Tell the Ford Government, School Boards and Others To Use Recommended New Standard for Ensuring Accessibility of the Built Environment


Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities
Web: https://www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: https://www.facebook.com/aodaalliance/

June 16, 2021

SUMMARY

Ontario desperately needs to modernize its outdated laws to ensure that buildings and the built environment becomes accessible to people with disabilities. The Ford Government has received a promising blueprint for this. This can help propel Ontario in the right direction towards becoming accessible to people with disabilities. Will the Ford Government act?

Below you can find one important part of the initial recommendations of the Government-appointed K-12 Education Standards Development Committee. These initial recommendations, which the Ford Government made public on June 1, 2021. This excerpt outlines what should be required for a school building to become physically accessible to students, school staff and family members with disabilities. We will have lots more to say in the coming days about the many other important initial recommendations that the K-12 Education Standards Development Committee offered for public feedback.

Many incorrectly think that the Ontario Building Code and accessibility standards enacted under the Accessibility for Ontarians with Disabilities Act require a new building or major renovations to be accessible for people with disabilities. Unfortunately, the physical accessibility requirements in those laws are grossly inadequate. The AODA Alliance gives compelling examples of this in three captioned online videos. These videos have been viewed thousands of times. These show serious accessibility problems in the Ryerson University’s new Student Learning Centre, in Centennial College’s new Culinary arts Centre, and in several new public transit stations in Toronto.

Two different AODA Independent Reviews, the 2014 Independent Review by Mayo Moran and the 2019 Independent Review by David Onley, each identified the disability barriers in the built environment as a priority. They both called for strong new action under the AODA. That action has not taken place.

Here’s what we set out below that is new and helpful to combat this situation. Written in non-technical language, is a list of important features that should be included in a building’s design. It is in a report that specifically talks about barriers facing students with disabilities in school. However, the recommendations listed below can equally apply to virtually any kind of building, not just schools.

These proposed requirements should be incorporated into the Ontario Building Code and AODA accessibility standards for buildings generally. In the meantime, and until they are enacted in laws, they should be followed whenever buildings, and especially public buildings are designed. This includes schools, hospitals, colleges, universities, government or private offices and any other public building.

These initial recommendations are the product of a joint collaboration between disability community and education sector representatives. The membership of the K-12 Education Standards Development Committee which approved these initial recommendations was appointed by the Ontario Government. Half of its members are drawn from the disability community, including AODA Alliance Chair David Lepofsky. The other half of the committee’s members are drawn from the education sector at all levels, including teachers, school board staff, and school board trustees. For an initial recommendation to be approved, the Ontario Government requires that it be supported by at least 75% of the committee’s membership.

Here is how the Ford Government can get an immediate start. Last summer, the Ford Government announced that at least a half a billion dollars were to be spent on new schools, and on major additions to existing schools. However the Government made no commitments that those new construction projects would be accessible to people with disabilities, and announced no new measures to achieve that goal. The Ontario Government should now require that those new school construction projects incorporate the accessibility requirements below. As well, even if the Ford Government does not act, school boards that will be undertaking these or any other construction projects can and should themselves use these recommendations in their building designs.

The K-12 Education Standards Development Committee confirmed in its initial recommendations report that the Ministry of Education does not now have a standard that sets accessibility requirements for school construction projects that the Government funds. Neither the Ontario Building Code nor AODA accessibility standards impose the requirements set out below.

Up to September 2, 2021, it is open to the public to send feedback to the K-12 Education Standards Development Committee on all its initial recommendations, including those set out below. We encourage everyone to send the Government that feedback. Send your feedback to the Government at [email protected]

We again urge the Ontario Government to now appoint a Built Environment Standards Development Committee to develop a comprehensive Built Environment Accessibility Standard under the AODA. The recommendations set out below would provide a great starting point for their discussions.

When he was seeking the public’s votes in the 2018 Ontario election, Doug Ford made specific commitments regarding the disability barriers in the built environment. Doug Ford’s May 15, 2018 letter to the AODA Alliance, setting out his party’s election commitments on disability accessibility, included:

a) “Your issues are close to the hearts of our Ontario PC Caucus and Candidates, which is why they will play an outstanding role in shaping policy for the Ontario PC Party to assist Ontarians in need.”

b) “Whether addressing standards for public housing, health care, employment or education, our goal when passing the AODA in 2005 was to help remove the barriers that prevent people with disabilities from participating more fully in their communities.”

c) “Making Ontario fully accessible by 2025 is an important goal under the AODA and it’s one that would be taken seriously by an Ontario PC government.”

d) “This is why we’re disappointed the current government has not kept its promise with respect to accessibility standards. An Ontario PC government is committed to working with the AODA Alliance to address implementation and enforcement issues when it comes to these standards.

Ontario needs a clear strategy to address AODA standards and the Ontario Building Code’s accessibility provisions. We need Ontario’s design professionals, such as architects, to receive substantially improved professional training on disability and accessibility.”

To learn more about the campaign to get Ontario to enact a strong and effective Education Accessibility Standard, visit the AODA Alliance website’s education page.
To learn more about the campaign to get the Ontario Government to enact a strong and effective Built Environment Accessibility Standard, visit the AODA Alliance website’s built environment page.

To download the entire set of initial recommendations by the K-12 Education Standards Development Committee on what the promised Education Accessibility Standard should include, visit https://www.aodaalliance.org/whats-new/download-in-ms-word-format-the-ontario-governments-survey-on-the-initial-or-draft-recommendations-of-the-k-12-education-standards-development-committee/

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:
81. Access to the site for pedestrians
a) Clear, intuitive connection to the accessible entrance
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
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.
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.
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
f) Tactile directional indicators shall be provided where large open paved areas happen along the route g) Accessible pedestrian directional signage at decision points
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. i) Accessible duress stations (Emergency safety zones in public spaces)
j) Heated walkways shall be used where possible to ensure the path is always clear of snow and ice

82. Access to the site for vehicles
a) Clear, intuitive connection to the drop-off and accessible parking
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
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
d) Heated walkways from the drop-off and parking shall be used to ensure the path is always clear of snow and ice
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)
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
g) Parking design should include potential expansion plans for future growth and/or to address increased need for accessible parking
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)
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.
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. 83. Parking
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.
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.
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.
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.

84. A Building’s Exterior doors
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.
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
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
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
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:
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:
a) Doors shall be sufficiently wide enough to accommodate stretchers, wheelchairs or assistive scooters, pushing strollers, or making a delivery
b) Threshold at the door’s base shall be level to allow a trip free and wheel friendly passage.
c) Heavy doors and those with auto closers shall provide automatic door openers. d) Room entrances shall have doors.
e) Direction of door swing shall be chosen to enhance the usability and limit the hazard to others of the door opening.
f) Sliding doors can be easier for some individuals to operate and can also require less wheelchair manoeuvring space. g) Doors that require two hands to operate will not be used. h) h. Revolving doors are not accessible.
i) Full glass doors are not to be used as they represent a hazard.
j) Colour-contrasting will be provided on door frames, door handles as well as the door edges.
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:
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.
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.
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
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.
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
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
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.
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
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
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
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.
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
a) Elevator Doors will provide a clear width to allow a stretcher and larger mobility devices to get in and out
b) Doors will have sensors so doors will auto open if the doorway is blocked
c) Elevators will be installed in pairs so that when one is out of service for repair or maintenance, there is an alternative available.
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.
e) Assistive listening will be available in each elevator to help make the audible announcements heard by those using hearing aids
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
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.
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.)
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.
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.
k) Lighting levels inside the elevator will match the lighting at the elevator lobbies. Lighting will be measured at the ground level
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
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
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.
b) A ramp’s textured surfaces, edge protection and handrails all provide important safety features.
c) On outdoor ramps, heated surfaces shall be provided to address the safety concerns associated with snow and ice.
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.
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
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.
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.
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
a) Stairs that are comfortable for many adults may be challenging for children, seniors or persons of short stature.
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.
c) Each stair in a staircase will use the same height and depth, to avoid creating tripping hazards
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.
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
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.
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.
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.
d) The appropriate design of all features will ensure the usability and safety of all toilet facilities.
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.
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.
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.
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.
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.
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.
k) Where shower stalls are provided, these shall include accessible sized stalls.
l) Portable Toilets at Special Events shall all be accessible. At least one will include an adult sized change table.

96. Washroom Stalls
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.
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.
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.
d) Universal features include accessible hardware and a minimum stall width to accommodate persons of large stature or parents with small children. 97. Toilets
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.
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. 98. Sinks
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.
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.
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.
d) For an individual in a wheelchair and younger children, a lower counter height and clearance for knees under the counter are required.
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.
f) The combination of shallow sinks and higher water pressures can cause unacceptable splashing at lavatories.

99. Urinals
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.
b) Urinal grab bars shall be provided to assist individuals rising from a seated position and others to steady themselves.
c) Floor-mounted urinals accommodate children and persons of short stature as well as enabling easier access to drain personal care devices.
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.
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.

100. Showers
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.
b) Grab bars and non-slip materials shall be included as safety measures that will support any individual.
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.
d) Other equipment that has contrasting colour from the shower stall shall be included to assist individuals with vision loss/no vision.
e) Shower floor drain locations will be located to avoid room flooding when they may get blocked
f) Colour contrast will be provided between the floor and the walls in the shower to assist with wayfinding
g) Shower curtains will be used for individual showers instead of doors as much as possible as it
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:
a) Elevated platforms, such as stage areas, speaker podiums, etc., shall be accessible to all.
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.
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.
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.
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:
a) Sensory rooms will be provided in a central location on each floor where there are classrooms or public meeting spaces b) They will be soundproof and identified with accessible signage
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
d) Lighting will be provided on a dimmer to allow for the room to be darkened
e) Weighted blankets will be available along with a variety of different seating options including beanbag chairs or bouncy seat balls
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:
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.
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.
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
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.
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.
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:
a) Areas for outdoor recreation, leisure and active sport participation shall be designed to be available to all members of the school community.
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
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.
d) Noise cancelling headphones shall be available to those with sensory disabilities.
e) Outdoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities undergoing rehabilitation.
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.
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:
a) Areas for recreation, leisure and active sport participation will be accessible to all members of the community.
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.
c) Noise cancelling headphones will be available to those with sensory disabilities.
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.
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.
f) Spaces will allow persons with disabilities to be active participants, as well as spectators, volunteers and members of staff.
g) Indoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities who are undergoing rehabilitation.
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:
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.
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.
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.
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:
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.
b) If tray slides are provided, they will be designed to move trays with minimal effort. c) Food signage will be accessible.
d) All areas where food is ordered and picked up will be designed to meet accessible service counter requirements
e) Self serve food will be within the reach of people who are shorter or using seated mobility assistive devices
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:
a) All service counters shall provide accessibility features
b) Study carrels will accommodate the knee-space and armrest requirements of a person using a mobility device.
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.
d) Workstations shall be equipped with assistive technology such as large displays, screen readers, to increase the accessibility of a library.
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:

a) Students, teachers and staff with disabilities will have accessibility to teaching and classroom facilities, including teaching computer labs.
b) All teaching spaces and classrooms will provide power door operators and assistive listening systems such as hearing loops
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.
d) Students teachers and staff with disabilities will be accommodated in all teaching spaces throughout the school.
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.
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.
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.
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.

110. 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:
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. b) All lines shall be accessible.
c) Waiting and queuing areas will provide space for mobility devices, such as wheelchairs and scooters.
d) Queuing lines that turn corners or double back on themselves will provide adequate space to manoeuvre mobility devices.
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.
f) Benches in waiting areas shall be provided for individuals who may have difficulty with standing for extended periods.
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:
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.
b) Counters will provide knee space under the counter to accommodate a person using a wheelchair or a scooter.
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.
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:
a) Lockers will be accessible with colour contrast and accessible signage
b) In change rooms an accessible bench will be provided in close proximity to lockers.
c) Lockers at lower heights serve the reach of children or a person using a wheelchair or scooter.
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:
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.
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.
c) Appropriate lighting and colour contrast are particularly important for persons with vision loss.
d) Signage provided will be accessible with braille, text, colour contrast and tactile features.

115. Public Address Systems
The following should be required:
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.
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.
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
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.
b) Areas of rescue assistance will be provided on all floors above or below the ground floor.
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.
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.
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.
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
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
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.
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. c) Patterned floors should be avoided, as they can create visual confusion.
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.
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
a) No floor-to-ceiling mirrors
b) Colour luminance contrast will be provided at least between: i. Floor to wall
ii. Door or door frame to wall
iii. Door hardware to door
iv. 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: a) Different spaces throughout the play area
b) Differentiate the rise and run on steps. Include colour contrasting on the edge of each step
c) Play space boundaries and areas where children should be cautious, such as around high traffic areas e.g. slide exits d) Entry to play areas with shorter doors to help avoid hitting heads
e) Tactile edges where there is a level change like at the top of the stairs or at a drop-off f) Transfer platforms
g) Railings and handrails contrasted to the supports to make them easier to find
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
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 a) Rubber Tile
b) Engineered wood fiber
c) Engineered carpet, artificial turf, and crushed rubber products 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
a) Accessible signage and raised line map at each entrance to the park b) Provide large colour contrasted text, pictograms, braille
c) provide signage at each play element with ID text and braille, marked with a Tactile attention paver to make it easier to find d) Identify the types of disability included at each play equipment/area

119.17 For Caregivers
a) Junior and senior play equipment within easy viewing of each other
b) Sitting areas that offer a clear line of sight to play areas and equipment c) Clear lines of sight throughout the play space
d) Access to all play areas in order to provide assistance e) Sitting areas with back support, arm rests and shade
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
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
b) Spaces where dogs can relive themselves dog relief area with nearby garbage can

119.19 Tips for Swings
a) Providing a safe boundary area around swings which is identified by surface material colour and texture b) Swings in a variety of sizes
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
a) Double Slides (side by side) allow caregivers to accompany and, if needed, to offer support b) Slide exits should not be directed into busy play areas c) Transfer platforms at the base of slide exits
d) Seating spaces with back support adjacent to the slide exit where children/caregivers can wait for their mobility device to be retrieved
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)
f) Roller slides are usually gentler in slope and provide both a tactile and sliding experience or an Avalanche Inclusive Slide




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Tell the Ford Government, School Boards and Others To Use Recommended New Standard for Ensuring Accessibility of the Built Environment


Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Society for All People with Disabilities

Web: www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: www.facebook.com/aodaalliance/

Tell the Ford Government, School Boards and Others  To Use Recommended New Standard for Ensuring Accessibility of the Built Environment

June 16, 2021

            SUMMARY

Ontario desperately needs to modernize its outdated laws to ensure that buildings and the built environment becomes accessible to people with disabilities. The Ford Government has received a promising blueprint for this. This can help propel Ontario in the right direction towards becoming accessible to people with disabilities. Will the Ford Government act?

Below you can find one important part of the initial recommendations of the Government-appointed K-12 Education Standards Development Committee. These initial recommendations, which the Ford Government made public on June 1, 2021. This excerpt outlines what should be required for a school building to become physically accessible to students, school staff and family members with disabilities. We will have lots more to say in the coming days about the many other important initial recommendations that the K-12 Education Standards Development Committee offered for public feedback.

Many incorrectly think that the Ontario Building Code and accessibility standards enacted under the Accessibility for Ontarians with Disabilities Act require a new building or major renovations to be accessible for people with disabilities. Unfortunately, the physical accessibility requirements in those laws are grossly inadequate. The AODA Alliance gives compelling examples of this in three captioned online videos. These videos have been viewed thousands of times. These show serious accessibility problems in the Ryerson University’s new Student Learning Centre, in Centennial College’s new Culinary arts Centre, and in several new public transit stations in Toronto.

Two different AODA Independent Reviews, the 2014 Independent Review by Mayo Moran and the 2019 Independent Review by David Onley, each identified the disability barriers in the built environment as a priority. They both called for strong new action under the AODA. That action has not taken place.

Here’s what we set out below that is new and helpful to combat this situation. Written in non-technical language, is a list of important features that should be included in a building’s design. It is in a report that specifically talks about barriers facing students with disabilities in school. However, the recommendations listed below can equally apply to virtually any kind of building, not just schools.

These proposed requirements should be incorporated into the Ontario Building Code and AODA accessibility standards for buildings generally. In the meantime, and until they are enacted in laws, they should be followed whenever buildings, and especially public buildings are designed. This includes schools, hospitals, colleges, universities, government or private offices and any other public building.

These initial recommendations are the product of a joint collaboration between disability community and education sector representatives. The membership of the K-12 Education Standards Development Committee which approved these initial recommendations was appointed by the Ontario Government. Half of its members are drawn from the disability community, including AODA Alliance Chair David Lepofsky. The other half of the committee’s members are drawn from the education sector at all levels, including teachers, school board staff, and school board trustees. For an initial recommendation to be approved, the Ontario Government requires that it be supported by at least 75% of the committee’s membership.

Here is how the Ford Government can get an immediate start. Last summer, the Ford Government announced that at least a half a billion dollars were to be spent on new schools, and on major additions to existing schools. However the Government made no commitments that those new construction projects would be accessible to people with disabilities, and announced no new measures to achieve that goal. The Ontario Government should now require that those new school construction projects incorporate the accessibility requirements below. As well, even if the Ford Government does not act, school boards that will be undertaking these or any other construction projects can and should themselves use these recommendations in their building designs.

The K-12 Education Standards Development Committee confirmed in its initial recommendations report that the Ministry of Education does not now have a standard that sets accessibility requirements for school construction projects that the Government funds. Neither the Ontario Building Code nor AODA accessibility standards impose the requirements set out below.

Up to September 2, 2021, it is open to the public to send feedback to the K-12 Education Standards Development Committee on all its initial recommendations, including those set out below. We encourage everyone to send the Government that feedback. Send your feedback to the Government at [email protected]

We again urge the Ontario Government to now appoint a Built Environment Standards Development Committee to develop a comprehensive Built Environment Accessibility Standard under the AODA. The recommendations set out below would provide a great starting point for their discussions.

When he was seeking the public’s votes in the 2018 Ontario election, Doug Ford made specific commitments regarding the disability barriers in the built environment. Doug Ford’s May 15, 2018 letter to the AODA Alliance, setting out his party’s election commitments on disability accessibility, included:

  1. a) “Your issues are close to the hearts of our Ontario PC Caucus and Candidates, which is why they will play an outstanding role in shaping policy for the Ontario PC Party to assist Ontarians in need.”
  1. b) “Whether addressing standards for public housing, health care, employment or education, our goal when passing the AODA in 2005 was to help remove the barriers that prevent people with disabilities from participating more fully in their communities.”
  1. c) “Making Ontario fully accessible by 2025 is an important goal under the AODA and it’s one that would be taken seriously by an Ontario PC government.”
  1. d) “This is why we’re disappointed the current government has not kept its promise with respect to accessibility standards. An Ontario PC government is committed to working with the AODA Alliance to address implementation and enforcement issues when it comes to these standards.

Ontario needs a clear strategy to address AODA standards and the Ontario Building Code’s accessibility provisions. We need Ontario’s design professionals, such as architects, to receive substantially improved professional training on disability and accessibility.”

To learn more about the campaign to get Ontario to enact a strong and effective Education Accessibility Standard, visit the AODA Alliance website’s education page.

To learn more about the campaign to get the Ontario Government to enact a strong and effective Built Environment Accessibility Standard, visit the AODA Alliance website’s built environment page.

To download the entire set of initial recommendations by the K-12 Education Standards Development Committee on what the promised Education Accessibility Standard should include, visit https://www.aodaalliance.org/whats-new/download-in-ms-word-format-the-ontario-governments-survey-on-the-initial-or-draft-recommendations-of-the-k-12-education-standards-development-committee/

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



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The Ford Government’s Announced Measures for Students with Disabilities Largely Leaves it to Each of 72 School Boards to Figure Out What to Do to Fully and Safely Include Them in School Re-opening


Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities
Web: http://www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: http://www.facebook.com/aodaalliance/

August 20, 2020

SUMMARY

Earlier this week, we asked this important question: What is the Ford Government’s plan to ensure that over 340,000 students with disabilities are fully and safely included in Ontario’s schools when they open next month? It is now clear that the Ford Government has no comprehensive plan.

At the start of this week, the August 17, 2020 AODA Alliance Update made public the fact that back on August 4, 2020 we had emailed the Ontario Ministry of Education to ask what measures the Government had announced for students with disabilities in connection with school re-opening, and that we had received no answer. Two days later, on August 19, the Ministry responded.

The list of measures that the Government provided is set out below. These include no comprehensive plan of action to ensure that students with disabilities are fully and safely included in school re-opening. These measures do not ensure that the barriers that faced students with disabilities last spring during distance learning are removed and that no new ones are created. The Government has once again left it to each of Ontario’s 72 school boards to figure out what to do for students with disabilities , floundering as they scramble to deal with the COVID-19 pandemic.

A month ago, on July 24, 2020, the Government received a strong report identifying key actions the Government needs to take to ensure that the needs of students with disabilities are met during the ongoing COVID-19 pandemic. These came from the COVID-19 subcommittee of the Government-appointed K-12 Education Standards Development Committee. Among other things, that report recommended the following, which the Government has not included in its list of actions for students with disabilities :

“1) The Ministry of Education should establish a Central Education Leadership Command Table with responsibilities for ensuring that students with disabilities have access to all accommodations and supports they require during the present COVID-19 pandemic. The responsibilities of the Command Table shall include:
a) immediately develop a comprehensive plan to meet the urgent learning needs of students with disabilities during COVID-19 pandemic quickly and resolve issues for students with disabilities as they arise. The comprehensive plan should be shared for implementation by school boards. This plan should include and incorporate the three options for education: * normal school day routine with enhanced public health protocols
* modified school day routine based on smaller class sizes, cohorting and alternative day or week delivery, and, * at-home learning with ongoing enhanced remote delivery
b) collect and share data on existing and emerging issues as a result of COVID-19, the effective responses of other jurisdictions in supporting students with disabilities during the current emergency, using evidence-based data collection methods for people with disabilities
c) establish a fully accessible centralized hub, and share and publicize the hub, for sharing of effective practices about supporting students with disabilities
d) develop a rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards
e) provide clear communication and guidance on school opening, health service delivery, etc. based on data collected.”

On August 19, 2020, the Ontario New Democratic Party wrote Ontario Education Minister Stephen Lecce about this subject. We set that letter out below. That letter calls on the Government to take action now to plan for the needs of students with disabilities during school re-opening.

What are parents of students with disabilities to do now, in this situation? Tune in to the Ontario Autism Coalition’s Youtube channel tomorrow, Friday at 11 am for the new virtual Town Hall to be convened by the AODA Alliance and the Ontario Autism Coalition, which will be entitled: “Preparing for School Re-Opening — Action Tips for Parents of Students with Disabilities.” This event will have American Sign Language interpretation and captioning. Check out the AODA Alliance’s announcement of this event for more details. Encourage others to log on to this event.

We always welcome your feedback. Write us at [email protected]

MORE DETAILS

August 19, 2020 Information Provided to the AODA Alliance from the Ontario Ministry of Education

School Re-Opening Initiatives for Students with Disabilities and Students with Special Education Needs

* As announced July 30, based on the best medical advice available, the province is implementing additional public health protocols to keep students and staff safe when they return to school in September. To support the implementation of these protocols, the government is providing over $300 million in targeted, immediate, and evidence-informed investments, including: * $10 million to support special needs students in the classroom; and * $10 million to support student mental health.

This funding is in addition to a $25 million investment in mental health and technology, which will see an additional $10 million dedicated to mental health staff, resources, and programs, as well as $15 million in technology funding to support the procurement of over 35,000 devices for Ontario’s students to support their synchronous learning in-school and beyond.

* As part of the plan the government is providing additional supports to enable a successful return to school. For students with a high-level of special education needs, the government is directing school boards to facilitate full-time in-school instruction, regardless of whether a secondary school begins the instructional year using an adapted model. The Ministry of Education will work with designated school boards to achieve this goal and will review and approve requests by designated school boards to open small or specialized secondary schools or programs with full-time attendance. Additionally, the government is directing boards to consider changing the school environment and remote learning needs in reviewing and updating Individualized Education Programs (IEPs) to best-serve students.

* In addition to doubling the mental health funding in the Ministry of Education, the government has also worked with School Mental Health Ontario and will provide school boards with a professional learning framework and toolkit to support the mental health of all students. This can be tailored at the board and school levels for different audiences. The professional learning will have a strong focus on building students’ social-emotional learning skills so that they can respond to what they are facing in the COVID-19 outbreak, manage their stress and build positive relationships. Professional learning will be provided for system leaders, educators and mental health professionals to support the approach to school re-entry, as well as throughout the school year.

The re-opening plan builds the summer learning plan for Ontario students to ensure students have every opportunity to continue their learning through the summer months that included focused programming for students with special education or mental health needs, including dedicated learning supports such as access to educational assistants and existing after-school programs that could be delivered through summer school and summer programming in Provincial and Demonstration Schools to focus on continued learning for our students with specialized learning needs.

* On August 12, the ministry communicated its expectations for three Professional Activity days be implemented prior to the start of the 2020-21 school year that will focus on topics for restarting the school year, to ensure the safety of staff, students and the broader community, and delivery of high-quality education for all learners. The ministry expects that professional learning will consider and incorporate the implications for teaching students with special education needs.

* The government recently issued Policy/Program Memorandum No. 164, Requirements for Remote Learning to provide direction to school boards on remote learning requirements. It includes specific requirements to support students with special education needs:

o Where appropriate, educators should provide more opportunities than the minimum requirements for synchronous learning for students with special education needs, based on their individual strengths and needs, and provide differentiated support and instruction.
o Educators should continue to provide accommodations, modified expectations, and alternative programming to students with special education needs, as detailed in theirIEPs. If it is not possible to meet a student’s needs through synchronous learning, educators and families will work together to find solutions.
o School boards are encouraged to provide continued access to assistive technology, including Special Equipment Amount (SEA) equipment, where possible, to support students with special education needs as they participate in remote learning. In situations where access to assistive technology is not feasible, educators are expected to work with students and parents to determine workable solutions on an individual basis.

August 19, 2020 letter from the Ontario New Democratic Party to the Ford Government

Hon. Stephen Lecce
Ministry of Education
5th Floor
438 University Ave.
Toronto, ON M5G 2K8

August 19, 2020

Dear Minister Lecce,

We are writing to insist that your government adopts a comprehensive COVID-19 plan for students with disabilities, ensuring that they have the tools they need to thrive during this pandemic.

On July 8, you stated in the legislature that you’ve been in touch with disability rights leaders, but there is still no plan to support the learning requirements of 340,000 students with special education needs.

Firstly, we are concerned about the lack of any uniform guidance on the issue of school exclusions. The AODA Alliance has reported that a majority of Ontario’s 72 school boards do not even have a policy guiding the use of exclusions.

This could set the stage for exclusions to be applied by administrators when schools lack the resources to accommodate students with disabilities.

Your Ministry should issue guidelines to school boards on the use of exclusions without delay, so that no student with a disability is unfairly denied the right to learn with their peers.

Another area where some students with disabilities have been denied equal learning opportunities relates to the discrepancies in how online learning has been implemented. Depending on the school board, different platforms with wildly varying levels of accessibility are being used. It is important for the Ministry to be supporting boards to ensure their online learning systems are equitable and accessible to all students.

Finally, your government has committed only $10 million in additional funding for students with special education needs to date. This amounts to a paltry investment of $34 per disabled student. How could anyone believe that is sufficient to meet the challenges before us? Significant investment in hiring additional educational assistants

and reducing class sizes is crucial to ensuring that all students’ learning needs are supported.

Minister, people with disabilities have been among those hit the hardest by this pandemic. This includes education, where many students with special education needs have struggled with the transition to distance learning.

In order to ensure that students with disabilities can thrive in the classroom or remotely, it is crucial that your Ministry develops a plan in consultation with the disability community, and puts real resources behind it.

We look forward to hearing from you.

Sincerely,

Joel Harden
Official Opposition Critic for Accessibility & People with Disabilities MPP for Ottawa Centre

Marit Stiles
Official Opposition Critic for Education
MPP for Davenport

Monique Taylor
Official Opposition Critic for Children & Youth Services
MPP for Hamilton Mountain




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The Ford Government’s Announced Measures for Students with Disabilities Largely Leaves it to Each of 72 School Boards to Figure Out What to Do to Fully and Safely Include Them in School Re-opening


Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Society for All People with Disabilities

Web: www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: www.facebook.com/aodaalliance/

The Ford Government’s Announced Measures for Students with Disabilities Largely Leaves it to Each of 72 School Boards to Figure Out What to Do to Fully and Safely Include Them in School Re-opening

August 20, 2020

          SUMMARY

Earlier this week, we asked this important question: What is the Ford Government’s plan to ensure that over 340,000 students with disabilities are fully and safely included in Ontario’s schools when they open next month? It is now clear that the Ford Government has no comprehensive plan.

At the start of this week, the August 17, 2020 AODA Alliance Update made public the fact that back on August 4, 2020 we had emailed the Ontario Ministry of Education to ask what measures the Government had announced for students with disabilities in connection with school re-opening, and that we had received no answer. Two days later, on August 19, the Ministry responded.

The list of measures that the Government provided is set out below. These include no comprehensive plan of action to ensure that students with disabilities are fully and safely included in school re-opening. These measures do not ensure that the barriers that faced students with disabilities last spring during distance learning are removed and that no new ones are created. The Government has once again left it to each of Ontario’s 72 school boards to figure out what to do for students with disabilities , floundering as they scramble to deal with the COVID-19 pandemic.

A month ago, on July 24, 2020, the Government received a strong report identifying key actions the Government needs to take to ensure that the needs of students with disabilities are met during the ongoing COVID-19 pandemic. These came from the COVID-19 subcommittee of the Government-appointed K-12 Education Standards Development Committee. Among other things, that report recommended the following, which the Government has not included in its list of actions for students with disabilities :

”1)  The Ministry of Education should establish a Central Education Leadership Command Table with responsibilities for ensuring that students with disabilities have access to all accommodations and supports they require during the present COVID-19 pandemic. The responsibilities of the Command Table shall include:

  1. a) immediately develop a comprehensive plan to meet the urgent learning needs of students with disabilities during COVID-19 pandemic quickly and resolve issues for students with disabilities as they arise. The comprehensive plan should be shared for implementation by school boards. This plan should include and incorporate the three options for education:
  • normal school day routine with enhanced public health protocols
  • modified school day routine based on smaller class sizes, cohorting and alternative day or week delivery, and,
  • at-home learning with ongoing enhanced remote delivery
  1. b) collect and share data on existing and emerging issues as a result of COVID-19, the effective responses of other jurisdictions in supporting students with disabilities during the current emergency, using evidence-based data collection methods for people with disabilities
  2. c) establish a fully accessible centralized hub, and share and publicize the hub, for sharing of effective practices about supporting students with disabilities
  3. d) develop a rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards
  4. e) provide clear communication and guidance on school opening, health service delivery, etc. based on data collected.”

On August 19, 2020, the Ontario New Democratic Party wrote Ontario Education Minister Stephen Lecce about this subject. We set that letter out below. That letter calls on the Government to take action now to plan for the needs of students with disabilities during school re-opening.

What are parents of students with disabilities to do now, in this situation? Tune in to the Ontario Autism Coalition‘s Youtube channel tomorrow, Friday at 11 am for the new virtual Town Hall to be convened by the AODA Alliance and the Ontario Autism Coalition, which will be entitled: “Preparing for School Re-Opening — Action Tips for Parents of Students with Disabilities.” This event will have American Sign Language interpretation and captioning. Check out the AODA Alliance’s announcement of this event for more details. Encourage others to log on to this event.

We always welcome your feedback. Write us at [email protected]

          MORE DETAILS

August 19, 2020 Information Provided to the AODA Alliance from the Ontario Ministry of Education

School Re-Opening Initiatives for Students with Disabilities and Students with Special Education Needs

  • As announced July 30, based on the best medical advice available, the province is implementing additional public health protocols to keep students and staff safe when they return to school in September. To support the implementation of these protocols, the government is providing over $300 million in targeted, immediate, and evidence-informed investments, including:
  • $10 million to support special needs students in the classroom; and
  • $10 million to support student mental health.

This funding is in addition to a $25 million investment in mental health and technology, which will see an additional $10 million dedicated to mental health staff, resources, and programs, as well as $15 million in technology funding to support the procurement of over 35,000 devices for Ontario’s students to support their synchronous learning in-school and beyond.

  • As part of the plan the government is providing additional supports to enable a successful return to school. For students with a high-level of special education needs, the government is directing school boards to facilitate full-time in-school instruction, regardless of whether a secondary school begins the instructional year using an adapted model. The Ministry of Education will work with designated school boards to achieve this goal and will review and approve requests by designated school boards to open small or specialized secondary schools or programs with full-time attendance. Additionally, the government is directing boards to consider changing the school environment and remote learning needs in reviewing and updating Individualized Education Programs (IEPs) to best-serve students.

 

  • In addition to doubling the mental health funding in the Ministry of Education, the government has also worked with School Mental Health Ontario and will provide school boards with a professional learning framework and toolkit to support the mental health of all students. This can be tailored at the board and school levels for different audiences. The professional learning will have a strong focus on building students’ social-emotional learning skills so that they can respond to what they are facing in the COVID-19 outbreak, manage their stress and build positive relationships. Professional learning will be provided for system leaders, educators and mental health professionals to support the approach to school re-entry, as well as throughout the school year.

The re-opening plan builds the summer learning plan for Ontario students to ensure students have every opportunity to continue their learning through the summer months that included focused programming for students with special education or mental health needs, including dedicated learning supports such as access to educational assistants and existing after-school programs that could be delivered through summer school and summer programming in Provincial and Demonstration Schools to focus on continued learning for our students with specialized learning needs.

  • On August 12, the ministry communicated its expectations for three Professional Activity days be implemented prior to the start of the 2020-21 school year that will focus on topics for restarting the school year, to ensure the safety of staff, students and the broader community, and delivery of high-quality education for all learners. The ministry expects that professional learning will consider and incorporate the implications for teaching students with special education needs.
  • Where appropriate, educators should provide more opportunities than the minimum requirements for synchronous learning for students with special education needs, based on their individual strengths and needs, and provide differentiated support and instruction.
  • Educators should continue to provide accommodations, modified expectations, and alternative programming to students with special education needs, as detailed in their IEPs. If it is not possible to meet a student’s needs through synchronous learning, educators and families will work together to find solutions.
  • School boards are encouraged to provide continued access to assistive technology, including Special Equipment Amount (SEA) equipment, where possible, to support students with special education needs as they participate in remote learning. In situations where access to assistive technology is not feasible, educators are expected to work with students and parents to determine workable solutions on an individual basis.

August 19, 2020 letter from the Ontario New Democratic Party to the Ford Government

Hon. Stephen Lecce

Ministry of Education

5th Floor

438 University Ave.

Toronto, ON M5G 2K8

August 19, 2020

Dear Minister Lecce,

We are writing to insist that your government adopts a comprehensive COVID-19 plan for students with disabilities, ensuring that they have the tools they need to thrive during this pandemic.

On July 8, you stated in the legislature that you’ve been in touch with disability rights leaders, but there is still no plan to support the learning requirements of 340,000 students with special education needs.

Firstly, we are concerned about the lack of any uniform guidance on the issue of school exclusions. The AODA Alliance has reported that a majority of Ontario’s 72 school boards do not even have a policy guiding the use of exclusions.

This could set the stage for exclusions to be applied by administrators when schools lack the resources to accommodate students with disabilities.

Your Ministry should issue guidelines to school boards on the use of exclusions without delay, so that no student with a disability is unfairly denied the right to learn with their peers.

Another area where some students with disabilities have been denied equal learning opportunities relates to the discrepancies in how online learning has been implemented. Depending on the school board, different platforms with wildly varying levels of accessibility are being used. It is important for the Ministry to be supporting boards to ensure their online learning systems are equitable and accessible to all students.

Finally, your government has committed only $10 million in additional funding for students with special education needs to date. This amounts to a paltry investment of $34 per disabled student. How could anyone believe that is sufficient to meet the challenges before us? Significant investment in hiring additional educational assistants

and reducing class sizes is crucial to ensuring that all students’ learning needs are supported.

Minister, people with disabilities have been among those hit the hardest by this pandemic. This includes education, where many students with special education needs have struggled with the transition to distance learning.

In order to ensure that students with disabilities can thrive in the classroom or remotely, it is crucial that your Ministry develops a plan in consultation with the disability community, and puts real resources behind it.

We look forward to hearing from you.

Sincerely,

Joel Harden

Official Opposition Critic for Accessibility & People with Disabilities

MPP for Ottawa Centre

Marit Stiles

Official Opposition Critic for Education

MPP for Davenport

Monique Taylor

Official Opposition Critic for Children & Youth Services

MPP for Hamilton Mountain



Source link

An Important New Report to the Ontario Government Calls on the Government and School Boards to Take Action Now to Ensure that One Third of a Million Students with Disabilities are Able to Fully Participate in Ontario Schools as They Re-Open This Fall


Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Society for All People with Disabilities

Web: www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: www.facebook.com/aodaalliance/

An Important New Report to the Ontario Government Calls on the Government and School Boards to Take Action Now to Ensure that One Third of a Million Students with Disabilities are Able to Fully Participate in Ontario Schools as They Re-Open This Fall

August 14, 2020

          SUMMARY

We today share with you a very important new report that bears on the needs of a third of a million students with disabilities in Ontario-funded schools, as the COVID-19 pandemic continues. Three weeks ago, the Ford Government received a detailed report on the steps it needs to take to meet the needs of students with disabilities now and into the fall, in the face of the ongoing COVID-19 crisis. This thorough report, which we set out in full below, was written by a subcommittee of the Government-appointed K-12 Education Standards Development Committee. AODA Alliance Chair David Lepofsky serves on that Standards Development Committee and was one of the members of the subcommittee that collectively developed this report. The subcommittee included representation from the disability sector and the school board community.

We are delighted that this report includes the substance of all the recommendations that the AODA Alliance put forward in its June 19, 2020 brief to the Ontario Government on how to meet the needs of students with disabilities during school re-opening. It expands and enhances on the recommendations in the AODA Alliance‘s June 19, 2020 brief to the Ontario Government. This report also goes further, adding other important recommendations.

With school re-opening fast approaching, it is important for the Ford Government to now announce a plan to implement these recommendations. Until the Ford Government does so, we call on all Ontario school boards to review this report and implement its recommendations in their plans for school re-opening.

We encourage one and all to send this report to your member of the Ontario legislature, your school board trustee, and your local media. Email Premier Doug Ford and Education Minister Stephen Lecce. Emphasize to all of them that this report needs immediate action.

The AODA Alliance has been spearheading a campaign for over a decade to tear down the barriers facing students with disabilities in Ontario’s education system. We led the multi-year campaign to get the Ontario Government to agree to create an Education Accessibility Standard under the Accessibility for Ontarians with Disabilities Act .

For more background on these issues, please visit the AODA Alliances COVID-19 web page and our education web page. Check out the widely-viewed online video of the May 4, 2020 virtual Town Hall on meeting the needs of students with disabilities during the COVID-19 crisis, co-organized by the Ontario Autism Coalition and the AODA Alliance.

Stay safe, and let us know what you do to help us press for these reforms. Email us at [email protected]

          MORE DETAILS

July 24, 2020 Letter to the Ontario Minister of Education and Minister for Accessibility from the Chair of the K-12 Education Standards Development Committee

Date: Friday, July 24, 2020

The Honourable Stephen Lecce

Minister of Education

5th Floor, 438 University Avenue,

Toronto, Ontario M7A 2A5

The Honourable Raymond Cho
Minister for Seniors and Accessibility
5th Floor, 777 Bay Street,

Toronto, Ontario M7A 1S5

Dear Minister Lecce and Minister Cho,

Re: K-12 Education Standards Development Committee: Planning for Emergencies and Safety Small Group Report

On behalf of the members of the Planning for Emergencies and Safety small group (the small group), I am pleased to submit the small group’s advice and recommendations on emergency planning and safety for students with disabilities in K-12 education during the COVID-19 pandemic.

The K-12 Education Standards Development Committee (The Committee) formed the small group when the Ministry of Education was seeking feedback from the Committee on the barriers and issues identified through the COVID-19 pandemic. The small group’s mandate includes using experiential learning from the COVID-19 pandemic to:

  • identify new and reoccurring accessibility barriers to learning for students with disabilities in the context of remote learning; and
  • develop an emergency plan framework (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency.

The small group members have put incredible effort, time and passion to complete this report that includes valuable advice and recommendations for government consideration. The report addresses the following 9 barriers for students with disabilities as a result of COVID-19:

  1. organizational, policy and procedural barriers
  2. mental health and well being
  3. academic (learning inequities for students with disabilities)
  4. support for secondary school students with disabilities
  5. transitions between in school and virtual learning
  6. accessible communication and technology
  7. training on the integration of digital technology into learning
  8. transportation
  9. recommendations addressing barriers for the Government and School Boards in emergency planning and safety

Thank you for your shared commitment to ensuring accessibility and inclusion for students with disabilities in Ontario. We have appreciated the discussions with Minister Lecce on Grants for Students Needs funding and the school board memos that address the current work being done to support students. The barriers in our report reflect what we have heard from various educational partners, families of student with disabilities and students within Ontario. I would be happy to meet with you to discuss these additional recommendations. The work and passion of the Committee continues, and we look forward to more opportunities to share our advice and feedback with you.

Together we can create an accessible and inclusive education system for students with disabilities during this unprecedented time.

Sincerely,

(Original signed by)

 

 

Lynn Ziraldo,
Chair, K-12 Education Standards Development Committee

Attachments:

  1. Small group report

July 24, 2020 Report to the Ontario Government from the Planning for Emergencies and Safety Subcommittee of the K-12 Education Standards Development Committee

July 24, 2020

Introduction

The COVID-19 Pandemic has tested emergency plans for all levels of government, businesses, agencies, education systems, communities, families, and citizens in the province of Ontario. Many risks have been identified and challenges have arisen because of the pandemic and more continue to be identified as we move through the stages of the emergency. Emergency plans, response and procedures need to be reviewed to address these risks and barriers immediately and to improve responses to emergencies in the future.

As the Ministry of Education was seeking feedback on barriers and emerging issues identified during the COVID-19 Pandemic, the K-12 Standards Development Committee formed the Planning for Emergency and Safety Working Group with a focus on students with disabilities with the following mandate:

Using experiential learning from the COVID-19 pandemic:

  • Identify new and reoccurring accessibility barriers to learning for students with disabilities in the context of remote learning
  • Develop an emergency plan framework (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency.

Methodology

The Planning for Emergencies & Safety Working Group gathered resources from experts including the Framework for Reopening Schools developed by UNICEF, SickKids recommendations to Reopening Schools, Letters to Minister Lecce from the Ontario Human Rights Commission of July 14, 2020; and various other resources and articles from educational partners within Ontario, other provinces and countries (See Resource Section). While reviewing the documents, the Working Group identified barriers and subsequently developed recommendations to address said barriers.

Organizational Challenges and Barriers during COVID-19

Through a review of resources, feedback from parents and guardians, agencies, health professionals and educational stakeholders’ opinions expressed, the Working Group found that students with disabilities have faced challenges compounded by COVID-19.  Their needs have been inconsistently addressed or not at all. These are some organizational, policy and procedural barriers identified:

  • Inconsistent or unclear messaging from varying levels of government, health agencies and school boards
  • Lack of or unable to access consistent data from all regions and school boards to support data driven decisions and implement actions quickly and effectively.
  • Policies and procedures outdated, non-existent, or inflexible to accommodate this type of emergency – COVID-19 pandemic.
  • Emergency response teams not reflecting the different subject knowledge needed to support decision making and development of a plan that reflects the needs of students with disabilities.
  • Inter-governmental, health service, service agencies and school board service agreements did not reflect the ability to provide services in a virtual learning environment
  • Service delivery models used by government, health services, service agencies and school boards not conducive to virtual service delivery.
  • The extent to which Board’s utilized or sought feedback from its SEACs in developing response or action plans to the COVID-19 pandemic varied from none to fully participated.
  • Not all school boards have an Accessibility Standards Committee or for those school boards that do have members of the community or people with disabilities who have lived experience that can help plan and implement the Public Health Guidelines to mitigate risks of COVID-19 in schools for students with disabilities
  • School board Accessibility Standards Committee can be helpful in helping to plan and implement the Public Health Guidelines to mitigate risks of COVID-19 in schools for students with disabilities. However, not all school boards have such committees, or committee membership that includes members of the community or people with disabilities who have lived experience that can inform planning and implementation.

Key Recommendations for Planning for Emergencies

It is important in planning for return to school, the opportunity is taken to review and create structures, policy and procedures that can adapt and be more flexible for a 2nd wave or future emergencies.

By learning from innovations and emergency processes, systems can adapt and scale up the more effective solutions. In doing so, they could become more effective, more agile, and more resilient” – (quoted from THE COVID-19 PANDEMIC: SHOCKS TO EDUCATION AND POLICY RESPONSES, World Bank).

There are 5 known steps to Emergency Planning and Preparedness: 1) Know your risk, 2) Build your Team, 3) Make critical information accessible quickly, 4) Update alert and response procedure, 5) Test the plan and revise.

To eliminate barriers identified, that a return to school plan has input from end users, be designed through an inclusive process and not by one team or group. A team of subject expertise from across the organization is critical for developing a strong plan.

Recommendations – Government

For the above reasons, it is recommended that

  • The Ministry of Education should establish a Central Education Leadership Command Table with responsibilities for ensuring that students with disabilities have access to all accommodations and supports they require during the present COVID-19 pandemic. The responsibilities of the Command Table shall include:
    1. immediately develop a comprehensive plan to meet the urgent learning needs of students with disabilities during COVID-19 pandemic quickly and resolve issues for students with disabilities as they arise. The comprehensive plan should be shared for implementation by school boards. This plan should include and incorporate the three options for education:
  • normal school day routine with enhanced public health protocols
  • modified school day routine based on smaller class sizes, cohorting and alternative day or week delivery, and,
  • at-home learning with ongoing enhanced remote delivery
    1. collect and share data on existing and emerging issues as a result of COVID-19, the effective responses of other jurisdictions in supporting students with disabilities during the current emergency, using evidence base data collection method for people with disabilities
    2. establish a fully accessible centralized hub, and share and publicize the hub, for sharing of effective practices about supporting students with disabilities
    3. develop a rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards
    4. provide clear communication and guidance on school opening, health service delivery, etc. based on data collected.
  • The government/Ministry of Education shall establish a cross sectorial Partnership Table at provincial and regional levels with the responsibility to integrate, coordinate and foster cross sector planning and response to emergencies. Responsibilities of this table are to:
    1. enhance an interlinked, coordinated and inter-ministerial approach in providing a seamless service delivery model to provide services and supports to students with disabilities (Psychology, Physical Therapy, Speech Therapy, Mental Health, etc.).
    2. collect data now, from respective sectors, health services, education, service agencies, etc. to identify existing and emerging barriers, know exactly which students with disabilities and how they are impacted, their needs, and how to better direct resources to support them
    3. provide clear communication and guidance on school opening, health service delivery, etc. based on data collected to ensure accessibility for students with disabilities.
  • The Ministry of Education provincial and regional partnership tables should include advisors that can provide insight on the needs and challenges of students with disabilities from lived experience and the collective experience of disability support groups, as well as students with disabilities.
  • The Ministry of Education should assign staff to assist the Central Educational Command Table by serving as a central rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards.
  • The Ministry of Education should direct that each school board shall establish a similar Board Command table. (See recommendation 12 for School Boards).
  • The provincial government continue and enhance an interlinked, coordinated and inter-ministerial approach in providing a seamless service delivery model to provide services and supports to students with disabilities (Psychology, Physical Therapy, Speech Therapy, Mental Health, etc.).
  • The Ministry of Education should collect and aggregate International data, resources and information from other countries experiences for use in planning transitions between in-school and distance education, including continuation of virtual learning at home.
  • The Ministry of Education should developed comprehensive plans for students with disabilities that addresses the surge in demand and increase capacity to provide specialized disability supports, including enhanced staffing, for the return to in-class and distance learning (increase in in-class supports, social workers, psychologists, guidance counsellors)
  • The Ministry of Education should develop guidelines that provide for alternate or enhanced childcare opportunities to be made available to families of students with a disability, for students required to stay home due to adapted model classroom scheduling. (Excludes childcare needs that are related to quarantine self-isolation for child or family due to exposure or a local outbreak of the virus.)
  • To get the most from the volunteer work of SEACs around Ontario, the Ministry of Education should:
  1. a) Create and maintain a listserv or other virtual network of all Ontario SEACs, to enable them to share their efforts with all other SEACs around Ontario, and
  2. b) Frequently gather input from SEACs around Ontario about the experiences of students with disabilities during the COVID-19 crisis to inform future policies and regulations and directions for school boards.
  • To promote transparency, accountability and identify trends, the Ministry of Education should immediately issue a policy direction for boards to create an exclusion policy, that imposes restrictions on when and how a principal may exclude a student from school, including directions that:
  1. a) Does not impede, create barrier, or disproportionally increase burdens for students with disabilities the right to attend school for the entire day as do students without disabilities. The power to refuse to admit a student to school for all or part of the school day should not be used in a way that disproportionately burdens students with disabilities or that creates a barrier to their right to attend school.
  2. b) Tracks exclusions and provide a transparent procedure and practice to parents/guardians, by requiring a principal who refuses to admit a student to school during the school re-opening process to immediately give the student and their parent/guardian written notice of their decision to do so, including written reasons for the refusal to admit, the duration of the refusal to admit and notice of the parent/guardian’s right to appeal this refusal to admit to the school board.
  3. c) Tracks exclusions, increases accountability and informs policies by requiring a principal who refuses to admit a student to school for all or part of the school day to immediately report this in writing to their school board’s senior management, including the reasons for the exclusion, its duration and whether the student has a disability. Each school board should be required to compile this information and to report it on a regular basis to the board of trustees, the public and the Ministry of Education (with individual information totally anonymized).
  • The Ministry of Education should provide clear guidelines and expectations to school boards on the implementation of Public Health Guidelines to mitigate risks of COVID-19 to ensure that school buildings and grounds be fully accessible for students with disabilities.

Recommendations – School Boards

  • School Boards should establish a similar Board Command/Central table as the Ministry of Education’s Central Education Command/Central Table, to receive and act on feedback from teachers, principals and families about problems they are encountering serving students with disabilities during the COVID-19 period. The Table will quickly network with similar offices/Tables at other school boards and can report recurring issues to the Ministry’s command table.
  • School Boards should utilize the expertise of the Special Education Advisory Committee members by directly involving members in the planning for the delivery of remote learning, other emergency plans, through regular meetings and frequent communications.
  • School Boards should enhance its hub of resources with successful practices, lesson plans, resources specific to students with disabilities in a virtual learning environment for ease of access and support teachers and students in their learning.
  • School Boards should involve their Accessibility Committee, or if there is no committee to establish an Accessibility Advisory Committee which will review all plans at the school board and school level for mitigating risk of COVID-19 meet the accessibility requirements of all students or people with disabilities.
  • School Boards should assign a leadership staff member responsible for ensuring that all changes at schools in response to COVID-19 maintain accessibility for all students with disabilities.

Mental Health & Well Being

As found through the review of resources, student and family mental health & wellbeing needs have soared to due to the traumatic effects of COVID-19. Students wellbeing has suffered for a variety of barriers: effects of isolation from social distancing, increased rise in domestic violence, lack of access to school breakfast programs, lack of access to mental health & therapeutic services, and negative financial impact to family’s income to name a few.

Barriers

  • Agencies, different levels of government and school boards developing plans and working on solutions to barriers with little or no coordination
  • Support for parents with students with complex needs are insufficient
  • Health services and supports not consistently or sufficiently prepared to provide health and mental health services in a virtual setting
  • There is a flood of information and resources being presented to teachers, parents and students
  • More inter-ministerial leadership and collaboration between Ministries of Education (MOE), Community, Children & Social Services (MCCSS) and Health (MOH) is required
  • School Boards and staff must be equipped with appropriate PPE for their own health and wellbeing
  • Need to safely deliver additional supports such and as breakfast & nutrition programs provided by community agencies
  • Plans for the next phase include a return to in-class and virtual instruction, including adapted models whereby some students will be scheduled at home on an alternate day or alternate week basis. Having students at home for short or long periods (alternate day to full semester) will be a significant challenge for families and may prevent the return to work for many parents. Some parents of children with disabilities face barriers to employment, and many others are overburdened with providing 24-hour care to students with complex care needs.

Recommendations – Government

  • The government should enhance the central hub of mental health & wellbeing information resources at provincial and regional levels with key messages and links to other resources. Ensure all resources are in an accessible digital format (as per Integrated Accessibility Standards Regulation), well publicised and shared with school boards.
  • Ministries should review and increase capacity of Ontario Telehealth Network (OTN) and other privacy protected health platforms to allow for boards to use (even in non-emergency times) and deliver services by regulated health care professionals that protect the privacy of the health services and IPRCs.
  • Ministries of Education, Health and Children, Community & Social Services should remove any cross-jurisdictional barriers related to the provision of health and education services to ensure students with disabilities can be provided with the mental health & wellbeing services they require to be delivered remotely. (For example, under Policy/Program Memorandum (PPM) 149, Protocol for Partnerships with External Agencies for Provision of Services by Regulated Health Professionals, Regulated Social Service Professionals, and Paraprofessionals permit electric consent for services and virtual access to services for students with disabilities).
  • The Ministry of Education should provide funding and clear guidelines on use of Personal Protective Equipment (PPE) and protocols for detection and containment of COVID-19 for boards, staff and all students, including those with disabilities. Public health authorities should establish clear protocols for the detection and containment of COVID-19 (and other infectious diseases) for school boards. The guidelines and protocols should be flexible for school boards to react to local situations to mitigate risks.
  • The Ministry of Education’s plan for school re-openings must include detailed directions on required measures to mitigate risk for students with disabilities from COVID-19 to maintain their health and wellbeing during any return to school. This requires additional planning in advance by school boards and additional funding to school boards to hire and train the additional Special Needs Assistants (SNA) and Educational Assistants (EA) they will need to ensure the safety of students with disabilities. It also requires safeguards to ensure that EAs or SNAs do not work at multiple sites and risk transmitting the COVID-19 virus from one location to another.
  • Ministries should review policies and regulations to continue to permit the virtual provision of therapy supports and services that have transitioned successfully to a virtual learning environment and where possible, permit and foster increased access to therapies and services to areas in province where a lack of services exists.

Recommendations – School Boards

  • Many students with disabilities volunteer at school events, in school daycares, kindergarten classes as part of their learning plan, IEP or fulfilling the 40 hours volunteer requirement. School Boards should develop/review guidelines for students with disabilities who volunteer in school to limits risk to health and safety but does not stop this valuable learning experience for students with disabilities.
  • Many adults with disabilities volunteer in schools and school daycares for the opportunity to exist as a valued contributing member within their community. School Boards should develop guidelines for people with disabilities who volunteer within the school that limits risk to the health and safety but continues to have the opportunity to be a contributing member of the school community.
  • School Board should provide virtual learning opportunities for volunteering and co-op courses for students with disabilities. Resources and guidelines should be developed to create the opportunity for the student to complete volunteering hours or cooperative credits successfully.
  • School Boards should develop and/or review guidelines for transitions plans for students with disabilities to outline supports and accommodations that may be offered in a virtual learning environment or enhanced by online tools and resources to support the physical and emotions wellbeing of student with disabilities when transitioning back to school. Accommodations or strategies should be reviewed and adapted to the virtual learning environment to support transitions. (An example would be for students with disabilities have access to audio described (DV) and closed-captioned (CC) virtual tours of the school facilities, so students could familiarize themselves with the school prior to the start of school. (See also Transition section).
  • In consultation with community agencies, School Boards should develop/revise procedures and protocols for volunteers and community agencies that support the health and wellbeing of students with disabilities continue to operate in the school (Example, Food nutrition programs, clothing exchanges, etc.)
  • In consultation with Public Health Regional Health, School Boards must develop clear protocols and procedures with accommodations for students with disabilities for the detection, isolation, tracing and follow up those students who develop symptoms for the virus, flu, respiratory infection, etc. For example: Ensure dedicated space to isolate students with disabilities who may need to return home is accessible and provides the accommodations required to meets the needs of any students with disabilities.

Academic

The pandemic has had profound impacts to student’s learning and staff’s ability to provide a learning environment that promotes student success and achievement. Learning inequities for students with disabilities have increased throughout the pandemic due to barriers faced. Some of the barriers identified were:

Barriers

  • Ongoing accessibility issues with online and virtual learning resources provided for learning at home
  • Wealth of resources, tools, etc. being developed by Boards, Agencies and Associations with limited sharing of resources. Resources developed may not be accessible.
  • Virtual learning is not working for many students with disabilities
  • Many students with disabilities were not effectively engaged in virtual learning for a variety of reasons, including accessibility challenges with the internet, computer software and hardware, nature of resources provided, individual challenges related to format, capacity of family, or behaviour.
  • Closure of schools for 3 months has resulted in significant loss of learning for many students
  • Special Education Advisory Committees meetings have been cancelled and some the skills and knowledge of SEAC members has not been fully utilized.
  • Teachers, students and parents were not prepared for the sudden transition from in-class instruction to the virtual learning environment and planning for future interruptions of schools would benefit from proactive planning for education in a virtual instruction and learning environment.

Recommendations – Government

  • The Ministry of Education should develop curriculum for students from Kindergarten to Grade 12 to enable students to develop the skills and knowledge they need for learning in a virtual learning environment. In the interim, the Ministry should share existing, accessible resources on this topic to teachers and School Boards (Please see Training for additional recommendations)
  • The Ministry of Education should collect and make readily available resources/information on practices, effective strategies in learning environment, and alternate approaches for students struggling with online learning, etc. from School Boards, agencies and disability specific associations.
  • Ministry of Education should provide clear expectations for teacher led instruction, synchronous learning, and weekly teacher student-teacher connections for students who are participating in virtual instruction and learning. Expectations should include monitoring if students with disabilities are fully participating, learning and benefiting from these activities; and if not, action to address barriers or issues identified.

Recommendations – School Board

  • School Boards should assess and document accommodations, modifications, resources and supports for all students with disabilities to plan for transition back to school and continuation of virtual instruction and learning. (Please see Transitions Recommendations for details)
  • School Boards should develop and provide all resources for instruction and assessment materials, homework assignments in an accessible digital format (See Communications & Technology section for recommendation on accessible digital format).

Secondary School

The secondary school experience is different from elementary school. It is where students develop, time management, organizational, advocacy skills, networking and social skills, become more aware of community and identify career paths. It is for this reason, the Working Group felt it was important to identify barriers and make recommendations specific to secondary students. Many of these recommendations can benefit the entire secondary school student population.

Barriers

  • Students with disabilities have experienced little to no personal contact with their school community social network supports (classroom teachers, Educational Assistants, custodians, administrative assistants, etc.), who rely on this contact to maintain their engagement within the school community and preserve their mental health.
  • At any time, students with disabilities have very limited opportunity to fulfill the 40 hours of volunteering required for graduation and rely heavily on volunteering at their high school or local elementary school events. All opportunities for volunteering were eliminated during the pandemic.
  • Many students with disabilities take optional specialized courses such as Specialized High School Major (SHSM), cooperative credits, etc. which provide hands on and participation within the community. Hands on learning, skills in applicable to trades and life skills were significantly diminished during COVID-19.
  • Clubs, councils, sports teams and extracurricular activities are a formative and important part of the high school experience. Often these extracurricular activities are the only opportunity students with disabilities has to socialize with their peers. Not having access to extracurricular activities has impacted their mental health and well-being.
  • Many students with disabilities rely on in class instruction be it due to learning disability, anxiety, learning style, ADHD, or simply due to preference in the way they individually learn, among others. The loss of in-class instruction has significantly impacted their learning and future for success.
  • Learning at home during school closure has been challenging for students in terms of academic achievement, mental health and wellbeing
  • All four years of high school are an integral part of a young person’s development and a multitude of students require and rely on in class instruction be it for specialized courses That require specialized equipment, trained staff;
  • The experience of four years of high school are incredibly formative of a young person’s social, emotional, mental and physical relationship with society, the world around them and indeed the values they will build their life around;
  • Return to school planning must consider the impacts on minority & racialized students, students in abusive households, students with limited access to technology or broadband, students with disabilities and students with other complex learning needs;
  • Many students rely on in class instruction be it due to learning disability, anxiety, learning style, ADHD, or simply due to preference in the way they individually learn, among others;

Recommendations – Ministry

  • The Ministry of Education should allow high school in-class instruction to operate for the 2020-2021 school year, if authorized by Ontario’s Chief Medical Officer of Health.
  • The Minister should direct School Boards to continue courses which require specialized forms of equipment, classrooms, teaching staff and/or resources (science labs, shops, media classrooms) continue to operate, in accordance with local public health advice.
  • As per the Canadian Mental Health Association, 70% of mental health challenges have their onset in childhood or youth and the Kids Help Phone Line has seen a increase in demand, The Ministries of Education and Health should increase capacity of mental health professionals and supports for School Boards, to ensure there is no waitlist for any secondary student requiring support.
  • The Ministry of Education should include student voice through student trustees’ association or other student leaders, when developing a plan for return to school.
  • The Ministry of Education should waive the compulsory credit in Health & Physical Education for students who have entered secondary school in the 2020-21 school or whose timetable will be negatively impacted, should Physical Education classes not operate in the conventional manner.
  • If required by Public Health, the Ministry of Education should fund PPE for students and staff to mitigate risks of infection.
  • The Ministry should direct School Boards to develop a prioritization and execution plan for conducting clinical assessments (e.g., psycho–educational assessments) that students with disabilities require in order to access necessary supports and services as they transition from secondary to post-secondary destinations.

Recommendations – School Board

  • School Boards and Schools should include student voice, including students with disabilities in developing the Board return to school plan, as well as, individual school return plans respectively.
  • School Boards and Schools should provide clear instruction on proper personal protection equipment (PPE) and safety measures to students, parents, and staff.
  • School Boards should follow or mirror Public Health protocols prescribed by the local Public Health. If PPE is not required by the local Public Health, student have the choice to wear PPE. If PPE is required, that school boards are funded appropriately to provide PPE for all students and staff.
  • Where local public health advice can be adhered to, Schools should continue to offer extracurricular activities such as clubs, councils, teams using proper social distancing and general safety protocols.
  • Where applicable, School Boards should waive parking fees for students to reduce financial burdens and help mitigate health risks for students by not riding on a crowded public transit bus.
  • School Boards should make decisions pertaining to cancellation of extracurricular activities in school mirror that of activities outside of school. (Example: If soccer clubs operate locally, then soccer clubs in schools should continue to operate).
  • School Boards should develop and offer online programming for students who cannot or wish not to attend school in person, but not be considered a long-term alternative to in class instruction.
  • School Boards and schools seek out the voice of students, including voices of students with disabilities, when they develop return to school plan options.
  • School Board should develop guidelines for clubs or programs that supplement or enhance education for students with disabilities so they can continue to operate upon return to school.
  • School Boards should continue to offer where possible, alternate classrooms, quiet workspaces, and other special education requirements prescribed in a student’s Individual Education Plan (IEP).
  • School Boards should research and investigate potential online coop placements that may be available for all students; including students with disabilities.
  • When permitted under local health advice, the School Board should review new health and safety protocols with student and the coop placement provider.

Transitions

An impact of the pandemic for students with disabilities is that learning has been lost or stagnant. Learning recovery will be important when returning to school. This will mean targeted measures to reversing learning loss or closing gaps. There will be a need for clear system wide guidance for in-class and central assessments to inform and plan for curriculum delivery, supports and service upon return to school.

Transition planning will occur at the provincial, local and student level. The Ministry of Education will need to identify barriers and gaps from all educational stakeholders to develop an informed return to school plan. School boards will need identify barriers and gaps at a system and individual student level to create an informed back to school plan as well as address the needs for students with disabilities.

The Individual Education Plan (IEP) is a tool for documenting student strengths and needs and the accommodations, programs and services they require to be successful. IEPs are a valuable tool in documenting the student’s current level of achievement and transition plans for planned changes in grades, schools, and life after secondary school. The IEP can also be used to plan for return to school, full time or in an adapted model, or for continued virtual learning.

Barriers

  • During the school closure gaps in student skills and knowledge related to on-line and distance learning has been evident
  • Planning for school year 2020-2021 will include in school and distance learning
  • School staff will need to assess student’s with disabilities to determine their accessibility and learning needs
  • Students with disabilities individual IEPs and transitions plans need to be reviewed to address barriers and gaps to allow for student success.
  • Student voice often forgotten in the planning process
  • Students and prospective students cannot visit the physical environments of schools during the COVID-19 pandemic and do not have the opportunity to check for physical accessibility and familiarize themselves with environment

Recommendations – Government

  • The Ministry of Education should direct School Boards to develop a prioritization and execution plan for conducting clinical assessments (e.g., psycho–educational assessments) that students with disabilities require, in order to access necessary supports and services as they transition from secondary to post-secondary destinations.
  • The Ministry of Education, in partnership with MCCSS should work with school boards to identify their cohorts of students with intellectual and other disabilities who completed their school careers in June 2020 and identify and assess if barriers faced during COVID-19 did not allow for successful student transitions to their chosen pathway (Examples: to work, volunteer work, recreation/leisure programs, and post-secondary education) as outlined in their transition plans. Jointly, the Ministries and School Boards should develop plans to help this cohort of students with disabilities achieve their individual transition goals.

Recommendations – School Boards

  • School Boards should be independently collecting board wide data on gaps, barriers, emerging issues, transition challenges, technology challenges, additional students’ needs and supports arising or as a result of COVID-19 through assessment, student and parent feedback to address and plan for system wide supports and services required by students with disabilities upon return to school.
  • To help with successful transitions for student with disabilities in returning to school, School Boards shall contact parent/guardians, as soon as possible, to discuss and identify learning gaps, individual needs arising from school shutdown and distance learning, transition challenges, social and emotional needs to inform and revise/or create individualized transition plans for students with disabilities.
  • To help reduce stress and anxiety and prepare themselves for return to school, students with disabilities should be involved with discussions and decision made in developing their Transition Plan.
  • School Boards and Administrators shall ensure Individual Education Plans for students with disabilities are revised/created to reflect specific goals and activities to address the individual needs identified in Recommendation #3 to help increase academic and transition success for each student with a disability upon returning to school.
  • School Boards shall include the student when developing their individualized Transition and IEP. All
  • When School Boards develop the Individualized Transition Plans for each student, it should be:
    1. flexible to accommodate the stop and start of in class learning. All methods of instruction should be considered for learning to ensure students have access to an education (virtual instruction, in home instruction, etc.)
    2. include a flexible and hybrid model for entry needs to accommodate the varying student needs. Any model developed for return to school shall be developed in consultation with parent/guardians and student
    3. include strategies for students around social/physical distancing. Social distancing guidelines should be developed in consultation with parents/guardians and student.
    4. Include steps for follow up and checking in with the student
    5. All documentation or information be provided to the parent/guardian and student before the meeting with enough time to review. Documents should be provided in an accessible format.
  • School Boards should take more interactive approaches to collect on-going feedback from parents, students and staff (i.e. “Thought exchange”) to guide and inform changes to policies and procedures impacted by COVID-19.
  • School Boards should develop a clear system wide plan to address increased classroom and school supports and services (Educational Assistants, Education Works, social workers, psychologists, guidance councillors) identified through assessments to help mitigate issues and support learning for students with disabilities.
  • School Boards should create audio described (DV) and closed-captioned (CC) virtual tours of their school. The virtual tour must be fully accessible and thoroughly provide information on accessibility and locations at the schools. Virtual tours should be made permanently available; not just during the pandemic.

Communications & Technology

For our purpose, communication includes technologies, systems, protocols and procedures that enable an organization to effectively communicate to its employees, partners and community. During an emergency, communication is essential and should ensure all relevant personnel can quickly and effectively communicate with each other during such crises, sharing information that will allow the organization to quickly rectify the situation, protect employees and assets, and allows the business to continue.

To relate this to Education – government, school boards, agencies, staff, students, parent/caregivers, should have the ability to communicate effectively during a crisis, while the business of providing learning continues.

Barriers

  • Ongoing accessibility issues with virtual learning environment or platform (Examples: no closed captions, compatibility issues with screen readers, lack of support or knowledge of accessibility features, no ASL interpretation)
  • Ongoing accessibility issue with information and resources provided
  • Conflicting guidelines provided by different ministries and level of government.

Recommendations – Government

  • That a designated communication lead should be assigned at the provincial and regional level for consistent messaging.
  • For efficiency and elimination of duplication of effort for School Boards, The Ministry of Education should immediately engage an arms-length digital accessibility consultant to evaluate the comparative accessibility of different digital learning and virtual learning environments or platforms available for use in Ontario schools. This should involve end-user testing. The Ministry should immediately send the resulting report and comparison to all school boards and make it public. This should be revisited as the fall approaches, in case there have been changes to the relative accessibility of different virtual instruction environments or platforms.
  • The Ministry of Education should provide a list of acceptable accessible, cross platform virtual learning environments and synchronous teaching systems to be used by school boards.
  • The Ministry of Education should make public a plan of action to swiftly make its own online learning content accessible for people with disabilities, setting out milestones and timelines, and should report to the public on its progress.
  • The Ministry of Education should immediately direct TVO/TFO to make its online learning content accessible to people with disabilities, and to promptly make public a plan of action to achieve this goal, with specific milestones and timelines. The implementation of this recommendation has become urgent since Royal Assent was given to Bill 197, COVID-19 Economic Recovery Act, 2020 as amends to the Ontario Educational Communications Authority Act broaden the mandates of both TVO and TFO to position them to provide centralized support for online learning in the English-language and French-language publicly-funded education systems, respectively.
  • The Ministry of Education should direct its entire staff and all School Boards that whenever making information public in a Portable Document Format (PDF), it must at the same time, make available a textual format such as an accessible Microsoft Word (MSWord) or accessible HTML document. Videos must be audio described (DV) and closed captioned (CC). Templates and technical guides should be developed and provided to school boards.

Recommendations – School Boards

  • For consistent messaging, that the School board should designate a communication lead for COVID-19 related issues.
  • School Boards should develop protocols and procedures to mitigate security risks for online and virtual learning platforms to help protect privacy of students with disabilities and staff. Online and virtual learning platforms should also be accessible for all students with disabilities.
  • That School Boards should provide clear communication around protocols and return to school plans. Boards should make written communications readily available and accessible by everyone in the community, parents and students.
  • School Boards should review and revise instructional videos for parents around virtual learning tools used in the school board. Videos must be clear and accessible.
  • School Boards should provide solely dedicated or designated staff, who are available to support technology including accessibility needs to parents who are supporting the learning needs of students with disabilities at home.

Training

The COVID-19 Pandemic has changed the way in which education is delivered. Students, parents/guardians, teachers, staff, school boards and government had to change the way they access, support or deliver education. The pandemic highlighted gaps in digital skills, adaptation of technology to teaching and learning. It has also increased demand for technology and the need to integrate technology effectively into teaching and learning. With this increased demand in the use of technology and the gaps in digital skills identified, it is imperative to train students, parent/guardians and staff in the use and integration of technology in teaching and learning.

Barriers

  • Teachers, students and parent/guardians unprepared for learning at home and use of virtual platforms such as google classroom, Microsoft teams, Zoom for individual and synchronous learning
  • Teachers, ECEs, Staff need training in virtual online learning platforms
  • Teachers, ECEs, Staff need training in strategies to support students with disabilities around transitions between education models, including preparation for changing environments and self regulation
  • Teachers, ECEs lack training in strategies to support Public Health directed precautions, such as social distancing, sanitizing procedures and use of PPE when required to support students
  • School closures have had a significant impact on the mental health and well being of students with disabilities and teachers, ECEs, staff will require training on child development and trauma informed practice to assist them in supporting students in transitioning back to school or continuation of virtual education.
  • The expectation on parent/guardians to support students with learning at home were significant and parents need supports and training in virtual learning software and how they can effectively support their child’s learning.

Recommendations – Government

  • That Ministry of Education should model leadership to School Boards and provide accessible virtual learning webinars, templates for learning, etc. to be utilized in training administrators and teachers.
  • The Ministry of Education should direct School Boards to provide all staff training in child development, mental health and wellbeing to support the wellbeing and learning of students with disabilities.
  • The Government should provide direction to School Boards and Public Service agencies to develop a coordinated training delivery model to support parents of students with rehabilitation needs, mental health concerns or who have complex or significant medically needs, with the delivery of virtual care, including privacy protected health platforms such as OTN, ADcare.

Recommendations – School Boards

  • School Boards should provide focused, practical training for administrators and teachers to support students with disabilities’ health, wellbeing and learning in a mixed or virtual environment.
  • School Boards should provide administrators training and guidelines on supporting students with disabilities through transitioning and change.
  • School Boards should develop parent training modules and resources to enable parent/guardians to develop the skills and knowledge required to support online and virtual learning at home for students with disabilities.
  • School Boards should provide training for teachers and staff on specific tips and solutions, successful and evidence based promising practices by disability to support teachers and students with disabilities learning. These should be made available as soon as possible or at the latest, during the first days of PD before school instruction begins.

Transportation

School Bus operation and delivery of bus services is regulated and governed both federally and provincially. Transport Canada has consulted with the Public Health Agency of Canada to provide guidelines around bus operations during the pandemic. The National Association for Pupil Transportation (NAPT) has also provided general guidelines for the provision of student (pupil) transportation services.

The Ministry of Education’s Return to School Framework directs School Boards to follow these federal guidelines.

To accommodate Federal Transportation and Public health guideline that require social and physical distancing, School Boards will have to revise transportation services delivery that will impact bus routes, increase the number of buses and drivers required, increase ridership time, etc. to mitigate risks to students with disabilities while transporting to and from school.

Barriers

  • Lack of or reduced public transportation available for students with disabilities, particularly for secondary students who take public transit. Municipal governments eliminated routes or reduced schedules during COVID-19. Municipalities have not made public transportation plans for when students return to school.
  • As School Boards and Consortiums plan transportation services to meet the Transport Canada guidelines, current challenges of inadequate buses, shortage of drivers and increasing fuel costs will be a barrier to boards.
  • Changes to routine can have a significant impact to a student with disabilities’ mental health, success for the start of school day and learning. Predictable changes to transportation for students with disabilities can include, increased ridership time, bus route, bus type (72-passenger, small bus), supports or accommodations required for a successful ride, etc. while maintaining safety and mitigating risks for infection.
  • Many School Boards currently overspend the transportation grant, while still achieving a high efficiency rating from the Ministry of Education. The additional requirements defined under the Transport Canada Guidelines will increase cost pressures to provide transportation services to students with disabilities while maintaining safety and mitigating risk of infection.
  • As students with disabilities require may require specific transportation accommodations such as a safety harness, seat belt, wheelchair accessible which cannot be accommodated in all vehicle types.

Recommendations – School Boards

  • As many School Boards overspend its transportation grant while maintaining a high efficiency rating, the Ministry of Education should provide school boards with additional COVID-19 specific funding to follow the guidelines as provided by Transport Canada around:
    • Measures to mitigate risk of exposure
    • Procedures to be taken before a trip, during a trip and at the end of the trip
    • PPE guidelines
    • Physical Distancing
    • Shield and Enclosure system guidelines (if bus operators choose to do so)
  • School Boards should review transportation accommodations and requirements, in consultation with parents and student, IEPs of students with disabilities who require transportation services to identify any change/modifications to accommodations required. The student’s IEP shall be modified to reflect additional requirements to transport the student safely on the bus. The review for medically fragile students should include professionals, such as nurses, occupational therapists, as well as parents. All transportation requirements shall be relayed to the Bus Consortia and administrator of the school for implementation.
  • School Boards must create/revise a protocol for the safe gathering of all students and parent/guardians at bus stops and safety on the bus. It is important that student with disabilities be included and familiarized with these protocols with their peers.
  • School Boards and Bus Consortia should provide bus drivers with training on new health and safety protocols for students with disabilities on a regular bus, small bus and wheelchair accessible bus.
  • Bus Consortia should minimize changes to routes, vehicle type, and schedules for students with disabilities while developing changes to routes, to limit increased anxiety or behaviours as a result of the changes. When changes are considered, parents and student should be consulted about changes.
  • School Boards and Bus Consortia should review procedures and protocols for persons responsible for putting a student with disability’s harness on/off or supporting a student on the school bus to mitigate health risks for the student, bus driver and support person.
  • School Boards and Bus Consortia should revise/develop, implement and disseminate bus safety protocol Information for parents needs to help mitigate health and safety risks and assuage parent’s fears. This includes protocols around harnesses. All communications should be clear and made readily available on the Board and Bus Consortia website in an accessible digital format.
  • Students with disabilities should be included in any training that is provide for all students on enhanced safety rules on the bus.
  • As students with disabilities are statistically proven to be at a higher risk of infection, School Boards and Bus Consortia should implement enhanced student bus ridership attendance procedures to aid in tracing of COVID-19 and mitigating health risks.
  • Traffic volume, student and road safety is always a concern around schools. It is expected for vehicle traffic to increase when school returns, as parent/caregiver or a secondary student chooses to drive to school. School Boards should work collaboratively with Municipalities to develop safe arrival and departure awareness campaigns for students, parents/caregivers and buses. These campaigns could include guidelines for kiss & ride, audio described (DV) and closed captioned (CC) virtual or diagrams of vehicle traffic flows for entering and exiting school property from the street, identifying school bus only access areas, promote other methods of transportation, etc.

Conclusion

The Planning for Emergencies are please to provide its draft recommendations related to the COVID-19 pandemic. The Working Group will continue to review resources and information on barriers and issues arising from COVID-19 and as students return to school. It will start work on its mandate to develop an emergency plan framework focused on students with disabilities (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency.

Thank you to all the members of the Planning for Emergencies Working Group for their dedication in developing this draft set of recommendations. Working Group members are:

  • Donna Edwards (Chair – Working Group)
  • Stephan Andrews
  • David Lepofsky
  • Dr. Ashleigh Malloy
  • Alison Morse
  • Rana Nasrazadani
  • Ben Smith
  • Angelo Tocco
  • Dr. Lindy Zaretsky
  • Lynn Ziraldo (Chair K-12 SDC)

Glossary

Accessibility: a general term for the degree of ease that something (e.g., device, service, physical environment and information) can be accessed, used and enjoyed by persons with disabilities. The term implies conscious planning, design and/or effort to make sure something is barrier-free to persons with disabilities. Accessibility also benefits the general population, by making things more usable and practical for everyone, including older people and families with small children.

Accessible: does not have obstacles for people with disabilities – something that can be easily reached or obtained; facility that can be easily entered; information that is easy to access.

Accessible digital format: Information that is provided in digital form that is accessible such as HTML and MS Word.

Synchronous learning: is the kind of learning that happens in real time. This means that you, your classmates, and your instructor interact in a specific virtual place, through a specific online medium, at a specific time. In other words, it’s not exactly anywhere, anyhow, anytime. Methods of synchronous online learning include video conferencing, teleconferencing, live chatting, and live-streaming lectures.

Asynchronous learning: happens on your schedule. While your course of study, instructor or degree program will provide materials for reading, lectures for viewing, assignments for completing, and exams for evaluation, you have the ability to access and satisfy these requirements within a flexible time frame. Methods of asynchronous online learning include self-guided lesson modules, streaming video content, virtual libraries, posted lecture notes, and exchanges across discussion boards or social media platforms.

Distance Education Program: Programs to provide courses of study online, through correspondence, or by other means that do not require the physical attendance by the student at a school. (From Bill 197)

Special Education Services – As defined in the Education Act, “facilities and resources, including support personnel and equipment, necessary for developing and implementing a special education program”.

Virtual learning: is defined as learning that can functionally and effectively occur in the absence of traditional classroom environments (Simonson & Schlosser, 2006).

Virtual education: refers to instruction in a learning environment where teacher and student are separated by time or space, or both, and the teacher provides course content through course management applications, multimedia resources, the Internet, videoconferencing, etc. Students receive the content and communicate with the teacher via the same technologies.

Virtual learning environment: refers to a system that offers educators digitally-based solutions aimed at creating interactive, active learning environments. VLEs can help educators create, store and disseminate content, plan courses and lessons and foster communication between student and educator. Virtual learning environments are often part of an education institution’s wider learning management system (LMS).

Virtual instruction: is a method of teaching that is taught either entirely online or when elements of face-to-face courses are taught online through learning management systems and other educational tools and platforms. Virtual instruction also includes digitally transmitting course materials to student.

Resources

Mental Health

Public Health Guidance and Safety

 

Tools/Best Practices

Stakeholder Reports and Information

Additional Reading



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An Important New Report to the Ontario Government Calls on the Government and School Boards to Take Action Now to Ensure that One Third of a Million Students with Disabilities are Able to Fully Participate in Ontario Schools as They Re-Open This Fall


Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities
Web: http://www.aodaalliance.org Email: [email protected] Twitter: @aodaalliance Facebook: http://www.facebook.com/aodaalliance/

August 14, 2020

SUMMARY

We today share with you a very important new report that bears on the needs of a third of a million students with disabilities in Ontario-funded schools, as the COVID-19 pandemic continues. Three weeks ago, the Ford Government received a detailed report on the steps it needs to take to meet the needs of students with disabilities now and into the fall, in the face of the ongoing COVID-19 crisis. This thorough report, which we set out in full below, was written by a subcommittee of the Government-appointed K-12 Education Standards Development Committee. AODA Alliance Chair David Lepofsky serves on that Standards Development Committee and was one of the members of the subcommittee that collectively developed this report. The subcommittee included representation from the disability sector and the school board community.

We are delighted that this report includes the substance of all the recommendations that the AODA Alliance put forward in its June 19, 2020 brief to the Ontario Government on how to meet the needs of students with disabilities during school re-opening. It expands and enhances on the recommendations in the AODA Alliances June 19, 2020 brief to the Ontario Government. This report also goes further, adding other important recommendations.

With school re-opening fast approaching, it is important for the Ford Government to now announce a plan to implement these recommendations. Until the Ford Government does so, we call on all Ontario school boards to review this report and implement its recommendations in their plans for school re-opening.

We encourage one and all to send this report to your member of the Ontario legislature, your school board trustee, and your local media. Email Premier Doug Ford and Education Minister Stephen Lecce. Emphasize to all of them that this report needs immediate action.

The AODA Alliance has been spearheading a campaign for over a decade to tear down the barriers facing students with disabilities in Ontarios education system. We led the multi-year campaign to get the Ontario Government to agree to create an Education Accessibility Standard under the Accessibility for Ontarians with Disabilities Act .

For more background on these issues, please visit the AODA Alliances COVID-19 web page and our education web page. Check out the widely-viewed online video of the May 4, 2020 virtual Town Hall on meeting the needs of students with disabilities during the COVID-19 crisis, co-organized by the Ontario Autism Coalition and the AODA Alliance.

Stay safe, and let us know what you do to help us press for these reforms. Email us at [email protected]

MORE DETAILS

July 24, 2020 Letter to the Ontario Minister of Education and Minister for Accessibility from the Chair of the K-12 Education Standards Development Committee

Date: Friday, July 24, 2020

The Honourable Stephen Lecce
Minister of Education
5th Floor, 438 University Avenue,
Toronto,Ontario M7A 2A5

The Honourable Raymond Cho
Minister for Seniors and Accessibility
5th Floor, 777 Bay Street,
Toronto, Ontario M7A 1S5

Dear Minister Lecce and Minister Cho,

Re: K-12 Education Standards Development Committee: Planning for Emergencies and Safety Small Group Report

On behalf of the members of the Planning for Emergencies and Safety small group (the small group), I am pleased to submit the small groups advice and recommendations on emergency planning and safety for students with disabilities in K-12 education during the COVID-19 pandemic.

The K-12 Education Standards Development Committee (The Committee) formed the small group when the Ministry of Education was seeking feedback from the Committee on the barriers and issues identified through the COVID-19 pandemic. The small groups mandate includes using experiential learning from the COVID-19 pandemic to:

* identify new and reoccurring accessibility barriers to learning for students with disabilities in the context of remote learning; and
* develop an emergency plan framework (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency.
The small group members have put incredible effort, time and passion to complete this report that includes valuable advice and recommendations for government consideration. The report addresses the following 9 barriers for students with disabilities as a result of COVID-19: 1. organizational, policy and procedural barriers
2. mental health and well being
3. academic (learning inequities for students with disabilities) 4. support for secondary school students with disabilities
5. transitions between in school and virtual learning
6. accessible communication and technology
7. training on the integration of digital technology into learning 8. transportation
9. recommendations addressing barriers for the Government and School Boards in emergency planning and safety

Thank you for your shared commitment to ensuring accessibility and inclusion for students with disabilities in Ontario. We have appreciated the discussions with Minister Lecce on Grants for Students Needs funding and the school board memos that address the current work being done to support students. The barriers in our report reflect what we have heard from various educational partners, families of student with disabilities and students within Ontario. I would be happy to meet with you to discuss these additional recommendations. The work and passion of the Committee continues, and we look forward to more opportunities to share our advice and feedback with you.

Together we can create an accessible and inclusive education system for students with disabilities during this unprecedented time.

Sincerely,

(Original signed by)

Lynn Ziraldo,
Chair, K-12 Education Standards Development Committee

Attachments:
1. Small group report

July 24, 2020 Report to the Ontario Government from the Planning for Emergencies and Safety Subcommittee of the K-12 Education Standards Development Committee

July 24, 2020

Introduction
The COVID-19 Pandemic has tested emergency plans for all levels of government, businesses, agencies, education systems, communities, families, and citizens in the province of Ontario. Many risks have been identified and challenges have arisen because of the pandemic and more continue to be identified as we move through the stages of the emergency. Emergency plans, response and procedures need to be reviewed to address these risks and barriers immediately and to improve responses to emergencies in the future.
As the Ministry of Education was seeking feedback on barriers and emerging issues identified during the COVID-19 Pandemic, the K-12 Standards Development Committee formed the Planning for Emergency and Safety Working Group with a focus on students with disabilities with the following mandate: Using experiential learning from the COVID-19 pandemic:
* Identify new and reoccurring accessibility barriers to learning for students with disabilities in the context of remote learning
* Develop an emergency plan framework (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency. Methodology
The Planning for Emergencies & Safety Working Group gathered resources from experts including the Framework for Reopening Schools developed by UNICEF, SickKids recommendations to Reopening Schools, Letters to Minister Lecce from the Ontario Human Rights Commission of July 14, 2020; and various other resources and articles from educational partners within Ontario, other provinces and countries (See Resource Section). While reviewing the documents, the Working Group identified barriers and subsequently developed recommendations to address said barriers. Organizational Challenges and Barriers during COVID-19
Through a review of resources, feedback from parents and guardians, agencies, health professionals and educational stakeholders opinions expressed, the Working Group found that students with disabilities have faced challenges compounded by COVID-19. Their needs have been inconsistently addressed or not at all. These are some organizational, policy and procedural barriers identified:
– Inconsistent or unclear messaging from varying levels of government, health agencies and school boards
– Lack of or unable to access consistent data from all regions and school boards to support data driven decisions and implement actions quickly and effectively.
– Policies and procedures outdated, non-existent, or inflexible to accommodate this type of emergency COVID-19 pandemic.
– Emergency response teams not reflecting the different subject knowledge needed to support decision making and development of a plan that reflects the needs of students with disabilities.
– Inter-governmental, health service, service agencies and school board service agreements did not reflect the ability to provide services in a virtual learning environment
– Service delivery models used by government, health services, service agencies and school boards not conducive to virtual service delivery.
– The extent to which Boards utilized or sought feedback from its SEACs in developing response or action plans to the COVID-19 pandemic varied from none to fully participated.
– Not all school boards have an Accessibility Standards Committee or for those school boards that do have members of the community or people with disabilities who have lived experience that can help plan and implement the Public Health Guidelines to mitigate risks of COVID-19 in schools for students with disabilities
– School board Accessibility Standards Committee can be helpful in helping to plan and implement the Public Health Guidelines to mitigate risks of COVID-19 in schools for students with disabilities. However, not all school boards have such committees, or committee membership that includes members of the community or people with disabilities who have lived experience that can inform planning and implementation. Key Recommendations for Planning for Emergencies
It is important in planning for return to school, the opportunity is taken to review and create structures, policy and procedures that can adapt and be more flexible for a 2nd wave or future emergencies.
By learning from innovations and emergency processes, systems can adapt and scale up the more effective solutions. In doing so, they could become more effective, more agile, and more resilient (quoted from THE COVID-19 PANDEMIC: SHOCKS TO EDUCATION AND POLICY RESPONSES, World Bank).
There are 5 known steps to Emergency Planning and Preparedness: 1) Know your risk, 2) Build your Team, 3) Make critical information accessible quickly, 4) Update alert and response procedure, 5) Test the plan and revise.
To eliminate barriers identified, that a return to school plan has input from end users, be designed through an inclusive process and not by one team or group. A team of subject expertise from across the organization is critical for developing a strong plan. Recommendations Government

For the above reasons, it is recommended that
1) The Ministry of Education should establish a Central Education Leadership Command Table with responsibilities for ensuring that students with disabilities have access to all accommodations and supports they require during the present COVID-19 pandemic. The responsibilities of the Command Table shall include:
a) immediately develop a comprehensive plan to meet the urgent learning needs of students with disabilities during COVID-19 pandemic quickly and resolve issues for students with disabilities as they arise. The comprehensive plan should be shared for implementation by school boards. This plan should include and incorporate the three options for education: * normal school day routine with enhanced public health protocols
* modified school day routine based on smaller class sizes, cohorting and alternative day or week delivery, and, * at-home learning with ongoing enhanced remote delivery
b) collect and share data on existing and emerging issues as a result of COVID-19, the effective responses of other jurisdictions in supporting students with disabilities during the current emergency, using evidence base data collection method for people with disabilities
c) establish a fully accessible centralized hub, and share and publicize the hub, for sharing of effective practices about supporting students with disabilities
d) develop a rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards
e) provide clear communication and guidance on school opening, health service delivery, etc. based on data collected.

2) The government/Ministry of Education shall establish a cross sectorial Partnership Table at provincial and regional levels with the responsibility to integrate, coordinate and foster cross sector planning and response to emergencies. Responsibilities of this table are to:
a) enhance an interlinked, coordinated and inter-ministerial approach in providing a seamless service delivery model to provide services and supports to students with disabilities (Psychology, Physical Therapy, Speech Therapy, Mental Health, etc.).
b) collect data now, from respective sectors, health services, education, service agencies, etc. to identify existing and emerging barriers, know exactly which students with disabilities and how they are impacted, their needs, and how to better direct resources to support them
c) provide clear communication and guidance on school opening, health service delivery, etc. based on data collected to ensure accessibility for students with disabilities.
3) The Ministry of Education provincial and regional partnership tables should include advisors that can provide insight on the needs and challenges of students with disabilities from lived experience and the collective experience of disability support groups, as well as students with disabilities.
4) The Ministry of Education should assign staff to assist the Central Educational Command Table by serving as a central rapid response team to receive feedback from school boards on recurring issues facing students with disabilities and to help find solutions to share with school boards.
5) The Ministry of Education should direct that each school board shall establish a similar Board Command table. (See recommendation 12 for School Boards).
6) The provincial government continue and enhance an interlinked, coordinated and inter-ministerial approach in providing a seamless service delivery model to provide services and supports to students with disabilities (Psychology, Physical Therapy, Speech Therapy, Mental Health, etc.).
7) The Ministry of Education should collect and aggregate International data, resources and information from other countries experiences for use in planning transitions between in-school and distance education, including continuation of virtual learning at home.
8) The Ministry of Education should developed comprehensive plans for students with disabilities that addresses the surge in demand and increase capacity to provide specialized disability supports, including enhanced staffing, for the return to in-class and distance learning (increase in in-class supports, social workers, psychologists, guidance counsellors)
9) The Ministry of Education should develop guidelines that provide for alternate or enhanced childcare opportunities to be made available to families of students with a disability, for students required to stay home due to adapted model classroom scheduling. (Excludes childcare needs that are related to quarantine self-isolation for child or family due to exposure or a local outbreak of the virus.)
10) To get the most from the volunteer work of SEACs around Ontario, the Ministry of Education should:
a) Create and maintain a listserv or other virtual network of all Ontario SEACs, to enable them to share their efforts with all other SEACs around Ontario, and
b) Frequently gather input from SEACs around Ontario about the experiences of students with disabilities during the COVID-19 crisis to inform future policies and regulations and directions for school boards.
11) To promote transparency, accountability and identify trends, the Ministry of Education should immediately issue a policy direction for boards to create an exclusion policy, that imposes restrictions on when and how a principal may exclude a student from school, including directions that:
a) Does not impede, create barrier, or disproportionally increase burdens for students with disabilities the right to attend school for the entire day as do students without disabilities. The power to refuse to admit a student to school for all or part of the school day should not be used in a way that disproportionately burdens students with disabilities or that creates a barrier to their right to attend school.
b) Tracks exclusions and provide a transparent procedure and practice to parents/guardians, by requiring a principal who refuses to admit a student to school during the school re-opening process to immediately give the student and their parent/guardian written notice of their decision to do so, including written reasons for the refusal to admit, the duration of the refusal to admit and notice of the parent/guardians right to appeal this refusal to admit to the school board.
c) Tracks exclusions, increases accountability and informs policies by requiring a principal who refuses to admit a student to school for all or part of the school day to immediately report this in writing to their school boards senior management, including the reasons for the exclusion, its duration and whether the student has a disability. Each school board should be required to compile this information and to report it on a regular basis to the board of trustees, the public and the Ministry of Education (with individual information totally anonymized).
12) The Ministry of Education should provide clear guidelines and expectations to school boards on the implementation of Public Health Guidelines to mitigate risks of COVID-19 to ensure that school buildings and grounds be fully accessible for students with disabilities. Recommendations School Boards

13) School Boards should establish a similar Board Command/Central table as the Ministry of Educations Central Education Command/Central Table, to receive and act on feedback from teachers, principals and families about problems they are encountering serving students with disabilities during the COVID-19 period. The Table will quickly network with similar offices/Tables at other school boards and can report recurring issues to the Ministrys command table.
14) School Boards should utilize the expertise of the Special Education Advisory Committee members by directly involving members in the planning for the delivery of remote learning, other emergency plans, through regular meetings and frequent communications.
15) School Boards should enhance its hub of resources with successful practices, lesson plans, resources specific to students with disabilities in a virtual learning environment for ease of access and support teachers and students in their learning.
16) School Boards should involve their Accessibility Committee, or if there is no committee to establish an Accessibility Advisory Committee which will review all plans at the school board and school level for mitigating risk of COVID-19 meet the accessibility requirements of all students or people with disabilities.
17) School Boards should assign a leadership staff member responsible for ensuring that all changes at schools in response to COVID-19 maintain accessibility for all students with disabilities. Mental Health & Well Being
As found through the review of resources, student and family mental health & wellbeing needs have soared to due to the traumatic effects of COVID-19. Students wellbeing has suffered for a variety of barriers: effects of isolation from social distancing, increased rise in domestic violence, lack of access to school breakfast programs, lack of access to mental health & therapeutic services, and negative financial impact to familys income to name a few. Barriers

* Agencies, different levels of government and school boards developing plans and working on solutions to barriers with little or no coordination * Support for parents with students with complex needs are insufficient
* Health services and supports not consistently or sufficiently prepared to provide health and mental health services in a virtual setting
* There is a flood of information and resources being presented to teachers, parents and students
* More inter-ministerial leadership and collaboration between Ministries of Education (MOE), Community, Children & Social Services (MCCSS) and Health (MOH) is required
* School Boards and staff must be equipped with appropriate PPE for their own health and wellbeing
* Need to safely deliver additional supports such and as breakfast & nutrition programs provided by community agencies
* Plans for the next phase include a return to in-class and virtual instruction, including adapted models whereby some students will be scheduled at home on an alternate day or alternate week basis. Having students at home for short or long periods (alternate day to full semester) will be a significant challenge for families and may prevent the return to work for many parents. Some parents of children with disabilities face barriers to employment, and many others are overburdened with providing 24-hour care to students with complex care needs.

Recommendations Government

18) The government should enhance the central hub of mental health & wellbeing information resources at provincial and regional levels with key messages and links to other resources. Ensure all resources are in an accessible digital format (as per Integrated Accessibility Standards Regulation), well publicised and shared with school boards.
19) Ministries should review and increase capacity of Ontario Telehealth Network (OTN) and other privacy protected health platforms to allow for boards to use (even in non-emergency times) and deliver services by regulated health care professionals that protect the privacy of the health services and IPRCs.
20) Ministries of Education, Health and Children, Community & Social Services should remove any cross-jurisdictional barriers related to the provision of health and education services to ensure students with disabilities can be provided with the mental health & wellbeing services they require to be delivered remotely. (For example, under Policy/Program Memorandum (PPM) 149, Protocol for Partnerships with External Agencies for Provision of Services by Regulated Health Professionals, Regulated Social Service Professionals, and Paraprofessionals permit electric consent for services and virtual access to services for students with disabilities).
21) The Ministry of Education should provide funding and clear guidelines on use of Personal Protective Equipment (PPE) and protocols for detection and containment of COVID-19 for boards, staff and all students, including those with disabilities. Public health authorities should establish clear protocols for the detection and containment of COVID-19 (and other infectious diseases) for school boards. The guidelines and protocols should be flexible for school boards to react to local situations to mitigate risks.
22) The Ministry of Educations plan for school re-openings must include detailed directions on required measures to mitigate risk for students with disabilities from COVID-19 to maintain their health and wellbeing during any return to school. This requires additional planning in advance by school boards and additional funding to school boards to hire and train the additional Special Needs Assistants (SNA) and Educational Assistants (EA) they will need to ensure the safety of students with disabilities. It also requires safeguards to ensure that EAs or SNAs do not work at multiple sites and risk transmitting the COVID-19 virus from one location to another.
23) Ministries should review policies and regulations to continue to permit the virtual provision of therapy supports and services that have transitioned successfully to a virtual learning environment and where possible, permit and foster increased access to therapies and services to areas in province where a lack of services exists. Recommendations School Boards

24) Many students with disabilities volunteer at school events, in school daycares, kindergarten classes as part of their learning plan, IEP or fulfilling the 40 hours volunteer requirement. School Boards should develop/review guidelines for students with disabilities who volunteer in school to limits risk to health and safety but does not stop this valuable learning experience for students with disabilities.
25) Many adults with disabilities volunteer in schools and school daycares for the opportunity to exist as a valued contributing member within their community. School Boards should develop guidelines for people with disabilities who volunteer within the school that limits risk to the health and safety but continues to have the opportunity to be a contributing member of the school community.
26) School Board should provide virtual learning opportunities for volunteering and co-op courses for students with disabilities. Resources and guidelines should be developed to create the opportunity for the student to complete volunteering hours or cooperative credits successfully.
27) School Boards should develop and/or review guidelines for transitions plans for students with disabilities to outline supports and accommodations that may be offered in a virtual learning environment or enhanced by online tools and resources to support the physical and emotions wellbeing of student with disabilities when transitioning back to school. Accommodations or strategies should be reviewed and adapted to the virtual learning environment to support transitions. (An example would be for students with disabilities have access to audio described (DV) and closed-captioned (CC) virtual tours of the school facilities, so students could familiarize themselves with the school prior to the start of school. (See also Transition section).
28) In consultation with community agencies, School Boards should develop/revise procedures and protocols for volunteers and community agencies that support the health and wellbeing of students with disabilities continue to operate in the school (Example, Food nutrition programs, clothing exchanges, etc.)
29) In consultation with Public Health Regional Health, School Boards must develop clear protocols and procedures with accommodations for students with disabilities for the detection, isolation, tracing and follow up those students who develop symptoms for the virus, flu, respiratory infection, etc. For example: Ensure dedicated space to isolate students with disabilities who may need to return home is accessible and provides the accommodations required to meets the needs of any students with disabilities. Academic
The pandemic has had profound impacts to students learning and staffs ability to provide a learning environment that promotes student success and achievement. Learning inequities for students with disabilities have increased throughout the pandemic due to barriers faced. Some of the barriers identified were: Barriers

* Ongoing accessibility issues with online and virtual learning resources provided for learning at home
* Wealth of resources, tools, etc. being developed by Boards, Agencies and Associations with limited sharing of resources. Resources developed may not be accessible. * Virtual learning is not working for many students with disabilities
* Many students with disabilities were not effectively engaged in virtual learning for a variety of reasons, including accessibility challenges with the internet, computer software and hardware, nature of resources provided, individual challenges related to format, capacity of family, or behaviour.
* Closure of schools for 3 months has resulted in significant loss of learning for many students
* Special Education Advisory Committees meetings have been cancelled and some the skills and knowledge of SEAC members has not been fully utilized.
* Teachers, students and parents were not prepared for the sudden transition from in-class instruction to the virtual learning environment and planning for future interruptions of schools would benefit from proactive planning for education in a virtual instruction and learning environment. Recommendations Government

30) The Ministry of Education should develop curriculum for students from Kindergarten to Grade 12 to enable students to develop the skills and knowledge they need for learning in a virtual learning environment. In the interim, the Ministry should share existing, accessible resources on this topic to teachers and School Boards (Please see Training for additional recommendations)
31) The Ministry of Education should collect and make readily available resources/information on practices, effective strategies in learning environment, and alternate approaches for students struggling with online learning, etc. from School Boards, agencies and disability specific associations.
32) Ministry of Education should provide clear expectations for teacher led instruction, synchronous learning, and weekly teacher student-teacher connections for students who are participating in virtual instruction and learning. Expectations should include monitoring if students with disabilities are fully participating, learning and benefiting from these activities; and if not, action to address barriers or issues identified.

Recommendations School Board

33) School Boards should assess and document accommodations, modifications, resources and supports for all students with disabilities to plan for transition back to school and continuation of virtual instruction and learning. (Please see Transitions Recommendations for details)
34) School Boards should develop and provide all resources for instruction and assessment materials, homework assignments in an accessible digital format (See Communications & Technology section for recommendation on accessible digital format). Secondary School
The secondary school experience is different from elementary school. It is where students develop, time management, organizational, advocacy skills, networking and social skills, become more aware of community and identify career paths. It is for this reason, the Working Group felt it was important to identify barriers and make recommendations specific to secondary students. Many of these recommendations can benefit the entire secondary school student population. Barriers
* Students with disabilities have experienced little to no personal contact with their school community social network supports (classroom teachers, Educational Assistants, custodians, administrative assistants, etc.), who rely on this contact to maintain their engagement within the school community and preserve their mental health.
* At any time, students with disabilities have very limited opportunity to fulfill the 40 hours of volunteering required for graduation and rely heavily on volunteering at their high school or local elementary school events. All opportunities for volunteering were eliminated during the pandemic.
* Many students with disabilities take optional specialized courses such as Specialized High School Major (SHSM), cooperative credits, etc. which provide hands on and participation within the community. Hands on learning, skills in applicable to trades and life skills were significantly diminished during COVID-19.
* Clubs, councils, sports teams and extracurricular activities are a formative and important part of the high school experience. Often these extracurricular activities are the only opportunity students with disabilities has to socialize with their peers. Not having access to extracurricular activities has impacted their mental health and well-being.
* Many students with disabilities rely on in class instruction be it due to learning disability, anxiety, learning style, ADHD, or simply due to preference in the way they individually learn, among others. The loss of in-class instruction has significantly impacted their learning and future for success.
* Learning at home during school closure has been challenging for students in terms of academic achievement, mental health and wellbeing
* All four years of high school are an integral part of a young persons development and a multitude of students require and rely on in class instruction be it for specialized courses That require specialized equipment, trained staff;
* The experience of four years of high school are incredibly formative of a young persons social, emotional, mental and physical relationship with society, the world around them and indeed the values they will build their life around;
* Return to school planning must consider the impacts on minority & racialized students, students in abusive households, students with limited access to technology or broadband, students with disabilities and students with other complex learning needs;
* Many students rely on in class instruction be it due to learning disability, anxiety, learning style, ADHD, or simply due to preference in the way they individually learn, among others; Recommendations Ministry

35) The Ministry of Education should allow high school in-class instruction to operate for the 2020-2021 school year, if authorized by Ontarios Chief Medical Officer of Health.
36) The Minister should direct School Boards to continue courses which require specialized forms of equipment, classrooms, teaching staff and/or resources (science labs, shops, media classrooms) continue to operate, in accordance with local public health advice.
37) As per the Canadian Mental Health Association, 70% of mental health challenges have their onset in childhood or youth and the Kids Help Phone Line has seen a increase in demand, The Ministries of Education and Health should increase capacity of mental health professionals and supports for School Boards, to ensure there is no waitlist for any secondary student requiring support.
38) The Ministry of Education should include student voice through student trustees association or other student leaders, when developing a plan for return to school.
39) The Ministry of Education should waive the compulsory credit in Health & Physical Education for students who have entered secondary school in the 2020-21 school or whose timetable will be negatively impacted, should Physical Education classes not operate in the conventional manner.
40) If required by Public Health, the Ministry of Education should fund PPE for students and staff to mitigate risks of infection.
41) The Ministry should direct School Boards to develop a prioritization and execution plan for conducting clinical assessments (e.g., psycho–educational assessments) that students with disabilities require in order to access necessary supports and services as they transition from secondary to post-secondary destinations. Recommendations School Board

42) School Boards and Schools should include student voice, including students with disabilities in developing the Board return to school plan, as well as, individual school return plans respectively.
43) School Boards and Schools should provide clear instruction on proper personal protection equipment (PPE) and safety measures to students, parents, and staff.
44) School Boards should follow or mirror Public Health protocols prescribed by the local Public Health. If PPE is not required by the local Public Health, student have the choice to wear PPE. If PPE is required, that school boards are funded appropriately to provide PPE for all students and staff.
45) Where local public health advice can be adhered to, Schools should continue to offer extracurricular activities such as clubs, councils, teams using proper social distancing and general safety protocols.
46) Where applicable, School Boards should waive parking fees for students to reduce financial burdens and help mitigate health risks for students by not riding on a crowded public transit bus.
47) School Boards should make decisions pertaining to cancellation of extracurricular activities in school mirror that of activities outside of school. (Example: If soccer clubs operate locally, then soccer clubs in schools should continue to operate).
48) School Boards should develop and offer online programming for students who cannot or wish not to attend school in person, but not be considered a long-term alternative to in class instruction.
49) School Boards and schools seek out the voice of students, including voices of students with disabilities, when they develop return to school plan options.
50) School Board should develop guidelines for clubs or programs that supplement or enhance education for students with disabilities so they can continue to operate upon return to school.
51) School Boards should continue to offer where possible, alternate classrooms, quiet workspaces, and other special education requirements prescribed in a students Individual Education Plan (IEP).
52) School Boards should research and investigate potential online coop placements that may be available for all students; including students with disabilities.
53) When permitted under local health advice, the School Board should review new health and safety protocols with student and the coop placement provider. Transitions
An impact of the pandemic for students with disabilities is that learning has been lost or stagnant. Learning recovery will be important when returning to school. This will mean targeted measures to reversing learning loss or closing gaps. There will be a need for clear system wide guidance for in-class and central assessments to inform and plan for curriculum delivery, supports and service upon return to school.
Transition planning will occur at the provincial, local and student level. The Ministry of Education will need to identify barriers and gaps from all educational stakeholders to develop an informed return to school plan. School boards will need identify barriers and gaps at a system and individual student level to create an informed back to school plan as well as address the needs for students with disabilities.
The Individual Education Plan (IEP) is a tool for documenting student strengths and needs and the accommodations, programs and services they require to be successful. IEPs are a valuable tool in documenting the students current level of achievement and transition plans for planned changes in grades, schools, and life after secondary school. The IEP can also be used to plan for return to school, full time or in an adapted model, or for continued virtual learning. Barriers
* During the school closure gaps in student skills and knowledge related to on-line and distance learning has been evident
* Planning for school year 2020-2021 will include in school and distance learning
* School staff will need to assess students with disabilities to determine their accessibility and learning needs
* Students with disabilities individual IEPs and transitions plans need to be reviewed to address barriers and gaps to allow for student success. * Student voice often forgotten in the planning process
* Students and prospective students cannot visit the physical environments of schools during the COVID-19 pandemic and do not have the opportunity to check for physical accessibility and familiarize themselves with environment Recommendations Government

54) The Ministry of Education should direct School Boards to develop a prioritization and execution plan for conducting clinical assessments (e.g., psycho–educational assessments) that students with disabilities require, in order to access necessary supports and services as they transition from secondary to post-secondary destinations.
55) The Ministry of Education, in partnership with MCCSS should work with school boards to identify their cohorts of students with intellectual and other disabilities who completed their school careers in June 2020 and identify and assess if barriers faced during COVID-19 did not allow for successful student transitions to their chosen pathway (Examples: to work, volunteer work, recreation/leisure programs, and post-secondary education) as outlined in their transition plans. Jointly, the Ministries and School Boards should develop plans to help this cohort of students with disabilities achieve their individual transition goals. Recommendations School Boards

56) School Boards should be independently collecting board wide data on gaps, barriers, emerging issues, transition challenges, technology challenges, additional students needs and supports arising or as a result of COVID-19 through assessment, student and parent feedback to address and plan for system wide supports and services required by students with disabilities upon return to school.
57) To help with successful transitions for student with disabilities in returning to school, School Boards shall contact parent/guardians, as soon as possible, to discuss and identify learning gaps, individual needs arising from school shutdown and distance learning, transition challenges, social and emotional needs to inform and revise/or create individualized transition plans for students with disabilities.
58) To help reduce stress and anxiety and prepare themselves for return to school, students with disabilities should be involved with discussions and decision made in developing their Transition Plan.
59) School Boards and Administrators shall ensure Individual Education Plans for students with disabilities are revised/created to reflect specific goals and activities to address the individual needs identified in Recommendation #3 to help increase academic and transition success for each student with a disability upon returning to school.
60) School Boards shall include the student when developing their individualized Transition and IEP. All
61) When School Boards develop the Individualized Transition Plans for each student, it should be:
a) flexible to accommodate the stop and start of in class learning. All methods of instruction should be considered for learning to ensure students have access to an education (virtual instruction, in home instruction, etc.)
b) include a flexible and hybrid model for entry needs to accommodate the varying student needs. Any model developed for return to school shall be developed in consultation with parent/guardians and student
c) include strategies for students around social/physical distancing. Social distancing guidelines should be developed in consultation with parents/guardians and student. d) Include steps for follow up and checking in with the student
e) All documentation or information be provided to the parent/guardian and student before the meeting with enough time to review. Documents should be provided in an accessible format.
62) School Boards should take more interactive approaches to collect on-going feedback from parents, students and staff (i.e. Thought exchange) to guide and inform changes to policies and procedures impacted by COVID-19.
63) School Boards should develop a clear system wide plan to address increased classroom and school supports and services (Educational Assistants, Education Works, social workers, psychologists, guidance councillors) identified through assessments to help mitigate issues and support learning for students with disabilities.
64) School Boards should create audio described (DV) and closed-captioned (CC) virtual tours of their school. The virtual tour must be fully accessible and thoroughly provide information on accessibility and locations at the schools. Virtual tours should be made permanently available; not just during the pandemic. Communications & Technology
For our purpose, communication includes technologies, systems, protocols and procedures that enable an organization to effectively communicate to its employees, partners and community. During an emergency, communication is essential and should ensure all relevant personnel can quickly and effectively communicate with each other during such crises, sharing information that will allow the organization to quickly rectify the situation, protect employees and assets, and allows the business to continue.
To relate this to Education government, school boards, agencies, staff, students, parent/caregivers, should have the ability to communicate effectively during a crisis, while the business of providing learning continues. Barriers
* Ongoing accessibility issues with virtual learning environment or platform (Examples: no closed captions, compatibility issues with screen readers, lack of support or knowledge of accessibility features, no ASL interpretation) * Ongoing accessibility issue with information and resources provided
* Conflicting guidelines provided by different ministries and level of government. Recommendations Government

65) That a designated communication lead should be assigned at the provincial and regional level for consistent messaging.
66) For efficiency and elimination of duplication of effort for School Boards, The Ministry of Education should immediately engage an arms-length digital accessibility consultant to evaluate the comparative accessibility of different digital learning and virtual learning environments or platforms available for use in Ontario schools. This should involve end-user testing. The Ministry should immediately send the resulting report and comparison to all school boards and make it public. This should be revisited as the fall approaches, in case there have been changes to the relative accessibility of different virtual instruction environments or platforms.
67) The Ministry of Education should provide a list of acceptable accessible, cross platform virtual learning environments and synchronous teaching systems to be used by school boards.
68) The Ministry of Education should make public a plan of action to swiftly make its own online learning content accessible for people with disabilities, setting out milestones and timelines, and should report to the public on its progress.
69) The Ministry of Education should immediately direct TVO/TFO to make its online learning content accessible to people with disabilities, and to promptly make public a plan of action to achieve this goal, with specific milestones and timelines. The implementation of this recommendation has become urgent since Royal Assent was given to Bill 197, COVID-19 Economic Recovery Act, 2020 as amends to the Ontario Educational Communications Authority Act broaden the mandates of both TVO and TFO to position them to provide centralized support for online learning in the English-language and French-language publicly-funded education systems, respectively.
70) The Ministry of Education should direct its entire staff and all School Boards that whenever making information public in a Portable Document Format (PDF), it must at the same time, make available a textual format such as an accessible Microsoft Word (MSWord) or accessible HTML document. Videos must be audio described (DV) and closed captioned (CC). Templates and technical guides should be developed and provided to school boards. Recommendations School Boards

71) For consistent messaging, that the School board should designate a communication lead for COVID-19 related issues.
72) School Boards should develop protocols and procedures to mitigate security risks for online and virtual learning platforms to help protect privacy of students with disabilities and staff. Online and virtual learning platforms should also be accessible for all students with disabilities.
73) That School Boards should provide clear communication around protocols and return to school plans. Boards should make written communications readily available and accessible by everyone in the community, parents and students.
74) School Boards should review and revise instructional videos for parents around virtual learning tools used in the school board. Videos must be clear and accessible.
75) School Boards should provide solely dedicated or designated staff, who are available to support technology including accessibility needs to parents who are supporting the learning needs of students with disabilities at home. Training
The COVID-19 Pandemic has changed the way in which education is delivered. Students, parents/guardians, teachers, staff, school boards and government had to change the way they access, support or deliver education. The pandemic highlighted gaps in digital skills, adaptation of technology to teaching and learning. It has also increased demand for technology and the need to integrate technology effectively into teaching and learning. With this increased demand in the use of technology and the gaps in digital skills identified, it is imperative to train students, parent/guardians and staff in the use and integration of technology in teaching and learning. Barriers
* Teachers, students and parent/guardians unprepared for learning at home and use of virtual platforms such as google classroom, Microsoft teams, Zoom for individual and synchronous learning * Teachers, ECEs, Staff need training in virtual online learning platforms
* Teachers, ECEs, Staff need training in strategies to support students with disabilities around transitions between education models, including preparation for changing environments and self regulation
* Teachers, ECEs lack training in strategies to support Public Health directed precautions, such as social distancing, sanitizing procedures and use of PPE when required to support students
* School closures have had a significant impact on the mental health and well being of students with disabilities and teachers, ECEs, staff will require training on child development and trauma informed practice to assist them in supporting students in transitioning back to school or continuation of virtual education.
* The expectation on parent/guardians to support students with learning at home were significant and parents need supports and training in virtual learning software and how they can effectively support their childs learning. Recommendations Government

76) That Ministry of Education should model leadership to School Boards and provide accessible virtual learning webinars, templates for learning, etc. to be utilized in training administrators and teachers.
77) The Ministry of Education should direct School Boards to provide all staff training in child development, mental health and wellbeing to support the wellbeing and learning of students with disabilities.
78) The Government should provide direction to School Boards and Public Service agencies to develop a coordinated training delivery model to support parents of students with rehabilitation needs, mental health concerns or who have complex or significant medically needs, with the delivery of virtual care, including privacy protected health platforms such as OTN, ADcare. Recommendations School Boards

79) School Boards should provide focused, practical training for administrators and teachers to support students with disabilities health, wellbeing and learning in a mixed or virtual environment.
80) School Boards should provide administrators training and guidelines on supporting students with disabilities through transitioning and change.
81) School Boards should develop parent training modules and resources to enable parent/guardians to develop the skills and knowledge required to support online and virtual learning at home for students with disabilities.
82) School Boards should provide training for teachers and staff on specific tips and solutions, successful and evidence based promising practices by disability to support teachers and students with disabilities learning. These should be made available as soon as possible or at the latest, during the first days of PD before school instruction begins.

Transportation
School Bus operation and delivery of bus services is regulated and governed both federally and provincially. Transport Canada has consulted with the Public Health Agency of Canada to provide guidelines around bus operations during the pandemic. The National Association for Pupil Transportation (NAPT) has also provided general guidelines for the provision of student (pupil) transportation services.
The Ministry of Educations Return to School Framework directs School Boards to follow these federal guidelines.
To accommodate Federal Transportation and Public health guideline that require social and physical distancing, School Boards will have to revise transportation services delivery that will impact bus routes, increase the number of buses and drivers required, increase ridership time, etc. to mitigate risks to students with disabilities while transporting to and from school. Barriers

Lack of or reduced public transportation available for students with disabilities, particularly for secondary students who take public transit. Municipal governments eliminated routes or reduced schedules during COVID-19. Municipalities have not made public transportation plans for when students return to school.
As School Boards and Consortiums plan transportation services to meet the Transport Canada guidelines, current challenges of inadequate buses, shortage of drivers and increasing fuel costs will be a barrier to boards.
Changes to routine can have a significant impact to a student with disabilities mental health, success for the start of school day and learning. Predictable changes to transportation for students with disabilities can include, increased ridership time, bus route, bus type (72-passenger, small bus), supports or accommodations required for a successful ride, etc. while maintaining safety and mitigating risks for infection.
Many School Boards currently overspend the transportation grant, while still achieving a high efficiency rating from the Ministry of Education. The additional requirements defined under the Transport Canada Guidelines will increase cost pressures to provide transportation services to students with disabilities while maintaining safety and mitigating risk of infection.
As students with disabilities require may require specific transportation accommodations such as a safety harness, seat belt, wheelchair accessible which cannot be accommodated in all vehicle types.

Recommendations School Boards

83) As many School Boards overspend its transportation grant while maintaining a high efficiency rating, the Ministry of Education should provide school boards with additional COVID-19 specific funding to follow the guidelines as provided by Transport Canada around: o Measures to mitigate risk of exposure
o Procedures to be taken before a trip, during a trip and at the end of the trip o PPE guidelines
o Physical Distancing
o Shield and Enclosure system guidelines (if bus operators choose to do so)
84) School Boards should review transportation accommodations and requirements, in consultation with parents and student, IEPs of students with disabilities who require transportation services to identify any change/modifications to accommodations required. The students IEP shall be modified to reflect additional requirements to transport the student safely on the bus. The review for medically fragile students should include professionals, such as nurses, occupational therapists, as well as parents. All transportation requirements shall be relayed to the Bus Consortia and administrator of the school for implementation.
85) School Boards must create/revise a protocol for the safe gathering of all students and parent/guardians at bus stops and safety on the bus. It is important that student with disabilities be included and familiarized with these protocols with their peers.
86) School Boards and Bus Consortia should provide bus drivers with training on new health and safety protocols for students with disabilities on a regular bus, small bus and wheelchair accessible bus.
87) Bus Consortia should minimize changes to routes, vehicle type, and schedules for students with disabilities while developing changes to routes, to limit increased anxiety or behaviours as a result of the changes. When changes are considered, parents and student should be consulted about changes.
88) School Boards and Bus Consortia should review procedures and protocols for persons responsible for putting a student with disabilitys harness on/off or supporting a student on the school bus to mitigate health risks for the student, bus driver and support person.
89) School Boards and Bus Consortia should revise/develop, implement and disseminate bus safety protocol Information for parents needs to help mitigate health and safety risks and assuage parents fears. This includes protocols around harnesses. All communications should be clear and made readily available on the Board and Bus Consortia website in an accessible digital format.
90) Students with disabilities should be included in any training that is provide for all students on enhanced safety rules on the bus.
91) As students with disabilities are statistically proven to be at a higher risk of infection, School Boards and Bus Consortia should implement enhanced student bus ridership attendance procedures to aid in tracing of COVID-19 and mitigating health risks.
92) Traffic volume, student and road safety is always a concern around schools. It is expected for vehicle traffic to increase when school returns, as parent/caregiver or a secondary student chooses to drive to school. School Boards should work collaboratively with Municipalities to develop safe arrival and departure awareness campaigns for students, parents/caregivers and buses. These campaigns could include guidelines for kiss & ride, audio described (DV) and closed captioned (CC) virtual or diagrams of vehicle traffic flows for entering and exiting school property from the street, identifying school bus only access areas, promote other methods of transportation, etc.

Conclusion
The Planning for Emergencies are please to provide its draft recommendations related to the COVID-19 pandemic. The Working Group will continue to review resources and information on barriers and issues arising from COVID-19 and as students return to school. It will start work on its mandate to develop an emergency plan framework focused on students with disabilities (that covers the phases of preparing, planning, response and recovery) for a systematic response to an emergency.
Thank you to all the members of the Planning for Emergencies Working Group for their dedication in developing this draft set of recommendations. Working Group members are: * Donna Edwards (Chair Working Group)
* Stephan Andrews
* David Lepofsky
* Dr. Ashleigh Malloy
* Alison Morse
* Rana Nasrazadani
* Ben Smith
* Angelo Tocco
* Dr. Lindy Zaretsky
* Lynn Ziraldo (Chair K-12 SDC)

Glossary
Accessibility: a general term for the degree of ease that something (e.g., device, service, physical environment and information) can be accessed, used and enjoyedby persons with disabilities. The term implies conscious planning, design and/or effortto make sure something is barrier-free to persons with disabilities. Accessibility also benefits the general population, by making things more usable and practical for everyone, including older people and families with small children.
Accessible: does not have obstacles for people with disabilities something that can be easily reached or obtained; facility that can be easily entered; information that is easy to access.
Accessible digital format: Information that is provided in digital form that is accessible such as HTML and MS Word.
Synchronous learning: is the kind of learning that happens in real time. This means that you, your classmates, and your instructor interact in a specific virtual place, through a specific online medium, at a specific time. In other words, its not exactly anywhere, anyhow, anytime. Methods of synchronous online learning include video conferencing, teleconferencing, live chatting, and live-streaming lectures.

Asynchronous learning: happens on your schedule. While your course of study, instructor or degree program will provide materials for reading, lectures for viewing, assignments for completing, and exams for evaluation, you have the ability to access and satisfy these requirements within a flexible time frame. Methods of asynchronous online learning include self-guided lesson modules, streaming video content, virtual libraries, posted lecture notes, and exchanges across discussion boards or social media platforms.

Distance Education Program: Programs to provide courses of study online, through correspondence, or by other means that do not require the physical attendance by the student at a school. (From Bill 197)
Special Education Services – As defined in the Education Act, facilities and resources, including support personnel and equipment, necessary for developing and implementing a special education program.
Virtual learning: is defined as learning that can functionally and effectively occur in the absence of traditional classroom environments (Simonson & Schlosser, 2006).

Virtual education: refers to instruction in a learning environment where teacher and student are separated by time or space, or both, and the teacher provides course content through course management applications, multimedia resources, the Internet, videoconferencing, etc. Students receive the content and communicate with the teacher via the same technologies.

Virtual learning environment: refers to a system that offers educators digitally-based solutions aimed at creating interactive, active learning environments. VLEs can help educators create, store and disseminate content, plan courses and lessons and foster communication between student and educator. Virtual learning environments are often part of an education institutions wider learning management system (LMS).

Virtual instruction: is a method of teaching that is taught either entirely online or when elements of face-to-face courses are taught online through learning management systems and other educational tools and platforms. Virtual instruction also includes digitally transmitting course materials to student. Resources
Mental Health
? School Mental Health https://smho-smso.ca/ – a variety of resources for students, parents, educators
? Mental Health and Teachers https://www.tes.com/news/will-fear-coronavirus-affect-your-teaching?utm_campaign=73103_20200608%20Editorial%20Daily%20Register&utm_medium=email&utm_source=Dot_Digital&utm_content=73103_20200608%20Editorial%20Daily%20Register&dm_i=5NNY,1KEN,M10WD,5U5E,1 ? People for Education Educational reading in a Pandemic – https://peopleforeducation.ca/our-work/education-reading-in-a-pandemic/

Public Health Guidance and Safety

? Alberta Public Health guidance for schools –
https://www.alberta.ca/release.cfm?xID=72576418BE34F-D428-6986-0F85E17B91BA2A40#toc-0
? Centre for Disease Control – Case Investigation and Contact Tracing : Part of a Multipronged Approach to Fight the COVID-19 Pandemic –https://www.cdc.gov/coronavirus/2019-ncov/php/principles-contact-tracing.html
? Canada Public Health -Updated: Public health management of cases and contacts associated with coronavirus disease 2019 (COVID-19) = https://www.canada.ca/en/public-health/services/diseases/2019-novel-coronavirus-infection/health-professionals/interim-guidance-cases-contacts.html#co ? UNICEF- a framework to reopening schools –
https://www.unicef.org/documents/framework-reopening-schools ? Government of Canada resources for parents –
https://www.canada.ca/en/public-health/services/diseases/coronavirus-disease-covid-19/resources-parents-children.html ? SickKids Recommendations for School Reopenings –
https://www.sickkids.ca/PDFs/About-SickKids/81407-COVID19-Recommendations-for-School-Reopening-SickKids.pdf ? Federal Guidance for School Bus Operations during the COVID-19 Pandemic –
https://www2.tc.gc.ca/en/services/road/federal-guidance-school-bus-operations-during-covid-19-pandemic.html).
? National Association for Pupil Transportation (NAPT) Guidelines – https://www.napt.org/covid ? Considerations for Wearing Cloth Face Coverings, Centre for Disease Control –
https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/cloth-face-cover-guidance.html#feasibility-adaptations

Tools/Best Practices

? York Catholic District School Board https://sites.google.com/ycdsb.ca/ycdsb-ssd-distance-learning/home – learning from home resource
? Durham District School Board https://www.ddsb.ca/en/programs-and-learning/distance-learning.aspx distance learning resources
? Durham District School Board https://www.ddsb.ca/en/programs-and-learning/resources/Documents/Distance-Learning/IEPs-Documenting-Accommodation-and-Programming-During-Distance-Learning-05-2020.pdf IEPs documenting accommodations and programing during distance learning ? Durham District School Board –
https://www.ddsb.ca/en/programs-and-learning/resources/Documents/Distance-Learning/Distance-Learning–Identification-Placement-and-Review-Committee-IPRC-Process.pdf IPRC process during distance learning ? Thames Valley District School Board –
https://www.tvdsb.ca/en/our-board/learning-at-a-distance.aspx distance learning resources and more ? Ottawa-Carleton District School Board –
https://ocdsb.ca/cms/one.aspx?portalId=55478&pageId=32163119 learning at home resources
? York Region District School Board has a variety of learning resources, resources for parents etc. –
http://www.yrdsb.ca/schools/Repository/NewsEvents/Pages/BoardNews/Coronavirus.aspx
? Toronto District School Board https://sites.google.com/tcdsb.ca/tcdsb-parents-at/home – a guide to assistive technology for parents
? University of Toronto Accessibility formats and communication supports http://aoda.hrandequity.utoronto.ca/communications/ ? Best Practices for Collecting Data on Disabilities, Education Links – https://www.edu-links.org/learning/best-practices-collecting-data-disabilities
? Accessibility for Ontario Disabilities Act, Integrated Guide, Section 12: Accessible Formats and Communication Supports –
https://www.aoda.ca/a-guide-to-the-integrated-accessibility-standards-regulation/#sect12 ? Ontario Human Rights Code Policies and Guidelines on Duty to Accommodate –
http://www3.ohrc.on.ca/sites/default/files/policy%20and%20guidelines%20on%20disability%20and%20the%20duty%20to%20accommodate.pdf
? Preparing K-12 School Administrators for a Safe Return to School in Fall 2020, Centre for Disease Control –
https://www.cdc.gov/coronavirus/2019-ncov/community/schools-childcare/prepare-safe-return.html

Stakeholder Reports and Information

? OHRC Letter to the Minister of Education about convening a return-to-school partnership table –
http://www.ohrc.on.ca/en/news_centre/letter-minister-education-about-convening-return-school-partnership-table
? OHC Letter to the Minister of Education, school leaders on respecting the rights of students with disabilities –
http://www.ohrc.on.ca/en/news_centre/letter-minister-education-school-leaders-respecting-rights-students-disabilities
? OHRC Letter to Ministers re: accessible education for students with disabilities –
http://www.ohrc.on.ca/en/letter-ministers-re-accessible-education-students-disabilities
? Report of The Third Review Of The Accessibility For Ontarians With Disabilities Act, 2005 By The Honourable David C. Onley – https://files.ontario.ca/seniors-accessibility-third-review-of-aoda-en-2019.pdf
? AFT, American Federation of Teachers https://www.aft.org/sites/default/files/guide_reopen-america-schools.pdf – a guide to safely open schools
? AODA Alliance Final Brief to Ontario Government on Urgent needs of K-12 Students with Disabilities during COVID-19 Crisis –
https://www.aodaalliance.org/whats-new/download-in-ms-word-format-the-aoda-alliances-june-18-2020-finalized-brief-to-the-ontario-government-on-what-needs-to-be-done-to-meet-the-needs-of-students-with-disabilities-during-the-trans/
? AODA Alliance – New Report Reveals that Majority of Ontarios School Boards, Each School Principal can Exclude a Student From School Real Risk of a Rash of Exclusion of Some Students with Disabilities When Schools Re-Open –
https://www.aodaalliance.org/whats-new/new-report-reveals-that-at-majority-of-ontarios-school-boards-each-school-principal-is-a-law-unto-themselves-with-arbitrary-power-to-exclude-a-student-from-school-real-risk-of-a-rash-of-exclusio/
? Wisconsin DPI releases guidelines for reopening schools this fall: Proactive approach –
https://fox6now.com/2020/06/22/wisconsin-department-of-public-instruction-releases-guidelines-for-reopening-schools-this-fall/
? ASCD http://www.ascd.org/publications/newsletters/education-update/may20/vol62/num05/7-Ways-Educators-Can-Help-Students-Cope-in-a-Pandemic.aspx
? Easter Seals https://education.easterseals.org/supporting-learning-at-home-through-the-covid-19-crisis/ – online learning resources ? [email protected] resources for parents – https://www.ldathome.ca/
? [email protected] resources for teachers – https://www.ldatschool.ca/ ? People for Education Effective e-learning need structures and supports –
https://peopleforeducation.ca/our-work/technology-in-schools-a-tool-and-a-strategy/ ? Accessibility Digital Office Project – https://adod.idrc.ocadu.ca/ ? People for Education Educational reading in a Pandemic – https://peopleforeducation.ca/our-work/education-reading-in-a-pandemic

Additional Reading

? How brain research help retool our school schedule for remote learning –
https://www.edsurge.com/news/2020-06-10-how-brain-research-helped-retool-our-school-schedule-for-remote-learning
? Ontario Developmental Services https://www.dsontario.ca/resources/webcasts-podcasts – podcast to Passport Funding
? Survey Place resources https://www.surreyplace.ca/resources-publications/coronavirus-updates-resources/#parents ? Statistics Canada Survey parenting during pandemic –
https://surveys-enquetes.statcan.gc.ca/form-formulaire/q/en/eqgs4b1d8328edfa4922aa915b5436328916/p0 ? Globe & Mail -Children being rendered invisible https://www.theglobeandmail.com/canada/article-children-being-rendered-invisible-by-province-former-ontario-child/
? CTV News – Parents should ‘respect custody arrangements’ during COVID-19 pandemic –
https://toronto.ctvnews.ca/parents-should-respect-custody-arrangements-during-covid-19-pandemic-1.4874720?cache=wcoseppn%3FautoPlay%3Dtrue%3FclipId%3D89680
? Top 10 – A New New Deal For Education: Top 10 Policy Moves For States In The COVID 2.0 Era –
https://www.forbes.com/sites/lindadarlinghammond/2020/05/19/a-new-new-deal-for-education-top-10-policy-moves-for-states-in-the-covid-20-era/#203440f16266
? UNESCO MGIEP Essential SEL Resources: COVID-19 – https://mgiep.unesco.org/covid
? Inter-agency Network for Education in Emergencies https://inee.org/resources/inee-minimum-standards Minimum Standards Handbook: Preparedness, Emergency, Recovery
? George Lucas Foundation https://www.edutopia.org/article/schools-are-opening-worldwide-providing-model-us?utm_source=Edutopia+Newsletter&utm_campaign=9f50493399-EMAIL_CAMPAIGN_052720_enews_schoolsare&utm_medium=email&utm_term=0_f72e8cc8c4-9f50493399-78670447 article on school opening around the world ? Teacher Magazine- How teachers can help students transition back to school –
https://www.teachermagazine.com.au/articles/covid-19-how-teachers-can-help-students-transition-back-to-school ? Tes What 1 week after returning to school looks like –
https://www.tes.com/news/coronavirus-reopening-schools-one-week-back-what-has-return-school-been ? How brain research help retool our school schedule for remote learning –
https://www.edsurge.com/news/2020-06-10-how-brain-research-helped-retool-our-school-schedule-for-remote-learning




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New Report Reveals that At Majority of Ontarios School Boards, Each School Principal Is a Law Unto Themselves, With Arbitrary Power to Exclude a Student From School ? Real Risk of a Rash of Exclusion of Some Students with Disabilities When Schools Re-Open


ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
NEWS RELEASE – FOR IMMEDIATE RELEASE

July 23, 2020 Toronto: Parents of a third of a million Ontario K-12 students with disabilities have much to fear when schools re-open. A ground-breaking report by the non-partisan AODA Alliance (unveiled today, summary below) shows that for much of Ontario, each school principal is a law unto themselves, armed with a sweeping, arbitrary power to refuse to allow a student to come to school. If schools re-open this fall, there is a real risk of a rash of principals excluding some students with disabilities from school, because well-intentioned, overburdened principals wont know how to accommodate them during COVID-19.

The Education Act gives each school principal the drastic power to refuse to admit to school any person whose presence in the school or classroom would in the principals judgment be detrimental to the physical or mental well-being of the pupils”. A survey of Ontarios 72 school boards, unveiled today, shows that a majority of school boards have no policy reining in their principals sweeping power. Ontarios Ministry of Education gives principals precious little direction. Principals need not keep track of how many students they exclude, or for how long, or for what reason, nor need they report this information to anyone. School Boards are left largely free to do as little as they wish to monitor for and prevent abuse of this power.

This is especially worrisome for students with disabilities. Disproportionately, its students with disabilities who are at risk of being excluded from school.

Todays report details how the most vulnerable students can unjustifiably be treated very differently from one part of Ontario to the next. Of Ontarios 72 School Boards, only 33 Boards have been found to have any policy on this. Only 36 School Boards even responded to the AODA Alliance survey. Only 11 Boards gave the AODA Alliance a policy. A web search revealed that another 22 Boards have a policy on this.

As for the minority of 33 boards that have any policy on point, this report documented wild and arbitrary differences from Board to Board. Some Board policies have commendable and helpful ingredients that all boards should have. Some Board policies contain unfair and inappropriate ingredients that should be forbidden. For example, no Board should impose on a student or their family an arbitrary time limit for presenting an appeal from their exclusion to school.

Every student facing the trauma of an exclusion from school deserves full and equally fair procedures and safeguards, said AODA Alliance Chair David Lepofsky. The current arbitrary pattern of patchwork injustice cries out for new leadership now by the Ford Government.

COVID-19 escalates this issues urgency. The Ministry of Education should head off a rash of new exclusions from school this fall before it happens, by immediately directing School Boards to implement common sense restrictions on a principal, outlined in the report, on when and how a principal may exclude a student from school.

Contact: AODA Alliance Chair David Lepofsky, [email protected] Twitter: @aodaalliance

Download the entire AODA Alliance report on Refusals to Admit A Student to School by visiting https://www.aodaalliance.org/wp-content/uploads/2020/07/july-23-2020-AODA-Alliance-finalized-refusals-to-admit-brief.docx

The AODA Alliances COVID-19 web page details its efforts to ensure that the urgent needs of people with disabilities are met during the COVID-19 crisis.
The AODA Alliance’s Education web page details its ongoing efforts over the past decade to tear down the many barriers impeding students with disabilities in Ontarios education system.

Introduction and Summary of the AODA Alliances Report on the Power of Ontario School Principals to Refuse to Admit a Student to School

I. Introduction and Summary
(a) Whats the Problem?
For years, Ontarios Education Act has given every Ontario school principal the drastic power to refuse to admit to school any person whose presence in the school or classroom would in the principals judgment be detrimental to the physical or mental well-being of the pupils”. A student can be excluded from school for part or all of the school day. This report uses the terms refusal to admit and exclusion from school or simply exclusion to mean the same thing.

When a principal refuses to admit a student to school, that violates that students right to go to school to get an education. Under the Education Act as interpreted or applied by the Ontario Government and school boards, a student can be excluded from school for days, weeks or even months.

Ontarios Ministry of Education has given School Boards and principals very little direction on how this sweeping power may be used. School Boards are therefore left largely free to do as much or as little as they wish to ensure that this power is not abused by an individual school principal.

A School Board can develop a policy on how a principal can use the power to refuse to admit a student to school; however, a School Board does not have to do so. If it does adopt a policy, it does not have to be a good policy. (b) Taking Stock The AODA Alliance Surveys Ontario School Boards
The AODA Alliance therefore conducted a survey of Ontarios major School Boards to find out what their policies and practices are regarding the exclusion of students from school. The non-partisan grassroots AODA Alliance advocates for accessibility for people with disabilities, including for students with disabilities. See its websites Education page.

This report makes public the results of the AODA Alliance’s survey and investigation. It reveals an arbitrary patchwork of different policies around Ontario, unjustifiably treating the most vulnerable students differently from one part of Ontario to the next. There is a pressing need for the Ontario Government to step into the gap, to protect students, and especially students with disabilities.
In an error which the AODA Alliance regrets, the survey was inadvertently not earlier sent to one board, the Dufferin Peel Catholic District School Board, before this report was written. It has just done so, and will make public an addendum to this report if a response is received that alters the results expressed in this report. This error does not diminish this reports findings or recommendations.

School Boards were asked (i) if it has a policy on when-and-how its school principals can refuse to admit a student to school, (ii) whether the Board tracks its principals use of this power, and (iii) how many students have been excluded from school. The AODA Alliance sent its survey to School Boards twice, once in 2019, and once in 2020. The Council of Directors of Education retained private legal counsel to get legal advice before responding to this survey.
(c) The Survey Revealed an Arbitrary Patchwork of Wildly Varying Local Requirements
Of Ontarios 72 School Boards, only 33 Boards have been found to have a written policy or procedure on refusals to admit a student to school. Only 36 School Boards responded to the AODA Alliances survey. Of those, only 11 Boards gave the AODA Alliance their policy or procedure on refusals to admit.

Six School Boards told the AODA Alliance that they have no policy on refusals to admit. An extensive web search by the AODA Alliance revealed that another 22 School Boards have a written policy or procedure on this topic. In a number of cases, these were not easy to find. Taken together, a large number of Ontario School Boards revealed a troubling lack of openness and accountability on this subject.

This reports analysis of the 33 policies or procedures on refusals to admit, as obtained by the AODA Alliance, revealed that there are wild variations between the written policies of School Boards across Ontario on excluding a student from school. Some are very short and say very little. Others are far more extensive and detailed.

As for safeguards for vulnerable students and their parents in the face of an exclusion from school, there are arbitrary and unjustified differences from Board to Board. Some Board policies have commendable and helpful ingredients that should be required of all School Boards. Some Board policies contain unfair and inappropriate ingredients that should be forbidden. For example, no Board should use a refusal to admit to facilitate a police investigation, or set an arbitrary time limit in advance for an appeal hearing from a refusal to admit, or give a student or their family an arbitrary time limit for presenting such an appeal.

There is no justification for such wild variations from Board to Board, from no policy, to policies that say very little, to substantially better policies. Every student facing an exclusion from school deserves fair procedures and effective safeguards. Every School Board should meet basic requirements of transparency and accountability in their use of this drastic power. No compelling policy objective is served by leaving each School Board to reinvent the wheel here. (d) The Urgently Needed Solution: Action Now by the Ontario Government
This situation cries out for leadership on this issue by Ontarios Ministry of Education. The failure of so many School Boards to even have a policy in this area, the unwillingness of so many School Boards to even answer questions about their policy on this issue, and the fact that policies are so hard to find on line combine to create a disturbing picture. For too much of Ontario, well-intentioned school principals are left to be a law unto themselves. The AODA Alliance expects that these hard-working and dedicated principals neither asked for this nor would like this situation to remain as is.

This issue has serious implications for students with disabilities. Refusals to admit a student to school disproportionately burden some students with disabilities.

The COVID-19 crisis escalates the urgency of this issue. When schools re-open this fall, there is a real risk that there could be a rash of more refusals to admit some students with disabilities to school. This threatens to be the way some overwhelmed and overburdened principals will cope with the stressful uncertainties surrounding the COVID-19 pandemic.

The Ministry of Education should head off this problem before it happens, by immediately directing School Boards to implement some basic and overdue requirements for refusals to admit a student to school. The Ministry should then develop a comprehensive and broader set of mandatory requirements for all School Boards when exercising the power to refuse to admit a student to school.

Examples of helpful requirements that the Ministry of Education should require, and that this report documents as now in place in one or more School Boards include the following:
1. Refusals to admit should be recognized as an infringement of the students right to go to school to get an education, and as raising potential human rights issues, especially for students with disabilities. The Ontario Human Rights Code has primacy over the Education Act and the power to refuse to admit a student to school.
2. A refusal to admit should only be imposed for a proper safety purpose. A student cannot be refused admission to school for purposes of discipline.
3. Maximum time limits should be set for a refusal to admit, with a process for considering how to extend it if necessary and justified.
4. A refusal to admit a student to school should only be permitted in very rare, extreme cases, as a last resort, after considering or trying all less intrusive alternatives. A principal should be required to take a step-by-step tiered approach to deciding whether to refuse to admit a student to school, first exhausting all less restrictive alternatives, and first ensuring that the students disability-related needs have been accommodated as required under the Ontario Human Rights Code.
5. It should not be left to an individual principal to unilaterally decide on their own to refuse to admit a student to school. Prior approval of a higher authority with the School Board should be required, supported by sufficient documentation of the deliberations.
6. A principal should be required to work with a student and their family on issues well before it degenerates to the point of considering a refusal to admit. The School Board should be required to have a mandatory meeting with the family before a refusal to admit is imposed.
7. A principal should be required to immediately send a letter to the parents of a student whom they are refusing to admit to school, setting out the facts and specifics that are the reasons for the exclusion from school. A senior Board supervisor that approved the decision should be required to co-sign the letter. The letter should also be signed by the Director of Education if the student is to be excluded from all schools in the Board.
8. A School Board that excludes a student from school should be required to put in place a plan for delivering an effective educational program to that student while excluded from school, including the option of face-to-face engagement with a teacher off of school property. This plan should be monitored to ensure it is sufficient.
9. If a student is excluded from school, the School Board should be under a strong duty to work with the student and family to get them back to school as soon as possible.
10. A School Board that excludes a student from school should be required to hold a re-entry meeting with the student and family to transition to the return to school.
11. Any appeals to the Board of Trustees for the School Board from a refusal to admit should assure fair procedures to the student and their family. An excluded student should at least have all the safeguards in the appeal process as does a student who is subjected to discipline.
12. The appeal should be heard by the entire Board of Trustees, and not just a sub-committee of some trustees. An appeal hearing should be held and decided quickly, since the student is languishing at home.
13. A Board of Trustees, hearing an appeal from a refusal to admit, should consider whether the School Board has justified the students initial exclusion from school and its continuation. The burden should be on the School Board to justify the exclusion from school, and not on the student trying to go back to school. At an appeal hearing, the principal should first present why the exclusion from school is justified and should continue, before the student or parents are asked to show why the student should be allowed to return to school.
14. When an appeal is launched, the School Board should be required to first try to resolve the issue short of a full appeal hearing.
15. A students record of a refusal to admit to school should not stain the students official school record.
16. If a School Board directs that a student can only come to school for part of the school day), the same safeguards for the student should be required as for a student who is excluded for the entire day. 17. Any policy in this area should be periodically reviewed and updated.




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New Report Reveals that At Majority of Ontario’s School Boards, Each School Principal Is a Law Unto Themselves, With Arbitrary Power to Exclude a Student From School – Real Risk of a Rash of Exclusion of Some Students with Disabilities When Schools Re-Open


ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE

NEWS RELEASE – FOR IMMEDIATE RELEASE

New Report Reveals that At Majority of Ontario’s School Boards, Each School Principal Is a Law Unto Themselves, With Arbitrary Power to Exclude a Student From School – Real Risk of a Rash of Exclusion of Some Students with Disabilities When Schools Re-Open

July 23, 2020 Toronto: Parents of a third of a million Ontario K-12 students with disabilities have much to fear when schools re-open. A ground-breaking report by the non-partisan AODA Alliance (unveiled today, summary below) shows that for much of Ontario, each school principal is a law unto themselves, armed with a sweeping, arbitrary power to refuse to allow a student to come to school. If schools re-open this fall, there is a real risk of a rash of principals excluding some students with disabilities from school, because well-intentioned, overburdened principals won’t know how to accommodate them during COVID-19.

The Education Act gives each school principal the drastic power to refuse to admit to school any “person whose presence in the school or classroom would in the principal’s judgment be detrimental to the physical or mental well-being of the pupils…”. A survey of Ontario’s 72 school boards, unveiled today, shows that a majority of school boards have no policy reining in their principals’ sweeping power. Ontario’s Ministry of Education gives principals precious little direction. Principals need not keep track of how many students they exclude, or for how long, or for what reason, nor need they report this information to anyone. School Boards are left largely free to do as little as they wish to monitor for and prevent abuse of this power.

This is especially worrisome for students with disabilities. Disproportionately, it’s students with disabilities who are at risk of being excluded from school.

Today’s report details how the most vulnerable students can unjustifiably be treated very differently from one part of Ontario to the next. Of Ontario’s 72 School Boards, only 33 Boards have been found to have any policy on this. Only 36 School Boards even responded to the AODA Alliance survey. Only 11 Boards gave the AODA Alliance a policy. A web search revealed that another 22 Boards have a policy on this.

As for the minority of 33 boards that have any policy on point, this report documented wild and arbitrary differences from Board to Board. Some Board policies have commendable and helpful ingredients that all boards should have. Some Board policies contain unfair and inappropriate ingredients that should be forbidden. For example, no Board should impose on a student or their family an arbitrary time limit for presenting an appeal from their exclusion to school.

“Every student facing the trauma of an exclusion from school deserves full and equally fair procedures and safeguards,” said AODA Alliance Chair David Lepofsky. “The current arbitrary pattern of patchwork injustice cries out for new leadership now by the Ford Government.”

COVID-19 escalates this issue’s urgency. The Ministry of Education should head off a rash of new exclusions from school this fall before it happens, by immediately directing School Boards to implement common sense restrictions on a principal, outlined in the report, on when and how a principal may exclude a student from school.

Contact: AODA Alliance Chair David Lepofsky, [email protected] Twitter: @aodaalliance

Download the entire AODA Alliance report on Refusals to Admit A Student to School by visiting https://www.aodaalliance.org/wp-content/uploads/2020/07/july-23-2020-AODA-Alliance-finalized-refusals-to-admit-brief.docx

The AODA Alliance’s COVID-19 web page details its efforts to ensure that the urgent needs of people with disabilities are met during the COVID-19 crisis.

The AODA Alliance‘s Education web page details its ongoing efforts over the past decade to tear down the many barriers impeding students with disabilities in Ontario’s education system.

Introduction and Summary of the AODA Alliance’s Report on the Power of Ontario School Principals to Refuse to Admit a Student to School

I. Introduction and Summary

(a) What’s the Problem?

For years, Ontario’s Education Act has given every Ontario school principal the drastic power to refuse to admit to school any “person whose presence in the school or classroom would in the principal’s judgment be detrimental to the physical or mental well-being of the pupils…”. A student can be excluded from school for part or all of the school day. This report uses the terms “refusal to admit” and “exclusion from school” or simply “exclusion” to mean the same thing.

When a principal refuses to admit a student to school, that violates that student’s right to go to school to get an education. Under the Education Act as interpreted or applied by the Ontario Government and school boards, a student can be excluded from school for days, weeks or even months.

Ontario’s Ministry of Education has given School Boards and principals very little direction on how this sweeping power may be used. School Boards are therefore left largely free to do as much or as little as they wish to ensure that this power is not abused by an individual school principal.

A School Board can develop a policy on how a principal can use the power to refuse to admit a student to school; however, a School Board does not have to do so. If it does adopt a policy, it does not have to be a good policy.

(b) Taking Stock – The AODA Alliance Surveys Ontario School Boards

The AODA Alliance therefore conducted a survey of Ontario’s major School Boards to find out what their policies and practices are regarding the exclusion of students from school. The non-partisan grassroots AODA Alliance advocates for accessibility for people with disabilities, including for students with disabilities. See its website’s Education page.

This report makes public the results of the AODA Alliance‘s survey and investigation. It reveals an arbitrary patchwork of different policies around Ontario, unjustifiably treating the most vulnerable students differently from one part of Ontario to the next. There is a pressing need for the Ontario Government to step into the gap, to protect students, and especially students with disabilities.

In an error which the AODA Alliance regrets, the survey was inadvertently not earlier sent to one board, the Dufferin Peel Catholic District School Board, before this report was written. It has just done so, and will make public an addendum to this report if a response is received that alters the results expressed in this report. This error does not diminish this report’s findings or recommendations.

School Boards were asked (i) if it has a policy on when-and-how its school principals can refuse to admit a student to school, (ii) whether the Board tracks its principal’s use of this power, and (iii) how many students have been excluded from school. The AODA Alliance sent its survey to School Boards twice, once in 2019, and once in 2020. The Council of Directors of Education retained private legal counsel to get legal advice before responding to this survey.

(c) The Survey Revealed an Arbitrary Patchwork of Wildly Varying Local Requirements

Of Ontario’s 72 School Boards, only 33 Boards have been found to have a written policy or procedure on refusals to admit a student to school. Only 36 School Boards responded to the AODA Alliance’s survey. Of those, only 11 Boards gave the AODA Alliance their policy or procedure on refusals to admit.

Six School Boards told the AODA Alliance that they have no policy on refusals to admit. An extensive web search by the AODA Alliance revealed that another 22 School Boards have a written policy or procedure on this topic. In a number of cases, these were not easy to find. Taken together, a large number of Ontario School Boards revealed a troubling lack of openness and accountability on this subject.

This report’s analysis of the 33 policies or procedures on refusals to admit, as obtained by the AODA Alliance, revealed that there are wild variations between the written policies of School Boards across Ontario on excluding a student from school. Some are very short and say very little. Others are far more extensive and detailed.

As for safeguards for vulnerable students and their parents in the face of an exclusion from school, there are arbitrary and unjustified differences from Board to Board. Some Board policies have commendable and helpful ingredients that should be required of all School Boards. Some Board policies contain unfair and inappropriate ingredients that should be forbidden. For example, no Board should use a refusal to admit to facilitate a police investigation, or set an arbitrary time limit in advance for an appeal hearing from a refusal to admit, or give a student or their family an arbitrary time limit for presenting such an appeal.

There is no justification for such wild variations from Board to Board, from no policy, to policies that say very little, to substantially better policies. Every student facing an exclusion from school deserves fair procedures and effective safeguards. Every School Board should meet basic requirements of transparency and accountability in their use of this drastic power. No compelling policy objective is served by leaving each School Board to reinvent the wheel here.

(d) The Urgently Needed Solution: Action Now by the Ontario Government

This situation cries out for leadership on this issue by Ontario’s Ministry of Education. The failure of so many School Boards to even have a policy in this area, the unwillingness of so many School Boards to even answer questions about their policy on this issue, and the fact that policies are so hard to find on line combine to create a disturbing picture. For too much of Ontario, well-intentioned school principals are left to be a law unto themselves. The AODA Alliance expects that these hard-working and dedicated principals neither asked for this nor would like this situation to remain as is.

This issue has serious implications for students with disabilities. Refusals to admit a student to school disproportionately burden some students with disabilities.

The COVID-19 crisis escalates the urgency of this issue. When schools re-open this fall, there is a real risk that there could be a rash of more refusals to admit some students with disabilities to school. This threatens to be the way some overwhelmed and overburdened principals will cope with the stressful uncertainties surrounding the COVID-19 pandemic.

The Ministry of Education should head off this problem before it happens, by immediately directing School Boards to implement some basic and overdue requirements for refusals to admit a student to school. The Ministry should then develop a comprehensive and broader set of mandatory requirements for all School Boards when exercising the power to refuse to admit a student to school.

Examples of helpful requirements that the Ministry of Education should require, and that this report documents as now in place in one or more School Boards include the following:

  1. Refusals to admit should be recognized as an infringement of the student’s right to go to school to get an education, and as raising potential human rights issues, especially for students with disabilities. The Ontario Human Rights Code has primacy over the Education Act and the power to refuse to admit a student to school.
  2. A refusal to admit should only be imposed for a proper safety purpose. A student cannot be refused admission to school for purposes of discipline.
  3. Maximum time limits should be set for a refusal to admit, with a process for considering how to extend it if necessary and justified.
  4. A refusal to admit a student to school should only be permitted in very rare, extreme cases, as a last resort, after considering or trying all less intrusive alternatives. A principal should be required to take a step-by-step tiered approach to deciding whether to refuse to admit a student to school, first exhausting all less restrictive alternatives, and first ensuring that the student’s disability-related needs have been accommodated as required under the Ontario Human Rights Code.
  5. It should not be left to an individual principal to unilaterally decide on their own to refuse to admit a student to school. Prior approval of a higher authority with the School Board should be required, supported by sufficient documentation of the deliberations.
  6. A principal should be required to work with a student and their family on issues well before it degenerates to the point of considering a refusal to admit. The School Board should be required to have a mandatory meeting with the family before a refusal to admit is imposed.
  7. A principal should be required to immediately send a letter to the parents of a student whom they are refusing to admit to school, setting out the facts and specifics that are the reasons for the exclusion from school. A senior Board supervisor that approved the decision should be required to co-sign the letter. The letter should also be signed by the Director of Education if the student is to be excluded from all schools in the Board.
  8. A School Board that excludes a student from school should be required to put in place a plan for delivering an effective educational program to that student while excluded from school, including the option of face-to-face engagement with a teacher off of school property. This plan should be monitored to ensure it is sufficient.
  9. If a student is excluded from school, the School Board should be under a strong duty to work with the student and family to get them back to school as soon as possible.
  10. A School Board that excludes a student from school should be required to hold a re-entry meeting with the student and family to transition to the return to school.
  11. Any appeals to the Board of Trustees for the School Board from a refusal to admit should assure fair procedures to the student and their family. An excluded student should at least have all the safeguards in the appeal process as does a student who is subjected to discipline.
  12. The appeal should be heard by the entire Board of Trustees, and not just a sub-committee of some trustees. An appeal hearing should be held and decided quickly, since the student is languishing at home.
  13. A Board of Trustees, hearing an appeal from a refusal to admit, should consider whether the School Board has justified the student’s initial exclusion from school and its continuation. The burden should be on the School Board to justify the exclusion from school, and not on the student trying to go back to school. At an appeal hearing, the principal should first present why the exclusion from school is justified and should continue, before the student or parents are asked to show why the student should be allowed to return to school.
  14. When an appeal is launched, the School Board should be required to first try to resolve the issue short of a full appeal hearing.
  15. A student’s record of a refusal to admit to school should not stain the student’s official school record.
  16. If a School Board directs that a student can only come to school for part of the school day), the same safeguards for the student should be required as for a student who is excluded for the entire day.
  17. Any policy in this area should be periodically reviewed and updated.



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The Ford Government Issues a Very Weak Policy Directive to Ontario School Boards on Addressing Requests by a Student with a Disability to Bring Their Service Animal to School


There Is No Assurance It Will Make It Easier for Students with Disabilities to Bring a Service Animal to an Ontario School

Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities http://www.aodaalliance.org [email protected] Twitter: @aodaalliance

September 10, 2019

SUMMARY

On September 9, 2019, the Ford Government issued a palpably weak policy direction to Ontario school boards on how to handle requests by students with disabilities to permit them to bring a service animal to school. It is good that this policy direction requires every Ontario school board to develop a policy for dealing with such requests. However, it falls far short of what students with disabilities and their families need. It does not require those school board policies to be good. It does not ensure that students with disabilities will be more readily able to bring a service animal to school than has been the case in the past, even though the Tories talked about making that easier, during the 2018 Ontario election campaign.

The Ford Government’s new policy direction to school boards, set out below, reads as if the school boards themselves wrote it, in order to require little of them, while appearing to show provincial leadership. The provincial policy wastefully requires each of over 70 school boards to reinvent the wheel. It burdens students with disabilities and their families with having to once again lobby every one of those school boards. Doug Ford’s policy directive provides no assurance of consistency across the province.

There are several deficiencies with the new provincial policy directive. For example:

* The provincial policy directive ultimately leaves it to over 70 school boards to invent their own rules on when they will permit a student with a disability to bring a service animal to school. In that regard, it largely sets no provincial standards at all. Each school is to decide each case, on a case-by-case basis. That really says nothing new.

* While the new provincial policy directive refers in brief and summary terms to the duty to accommodate students with disabilities under the Ontario Human Rights Code, Doug Ford’s policy new directive ultimately leaves it to school boards to decide when it is “appropriate” to allow a student to bring a service animal to school. The Ontario Human Rights Code does not, however, make the test a sweeping open-ended and unpredictable one of “appropriateness”.

* The provincial policy erroneously does not direct school boards that they should allow for trial periods with a service animal before refusing this accommodation outright for a student.

* The provincial policy directive erroneously focuses on requiring or considering documentation from “medical professionals.” Of course, it should be open to a student with a disability or their family to bring forward medical documentation if they wish. However, doctors likely have no expertise in this area. People with disabilities have for years battled against the undue medicalization of their disability accessibility and accommodation needs.

Two years ago, the Human Rights Tribunal of Ontario rendered a seriously flawed decision in this area. The Waterloo Catholic District School Board had wrongly refused to let a student with autism bring his autism service dog to school. The family took the case to the Human Rights Tribunal of Ontario. Shockingly, the family lost the case.

In a detailed article to be published in the National Journal of Constitutional Law, AODA Alliance Chair David Lepofsky shows that the human rights ruling is riddled with errors. Doug Ford’s new provincial policy directive does not address and solve those problems. That article can be downloaded by visiting https://www.aodaalliance.org/whats-new/how-ontarios-human-rights-tribunal-went-off-the-rails-in-an-important-disability-accessibility-case-read-the-new-article-by-aoda-alliance-chair-david-lepofsky-on-the-tribunals-ruling-against-an/

Here, the Ford Government had a great opportunity to do much better that it has done. For years, Ontario has had a patchwork of different practices from school board to school board. Some allow service animals. Some do not. Some have no policy. The Ford Government could and should have surveyed the policies of those Ontario school boards that allow service animals, and drawn on the best of them to create a strong, inclusive provincial policy for all school boards to follow, that would be more favourable to meeting the needs of students with disabilities . Instead, the Ford Government dropped the ball and did a tremendous disservice to students with disabilities.

Perhaps the most stunning illustration of the deficiency in this new provincial policy is that under it, the family that fought the Waterloo Catholic District School Board a few years ago in that human rights case could well have ended up with the same refusal from that school board, had this provincial policy been in place at that time. It is a matter of public record that the mother of the student in that case, Ms. Amy Fee, has since won a seat in the Ontario Legislature, as a Conservative MPP. The Ford Government should have been prepared to do better for her and for the other families in her situation.

The Ford Government should quickly issue a supplemental policy to strengthen its weak September 9, 2019 provincial directive to school boards. It will also now be up to the K-12 Education Standards Development Committee to try to set strong provincial accessibility standards in this area. The Ford Government had frozen its work for over one year. It is having its first preliminary conference call this afternoon to initiate the resumption of its work. MORE DETAILS
New Ford Government Policy Direction to Ontario School Boards on Allowing Students with Disabilities to Bring A Service Animal to School in Ontario

Originally posted at: http://www.edu.gov.on.ca/extra/eng/ppm/ppm163.pdf Policy/Program Memorandum No. 163
Date of Issue: September 9, 2019
Effective: Subject: Until revoked or modified
Application: School Board Policies on Service Animals
Directors of Education
Supervisory Officers and Secretary-Treasurers of School Authorities Executive Director, Provincial and Demonstration Schools Principals of Elementary Schools
Principals of Secondary Schools

Purpose
All school boards1 in Ontario are required to develop, implement, and maintain a policy on student use of service animals in schools.2 The purpose of this memorandum is to provide direction to school boards on the development and implementation of their policy. The ministry’s expectations regarding the components of a board’s policy are identified in this memorandum as well as the implementation and reporting requirements.

School boards are expected to:
* allow a student to be accompanied by a service animal in school when doing so would be an appropriate accommodation to support the student’s learning needs and would meet the school board’s duty to accommodate students with disabilities under the Ontario Human Rights Code;
* make determinations on whether to approve requests for a service animal on a case-by-case basis, based on the individual needs of each student;
* put in place consistent and transparent processes that allow for meaningful consideration of requests for service animals to accompany students in school.

This memorandum applies to all publicly funded elementary and secondary schools, including extended-day programs operated by school boards. However, this memorandum does not apply to licensed child-care providers, including those operating on the premises of publicly funded schools.

Context

The Ministry of Education is committed to supporting school boards in providing appropriate accommodations to all students with demonstrable learning needs, including special education programs and services in Ontario’s schools.

The term “service animal” refers to any animal that provides support to a person with a disability. Traditionally, service animals have been dogs, and dogs remain the most common species of service animal; however, other species may also provide services to individuals with disabilities. The types of functions performed by service animals are diverse, and may or may not include sensory, medical, therapeutic, and emotional support services.
In Ontario, the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) sets out a framework related to the use of service animals by individuals with a disability. The Blind Persons’ Rights Act sets out a framework specifically for the use of guide dogs for individuals who are blind.

People with disabilities who use service animals to assist them with disability-related needs are protected under the ground of “disability” in the Ontario Human Rights Code. Under the Human Rights Code, school boards have a duty to accommodate the needs of students with disabilities up to the point of undue hardship. The Ontario Human Rights Commission’s Policy on Accessible Education for Students with Disabilities (2018) states that: “Depending on a student’s individual needs and the nature of the education service being provided, accommodations may include . . . modifying ‘no pets’ policies to allow guide dogs and other service animals.”3

Nothing in this memorandum detracts from other legal obligations of school boards under applicable law, including the Ontario Human Rights Code.

Definition of “Service Animal”

In the context of this memorandum, “service animal” means an animal that provides support relating to a student’s disability to assist that student in meaningfully accessing education. Due consideration should be given to any documentation on how the service animal assists with the student’s learning needs, and disability-related needs (e.g., documentation from the student’s medical professionals).

School boards must make a determination, on a case-by-case basis, as to whether a service animal may accompany a student taking into account all the circumstances, including the needs of the student and the school community and a school board’s obligation to provide meaningful access to education.

School boards may also consider including service animals in training in their service animal policies.

Components of School Board Policies on Service Animals
When developing their policy on student use of service animals, school boards must respect their obligations under the Ontario Human Rights Code, the AODA, the Blind Persons’ Rights Act, and collective agreements as well as other applicable laws and government policies. When developing their policies on student use of service animals, school boards are encouraged to consult with local partners, as appropriate.

Each school board policy on student use of service animals must contain, at a minimum, the following components:

Communication Plan. The school board policy should say how the school board will inform the school community about the process by which parents4 can apply to have their child’s service animal in the school. It should also say how it will inform the school community of the presence of any service animals at the school.

Process. The school board policy should lay out how requests for students to be accompanied by service animals in schools can be made and the steps in the school board decision-making process. School board processes must be timely, equitable, and readily available, and decisions must be based on a student’s individual strengths and needs.

Policies should include the following:
* a clearly articulated process for a parent to follow when making a request for a student to be accompanied by a service animal in school, including: o a primary point of contact;
o supporting materials for initiating requests(e.g., templates);
* information around the process through which a determination is made about whether or not a service animal is an appropriate accommodation. This could include:
o a meeting or meetings for all appropriate parties(e.g., parents, school staff) to discuss the request for a service animal; o a list of documentation that a parent must provide;
o a list identifying who must be consulted in making the determination;
* information about the factors the board will consider when making a case-by-case determination, including:
o any documentation on how the service animal supports the student’s learning needs and/or disability-related needs, including documentation from the student’s medical professionals; o the disability-related needs and learning needs of the student; o other accommodations available;
o the rights of other students and the needs of the school community; o any training or certification of the service animal;
o any special considerations that may arise if the animal is a species other than a dog;
* consideration of privacy rights of the student seeking to bring a service animal to school;
* information about how the school board will document its decision regarding a request. For example, if a school board approves a request, that information could be recorded in the student’s Individual Education Plan (IEP), if one exists;
* if the school board approves a request for a service animal: a process for developing a plan that addresses:
o the ongoing documentation required for the animal(e.g., annual vaccination records); o the type of support the service animal will provide to the student; o who will be the handler of the service animal while at the school;
o a plan for how the care of the animal will be provided(including supporting the safety and biological needs of the animal); o how the animal will be readily identifiable;
o transportation of the animal to and from school;
o time line for implementation;
* if the school board approves a request for a service animal: strategies for sharing information with members of the broader school community who may be impacted by the decision (e.g., other students, parents, educators, school staff, volunteers, Special Education Advisory Committees) and organizations that use the school facilities (e.g., licensed child-care providers operating in schools of the board), while identifying how the student’s privacy will be considered;
* if the school board denies a request for a service animal: a statement that the school board will provide a written response to the family that made the request in a timely manner.

Health, Safety, and Other Concerns. The school board policy should include a protocol for the board to hear and address concerns from other students and staff who may come in contact with a service animal, and from parents of other students, including health and safety concerns such as allergies and fear or anxiety associated with the animal. Wherever possible, school boards should take steps to minimize conflict through cooperative problem-solving, and/or other supports which may include training for staff and students.

Roles and Responsibilities. The school board policy should clearly outline the roles and responsibilities of students, parents, and school staff regarding service animals at school, taking into account local circumstances.

Training. The school board policy should consider strategies for providing training related to service animals, as appropriate, for school staff who have direct contact with service animals in schools.

Review of School Board Service Animal Policies and Data Collection. The school board policy should be reviewed by the board on a regular basis.

School boards are expected to develop a process for data collection and to collect data regularly, including, but not limited to:

* total number of requests for students to be accompanied by service animals; * whether requests are for elementary or secondary school students; * the number of requests approved and denied;
* if denied, the rationale for the decision, including a description of other supports and/or services provided to the student to support their access to education; * species of service animals requested and approved;
* types of needs being supported (e.g., medical, physical, emotional).

School boards should use this data to inform their cyclical policy reviews.

Implementation

School boards must implement and make publicly available on their websites their newly developed or updated policies and procedures on student use of service animals by January 1, 2020.

School Board Reporting
School boards are required to report to the Ministry of Education, upon request, regarding their activities to achieve the expectations outlined in this memorandum. This could include specific data collected.
1 In this memorandum, school board(s) and board(s) refer to district school boards and school authorities. This memorandum also applies to Provincial and Demonstration Schools.
2 2. This policy is established under the authority of paragraph 29.5 of subsection 8(1) of the Education Act and school boards are required to develop their policies on service animals in schools in accordance with this policy.
3 Policy on Accessible Education for Students with Disabilities (Ontario: Ontario Human Rights Commission, 2018), pp. 5960.
4 4. In this memorandum, parent(s) refers to parent(s) and guardian(s).




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The Ford Government Issues a Very Weak Policy Directive to Ontario School Boards on Addressing Requests by a Student with a Disability to Bring Their Service Animal to School – There Is No Assurance It Will Make It Easier for Students with Disabilities to Bring a Service Animal to an Ontario School


Accessibility for Ontarians with Disabilities Act Alliance Update

United for a Barrier-Free Society for All People with Disabilities

www.aodaalliance.org [email protected] Twitter: @aodaalliance

The Ford Government Issues a Very Weak Policy Directive to Ontario School Boards on Addressing Requests by a Student with a Disability to Bring Their Service Animal to School – There Is No Assurance It Will Make It Easier for Students with Disabilities to Bring a Service Animal to an Ontario School

September 10, 2019

          SUMMARY

On September 9, 2019, the Ford Government issued a palpably weak policy direction to Ontario school boards on how to handle requests by students with disabilities to permit them to bring a service animal to school. It is good that this policy direction requires every Ontario school board to develop a policy for dealing with such requests. However, it falls far short of what students with disabilities and their families need. It does not require those school board policies to be good. It does not ensure that students with disabilities will be more readily able to bring a service animal to school than has been the case in the past, even though the Tories talked about making that easier, during the 2018 Ontario election campaign.

The Ford Government’s new policy direction to school boards, set out below, reads as if the school boards themselves wrote it, in order to require little of them, while appearing to show provincial leadership. The provincial policy wastefully requires each of over 70 school boards to reinvent the wheel. It burdens students with disabilities and their families with having to once again lobby every one of those school boards. Doug Ford’s policy directive provides no assurance of consistency across the province.

There are several deficiencies with the new provincial policy directive. For example:

* The provincial policy directive ultimately leaves it to over 70 school boards to invent their own rules on when they will permit a student with a disability to bring a service animal to school. In that regard, it largely sets no provincial standards at all. Each school is to decide each case, on a case-by-case basis. That really says nothing new.

* While the new provincial policy directive  refers in brief and summary terms to the duty to accommodate students with disabilities under the Ontario Human Rights Code, Doug Ford’s policy new directive ultimately leaves it to school boards to decide when it is “appropriate” to allow a student to bring a service animal to school. The Ontario Human Rights Code does not, however, make the test a sweeping open-ended and unpredictable one of “appropriateness”.

* The provincial policy erroneously does not direct school boards that they should allow for trial periods with a service animal before refusing this accommodation outright for a student.

* The provincial policy directive erroneously focuses on requiring or considering documentation from “medical professionals.” Of course, it should be open to a student with a disability or their family to bring forward medical documentation if they wish. However, doctors likely have no expertise in this area. People with disabilities have for years battled against the undue medicalization of their disability accessibility and accommodation needs.

Two years ago, the Human Rights Tribunal of Ontario rendered a seriously flawed decision in this area. The Waterloo Catholic District School Board had wrongly refused to let a student with autism bring his autism service dog to school. The family took the case to the Human Rights Tribunal of Ontario. Shockingly, the family lost the case.

In a detailed article to be published in the National Journal of Constitutional Law, AODA Alliance Chair David Lepofsky shows that the human rights ruling is riddled with errors. Doug Ford’s new provincial policy directive does not address and solve those problems. That article can be downloaded by visiting https://www.aodaalliance.org/whats-new/how-ontarios-human-rights-tribunal-went-off-the-rails-in-an-important-disability-accessibility-case-read-the-new-article-by-aoda-alliance-chair-david-lepofsky-on-the-tribunals-ruling-against-an/

Here, the Ford Government had a great opportunity to do much better that it has done. For years, Ontario has had a patchwork of different practices from school board to school board. Some allow service animals. Some do not. Some have no policy. The Ford Government could and should have surveyed the policies of those Ontario school boards that allow service animals, and drawn on the best of them to create a strong, inclusive provincial policy for all school boards to follow, that would be more favourable to meeting the needs of students with disabilities . Instead, the Ford Government dropped the ball and did a tremendous disservice to students with disabilities.

Perhaps the most stunning illustration of the deficiency in this new provincial policy is that under it, the family that fought the Waterloo Catholic District School Board a few years ago in that human rights case could well have ended up with the same refusal from that school board, had this provincial policy been in place at that time. It is a matter of public record that the mother of the student in that case, Ms. Amy Fee, has since won a seat in the Ontario Legislature, as a Conservative MPP. The Ford Government should have been prepared to do better for her and for the other families in her situation.

The Ford Government should quickly issue a supplemental policy to strengthen its weak September 9, 2019 provincial directive to school boards. It will also now be up to the K-12 Education Standards Development Committee to try to set strong provincial accessibility standards in this area. The Ford Government had frozen its work for over one year. It is having its first preliminary conference call this afternoon to initiate the resumption of its work.

MORE DETAILS

New Ford Government Policy Direction to Ontario School Boards on Allowing Students with Disabilities to Bring A Service Animal to School in Ontario

Originally posted at: http://www.edu.gov.on.ca/extra/eng/ppm/ppm163.pdf

Policy/Program Memorandum No. 163

Date of Issue: September 9, 2019

Effective: Subject: Until revoked or modified

Application: School Board Policies on Service Animals

Directors of Education

Supervisory Officers and Secretary-Treasurers of School Authorities Executive Director, Provincial and Demonstration Schools

Principals of Elementary Schools

Principals of Secondary Schools

Purpose

All school boards[1] in Ontario are required to develop, implement, and maintain a policy on student use of service animals in schools.[2] The purpose of this memorandum is to provide direction to school boards on the development and implementation of their policy. The ministry’s expectations regarding the components of a board’s policy are identified in this memorandum as well as the implementation and reporting requirements.

School boards are expected to:

  • allow a student to be accompanied by a service animal in school when doing so would be an appropriate accommodation to support the student’s learning needs and would meet the school board’s duty to accommodate students with disabilities under the Ontario Human Rights Code;
  • make determinations on whether to approve requests for a service animal on a case-by-case basis, based on the individual needs of each student;
  • put in place consistent and transparent processes that allow for meaningful consideration of requests for service animals to accompany students in school.

This memorandum applies to all publicly funded elementary and secondary schools, including extended-day programs operated by school boards. However, this memorandum does not apply to licensed child-care providers, including those operating on the premises of publicly funded schools.

Context

 

The Ministry of Education is committed to supporting school boards in providing appropriate accommodations to all students with demonstrable learning needs, including special education programs and services in Ontario’s schools.

The term “service animal” refers to any animal that provides support to a person with a disability. Traditionally, service animals have been dogs, and dogs remain the most common species of service animal; however, other species may also provide services to individuals with disabilities. The types of functions performed by service animals are diverse, and may or may not include sensory, medical, therapeutic, and emotional support services.

In Ontario, the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) sets out a framework related to the use of service animals by individuals with a disability. The Blind Persons’ Rights Act sets out a framework specifically for the use of guide dogs for individuals who are blind.

People with disabilities who use service animals to assist them with disability-related needs are protected under the ground of “disability” in the Ontario Human Rights Code. Under the Human Rights Code, school boards have a duty to accommodate the needs of students with disabilities up to the point of undue hardship. The Ontario Human Rights Commission’s Policy on Accessible Education for Students with Disabilities (2018) states that: “Depending on a student’s individual needs and the nature of the education service being provided, accommodations may include . . . modifying ‘no pets’ policies to allow guide dogs and other service animals.”[3]

Nothing in this memorandum detracts from other legal obligations of school boards under applicable law, including the Ontario Human Rights Code.

Definition of “Service Animal”

 

In the context of this memorandum, “service animal” means an animal that provides support relating to a student’s disability to assist that student in meaningfully accessing education. Due consideration should be given to any documentation on how the service animal assists with the student’s learning needs, and disability-related needs (e.g., documentation from the student’s medical professionals).

School boards must make a determination, on a case-by-case basis, as to whether a service animal may accompany a student taking into account all the circumstances, including the needs of the student and the school community and a school board’s obligation to provide meaningful access to education.

School boards may also consider including service animals in training in their service animal policies.

Components of School Board Policies on Service Animals

When developing their policy on student use of service animals, school boards must respect their obligations under the Ontario Human Rights Code, the AODA, the Blind Persons’ Rights Act, and collective agreements as well as other applicable laws and government policies. When developing their policies on student use of service animals, school boards are encouraged to consult with local partners, as appropriate.

Each school board policy on student use of service animals must contain, at a minimum, the following components:

Communication Plan. The school board policy should say how the school board will inform the school community about the process by which parents[4] can apply to have their child’s service animal in the school. It should also say how it will inform the school community of the presence of any service animals at the school.

Process. The school board policy should lay out how requests for students to be accompanied by service animals in schools can be made and the steps in the school board decision-making process. School board processes must be timely, equitable, and readily available, and decisions must be based on a student’s individual strengths and needs.

Policies should include the following:

  • a clearly articulated process for a parent to follow when making a request for a student to be accompanied by a service animal in school, including:
    • a primary point of contact;
    • supporting materials for initiating requests(e.g., templates);
  • information around the process through which a determination is made about whether or not a service animal is an appropriate accommodation. This could include:
    • a meeting or meetings for all appropriate parties(e.g., parents, school staff) to discuss the request for a service animal;
    • a list of documentation that a parent must provide;
    • a list identifying who must be consulted in making the determination;
  • information about the factors the board will consider when making a case-by-case determination, including:
    • any documentation on how the service animal supports the student’s learning needs and/or disability-related needs, including documentation from the student’s medical professionals;
    • the disability-related needs and learning needs of the student;
    • other accommodations available;
    • the rights of other students and the needs of the school community;
    • any training or certification of the service animal;
    • any special considerations that may arise if the animal is a species other than a dog;
  • consideration of privacy rights of the student seeking to bring a service animal to school;
  • information about how the school board will document its decision regarding a request. For example, if a school board approves a request, that information could be recorded in the student’s Individual Education Plan (IEP), if one exists;
  • if the school board approves a request for a service animal: a process for developing a plan that addresses:
    • the ongoing documentation required for the animal(e.g., annual vaccination records);
    • the type of support the service animal will provide to the student;
    • who will be the handler of the service animal while at the school;
    • a plan for how the care of the animal will be provided(including supporting the safety and biological needs of the animal);
    • how the animal will be readily identifiable;
    • transportation of the animal to and from school;
    • time line for implementation;
  • if the school board approves a request for a service animal: strategies for sharing information with members of the broader school community who may be impacted by the decision (e.g., other students, parents, educators, school staff, volunteers, Special Education Advisory Committees) and organizations that use the school facilities (e.g., licensed child-care providers operating in schools of the board), while identifying how the student’s privacy will be considered;
  • if the school board denies a request for a service animal: a statement that the school board will provide a written response to the family that made the request in a timely manner.

Health, Safety, and Other Concerns. The school board policy should include a protocol for the board to hear and address concerns from other students and staff who may come in contact with a service animal, and from parents of other students, including health and safety concerns such as allergies and fear or anxiety associated with the animal. Wherever possible, school boards should take steps to minimize conflict through cooperative problem-solving, and/or other supports which may include training for staff and students.

Roles and Responsibilities. The school board policy should clearly outline the roles and responsibilities of students, parents, and school staff regarding service animals at school, taking into account local circumstances.

Training. The school board policy should consider strategies for providing training related to service animals, as appropriate, for school staff who have direct contact with service animals in schools.

Review of School Board Service Animal Policies and Data Collection. The school board policy should be reviewed by the board on a regular basis.

School boards are expected to develop a process for data collection and to collect data regularly, including, but not limited to:

  • total number of requests for students to be accompanied by service animals;
  • whether requests are for elementary or secondary school students;
  • the number of requests approved and denied;
  • if denied, the rationale for the decision, including a description of other supports and/or services provided to the student to support their access to education;
  • species of service animals requested and approved;
  • types of needs being supported (e.g., medical, physical, emotional).

School boards should use this data to inform their cyclical policy reviews.

Implementation

School boards must implement and make publicly available on their websites their newly developed or updated policies and procedures on student use of service animals by January 1, 2020.

School Board Reporting

School boards are required to report to the Ministry of Education, upon request, regarding their activities to achieve the expectations outlined in this memorandum. This could include specific

data collected.

[1] In this memorandum, school board(s) and board(s) refer to district school boards and school authorities. This memorandum also applies to Provincial and Demonstration Schools.

[2] 2. This policy is established under the authority of paragraph 29.5 of subsection 8(1) of the Education Act and school boards are required to develop their policies on service animals in schools in accordance with this policy.

[3] Policy on Accessible Education for Students with Disabilities (Ontario: Ontario Human Rights

Commission, 2018), pp. 59–60.

[4] 4. In this memorandum, parent(s) refers to parent(s) and guardian(s).



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