policy-and-guidelines-disability-and-duty-accom….
County of Wellington. County of Wellington - Multi-year Accessibility Plan. [Online]. [cited 2016 04 27]. Available from: http://www.wellington.ca/en/government/resources/hrMulti-yearAccessibili….
O. Reg. 191/11: INTEGRATED ACCESSIBILITY STANDARDS. [Online]. [cited 2016 05 02]. Available from: https://www.ontario.ca/laws/regulation/110191.
Wellington-Dufferin-Guelph Public Health. Wellington-Dufferin-Guelph Public Health. Multi-year Accessibility Plan. [Online]. Available from: http://www.wdgpublichealth.ca/sites/default/files/wdgphfiles/accessibili…

Prepared by: Justin Brown,
Manager, Human Resources

Reviewed by: Elizabeth Bowden,
(Interim) Director, Human Resources and Corporate Services

Approved by: Dr. Nicola Mercer,
Medical Officer of Health & CEO

File Attachments

Accessibility for Ontarians with Disabilities Act Update (PDF, 8 pages, 262 KB)