Ford Government Must Ensure the New Vaccine Passport System Does Not Create New Barriers for People with Disabilities


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/

September 3, 2021

SUMMARY
The Ford Government’s plan to require vaccination passports starting September 22, 2021 to access certain places is an important step to get as many people as possible to get fully vaccinated. However, it is very important that this new vaccination passport requirement and system not create any new barriers for people with disabilities in Ontario. This can be achieved if the Ford Government shows strong leadership, and takes the steps outlined here as a swift and clear priority.

As it is, people with disabilities face far too many disability barriers when seeking goods, services facilities and jobs. It is good that the Government’s introductory announcement plans for an exemption for people who cannot get vaccinated for medical reasons. The Ford Government’s September 1, 2021 news release included:

Individuals who cannot receive the vaccine due to medical exemptions will be permitted entry with a doctor’s note until recognized medical exemptions can be integrated as part of a digital vaccine certificate. Children who are 11 years of age and younger and unable to be vaccinated will also be exempted from these requirements.

This general statement, while helpful, does not protect people with disabilities from the creation of new barriers. Before this vaccination passport requirement goes into effect, the Ontario Government must immediately put in place several important measures to ensure that the Government creates no new disability barriers. While this requires further exploration, we know that the following is absolutely necessary:

1. Any mobile app for vaccine passports must be designed and tested to ensure it is fully accessible to adaptive technology for smart phone users with disabilities, such as screen readers. The Federal Government did not do so for its COVID-19-related smart phone ArriveCan app for entering Canada.

2. The Ontario Government must make available an easily-accessed alternative hard copy document to a smart phone app for vaccine passports. Too many people cannot afford smart phones, including many people with disabilities (who disproportionately live in poverty).

3. It is not sufficient for the Government to impose the burden on those individuals with disabilities, who cannot take the vaccine for medical reasons, to get a letter from their physician. This is especially a hardship if it needs to be accomplished in under three weeks.

As it is, well before the COVID-19 pandemic arrived, people with disabilities have faced far too many disability barriers in Ontario’s health care system. The initial report of the Government-appointed Health Care Standards Development Committee documents this in detail. The AODA Alliance’s August 3, 2021 brief to that Standards Development Committee amplifies its concerns. Disability barriers in the health care system got considerably worse during the pandemic. See generally, the AODA Alliance website’s health care page and COVID-19 page.

Some people with disabilities have no doctor to give them an exemption letter. For those who do have a doctor, getting to a doctor can involve disability barriers. The Government has not announced that it is going to pay doctors to provide those letters. We fear that doctors will be even harder to reach if flooded with requests for vaccine exemption letters.

As a result, the Ford Government should immediately provide a vaccine exemption passport for people with disabilities who are medically unable to get the vaccine. The process for obtaining these passports should be ensured to be free of disability barriers. The Ford Government’s related record is not good. To apply for a replacement for one’s expired health care card, one can use a Government website and avoid going to a Service Ontario office, but only if one has a driver’s license. This is an obvious barrier for people with disabilities who cannot qualify for a driver’s license, such as blind people.

4. The Ontario Government’s problematic roll-out of the COVID-19 vaccine over the past months included real problems facing some people with disabilities who wanted to get vaccinated. The Government did not include in its roll-out plans for the start a comprehensive plan to ensure that there was a barrier-free way for people with disabilities to get vaccinated.

While more vaccination opportunities now exist, the Government needs to now put in place a swift, pro-active, accessible and comprehensive strategy for people with disabilities needing and wanting the vaccine, to get swift, barrier-free and ready access to vaccination

5. Public protections need to be put in place for any vulnerable people with disabilities for whom a substitute decision-maker is in place, to address situations where the substitute decision-maker has refused to let a person with a disability for whom they are responsible get vaccinated, in circumstances where there is no medical justification for that refusal.

People with disabilities have disproportionally suffered the worst hardships of the pandemic. It is essential that this understandable new passport requirement not make things worse for any people with disabilities.

As our AODA Alliance Updates have documented, time and again the Ford Government has failed to effectively accommodate the urgent needs of people with disabilities during the pandemic. Time and again, we and others from the disability community have come forward with constructive proposals to fix this.

Overall, the Ford Government has a poor track record, when it comes to achieving accessibility for people with disabilities by 2025, the deadline that the Accessibility for Ontarians with Disabilities Act requires. We commend CTV news for focusing on this vaccine passport disability this issue, and for including it in a news report on August 31, 2021, set out below.

MORE DETAILS

CTV News August 31, 2021
Originally posted at: https://toronto.ctvnews.ca/how-will-vaccine-passport-system-work-in-ontario-for-people-without-cellphones-1.5568573

How will vaccine passport system work in Ontario for people without cellphones? Jon Woodward
CTV News Toronto Video Journalist
@CTV_Jon

TORONTO — Advocates are cautioning a headlong rush into implementing a vaccine passport using only smartphone apps warning it could leave the elderly, the poor or the homeless out in the cold.

Angie Peters of the Yonge St. Mission said designing a vaccine passport to work for disadvantaged people has to be as creative and motivated as the push to get those people vaccines was.

“They may have a cellphone but need to print it because technology is fleeting for them. They have a cellphone this month, but not next month,” she said.

And the solution of a printed out code may also not solve all the problems, Peters said.

“If they have a printer, they may not be able to afford the ink. There are people that we work with that lose their ID, they get rolled on the street regularly. If they’re keeping a printed card, it’s going to get lost and it’s going to have to get replaced, just like other ID on a regular basis,” she said.

It all could add up to a barrier that could result in properly vaccinated people denied entry for factors other than just vaccination, she said.

The Ontario government is expected to introduce some form of vaccine passport this week after calls from the medical community that checking vaccine status at the door could prevent the spread of COVID-19 inside any non-essential venues.

The business community has pushed for a vaccine passport, reasoning that it would lead to more business to be done if capacity limits could be raised safely.

But for those without cellphones, with older cellphones, or those who would have a more difficult time navigating the steps to prove that they are vaccinated, this could be a major headache, said David Lepofsky of the AODA Alliance.
If there’s any reason why someone with a disability couldn’t get the passport, they would need an alternative passport, he said, pointing to people for whom there could be medical exemptions from vaccination.

“We don’t want this to become a long-term thing that could be used against people when the health situation has changed so it should be very time-limited and circumstance-dependent,” he said.

In Manitoba, an immunization card alternative has proved so popular that the government ran out of plastic to print it on.

In Quebec and in B.C.’s planned card, printing the code onto paper is an option as the readers can read the QR codes just as well from paper as from a screen.




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Ford Government Must Ensure the New Vaccine Passport System Does Not Create New Barriers for People with Disabilities – AODA Alliance


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/

Ford Government Must Ensure the New Vaccine Passport System Does Not Create New Barriers for People with Disabilities

September 3, 2021

        SUMMARY

The Ford Government’s plan to require vaccination passports starting September 22, 2021 to access certain places is an important step to get as many people as possible to get fully vaccinated. However, it is very important that this new vaccination passport requirement and system not create any new barriers for people with disabilities in Ontario. This can be achieved if the Ford Government shows strong leadership, and takes the steps outlined here as a swift and clear priority.

As it is, people with disabilities face far too many disability barriers when seeking goods, services facilities and jobs. It is good that the Government’s introductory announcement plans for an exemption for people who cannot get vaccinated for medical reasons. The Ford Government’s September 1, 2021 news release included:

Individuals who cannot receive the vaccine due to medical exemptions will be permitted entry with a doctor’s note until recognized medical exemptions can be integrated as part of a digital vaccine certificate. Children who are 11 years of age and younger and unable to be vaccinated will also be exempted from these requirements.

This general statement, while helpful, does not protect people with disabilities from the creation of new barriers. Before this vaccination passport requirement goes into effect, the Ontario Government must immediately put in place several important measures to ensure that the Government creates no new disability barriers. While this requires further exploration, we know that the following is absolutely necessary:

  1. Any mobile app for vaccine passports must be designed and tested to ensure it is fully accessible to adaptive technology for smart phone users with disabilities, such as screen readers. The Federal Government did not do so for its COVID-19-related smart phone ArriveCan app for entering Canada.
  1. The Ontario Government must make available an easily-accessed alternative hard copy document to a smart phone app for vaccine passports. Too many people cannot afford smart phones, including many people with disabilities (who disproportionately live in poverty).
  1. It is not sufficient for the Government to impose the burden on those individuals with disabilities, who cannot take the vaccine for medical reasons, to get a letter from their physician. This is especially a hardship if it needs to be accomplished in under three weeks.

As it is, well before the COVID-19 pandemic arrived, people with disabilities have faced far too many disability barriers in Ontario’s health care system. The initial report of the Government-appointed Health Care Standards Development Committee documents this in detail. The AODA Alliance’s August 3, 2021 brief to that Standards Development Committee amplifies its concerns. Disability barriers in the health care system got considerably worse during the pandemic. See generally, the AODA Alliance website’s health care page and COVID-19 page.

Some people with disabilities have no doctor to give them an exemption letter. For those who do have a doctor, getting to a doctor can involve disability barriers. The Government has not announced that it is going to pay doctors to provide those letters. We fear that doctors will be even harder to reach if flooded with requests for vaccine exemption letters.

As a result, the Ford Government should immediately provide a vaccine exemption passport for people with disabilities who are medically unable to get the vaccine. The process for obtaining these passports should be ensured to be free of disability barriers. The Ford Government’s related record is not good. To apply for a replacement for one’s expired health care card, one can use a Government website and avoid going to a Service Ontario office, but only if one has a driver’s license. This is an obvious barrier for people with disabilities who cannot qualify for a driver’s license, such as blind people.

  1. The Ontario Government’s problematic roll-out of the COVID-19 vaccine over the past months included real problems facing some people with disabilities who wanted to get vaccinated. The Government did not include in its roll-out plans for the start a comprehensive plan to ensure that there was a barrier-free way for people with disabilities to get vaccinated.

While more vaccination opportunities now exist, the Government needs to now put in place a swift, pro-active, accessible and comprehensive strategy for people with disabilities needing and wanting the vaccine, to get swift, barrier-free and ready access to vaccination

  1. Public protections need to be put in place for any vulnerable people with disabilities for whom a substitute decision-maker is in place, to address situations where the substitute decision-maker has refused to let a person with a disability for whom they are responsible get vaccinated, in circumstances where there is no medical justification for that refusal.

People with disabilities have disproportionally suffered the worst hardships of the pandemic. It is essential that this understandable new passport requirement not make things worse for any people with disabilities.

As our AODA Alliance Updates have documented, time and again the Ford Government has failed to effectively accommodate the urgent needs of people with disabilities during the pandemic. Time and again, we and others from the disability community have come forward with constructive proposals to fix this.

Overall, the Ford Government has a poor track record, when it comes to achieving accessibility for people with disabilities by 2025, the deadline that the Accessibility for Ontarians with Disabilities Act requires. We commend CTV news for focusing on this vaccine passport disability this issue, and for including it in a news report on August 31, 2021, set out below.

        MORE DETAILS

CTV News August 31, 2021

Originally posted at: https://toronto.ctvnews.ca/how-will-vaccine-passport-system-work-in-ontario-for-people-without-cellphones-1.5568573

How will vaccine passport system work in Ontario for people without cellphones?

Jon Woodward

CTV News Toronto Video Journalist

@CTV_Jon

TORONTO — Advocates are cautioning a headlong rush into implementing a vaccine passport using only smartphone apps — warning it could leave the elderly, the poor or the homeless out in the cold.

Angie Peters of the Yonge St. Mission said designing a vaccine passport to work for disadvantaged people has to be as creative and motivated as the push to get those people vaccines was.

“They may have a cellphone but need to print it because technology is fleeting for them. They have a cellphone this month, but not next month,” she said.

And the solution of a printed out code may also not solve all the problems, Peters said.

“If they have a printer, they may not be able to afford the ink. There are people that we work with that lose their ID, they get rolled on the street regularly. If they’re keeping a printed card, it’s going to get lost and it’s going to have to get replaced, just like other ID on a regular basis,” she said.

It all could add up to a barrier that could result in properly vaccinated people denied entry for factors other than just vaccination, she said.

The Ontario government is expected to introduce some form of vaccine passport this week after calls from the medical community that checking vaccine status at the door could prevent the spread of COVID-19 inside any non-essential venues.

The business community has pushed for a vaccine passport, reasoning that it would lead to more business to be done if capacity limits could be raised safely.

But for those without cellphones, with older cellphones, or those who would have a more difficult time navigating the steps to prove that they are vaccinated, this could be a major headache, said David Lepofsky of the AODA Alliance.

If there’s any reason why someone with a disability couldn’t get the passport, they would need an alternative passport, he said, pointing to people for whom there could be medical exemptions from vaccination.

“We don’t want this to become a long-term thing that could be used against people when the health situation has changed so it should be very time-limited and circumstance-dependent,” he said.

In Manitoba, an immunization card alternative has proved so popular that the government ran out of plastic to print it on.

In Quebec and in B.C.’s planned card, printing the code onto paper is an option as the readers can read the QR codes just as well from paper as from a screen.



Source link

Ford Government Belatedly Extended to September 13, 2021 the Deadline for Sending Feedback on Recommendations to Remove Disability Barriers from Ontario’s Health Care System


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/

Ford Government Belatedly Extended to September 13, 2021 the Deadline for Sending Feedback on Recommendations to Remove Disability Barriers from Ontario’s Health Care System

August 18, 2021

        SUMMARY

1. Summary of All Deadlines for Sending Feedback to the Ford Government on What is Needed in New Education and Health Care Accessibility Standards

Last week, after the Ford Government’s deadline had already expired for submitting feedback on the barriers that people with disabilities face in the health care system, the Government extended that deadline. The Government never told us about that extension. After we heard a rumour about it, we asked the Government if there was an extension. The Government then put us on a list of people being notified about this extension. We do not know who else has been alerted to it.

You may understandably be very confused about when you can give the Ford Government this feedback, as well as your input on two other proposals that are out for public feedback, under the Accessibility for Ontarians with Disabilities Act. We here try to clarify things for you.

The bottom line is this: The Ford Government now has the initial reports of three different AODA Standards Development Committees publicly posted for your feedback and input. The Government has now extended two of the three deadlines it earlier announced for giving your feedback.

The AODA Alliance is taking part in all three consultations. We urge you to do so as well. We have submitted our detailed August 3, 2021 brief to the Health Care Standards Development Committee on its initial report. Please email that Committee to endorse the AODA Alliance brief. We know that the March of dimes of Canada and the Ontario Autism Coalition have already done so. Send them your endorsement of our brief by writing [email protected]

The deadlines for sending the Government your feedback are now as follows:

  1. You have up to September 13, 2021 to give feedback on the initial report of the Health Care Standards Development Committee. It recommends what should be included in the promised Health Care Accessibility Standard to tear down the disability barriers facing people with disabilities in Ontario’s health care system.
  1. You have up to September 29, 2021 to give the Government feedback on the initial report of the Post-Secondary Education Standards Development Committee. It recommends what should be included in the Education Accessibility Standard to tear down the disability barriers impeding students with disabilities in Ontario’s colleges and universities.
  1. You have up to September 30, 2021 to give feedback on the initial report of the K-12 Education Standards Development Committee. It recommends what should be included in the promised Education Accessibility Standard to tear down the disability barriers facing students with disabilities in Ontario’s education system.

Where do you send your feedback? Here are the email addresses to use:

 2. What Comes Next

What happens after all this feedback is gathered? After these feedback periods expire, three Government-appointed Standards Development Committees are to go back to work. They are supposed to review all the public feedback they received, and make any changes to their recommendations to the Government. They then submit their finalized report to the Ford Government on what they think the Government should include in the AODA accessibility standard on which they are working.

Section 10(2) of the AODA requires the Government to publicly post each final report from a Standards Development Committee upon receiving it. After the Government receives a Standards Development Committees final report, it can enact the accessibility standard that the Committee recommended as is, or with any changes it wishes. The Government can also do nothing at all.

At the very lethargic and sluggish rate that the Ford Government has been acting on implementing the AODA, it is extremely unlikely that it will enact a Health Care Accessibility Standard or Education Accessibility Standard before next June’s provincial election. It has enacted no accessibility standards and made no revisions to any accessibility standards since it took office over three years ago.

Making this worse, the Ford Government has not made any changes to strengthen the 2011 Transportation Accessibility Standard, even though the Government received a final report from the Transportation Accessibility Standard in the spring of 2018. It has not made any revisions to strengthen the Employment Accessibility Standard, even though it received the final report of the Employment Standards Development Committee over two years ago. It has not enacted any revisions to strengthen the Information and Communication Accessibility Standard, even though it received the Information and Communication Standards Development Committees final report almost one and a half years ago.

The AODA Alliance campaigned for over half a decade to get the Ontario Government to agree to develop and enact accessibility standards under the Accessibility for Ontarians with Disabilities Act in health care and education. The door is open for your input. These opportunities don’t often come along.

In next June’s provincial election, we plan to ask the major parties to commit to action to make Ontario’s education system and health care system fully accessible to people with disabilities. The current public consultations can help with that effort.

 3. Helpful Resources

a) On Disability Barriers in the K-12 Ontario School system

  1. The entire 185-page K-12 Education Standards Development Committee initial report and initial recommendations on what the promised Education Accessibility Standard should include to make education in Ontario schools barrier-free for all students with disabilities.
  1. The AODA Alliance’s 55-page condensed and annotated version of the K-12 Education Standards Development Committee initial report and recommendations.
  1. The AODA Alliance’s 15-page summary of the K-12 Education Standards Development Committee initial report and recommendations.
  1. The AODA Alliance‘s action kit on how to give public feedback on the K-12 Education Standards Development Committee initial report and recommendations.
  1. A captioned video by AODA Alliance Chair David Lepofsky explaining what is in the K-12 Education Standards Development Committee initial report.
  1. A captioned video of tips for parents of students with disabilities on how to advocate at school for their child’s needs.
  1. For general background, the AODA Alliance website Education page.

b) On Disability Barriers in Ontario Colleges and Universities

  1. The initial report of the Post-Secondary Education Standards Development Committee is available at https://www.aodaalliance.org/wp-content/uploads/2021/06/PSE-SDC-Initial-Recommendations-Report_June-25-2021.docx
  1. The draft framework for the Post-Secondary Education Accessibility Standard that the AODA Alliance sent to the Post-Secondary Education Standards Development Committee in March, 2020.
  1. You can learn more about our years of advocacy to make all parts of Ontario’s education system accessible for students with disabilities by visiting the AODA Alliance website’s education page.

c) On Disability Barriers in Ontario’s Health Care System

  1. The initial report of the Health Care Standards Development Committee is available at https://www.aodaalliance.org/wp-content/uploads/2021/05/Health-Care-SDC-Initial-Report-As-Submitted.doc
  1. The AODA Alliance’s August 3, 2021 brief to the Health Care Standards Development Committee giving feedback on its initial report is available at https://www.aodaalliance.org/wp-content/uploads/2021/08/August-3-2021-finalized-AODA-Alliance-Brief-to-Health-Care-Standards-Development-Committee.docx
  1. The AODA Alliance’s February 25, 2020 Framework that it submitted to the Health Care Standards Development Committee on what the promised Health Care Accessibility Standard should include.
  1. A comprehensive captioned video by AODA Alliance Chair David Lepofsky on the barriers facing people with disabilities in the health care system.
  1. A detailed captioned video by AODA Alliance Chair David Lepofsky on the dangers of disability discrimination in Ontario’s controversial critical care triage protocol during the COVID-19 pandemic.
  1. Background on the AODA Alliance’s campaign for barrier-free health care services for people with disabilities is available on the AODA Alliance website’s health care page.

 4. The Ford Government’s Confused and Confusing Handling of the current Public Consultations on AODA Accessibility Standards

So far, the Ford Government has shown poor leadership in how it has handled the current public consultations. For example:

  • It withheld publicly posting these three initial reports for a long time, even though the AODA s. 10(1) requires the Government to post each upon receiving the report. It delayed publicly posting the health Care Standards Development Committee initial report for over 5 months after receiving it. It delayed publicly posting the Post-Secondary Education Standards Development Committee’s initial report for 3.5 months after receiving it. It delayed publicly posting the K-12 Education Standards Development Committee initial report for 2.5 months after receiving it. In the case of the Health Care Standards Development Committee, that Committee voted to approve its initial report back in September 2020, almost a full year ago.
  • The Government’s delay in publicly posting the Health Care Standards Development Committee’s typifies how this governmental lethargy hurts people with disabilities. That initial report includes recommendations for action needed as a result of the COVID-19 pandemic. For example, it raises concerns about the Government’s critical care triage protocol that endangers some patients with disabilities in Ontario hospitals. The Government kept that report secret from the public over critical months when the danger to people with disabilities was especially high. During that same time, the Minister of Health refused to answer any of the AODA Alliance’s detailed letters raising serious human rights concerns about the Government’s critical care triage protocol and plans.
  • The Government did not announce the extension of the original August 11, 2021 deadline for submitting public feedback on the ‘Health Care Standards Development Committees initial report until August 13, 2021, after that feedback period had already expired. Organizations like the AODA Alliance therefore unnecessarily were forced to rush in the midst of the summer vacation period to submit their feedback before the August 11, 2021 period.
  • Rather than properly informing the entire public, the Ford Government appears to have only let some people know about the extension of the deadline for feedback on the Health Care Standards Development Committees initial report. As noted above, when we heard a rumour about this late last week, we wrote the Government to ask about it. It was only after that that the Government sent out an email to us announcing its extension.
  • The Government initially scheduled the public feedback period on the K-12 Education Standards Development Committee’s initial report to end on September 2, 2021, before the school year begins. This created hardships for giving feedback in connection with the school system. The Government only belatedly agreed to lengthen that feedback period.

 5. Will the Ford Government’s Delays on Accessibility for Ontarians with Disabilities Ever End?

For over three years, we have pressed the Ford Government to develop a detailed plan on accessibility, to lay out how it will get Ontario to the AODA’s mandatory goal of becoming accessible to people with disabilities by 2025. It has never done so.

On January 31, 2019, the Government received the blistering final report of the David Onley Independent Review of the AODA’s implementation. Minister for Accessibility Raymond Cho publicly said on April 10, 2019, that David Onley did a “marvelous job.”

The Onley report found that Ontario is full of “soul-crushing” barriers impeding people with disabilities. It concluded that progress on accessibility has taken place at a “glacial pace.” It determined that that the goal of accessibility by 2025 is nowhere in sight, and that specific new Government actions, spelled out in the report, are needed.

In the 931 days since receiving the Onley Report, the Ford Government has not made public a comprehensive plan to implement that report’s findings and recommendations. The Government has staged some media events with the Accessibility Minister to make announcements, but little if anything new was ever announced.

        MORE DETAILS

August 13, 2021 Broadcast Email from the Accessibility Directorate of Ontario

Dear all,

We are pleased to share that the public feedback period for the Health Care SDC Initial Recommendations has been extended for an additional month, to September 13, 2021. The additional time is intended to recognize that organizations across the health sector and the disability community may require more time to review and respond given the ongoing COVID-19 pandemic.

As a reminder, the Initial Recommendations Report of the Health Care Standards Development Committee is available online here for public comment:

https://www.ontario.ca/page/consultation-initial-recommendations-development-health-care-accessibility-standards

 

As these recommendations may impact you or your community, we would encourage you to participate in this process. We would also encourage you to share this information broadly with your networks.

A survey has been developed to seek public feedback and is linked from the consultation page together with the report itself.

Written submissions can also be sent by email to [email protected]. Members of the public or interested organizations can also reach out to the Accessibility for Ontarians with Disabilities Division by email at [email protected] for any questions.

All feedback received will be considered by the Committee before finalizing their recommendations to the Minister. Identifying information will remain confidential as per the Government of Ontario’s Privacy Policy, and all survey responses will remain anonymous.

Sincerely,

Accessibility for Ontarians with Disabilities Division

Ministry for Seniors and Accessibility



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Ford Government Belatedly Extended to September 13, 2021 the Deadline for Sending Feedback on Recommendations to Remove Disability Barriers from Ontario’s Health Care System


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/

August 18, 2021

SUMMARY

1. Summary of All Deadlines for Sending Feedback to the Ford Government on What is Needed in New Education and Health Care Accessibility Standards

Last week, after the Ford Government’s deadline had already expired for submitting feedback on the barriers that people with disabilities face in the health care system, the Government extended that deadline. The Government never told us about that extension. After we heard a rumour about it, we asked the Government if there was an extension. The Government then put us on a list of people being notified about this extension. We do not know who else has been alerted to it.

You may understandably be very confused about when you can give the Ford Government this feedback, as well as your input on two other proposals that are out for public feedback, under the Accessibility for Ontarians with Disabilities Act. We here try to clarify things for you.

The bottom line is this: The Ford Government now has the initial reports of three different AODA Standards Development Committees publicly posted for your feedback and input. The Government has now extended two of the three deadlines it earlier announced for giving your feedback.

The AODA Alliance is taking part in all three consultations. We urge you to do so as well. We have submitted our detailed August 3, 2021 brief to the Health Care Standards Development Committee on its initial report. Please email that Committee to endorse the AODA Alliance brief. We know that the March of dimes of Canada and the Ontario Autism Coalition have already done so. Send them your endorsement of our brief by writing [email protected]

The deadlines for sending the Government your feedback are now as follows:

1. You have up to September 13, 2021 to give feedback on the initial report of the Health Care Standards Development Committee. It recommends what should be included in the promised Health Care Accessibility Standard to tear down the disability barriers facing people with disabilities in Ontario’s health care system.

2. You have up to September 29, 2021 to give the Government feedback on the initial report of the Post-Secondary Education Standards Development Committee. It recommends what should be included in the Education Accessibility Standard to tear down the disability barriers impeding students with disabilities in Ontario’s colleges and universities.

3. You have up to September 30, 2021 to give feedback on the initial report of the K-12 Education Standards Development Committee. It recommends what should be included in the promised Education Accessibility Standard to tear down the disability barriers facing students with disabilities in Ontario’s education system.

Where do you send your feedback? Here are the email addresses to use:

* Send your feedback on disability barriers in the health care system to [email protected]
* Send your feedback on disability barriers in the K-12 school system to: [email protected]
* Send your feedback on disability barriers in Ontario’s colleges and universities to: [email protected]

2. What Comes Next

What happens after all this feedback is gathered? After these feedback periods expire, three Government-appointed Standards Development Committees are to go back to work. They are supposed to review all the public feedback they received, and make any changes to their recommendations to the Government. They then submit their finalized report to the Ford Government on what they think the Government should include in the AODA accessibility standard on which they are working.

Section 10(2) of the AODA requires the Government to publicly post each final report from a Standards Development Committee upon receiving it. After the Government receives a Standards Development Committees final report, it can enact the accessibility standard that the Committee recommended as is, or with any changes it wishes. The Government can also do nothing at all.

At the very lethargic and sluggish rate that the Ford Government has been acting on implementing the AODA, it is extremely unlikely that it will enact a Health Care Accessibility Standard or Education Accessibility Standard before next June’s provincial election. It has enacted no accessibility standards and made no revisions to any accessibility standards since it took office over three years ago.

Making this worse, the Ford Government has not made any changes to strengthen the 2011 Transportation Accessibility Standard, even though the Government received a final report from the Transportation Accessibility Standard in the spring of 2018. It has not made any revisions to strengthen the Employment Accessibility Standard, even though it received the final report of the Employment Standards Development Committee over two years ago. It has not enacted any revisions to strengthen the Information and Communication Accessibility Standard, even though it received the Information and Communication Standards Development Committees final report almost one and a half years ago.

The AODA Alliance campaigned for over half a decade to get the Ontario Government to agree to develop and enact accessibility standards under the Accessibility for Ontarians with Disabilities Act in health care and education. The door is open for your input. These opportunities don’t often come along.

In next June’s provincial election, we plan to ask the major parties to commit to action to make Ontario’s education system and health care system fully accessible to people with disabilities. The current public consultations can help with that effort.

3. Helpful Resources

a) On Disability Barriers in the K-12 Ontario School system

1. The entire 185-page K-12 Education Standards Development Committee initial report and initial recommendations on what the promised Education Accessibility Standard should include to make education in Ontario schools barrier-free for all students with disabilities.

2. The AODA Alliance’s 55-page condensed and annotated version of the K-12 Education Standards Development Committee initial report and recommendations.

3. The AODA Alliance’s 15-page summary of the K-12 Education Standards Development Committee initial report and recommendations.

4. The AODA Alliance’s action kit on how to give public feedback on the K-12 Education Standards Development Committee initial report and recommendations.

5. A captioned video by AODA Alliance Chair David Lepofsky explaining what is in the K-12 Education Standards Development Committee initial report.

6. A captioned video of tips for parents of students with disabilities on how to advocate at school for their child’s needs.

7. For general background, the AODA Alliance website Education page.

b) On Disability Barriers in Ontario Colleges and Universities

1. The initial report of the Post-Secondary Education Standards Development Committee is available at https://www.aodaalliance.org/wp-content/uploads/2021/06/PSE-SDC-Initial-Recommendations-Report_June-25-2021.docx

2. The draft framework for the Post-Secondary Education Accessibility Standard that the AODA Alliance sent to the Post-Secondary Education Standards Development Committee in March, 2020.

3. You can learn more about our years of advocacy to make all parts of Ontario’s education system accessible for students with disabilities by visiting the AODA Alliance website’s education page.

c) On Disability Barriers in Ontario’s Health Care System

1. The initial report of the Health Care Standards Development Committee is available at https://www.aodaalliance.org/wp-content/uploads/2021/05/Health-Care-SDC-Initial-Report-As-Submitted.doc

2. The AODA Alliance’s August 3, 2021 brief to the Health Care Standards Development Committee giving feedback on its initial report is available at https://www.aodaalliance.org/wp-content/uploads/2021/08/August-3-2021-finalized-AODA-Alliance-Brief-to-Health-Care-Standards-Development-Committee.docx

3. The AODA Alliance’s February 25, 2020 Framework that it submitted to the Health Care Standards Development Committee on what the promised Health Care Accessibility Standard should include.

4. A comprehensive captioned video by AODA Alliance Chair David Lepofsky on the barriers facing people with disabilities in the health care system.

5. A detailed captioned video by AODA Alliance Chair David Lepofsky on the dangers of disability discrimination in Ontario’s controversial critical care triage protocol during the COVID-19 pandemic.

6. Background on the AODA Alliance’s campaign for barrier-free health care services for people with disabilities is available on the AODA Alliance website’s health care page.

4. The Ford Government’s Confused and Confusing Handling of the current Public Consultations on AODA Accessibility Standards

So far, the Ford Government has shown poor leadership in how it has handled the current public consultations. For example:

* It withheld publicly posting these three initial reports for a long time, even though the AODA s. 10(1) requires the Government to post each upon receiving the report. It delayed publicly posting the health Care Standards Development Committee initial report for over 5 months after receiving it. It delayed publicly posting the Post-Secondary Education Standards Development Committee’s initial report for 3.5 months after receiving it. It delayed publicly posting the K-12 Education Standards Development Committee initial report for 2.5 months after receiving it. In the case of the Health Care Standards Development Committee, that Committee voted to approve its initial report back in September 2020, almost a full year ago.
* The Government’s delay in publicly posting the Health Care Standards Development Committee’s typifies how this governmental lethargy hurts people with disabilities. That initial report includes recommendations for action needed as a result of the COVID-19 pandemic. For example, it raises concerns about the Government’s critical care triage protocol that endangers some patients with disabilities in Ontario hospitals. The Government kept that report secret from the public over critical months when the danger to people with disabilities was especially high. During that same time, the Minister of Health refused to answer any of the AODA Alliance’s detailed letters raising serious human rights concerns about the Government’s critical care triage protocol and plans.
* The Government did not announce the extension of the original August 11, 2021 deadline for submitting public feedback on the ‘Health Care Standards Development Committees initial report until August 13, 2021, after that feedback period had already expired. Organizations like the AODA Alliance therefore unnecessarily were forced to rush in the midst of the summer vacation period to submit their feedback before the August 11, 2021 period.
* Rather than properly informing the entire public, the Ford Government appears to have only let some people know about the extension of the deadline for feedback on the Health Care Standards Development Committees initial report. As noted above, when we heard a rumour about this late last week, we wrote the Government to ask about it. It was only after that that the Government sent out an email to us announcing its extension.
* The Government initially scheduled the public feedback period on the K-12 Education Standards Development Committee’s initial report to end on September 2, 2021, before the school year begins. This created hardships for giving feedback in connection with the school system. The Government only belatedly agreed to lengthen that feedback period.

5. Will the Ford Government’s Delays on Accessibility for Ontarians with Disabilities Ever End?

For over three years, we have pressed the Ford Government to develop a detailed plan on accessibility, to lay out how it will get Ontario to the AODA’s mandatory goal of becoming accessible to people with disabilities by 2025. It has never done so.

On January 31, 2019, the Government received the blistering final report of the David Onley Independent Review of the AODA’s implementation. Minister for Accessibility Raymond Cho publicly said on April 10, 2019, that David Onley did a “marvelous job.”

The Onley report found that Ontario is full of “soul-crushing” barriers impeding people with disabilities. It concluded that progress on accessibility has taken place at a “glacial pace.” It determined that that the goal of accessibility by 2025 is nowhere in sight, and that specific new Government actions, spelled out in the report, are needed.

In the 931 days since receiving the Onley Report, the Ford Government has not made public a comprehensive plan to implement that report’s findings and recommendations. The Government has staged some media events with the Accessibility Minister to make announcements, but little if anything new was ever announced.

MORE DETAILS

August 13, 2021 Broadcast Email from the Accessibility Directorate of Ontario

Dear all,

We are pleased to share that the public feedback period for the Health Care SDC Initial Recommendations has been extended for an additional month, to September 13, 2021. The additional time is intended to recognize that organizations across the health sector and the disability community may require more time to review and respond given the ongoing COVID-19 pandemic.

As a reminder, the Initial Recommendations Report of the Health Care Standards Development Committee is available online here for public comment:
https://www.ontario.ca/page/consultation-initial-recommendations-development-health-care-accessibility-standards

As these recommendations may impact you or your community, we would encourage you to participate in this process. We would also encourage you to share this information broadly with your networks.

A survey has been developed to seek public feedback and is linked from the consultation page together with the report itself.

Written submissions can also be sent by email to [email protected] Members of the public or interested organizations can also reach out to the Accessibility for Ontarians with Disabilities Division by email at [email protected] for any questions.

All feedback received will be considered by the Committee before finalizing their recommendations to the Minister. Identifying information will remain confidential as per the Government of Ontario’sPrivacy Policy, and all survey responses will remain anonymous.

Sincerely,

Accessibility for Ontarians with Disabilities Division
Ministry for Seniors and Accessibility




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CBC Reports on Troubling Disability Barrier at Canada’s Wonderland – and – Ford Government Extends Deadline to September 30, 2021 to Send in Public Feedback on Disability Barriers in Ontario’s School system


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/

CBC Reports on Troubling Disability Barrier at Canada’s Wonderland – and – Ford Government Extends Deadline to September 30, 2021 to Send in Public Feedback on Disability Barriers in Ontario’s School system

August 6, 2021

SUMMARY

1. More Proof that the Ontario Government’s Implementation and Enforcement of the Accessibility for Ontarians with Disabilities Act is Ineffectual

The AODA was passed in 2005 so that disability barriers in Ontario would be removed and prevented, without people with disabilities having to battle those barriers one at a time. Here is another inexcusable illustration of how still we must continue to battle those barriers, one at a time, even more than 16 years after the AODA was enacted.

CBC Radio Toronto reported yesterday on a recent incident where Canada’s Wonderland, a well-established amusement park north of Toronto, refused to allow a person with a disability to go on any rides whatsoever. We set out below the online report on CBC’s website. If Ontario had a strong, effective Customer Service Accessibility Standard under the AODA, and if the Ford Government enforced it effectively, such incidents would not continue to occur.

Even 918 days after the Ford Government received a strong call to beef up the AODA’s implementation and enforcement by the Independent Review Report prepared by former Lieutenant Governor David Onley, The Government still has no comprehensive plan to ensure that Ontario becomes accessible to people with disabilities by 2025, under 3.5 years from now.

2. The Ford Government Has Extended to September 30, 2021 the Deadline for Submitting Public Feedback on the Initial Report of the K-12 Education Standards Development Committee

The Ford Government has given you more time to send in your feedback on the disability barriers that impede students with disabilities in Ontario schools. You now have up to September 30, rather than September 2, 2021, to send in your feedback.

This is a once-in-a-generation opportunity. We encourage one and all to let that Standards Development Committee know what you think.

The Government’s original September 2, 2021 deadline was exceedingly unrealistic, since schools are closed for the summer. However, the Government earlier unfairly delayed the entire feedback process, because it withheld the K-12 Education Standards Development Committee’s initial report for 2.5 months before publicly posting it. We are eager for all Standards Development Committees to have their final reports submitted to the Government by the end of this year, if possible, and to have them made public upon the Government receiving them, not months later.

We especially call on each school board’s Special Education Advisory Committee to take this extended opportunity to have their say by sending their feedback to The Government, and by urging their school board to now start implementing the recommendations that the K-12 Education Standards Development Committee prepared.

The AODA Alliance website has helpful resources to make it easier to give your feedback:

  1. A 50 minute captioned video that explains what the K-12 Education Standards Development Committee initial report recommends.
  1. The entire 185-page K-12 Education Standards Development Committee initial report and initial recommendations on what the promised Education Accessibility Standard should include to make education in Ontario schools barrier-free for all students with disabilities.
  1. The AODA Alliance’s 55-page condensed and annotated version of the K-12 Education Standards Development Committee initial report and recommendations.
  1. The AODA Alliance’s 15-page summary of the K-12 Education Standards Development Committee initial report and recommendations.
  1. The AODA Alliance‘s action kit on how to give public feedback on the K-12 Education Standards Development Committee initial report and recommendations.
  1. A captioned video of tips for parents of students with disabilities on how to advocate at school for their child’s needs.
  1. For general background, the AODA Alliance website Education page.

^MORE DETAILS

CBC News Online August 5, 2021

Originally posted at https://www.cbc.ca/news/canada/toronto/paraplegic-man-denied-access-to-rides-1.6129624

Man with disability feels ‘belittled’ after Canada’s Wonderland denies him access to all its rides |

By Jessica Cheung, CBC News

Ahmad El Nasser was looking forward to a visit to Canada’s Wonderland with his niece, but when they got there, he found out he wouldn’t be able to go on any of the rides due to his disability.

“When I was denied access. I kind of felt belittled. I felt a little bit humiliated,” El Nasser, who is paralyzed from the waist down due to a spinal cord injury, told CBC News.

“Being able to ride on these rides is not the big deal; the big deal is seeing my niece upset.”

When El Nasser arrived at the park on July 19 he was given a “boarding pass,” which allows guests with mobility restrictions or cognitive impairment to get on attractions at specified times via the alternate access entrance without having to be in lineups.

Then, El Nasser said he was asked a series of questions, such as “Can you transfer?” That means moving from a wheelchair to other locations — something he is able to do.

Ahmad El Nasser is paralyzed from the waist down after a motorcycle accident 10 years ago. He uses a wheelchair but says he is still very active and outgoing.

“I have full, complete upper body control … I can transfer. I can get on beds. I can get in my car. I can get in rides, no problem,” he said.

“I answered all of them as best I could.”

But the rider access form El Nasser received said he would not be allowed to go on any rides in the park and when he asked why, staff said it was due to manufacturers’ liability.

“I couldn’t even get on little kiddy rides,” he said.

“So it pretty much had nothing to do with my physical capabilities, whether I can transfer, whether I can do this or that. It was, ‘Hey, we don’t want to get sued, so you can’t go on.’”

In a statement, Canada’s Wonderland said it is committed to giving all guests with disabilities the same opportunity to enjoy and benefit from their services and attractions in a similar way as other guests.

“The ride admission policy at Canada’s Wonderland is developed in consultation with industry experts and based on the safety recommendations of the ride manufacturers,” the amusement park’s management said in a statement.

“The safety of our guests and associates is our first priority and we reserve the right to make the final decision regarding the eligibility of a rider to endure the dynamics of a ride without risk of injury to themselves or other riders.”

The company said it is equally committed to providing accommodations to people with disabilities.

El Nasser, whose injury is the result of a motorcycle accident about a decade ago, was refunded the money for his park pass. He said the experience felt discriminatory.

“Nobody really took the time on their end to understand each [of our] individual needs … I felt it was easier for them to just put us all in one bag and say, ‘This is the no section.’”

Laverne Jacobs, a faculty of law professor at the University of Windsor, said when El Nasser paid his admission fee for the park, he entered into a contract that gives him the right to be accommodated to the point of undue hardship under Ontario’s Accessibility Standards for Customer Service.

“What that means is that the park not only should be asking questions about what he can do, but should be trying to use that information in order to accommodate him to make sure that they can help to support and enable him to participate in the activities,” Jacobs said.

Jacobs says safety is a factor in this incident but believes the park created a blanket exclusion to “contract out their obligation to accommodate people with disabilities.”

“It seems that [the park] wanted to enter into a contract that says we don’t want to take on any risk of an accident whatsoever … the very problematic piece of this, though, is that in order to avoid all risk, they’ve essentially categorically excluded individuals with particular disabilities.”

David Lepofsky, the chair of the Accessibility for Ontarians with Disabilities Act Alliance, says service providers like Canada’s Wonderland have a duty to accommodate customers with disabilities.

“If the individual can make an informed decision for themselves that they want to assume that risk, then it’s not for Canada’s Wonderland to unilaterally make that decision for them,” he said.

Canada’s Wonderland does have a guest assistance guide, but Lepofsky says individuals with disabilities need to be dealt with case-by-case.

“Canada’s Wonderland has a duty to investigate solutions,” he said.

“Including investigating it with the individual and find out if other amusement parks have allowed something similar before they could just slam the door on this individual.”

A petition launched by El Nasser’s sister is calling for an end to the exclusion of paraplegics and quadriplegics from rides at the park. It has since garnered hundreds of signatures. El Nasser said he hopes shedding light on this will spark some action.

“What I would like to see changed is for people with disabilities to have that confidence to know that [the park is] doing more and they’re treating us with respect individually, that they want to let us ride.”



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Download in MS Word format the Survey Questionnaire that the Ontario Government posted on June 25, 2021 regarding the initial report/recommendations of the Post-Secondary Education Standards Development Committee



Download in MS Word format the survey questionnaire that the Ontario Government posted on June 25, 2021 regarding the initial report/recommendations of the Post-Secondary Education Standards Development Committee



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Advancing Government Leadership on Accessibility in Ontario


In the Third Review of the AODA, the Honourable David Onley recommends needed improvements to the Act. One of these improvements is a renewal of government leadership to implement the AODA. Therefore, in response to the review, the Ontario government has implemented a framework to make the province more accessible. Through this framework, called Advancing Accessibility in Ontario, the government commits to making changes that will improve opportunities for citizens with disabilities. These changes will take place in four areas of the economy. In this article, we will focus on the area of government leadership on accessibility in Ontario.

Advancing Government Leadership on Accessibility in Ontario

The framework outlines the government’s plans to lead by example and achieve the AODA’s goal of an accessible Ontario by 2025. These plans include:

Customer Service

Similarly, the framework also includes plans to improve customer service for citizens with disabilities. For example, these plans include:

  • Improving trails, beach access routes, and provincial parks, with mobility mats and other features
  • Simplifying the application process for accessible parking permits
  • Funding retrofits, such as elevators, in community agencies throughout the province
  • Removing information barriers in publicly accessible government websites
  • Improvements in specific cities, such as:
    • Adding ramps, elevators, and other features at Toronto’s Go Transit stations
    • Funding research and programming at the Abilities Centre in Whitby

Employment

Likewise, the framework outlines the government’s plans to become more accessible as an employer. For instance, these plans include:

  • Supporting ministries, and workers in the Ontario Public Service (OPS), to meet AODA requirements
  • Ensuring that internal government activities are accessible for government workers with disabilities
  • Forming cross-government committees of deputy ministers to:
    • Address systemic barriers and gaps
    • Plan and implement accessibility improvements
  • Expanding eligibility for youth to work as interns in the OPS, to gain work experience
  • Connecting students and graduates with disabilities to mentors within the OPS and broader public sector

Recommendations for More Government Leadership from the Third Review of the AODA

All these strategies are valuable steps that the government should take to make Ontario more accessible. However, the Third Review of the AODA recommends many more important actions to enhance government accessibility. For example, the Review recommends that the government should:

  • Include deadlines for each of its accessibility goals
  • Improve AODA enforcement, through the Accessibility Directorate of Ontario (ADO)
  • Remove any accessibility problems in current laws, and create new laws without such problems
  • Hold all meetings and public events in accessible locations
  • Hire qualified candidates with disabilities to work at the OPS

In other words, the government’s current framework will not create enough improvement to make Ontario fully accessible by 2025. Moreover, some of the framework’s goals for the future involve laws that the government should already be following. For instance, in January 2020, the government was required to make all its websites accessible. Therefore, the framework should not include this element as a current goal. Instead, all government websites should already be accessible to citizens with disabilities.




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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: 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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