Meeting Accessibility Standards: AODA
The 2011 accessibility regulation requires the City to ensure alignment of its accessibility policies with Accessibility for Ontarians with Disabilities Act (AODA) legislation in its multi-year accessibility plan. The following outlines key obligations of the City on accessibility.
Establishment of Accessibility Plans and Policies
The City of Toronto shall produce a multi-year Accessibility Plan. The plan will be posted on the City’s website and made available in accessible formats upon request. Each year, a status report on the progress of measures taken to implement the multi-year accessibility plan will be prepared and posted publicly. The Accessibility Plan will be reviewed and updated at least once every five years.
The City of Toronto maintains policies on how it shall meet AODA requirement and will provide policies in an accessible format upon request.
Accessibility in Procurement
When procuring goods, services, self-service kiosks or facilities, the City shall incorporate accessibility criteria and features, unless it is not feasible (practicable) to do so. If not practicable, the City shall provide an explanation, upon request. Accessibility criteria, guidelines and checklists have been developed as resources for City employees.
A kiosk means an interactive electronic terminal, including a point-of-sale device, intended for public use that allows users to access one or more services or both.
General Training Requirements
City employees, volunteers, all those who participate in developing the City’s policies and those who provide goods, services or facilities on the City’s behalf shall be required to undergo training on the requirements of the AODA accessibility standards and on the Ontario Human Rights Code as it relates to people with disabilities.
City employees, volunteers and third party contractors shall accommodate the use of personal assistive devices, which enable a person with a disability to access the City’s services, programs and facilities. Assistive devices include and are not limited to: GPS, mobility devices, personal oxygen tanks, mini pocket recorder and communication boards (e.g. a Bliss board).
Assistive devices for access to specific services and programs shall be kept in good working order and the public shall be informed of their availability. Examples are: Assistive Listening Devices and FM Loop systems.
City employees, volunteers and third party contractors shall accommodate the use of service animals by people with disabilities who are accessing City services, programs and facilities unless the animal is otherwise excluded by law, such as food preparation areas as prohibited by Food Premises, R.R.O. 1990, Reg. 562 under the Health Protection and Promotion Act, R.S.O. 1990, c. H.7.
A guide dog is defined in Section One of the Blind Persons’ Rights Act. To be considered a service animal under the Customer Service Standard, it must be readily apparent that the animal is being used because of a person’s disability or the person with a disability must provide a letter from a physician or nurse confirming that it is required because of his or her disability.
Where a person with a disability accessing City services, programs or facilities is accompanied by a support person, City employees, volunteers and third party contractors shall ensure that both persons are permitted to enter the premises together and shall ensure that the person with a disability can access the support person while on the premises.
A support person is a person who accompanies the person with a disability in order to help with communication, mobility, personal care or medical needs or with access to goods or services. The support person can be a paid support worker, volunteer, a friend or a family member.
If the City charges an admission fee in connection with a support person’s presence at an event or function, the City shall post a notice, providing information in advance about the amount, if any, that is payable by the support person accompanying a person with a disability.
When communicating with a person with a disability, City employees, volunteers and third party contractors shall do so in a manner that respects the person’s disability.
Notice of Service Disruption
If there is a temporary disruption in the availability of services, programs and facilities used by persons with disabilities (e.g., temporary loss of elevator service), the City shall notify the public of the reason for the disruption, the date(s) of disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available. Such notice may be provided by a variety of methods, depending on the circumstances, and may include postings in conspicuous places at the affected premises, other City facilities, and the City’s website, as well as by other means that will ensure that the notice reaches those persons potentially affected by the temporary disruption.
Training – Contractors, Consultants and Service Providers
The City of Toronto shall ensure that City employees and volunteers who deal with the public on behalf of the City, and those who are involved in City policy and program development receive training on accessible customer service.
Third party contractors who deliver goods and services on behalf of the City are also required to ensure that they meet the legislative requirements of accessible customer service.
Training includes information on the Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005, c. 11 and the requirements of the Accessibility Standards for Customer Service, O. Reg. 429/07.
Managers and supervisors shall ensure that training records are maintained, including dates when training is provided and the number of employees who received training.
Customer Service training can take various forms as a part of an orientation; or a separate training program. The training can be provided through handouts at an orientation session, a mandatory online module, in a classroom setting, or through other formats.
The City of Toronto shall ensure that every area that interacts directly with the public develops and publishes a process for receiving and responding to feedback about how services and programs are delivered to people with disabilities.
Public feedback may be provided in person, by telephone, in writing or by electronic means. Feedback received by the City of Toronto shall be responded to, documented and tracked.
The documents required of the Accessible Customer Service Standards (Guidelines for implementation and training requirements of Contractors, Consultants and Service Providers) shall be maintained on the City’s website and provided to individuals, upon request, in the appropriate format.
The City Manager’s Office is responsible for reviewing this Statement and accessibility requirements annually and recommending amendments to ensure on-going compliance with regulated accessibility standards and legislated obligations.
The City Manager’s Office shall provide advice and direction on the implementation of this Statement.
The City is to ensure that any process for receiving and responding to feedback is accessible to persons with disabilities by providing or arranging for the provision of accessible formats and communication supports. The public shall be notified about the availability of accessible formats and communication supports.
Accessible Formats and Communication Supports
The City will provide or arrange for the provision of accessible formats and communication supports for persons with disabilities, upon request. Accessible formats and communication supports shall be provided in a timely manner, taking into account, the person’s accessibility needs to determine the suitability of an accessible format or communication support. The public shall be notified about the availability of accessible formats and communication supports.
Accessible formats may include but are not limited to, large print, recorded audio and electronic formats, Braille and other formats used by persons with disabilities.
Emergency Procedures, Plans or Safety Information
The City shall provide public emergency procedures, plans and public safety information to the public upon request, in an accessible format with appropriate communication supports in a timely manner.
Accessible Websites and Web Content
Make internet websites and web content controlled directly by the City of Toronto or through a contractual relationship that allows for modification of the product, shall conform with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0 Level A initially and Level AA in accordance with the schedule set out in the AODA Integrated Accessibility Standards.
Web Content Accessibility Guidelines (WCAG) is an international standard for making websites and web content accessible through a series of technical checkpoints (Level A and Level AA) so that websites and content are increasingly accessible to a broader range of users with disabilities. Web accessibility involves understanding a broad spectrum of disabilities, including visual, auditory, physical, cognitive, speech, learning, language, and neurological disabilities.
The City of Toronto shall post information about the availability of accommodation for applicants with disabilities in its recruitment process. Job applicants who are selected for an assessment /interview shall be notified that accommodations are available for materials/processes used in selection, upon request. Successful applicants shall be notified about the City’s policies for accommodating employees with disabilities.
The City shall inform employees of policies used to support employees with disabilities, including policies on the provision of job accommodations that take into account an employee’s accessibility needs due to a disability. The City shall provide this information to new employees as soon as practicable after they begin their employment and provide updated information to employees whenever there is a change to existing policies on the provision of job accommodations.
Accessible formats and communication supports for employees
Upon the request of an employee with a disability, the City shall consult with the employee to provide/arrange for the provision of accessible formats and communication supports for:
- information needed to perform the employee’s job; and,
- for information that is generally available to employees in the workplace
The City will consult with the employee making the request in determining the suitability of an accessible format or communication support.
Workplace Emergency Response Information
If an employee’s disability is such that the individualized workplace emergency response information is necessary and the City is aware of the need for accommodation, this information shall be provided to employees. In addition, this information shall be provided, with the person’s consent, to the person designated to provide assistance. The information shall be reviewed when the employee moves to a different location, when the employee’s overall accommodation needs or plans are reviewed and when the City reviews its general emergency response plan.
Documented individual accommodation plans
A written process for the development and maintenance of documented individual accommodation plans shall be developed for employees with disabilities. If requested, the plans shall include individualized workplace emergency response information. Elements for the individual accommodation plans are set out in the AODA Integrated Accessibility Standards.
Return to work process
The City shall have in place a documented return to work process for employees who are returning to work due to a disability and require disability-related accommodations. The return to work process shall outline the steps that the City shall take to facilitate the return to work.
Performance Management and Career Development and Redeployment
The City shall take into account the accessibility needs of employees with disabilities as well as any individual accommodation plans when providing career development, performance management and when considering redeployment.
Availability of Information on Accessibility Equipment and Features
The City shall provide information to the public about accessibility equipment and features of the ferry routes and services; and, upon request, information must be provided in an accessible format.
The City shall conduct employee and volunteer accessibility training on:
- The safe use of accessibility equipment and features
- Acceptable modifications to procedures in situations where temporary barriers exist or accessibility equipment on a vehicle fails; and
- Emergency preparedness and response procedures that provide for the safety of persons with disabilities.
The City shall keep a record of the training provided, including the training dates and number of people who attended.
Emergency Preparedness and Response Policies
The City shall make public emergency preparedness and response policies that provide for the safety of persons with disabilities; and upon request, provide them in an accessible format.
Fares, Support Persons
Where a person with a disability requires a support worker to accompany them, the support worker will not be charged a fare.
It is the responsibility of a person with a disability to demonstrate to a ferry service provider their need for a support person to accompany them on the ferry and to ensure that the appropriate designation for a support person is in place.
The City shall provide the following ferry services and upon request, make information available in an accessible format:
- Deploy lifting devices, ramps or portable bridge plates upon the request of a person with a disability
- Ensure that adequate time is provided to person with disabilities to safely board, be secured and deboard transportation vehicles with assistance, when requested
- Assist with safe and careful storage of mobility aids or mobility assistive devices used by persons with disabilities; and
- Allow a person with a disability to travel with a medical aid
The City will ensure that a person with a disability will not be charged a higher fare than a person without a disability; however a person with a disability can be charged a lesser fare. The City shall make available alternative fare payment options to persons with disabilities who cannot, because of their disability, use a fare payment option.
Storage of Mobility Aids, etc
The City shall allow passengers with disabilities to travel with their mobility aids and assistive devices. Upon request and pending safety provisions, ferry operators shall provide safe storage of mobility aid and assistive devices, at no additional charge.
If a route or scheduled service is temporarily changed, and the change is known in advance, the City shall make alternate arrangements to transfer people with disabilities to their route destination; providing information in a manner that takes into account the person’s disability.
Duties of Municipalities, General
The City shall consult with its municipal accessibility advisory committee, the public and persons with disabilities in planning for accessible bus stops and shelters; and in the development of accessible design criteria to be considered in the construction, renovation or replacement of bus stops and shelters.
When the City enters into arrangements with a person respecting the construction of bus stops and shelters in its jurisdiction, the City shall ensure that the person participates in the consultation and planning.
Owners and operators of taxicabs licensed by the City of Toronto are prohibited from charging additional fares or fees to persons with disabilities than for people without disabilities and for the storage of mobility aids or mobility assistive devices. The City requires that taxicabs licensed by the City make available vehicle registration and identification information in an accessible format.
The City shall consult with its municipal accessibility advisory committee, the public and persons with disabilities in planning for required proportion of on-demand accessible taxicabs and shall identify progress made in its accessibility plan.
Legislative and administrative authorities
- Accessibility for Ontarians with Disabilities Act, 2005, S.O. 2005.
- Accessibility Standards for Customer Service, O. Reg. 429/07.
- Integrated Accessibility Standards, O. Reg. 191/11.
- Ontario Human Rights Code, R.S.O. 1990, c. H.19.
Compliance Resources: Accessibility Directorate of Ontario
- Compliance Manual, October 2008
- Guide to the Accessibility Standards for Customer Service, O. Reg. 429/07, January 2008
- Training Resource, February 2009
- Guide to the Integrated Accessibility Standards Regulation, July 2012
Public spaces that are newly constructed or redeveloped by the City shall meet the accessibility requirements set out in the AODA Design of Public Spaces Standards, including the following areas:
- Recreation Trails and Beach Access Routes
- Outdoor Public Use Eating Areas
- Outdoor Play Spaces
- Exterior paths of Travel
- Accessible Parking
- Service counters, queuing guides and waiting areas
- Consultation with the Toronto Accessibility Advisory Committee, the public and persons with disabilities
In addition to incorporating accessible design requirements in new or renovated public spaces, the updated City’s Accessibility Plan (2017 – 2025) will document procedures for maintenance of the accessible elements, and for dealing with temporary disruptions of accessible elements.