INTEGRATED ACCESSIBILITY STANDARDS POLICY
1. PURPOSE AND STATEMENT OF COMMITMENT
The goal of the Accessibility for Ontarians with Disabilities Act, 2005 (the “Act”) is to create a more accessible Ontario, by identifying and, to the extent possible, preventing and eliminating barriers experienced by a person with a disability.
The Integrated Accessibility Standards (“IAS”) has been established under the Act to ensure accessibility for every person with a disability in the areas of (i) information and communication, (ii) employment, (iii) transportation, (iv) design of public space and (v) customer service.
Primont (the “Company”) strives to provide an accessible environment for its employees and members of the public. The Company is committed to developing, implementing and maintaining policies aimed at meeting the accessibility needs of persons with a disability in a timely manner.
The objective of this policy (the “Policy”) is to identify and document how the Company seeks to achieve compliance with the requirements of the IAS and how it will continue to work toward improving accessibility for persons with a disability.
Nothing in this Policy is intended to replace or negate existing laws related to accessibility for persons with disabilities including but not limited to the Human Rights Code and the Workplace Safety and Insurance Act, 1997.
2. APPLICATION OF THE POLICY
The Policy applies to:
- (a) Every person who is an employee of, or a volunteer with, the Company.
- (b) Every person who participates in developing the Company’s policies.
- (c) Every other person who provides goods, services or facilities on behalf of the Company.
3. DEFINITIONS
Accessible Format - May include, but is not limited to, large print, recorded audio and electronic format, braille and any other format usable by a person with a disability.
Communication Support - May include, but is not limited to, captioning, alternative and an augmentative communication support, plain language, sign language and any other support that facilitates effective communication.
Disability – means:
- (a) 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.
- (b) A condition of mental impairment or a developmental disability.
- (c) A learning disability, or a dysfunction in one or more of the processes involved in understanding or using symbols or spoken language.
- (d) A mental disorder.
- (e) An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Maintenance - means activities that are intended to keep existing public spaces and elements in existing public spaces in good working order or to restore the spaces or elements to their original condition, examples of which include painting and minor repairs
New Internet Website - means either a website with a new domain name or a website with an existing domain name undergoing a significant refresh.
Off-street Parking Facilities - includes open area parking lots and structures intended for the temporary parking of vehicles by the public, whether or not the payment of a fee is charged and includes visitor parking spaces in parking facilities
Performance Management - means an activity related to assessing and improving employee performance, productivity and effectiveness, with the goal of facilitating employee success.
Redeployment - means the reassignment of an employee to other department or job as an alternative to layoff, when a particular job or department has been eliminated.
Redeveloped – means planned significant alterations to public spaces, but does not include maintenance activities, environmental mitigation or environmental restoration
Self-Service Kiosk – means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows a user to access one or more services or products or both.
Unconvertible Information or Communication – means information or communication that it is not technically feasible to convert, or if it is technically feasible to convert, the technology required to do so is not readily available.
Web Content Accessibility Guidelines (“WCAG”) – means the international standard for making a website and web content accessible to people with a wide-range of disabilities. The IAS requires an organization to become compliant with two levels of the WCAG - Level A and Level AA.
4. GENERAL ACCESSIBILITY STANDARDS
(a) Communication
The Company strives to communicate with a person with a disability in a manner that takes into account the individual’s disability.
(b) Accessibility Plan
The Company has established and implemented an Accessibility Plan to outline the Company’s strategy to prevent and remove barriers for a person with a disability and meet the requirements of the IAS.
The Company will maintain the Accessibility Plan in accordance with the requirements of the IAS and will review and update it at least once every five (5) years.
The Accessibility Plan is posted on the Company’s website and will be made available in an Accessible Format, upon request.
(c) Training
The Company will provide initial training, and ongoing training as required under the IAS, to all persons to whom this Policy applies.
Training will be provided on:
- (i) The requirements of the IAS and the Policy.
- (ii) The Company’s obligations under the Human Rights Code as they relate to a person with a disability.
The Company will ensure training is provided to all persons to whom this Policy applies as soon as practicable after the person is hired or otherwise retained. On-going training will also occur as changes are made to the Policy.
The Company will maintain records of the individuals to whom training is provided and when the training occurred.
(d) Self-Service Kiosk
The Company will consider the accessibility needs of a person with a disability should it design, procure or acquire a Self-Service Kiosk.
5. INFORMATION AND COMMUNICATION STANDARDS
(a) Feedback Procedure
The Company will ensure its process for receiving and responding to feedback is accessible to a person with a disability by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request.
The Company will notify the public of the availability of Accessible Formats and Communication Supports for feedback purposes.
(b) Accessible Formats and Communication Supports
Upon request, the Company will provide or arrange for the provision of Accessible Formats and Communication Supports to make its communication or information about its goods, services and/or facilities accessible to a person with a disability. Accessible Formats and Communication Supports will be provided in a timely manner and at a cost no more than the regular cost charged to any other person.
The Company will consult with the person making the request when determining the suitability of an Accessible Format or Communication Support. The Company will also notify the public of the availability of Accessible Formats and Communication Supports.
(c) Emergency Plans, Procedures and Public Safety Information
The Company will provide any emergency plans, procedures or public safety information that it makes available to the public in an Accessible Format or with appropriate Communication Supports upon request and as soon as practicable.
(d) Accessible Websites and Web Content
The Company will ensure, where practicable, any New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A.
The Company will ensure, where practicable, any website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS.
When determining whether meeting the requirements of this section are practicable the Company will consider the availability of commercial software or tools required to achieve web accessibility; and the impact meeting the requirements of this section will have on any project planned before January 1, 2012.
The commitment to provide an accessible website and web content only applies to a website and web content the Company controls directly or indirectly through a contractual relationship allowing for modification of the website or web content at issue.
6. EMPLOYMENT STANDARDS
The Employment Standards only apply to employees of the Company. They do not apply to volunteers or other unpaid individuals or contractors.
(a) Recruitment, Selection and Assessment
The Company will notify the public and employees of the availability of accommodation during the recruitment process.
The Company will notify job applicants who are individually selected to participate in an assessment or selection process that accommodation is available upon request if the applicant requires accommodation due to a disability.
If an applicant requests accommodation, the Company will consult with the applicant and provide or arrange for the provision of a reasonable and suitable accommodation in a manner that takes into account the applicant’s accessibility needs.
(b) Notice to Successful Applicants
When making an offer of employment the Company will notify the successful applicant of the Company’s policy on accommodating employees with a disability.
(c) Informing Employees of Supports
The Company will inform its employees of its policies on supporting an employee with a disability, including, but not limited to, its policy on the provision of job accommodation that takes into account an employee’s accessibility needs due to disability. This information will be provided to a new employee as soon as practicable after commencing employment.
The Company will provide employees with updated information whenever there is a material change to its policies on the provision of job accommodation for an employee with a disability.
(d) Accessible Formats and Communication Supports for Employees
Upon the request of an employee with a disability, the Company will provide or arrange for the provision of Accessible Formats and Communication Supports to ensure information required by the employee to perform his or her job and/or information generally available to an employee in the workplace is accessible to the employee with a disability.
The Company will consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However, the Company reserves the right to determine the Accessible Format or Communication Support provided.
(e) Workplace Emergency Response Information
The Company will provide individualized emergency response information to any employee who requires it as a result of a disability. This information will be provided as soon as practicable after the Company becomes aware of the employee’s need for an individualized response.
Where the employee will require assistance in an emergency, and with the employee’s consent, the Company will designate a colleague(s) to provide such individualized assistance and will provide the colleague(s) with the employee’s individualized emergency response information.
The Company will review the individualized workplace emergency response information when (i) the employee moves to a different work location, (ii) the employee’s overall accommodation needs or plans are reviewed, and/or (iii) the Company reviews its general emergency response policies.
(f) Individual Accommodation and Return to Work
The Company has a written process for developing a documented individual accommodation plan for an employee with a disability. The process includes all elements required by the IAS.
Any individual accommodation plan prepared for an employee will include:
- (i) Information on Accessible Formats or Communication Supports provided to the employee.
- (ii) Any individualized workplace emergency response plan developed for the employee.
- (iii) Any other forms of accommodation being provided to the employee as a result of his or her disability.
The Company also has a written process for any employee who may be returning to work following a disability-related leave of absence. The process includes the steps taken to facilitate the employee’s return to work and the development of any required individual accommodation plan on return.
For more information, please consult the Company’s Individual Accommodation and Return to Work Policy.
(g) Performance Management, Career Development and Advancement and Redeployment
The Company will take an employee’s accessibility needs, and any individualized accommodation plan, into account in:
- (i) Conducting performance management.
- (ii) Providing opportunities for career development and advancement.
- (iii) Making redeployment decisions.
7. DESIGN OF PUBLIC SPACES
(a) Construction and Redevelopment of Public Spaces
The Company is committed to meeting its obligations with respect to the construction or redevelopment of public spaces covered under the IAS on or after January 1, 2017. Public spaces includes certain of the following:
- (i) Exterior paths of travel (g., walkways, ramps, and stairs).
- (ii) Off-street parking.
- (iii) Service counters, fixed queuing lines, and waiting areas.
(b) Maintenance of Accessible Elements in Public Spaces
The Company has developed a procedure for preventative and emergency maintenance of accessible elements in Primont public spaces covered under the IAS.
This procedure includes:
- (i) Developing preventative maintenance schedules for accessible elements.
- (ii) Inspecting accessible elements monthly; identifying any accessible elements with defects or requiring maintenance; and reporting this information to Director of Customer Service in a timely manner so that appropriate action can be taken.
- (iii) Upon receiving information or feedback from a third party that an accessible element has a defect or requires maintenance, reporting this information to Director of Customer Service in a timely manner so that the accessible element can be inspected and appropriate action can be taken.
- (iv) Where it is determined that preventative or emergency maintenance is required, taking the accessible element out of service to perform necessary repairs in a timely manner.
- (v) To the extent possible, ensuring steps are taken to divert individuals from accessible elements that are out of order or pose a danger to safety. This may include putting in place barriers or temporary signage, and/or posting notices as indicated below.
- (vi) In the event of a temporary disruption to accessible elements, to the extent possible, and as soon as reasonably practicable, giving notice of the disruption, the anticipated duration, and any alternative accessible elements that may be available. This notice may include posting information notices in conspicuous places on the Company’s premises or on the Company’s website and/or any other methods reasonable in the circumstances.
8. QUESTIONS ABOUT THIS POLICY
For more information about the Policy please contact:
Marsha Jodrell
905-770-7002
primont@primont.com