Interacting with Service Animals in School


Our last article outlined how an education standard could include a province-wide policy for allowing students to bring their service animals to school. Once an elementary or high school student’s service animal is allowed in school, staff should know how to interact with it. In addition, fellow staff members may also have service animals. Moreover, staff of other educational institutions should also know how to behave around service animals. For instance, staff at universities, colleges, and private schools should know how to interact with the service animals of students or colleagues. In this article, we suggest some best practices for interacting with service animals in school.

Interacting with Service Animals in School

Do’s and don’ts when encountering service animals

When service animals are at school, staff should know what to do or not do. They should also be able to explain these do’s and don’ts to other students in the class or school. Here is a list with some suggestions.

For instance, do:

  • Pay attention to the student or staff member, not the animal
  • Ask what tasks the animal assists with, not what the student or staff member’s diagnosis is

On the other hand, don’t:

  • Ask that the animal be left elsewhere
  • Pet the animal, unless its owner gives permission
  • Call the animal
  • Feed the animal
  • Entice the animal with toys
  • Disturb the animal if it is sleeping

Service Animal Responsibilities

Older service-animal owners, such as high school students, adult learners, or staff, should have full responsibility for interacting with their service animals in school. For instance, the animal’s owner should be in charge of:

  • Giving commands, such as “sit” or “stay”
  • Feeding the animal
  • Taking it outside when needed, and cleaning up after it
  • Correcting it if it does something wrong

When students are younger, an adult handler may share or take responsibility for some or all of these tasks. Some service-animal owners may want to tell students about why their animal is there and what it does. Alternatively, others may want their animal’s handler to do so. some owners may also be willing to talk briefly about their disabilities. However, others may prefer to answer curious classmates’ questions but not draw extra attention to the animal. Staff should work with each student or staff member to find out which approach they would like to take.

Exceptions

Under the Customer Service Standards of the AODA, service animals are allowed almost anywhere the public can go. Exceptions include places where food is made, but not where it is served. If school board policies follow this standard, service animals should be able to go almost everywhere their students and staff do. For instance, students and staff should be able to bring their service animals with them:

  • In class
  • In the school yard
  • In the cafeteria

However, students and staff should not bring their service animals into school kitchens or food laboratories. If a student or staff member needs to use them, such as for a cooking or baking activity, their service animal should stay in a different room. Meanwhile, staff should provide a different way for the student or colleague to receive the help the animal usually gives. For instance, an animal may:

  • Calm a student
  • Alert a staff member to sounds
  • Open doors

Staff should work with the animal’s owner to plan how the student or colleague will access the event without the animal.

School staff can best serve all their students when they know about interacting with service animals in school.




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Service Animals in Schools


The AODA does not yet have an education standard. Two committees are making recommendations about what an education standard should include. Our recent articles have considered how the education standards can build on requirements from the AODA’s existing standards. Now, we will explore new mandates that the education standards could create. One issue that an education standard should address is service animals in schools. Currently, students must ask their school boards if they can bring their service animals to school. Every school board must make its own service animal policy. A new standard is needed for service animals in schools.

Service Animals

Service animals are animals, typically dogs, trained to help people with disabilities maintain independence. They help people with many disabilities and medical conditions, such as:

  • Visual impairments
  • Diabetes
  • Epilepsy
  • Autism
  • Hearing disabilities
  • Physical disabilities

Service animals are working animals with duties. They are not pets. Instead, they are assistants or guides and they usually wear harnesses or vests identifying them as service animals.

Moreover, service animals have specialized training to perform tasks, such as:

  • Guiding a person around obstacles
  • Warning a person about low blood sugar
  • Protecting a person during seizures
  • Calming a person in an environment with too much sensory stimulation and preventing behavioural outbursts
  • Retrieving out-of-reach objects
  • Alerting a person to sounds, such as ringing phones or fire alarms

In addition, service animals are also trained to behave appropriately in public places where non-service-animals are not allowed. For example, good service animal behaviour includes:

  • Focusing on the handler’s needs
  • Avoiding distractions
  • Never barking, growling, or jumping

Standard Needed for Service Animals in Schools

Under the Integrated Accessibility Standards Regulation (IASR), service animals are welcome in all public places. However, the Human Rights Code ruled in 2017 that schools are not places that all members of the public have access to. This ruling means that students with service animals cannot automatically bring their animals to school with them. Instead, they must ask their school boards if they can bring the animal. School boards then make decisions on a case-by-case basis.

There are seventy-two school boards in Ontario. Currently, each school board must develop its own policy  outlining the process families should follow when requesting the accommodation of service animals in schools. As a result, policies may differ widely. Students’ chances to bring service animals to school may depend not on their needs, but on where they live.

When school boards do not have strong policies for students with service animals, children may not receive the classroom accommodations they need. Moreover, students should have the same chance for this accommodation, no matter where they live. A province-wide policy in the education standard could solve this problem. This policy could provide clear guidelines for allowing service animals in schools. It could also offer guidance for situations where staff and students have conflicting accommodation needs. For instance, it could include ways to balance the needs of a service-animal handler and someone with severe allergies to animals.

Our next article will outline some best practices for interacting with service animals.




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Wheel-Trans Users Fear Loss of Service Under TTC’s Plans to Have Thousands Reassessed


By Ben SpurrTransportation Reporter
Mon., Sept. 23, 2019

Some Wheel-Trans users fear they could soon lose access to the specialized service as the TTC is set to start compelling thousands of clients who for years have relied on the paratransit program to reregister for it.

The TTC says that starting as early as this fall, users who signed up for Wheel-Trans before 2017 will have to be reassessed to determine their eligibility. The TTC estimates at least 25,000 customers will have to go through the process, which they expect will take years.

Wheel-Trans user Terri-Lynn Langdon waits at a west-end stop after dropping off her daughter to daycare while on her way to work. She fears her access to the service will change as a result of the TTC forcing all users to re-register for the service.

According to the transit agency, the need to reassess Wheel-Trans clients stems from the provincial Accessibility for Ontarians with Disabilities Act (AODA). But many who use the service are apprehensive.

“I don’t know of anyone in the community that’s supportive of it,” said Wheel-Trans user Terri-Lynn Langdon.

Wheel-Trans is the division of the TTC that serves transit users who have physical, cognitive, sensory and mental health disabilities. This year it was projected to provide 4.3 million trips, with a budget of $149 million.

Those eligible for the program have traditionally been able to take “door-to-door” trips on Wheel-Trans vehicles or contracted taxis for the price of a regular TTC fare.

But changes are coming as a result of AODA, legislation the then-Ontario Liberal government passed in 2005 to set provincewide accessibility standards that have to be met by 2025. The law compels the TTC to introduce three categories for Wheel-Trans eligibility: unconditional, conditional and temporary.

To fall under the unconditional category, customers must have a disability that effectively prevents them from using conventional TTC service at any time.

Riders falling under the conditional category have a disability that limits their ability to “consistently” use conventional transit, but are deemed able to use the conventional TTC system under certain conditions, such as if their trip is between two subway stations that are designated accessible.

Temporary eligibility applies to people with non-permanent disabilities.

While riders with the unconditional designation qualify for door-to-door Wheel-Trans trips, the provincial regulations state the TTC can deny Wheel-Trans service to people who have conditional or temporary designations in instances where they’re able to use the conventional transit system.

Although the TTC has been sorting new clients into the three designations since January 2017 as it moves toward full compliance with the act, the thousands of clients who enrolled prior to that date will have to reregister to determine which category they fall under.

In addition to ensuring clients who signed up before and after January 2017 are treated the same, TTC spokesperson Stuart Green said the reassessment process will allow the agency to “make better use of limited resources” and is the “fairest way to ensure that the customer receives the level of service that best matches their abilities.”

He said the agency expects “the vast majority of customers reregistering” will retain “some level of Wheel-Trans access.”

The TTC hasn’t started enforcing the new eligibility criteria for any customers, which means clients with the conditional eligibility still have the option of choosing door-to-door Wheel-Trans service. Green didn’t give a timeline for when the new rules will be put into effect, saying only it would be sometime “in the future.”

He said the TTC expects as many as 60 per cent of reregistered riders to fall into the conditional category, meaning thousands of people who currently receive door-to-door service on Wheel-Trans vehicles will be compelled to use the conventional system for at least some trips. In some cases they will be offered Wheel-Trans service for a segment of a journey but be required to take the conventional system for the remainder.

Using the conventional system is something the TTC says is getting easier as the agency improves accessibility by buying low-floor buses and streetcars, and making extensive renovations to subway stations. Forty-five of the network’s 75 subway stations are accessible.

There are also advantages to disabled customers being able the conventional system, because door-to-door Wheel-Trans trips have to be booked in advance, and being able to simply take the next bus, streetcar or subway allows riders more flexibility.

Under the provincial legislation, the TTC must make the entire transit system accessible by 2025. But even then it’s expected many people with mobility issues will still require Wheel-Trans.

Langdon, who uses a wheelchair, doesn’t think the new assessment process is fair. She was placed in the “conditional” category when she applied for the service in the summer of 2018 after she became pregnant with her daughter.

She said the conditions of her new designation will allow her to use Wheel-Trans during rush hour and when weather is bad, but at other times she’ll have to take the conventional system.

Langdon says the criteria doesn’t take into account the fact that when she travels with her young daughter it’s impossible for her to navigate both her own wheelchair and a stroller on the conventional system.

She said she tried to get the conditional designation reversed, “because it’s not true, it doesn’t reflect how I have to take transit and the barriers that I experience with it.”

Louise Bark, a 59-year-old wheelchair user who registered with Wheel-Trans prior to 2017, says she’s worried the new eligibility criteria will also force her to use the conventional TTC network.

“I may very easily be perceived to be a ‘conditional,’ and that’s scary to me,” she said.

Her concern is that she has a power wheelchair that the TTC may assume allows her to easily get to a transit stop to take an accessible bus or streetcar, while the reality isn’t that simple. She said she has sensitivities to pain, extreme temperatures and scent that would be difficult to objectively quantify on an application form but which can make riding on a bumpy, crowded vehicle unbearable.

Bark said she tries to stay active in order to fend off isolation and depression, and not being able to get around the city to volunteer jobs and to go exercise would significantly reduce her quality of life.

“I don’t know until I actually do the application. But these are things that are definitely on my mind,” she said.

Some accessibility advocates say they understand why the TTC is making users reregister. Mazin Aribi, who chairs the Advisory Committee on Accessible Transit (ACAT), a volunteer group that advises the TTC on these issues, said that as the system becomes more accessible it only makes sense to get people who couldn’t previously use the conventional system to start riding it.

Aribi uses a wheelchair, and said improvements like the TTC’s introduction of accessible streetcars has allowed him to travel on routes he wasn’t able to before, such as Queen St.

But he acknowledged there is anxiety among some Wheel-Trans clients about being reassessed.

“The TTC’s got to do it right, and we are monitoring it very carefully, and we need it to be done correctly. They’re asking ACAT’s advice, and we’re providing. It’s a process,” he said.

Ben Spurr is a Toronto-based reporter covering transportation. Reach him by email at [email protected] or follow him on Twitter: @BenSpurr

Original at https://www.thestar.com/news/gta/2019/09/23/wheel-trans-users-fear-loss-of-service-under-ttcs-plans-to-have-thousands-reassessed.html




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


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

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

September 10, 2019

SUMMARY

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Context

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

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

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

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

Definition of “Service Animal”

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Implementation

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

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




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


Accessibility for Ontarians with Disabilities Act Alliance Update

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

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

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

September 10, 2019

          SUMMARY

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

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

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

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

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

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

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

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

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

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

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

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

MORE DETAILS

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

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

Policy/Program Memorandum No. 163

Date of Issue: September 9, 2019

Effective: Subject: Until revoked or modified

Application: School Board Policies on Service Animals

Directors of Education

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

Principals of Elementary Schools

Principals of Secondary Schools

Purpose

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

School boards are expected to:

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

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

Context

 

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

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

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

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

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

Definition of “Service Animal”

 

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

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

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

Components of School Board Policies on Service Animals

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

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

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

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

Policies should include the following:

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

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

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

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

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

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

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

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

Implementation

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

School Board Reporting

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

data collected.

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

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

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

Commission, 2018), pp. 59–60.

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



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Creating a More Robust Customer Service Standards in Healthcare


Currently, the AODA does not have a healthcare standard. A committee is making recommendations about what a healthcare standard should include. In the meantime, however, there are still AODA requirements for healthcare providers to follow. The Customer Service Standards have regulations that apply to healthcare providers. When providers follow these requirements, they make healthcare services more accessible to patients, workers, and visitors with disabilities. Customer service standards in healthcare apply to service in:

  • Doctors’ offices
  • Hospitals
  • Walk-in clinics
  • Wellness centres
  • Pharmacies
  • Labs
  • Health Regulating Colleges

Current Customer Service Standards in Healthcare

Under the Customer Service Standards, healthcare providers need to make their goods, services, and facilities accessible to people with disabilities. For instance, providers must:

Stronger Customer Service Standards in Healthcare are Needed

The Customer Service Standards mandate many important requirements for healthcare providers and other organizations to become accessible. However, there are no guidelines advising organizations on how to implement these requirements. For instance, the mandate about training lists the topics that the training needs to address. However, the mandate does not state how providers can educate themselves on these topics to train their employees. In addition, providers can choose types of training that offer different levels of information, such as classroom sessions or handouts. On one hand, this lack of direction can be helpful. For instance, organizations developing their own policies and training can tailor them specifically to their clientele and services. On the other hand, the lack of guidance is harmful when providers have no experience with accessibility.

Accessibility Training

Providers uncomfortable working with patients who have disabilities may not know how to train themselves or their employees. They may easily create brief policies and training modules that do not cover everything they should. When healthcare workers receive little accessibility training, they may think that a patient’s health problem is due to their disability when the two concerns are not connected. For example, a patient who uses a wheelchair may come to the emergency room. Staff with little accessibility training may spend time trying to learn about the patient’s disability instead of diagnosing their health concern.

Moreover, a healthcare worker may not know how to accommodate treatment to a patient’s disability. For instance, a patient with an intellectual disability may have multiple treatment options with different instructions and side effects. Staff might think it best to choose one treatment instead of taking the time to communicate all options in an accessible way.

Thorough accessibility training for all healthcare workers would ensure that all Ontarians have quality care. A healthcare standard should ensure that all Ontarians have equal access to medical practitioners who respect and understand their needs. Therefore, the new healthcare standard should include specific recommendations about what training and policies should include. However, all customer service organizations should show equal respect and understanding for customers with disabilities. Revised Customer Service Standards in healthcare could also benefit from more guidance within the training mandate.



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How Ontario’s Human Rights Tribunal Went Off the Rails in an Important Disability Accessibility Case–Read the New Article by AODA Alliance Chair David Lepofsky on the Tribunal’s Ruling Against an 8-Year-Old Student With Autism Who Wanted to Bring His Autism Service Dog to School


Accessibility for Ontarians with Disabilities Act Alliance Update

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

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

How Ontario’s Human Rights Tribunal Went Off the Rails in an Important  Disability Accessibility Case–Read the New Article by AODA Alliance Chair David Lepofsky on the Tribunal’s Ruling Against an 8-Year-Old Student With Autism Who Wanted to Bring His Autism Service Dog to School

July 5, 2019

          SUMMARY

Two years ago, the Human Rights Tribunal of Ontario rendered a controversial and deeply troubling decision about the rights of students with disabilities in Ontario schools. An 8-year-old boy with autism wanted to bring his certified autism service dog to school with him. The school board refused. His family filed a human rights complaint with the Human Rights Tribunal of Ontario. The Tribunal ruled in favour of the school board and against the student.

Many reacted with surprise or shock at this ruling. Now you have a chance to delve deeper and see what went wrong. AODA Alliance Chair David Lepofsky has written a 28-page article analyzing this human rights decision. He found that there are several problems with the decision. His article is entitled “Ontario’s Human Rights Tribunal Bungles the School Boards’ Human Rights Duty to Accommodate Students with Disabilities – J.F. v Waterloo District Catholic School Board – An Erroneous Rejection of A Student’s Request to Bring His Autism Service Dog to School.”

In the fall of 2020, this article will be published in volume 40.1 of the National Journal of Constitutional Law. You don’t need any legal training or background to read this article.

Below we set out this article’s introduction. You can download the entire article in an accessible MS Word format by clicking here https://www.aodaalliance.org/wp-content/uploads/2019/07/ASD-Dog-Article-by-David-Lepofsky-Accepted-for-Publication-in-the-NJCL-dated-july-4-2019.docx

The published text of this article next year may have minor editorial changes.

The AODA Alliance has pressed the Ford Government for over a year to get the Education Standards Development Committee back to work, developing recommendations for what should be included in an Education Accessibility Standard to be enacted under the AODA. Among other things, we plan to propose detailed standards to bind all schools on letting students with autism bring their qualified service animal to school.

AODA Alliance Chair David Lepofsky is a member of the K-12 Education Standards Development Committee. On March 7, 2019, the Ford Government said it was lifting that freeze. Yet no date for the next meeting of that AODA Standards Development Committee is set.

There have been 155 days since the Ford Government received the final report of the Independent Review of the implementation and enforcement of the Accessibility for Ontarians with Disabilities Act by former Lieutenant Governor David Onley. That report found that Ontario is full of “soul-crushing” barriers that impede over 1.9 million Ontarians with disabilities. It calls on the Ontario Government to show new leadership and to take strong action on accessibility for people with disabilities. the Ford Government has not announced a plan to implement the Onley Report.

          MORE DETAILS

Excerpt from the Article ” Ontario’s Human Rights Tribunal Bungles the School Boards’ Human Rights Duty to Accommodate Students with Disabilities – J.F. v Waterloo District Catholic School Board – An Erroneous Rejection of A Student’s Request to Bring His Autism Service Dog to School” by AODA Alliance Chair David Lepofsky to be Published in Volume 40.1 of the National Journal of Constitutional Law

A child with autism spectrum disorder (ASD) can experience anxiety, challenges in self-regulating their mood and behaviours, and difficulty adjusting to transitions. Helpful measures to address these needs contribute to a child’s developmental progress. An autism service dog can help with these needs.

ASD’s emotional, behavioural and communicational impacts on a child cannot be measured, day-by-day, by a blood test or thermometer. It is typically not possible to isolate and quantify exactly when and how an intervention such as a service dog has helped, any more than an omelet can be unscrambled. This does not derogate from the benefits experienced from using such a service dog. For children with ASD, as with many others, trial and error is so often the best approach.

This article examines a troubling case where a school board, and then Ontario’s Human Rights Tribunal, each got it wrong when it came to accommodating a student with ASD. In J.F. v. Waterloo District Catholic School Board, an eight-year-old boy with ASD benefitted at home from a trained autism service dog. His family asked the school board to let him bring the service dog to school, to help accommodate his ASD. The school board said no. The Tribunal sided with the board.

There was no showing that board employees, addressing this issue, had prior knowledge, experience or expertise with autism service dogs, or that those officials tried to observe the boy outside school when using the autism service dog. There was no indication that the board took any proactive steps to learn about the benefits of these service dogs, or considered a trial period with this boy bringing his autism service dog to school.

In contrast, some other Ontario school boards let students with ASD bring a service dog to school. If other school boards can do so, the Waterloo District Catholic School Board could do the same, rather than putting barriers in the path of a vulnerable student.

The boy’s family filed a human rights complaint against the school board. It alleged a violation of his right to equal treatment in education without discrimination due to his disability, guaranteed by s. 1 of the Ontario Human Rights Code. The family argued that the board failed to fulfil its substantive duty to accommodate (its duty to provide a disability-related accommodation he needed), and its procedural duty to accommodate (its duty to adequately investigate his disability-related needs and the options for accommodating them). In a widely-publicized and erroneous decision, the Tribunal ruled against the boy on both scores.

The school board and the Human Rights Tribunal of Ontario failed to properly apply human rights principles to a vulnerable student with an undisputed disability. This case provides a powerful illustration of a Human Rights Tribunal that failed to properly apply both the human rights procedural duty to accommodate and the substantive duty to accommodate. The school board’s failure to fulfil its procedural duty to accommodate this boy’s disability also serves to substantially weaken the board’s claim that it met its substantive duty to accommodate.

As well, this case illustrates unfair accessibility barriers that students with disabilities too often face in Ontario’s education system. It shows how families must repeatedly fight against the same barriers, at school board after school board. This case also highlights serious flaws in Ontario’s controversial system for enforcing human rights. It shows why Ontario needs a strong and effective Education Accessibility Standard under the Accessibility for Ontarians with Disabilities Act, to remove such recurring disability accessibility barriers in Ontario’s education system.

Had this school board redirected more of its effort and public money towards working out a way to let this student bring his autism service dog to school, rather than fighting against him, a more positive outcome here was likely. Instead the Board marshalled its formidable legal resources to fight against this boy.

This article first delineates the case’s largely undisputed facts. It then explores the evolution of the procedural duty to accommodate in human rights law. The importance of the duty to accommodate in the education context is then investigated.

Attention next turns to problems in the Tribunal’s reasoning that led it to find that the school board did not violate the procedural duty to accommodate. After that, serious problems are identified with the Tribunal’s finding that the school board did not violate its substantive duty to accommodate.

This article concludes with a look more broadly at this case’s implications. This case typifies problems since 2008 with the way human rights are enforced in Ontario. This case also illustrates the need for the Ontario Government to adopt a reformed approach to the education of students with disabilities in Ontario schools as well as the need for an Education Accessibility Standard to be enacted under the Accessibility for Ontarians with Disabilities Act.



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Accessible Service in Sports Venues


Under the Customer Service Standards of the AODA, service providers must make their goods, services, and facilities accessible to customers with disabilities. Our last article outlined accessible information in sports venues, such as arenas and stadiums. In this article, we cover best practices for accessible service in sports venues. In particular, we look at how staff can find ways to make their premises welcoming to fans who need accessible features that a venue does not have yet.

Accessible Service in Sports Venues

Service Animals, Support Persons,  and Assistive Devices

Accessible sports venues must welcome all guests who enter with assistive devices, support persons, or service animals. Service animals are legally permitted in all areas open to the public, including areas where fans buy or consume food. Venues should work with fans who have service animals to book seats with room for the animals. Similarly, if arenas or stadiums choose to waive or reduce fees for support-person tickets, they should advertise this pricing.

Training Staff

Venues must ensure that their staff are trained to interact with fans who have disabilities. Staff should understand how to communicate with fans, both in person and remotely. Additionally, staff should know where all the accessible features of their buildings or outdoor amenities are, including seats offering different kinds of accessibility. For instance, a fan with a visual impairment might want to book a front seat on the left side of the stadium. However, this fan may not be able to access the stadium’s online seating map. In this case, the fan may choose to book by phone so that a staff member can assist them.

Communication Support Awareness

Similarly, staff should know about any communication supports their locations offer. For example, staff should know whether certain games or concerts will be available with:

  • American Sign Language (ASL) interpretation
  • Closed or open captioning
  • Assistive listening devices
  • Live description

Moreover, staff should know which equipment is used for which service, where it is stored, and how to trouble-shoot when it malfunctions.

If venues cannot offer some or all of these services, staff can still offer fans an accessible experience. For instance, if a venue cannot offer live description for games, it can waive the ticket fee for companions of fans with visual disabilities. A companion can act as a support person and give a verbal play-by-play of the game.

Finally, accessible service in sports venues involves welcoming amateur and professional athletes with disabilities. Arenas and stadiums should seek out and host players and teams with disabilities. Our next set of articles will cover a few sports programs for athletes with disabilities. Programs range from recreational to competitive. Athletes with disabilities participate in summer and winter sports on the local, national, and international levels.



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Providing Accessible Service in Amusement Parks


Under the Customer Service Standards of the AODA, service providers must make their goods, services, and facilities accessible to customers with disabilities. Our last article outlined accessible information in amusement parks. In this article, we cover best practices for accessible service in amusement parks. In particular, we look at how staff can find ways to make their premises welcoming to clients who need accessible features that an amusement park does not have yet.

Providing Accessible Service in Amusement Parks

Service Animals, Support Persons,  and Assistive Devices

Parks must welcome all guests who enter with assistive devices, support persons, or service animals. If parks choose to waive or reduce fees for support-person tickets, they should advertise this pricing. Service animals are legally permitted in all areas open to the public, including dining areas. Park staff and websites should alert guests to the locations of all nearby service animal relief areas.

Structural Features

If parks have any accessible structural features, staff should know what and where they are. For example, staff should know where guests can find accessible parking, entrances, and washrooms.

Staff Assistance

Furthermore, parks must train their staff to interact with guests who have disabilities. Training should show staff how to help guests access their services if their grounds or buildings lack the features those guests need. Staff should understand how to communicate with guests, both in person and remotely.

In addition, staff members should be available to greet guests and ask if they need any assistance. In this way, they can make guests aware that they are willing to provide services if their parks lack certain amenities. For instance, if guests cannot read signs, staff should be able to direct them to the areas or attractions they want to reach.

Similarly, staff should know which kinds of assistive devices guests can bring with them on rides. For example, staff should know whether a guest can ride with their own:

  • Wheelchair
  • Scooter
  • Walker
  • Crutches
  • Cane

If a guest cannot ride with their own device, staff should know whether a guest can:

  • Approach the ride with the device but ride without it
  • Transfer from large devices into on-site devices or ride seats

Staff should also return riders’ devices to them as soon as possible. For instance, riders who entered a ride using a device may need to have the device back in order to exit the ride. Some guests might bring a support person to help them perform any or all of these tasks. However, parks should not require that a guest has a support person with them.

Accessible Format Awareness

When parks offer accessible versions of hard-copy print, such as pamphlets, guides, maps, or other documents, staff need to be aware of:

  • What information is available in what format(s)
  • Where hard copies are kept 
  • Whether hard-copy Braille or large print versions can be created upon request
  • How clients can find web versions
  • Whether alternate-format versions are up-to-date

Staff should know the differences between a current printed version of a document and the version a guest can read. For example, staff can keep a printed list of the differences clipped to the Braille version of a document. They can then let the guest know what the differences are.

If a document is not available in any of the formats a guest can use, staff should read the document to the guest. If it is a form, staff should fill it in according to the guest’s directions.

Communication Support Awareness

Similarly, when parks provide communication supports for performances or other interactions, staff should know:

  • What supports are available for what kinds of interaction
  • Where on-site communication devices are stored, and best practices for serving guests using them
  • Whether plain-language versions of documents are available and how to access them
  • How to arrange Sign language interpretation
  • How far in advance arrangements should be made

Accessible service in amusement parks ensures that all guests can have fun with their families and friends.



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