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5.26 Integrated Accessibility Standards
Purpose:
Under the Accessibility for Ontarians with Disabilities Act (AODA), 2005 all public and private
sector organizations must meet the requirements of accessibility standards established by
regulation. This policy establishes the Integrated Accessibility Standards in the areas of
Employment, Information and Communication and Transportation for the Town of Goderich in
accordance with Ontario Regulation 191/11 and with the Ministry of Community and Social
Services intent to "streamline, align and phase-in accessibility requirements and allow for progress
on accessibility and reduce the regulatory burden for obligated organizations". This regulation
came into force July 1, 2011.
The requirements set out in this policy and the Integrated Accessibility Regulation (IAR) are not
a replacement or a substitution for the requirements established under the Human Rights Code nor
do the standards or policy limit any obligations owed to persons with disabilities under any other
legislation.
Scope and Responsibilities
This policy has been drafted in accordance with the Regulation and addresses how the Town of
Goderich will achieve accessibility through meeting the Regulation's requirements. It provides
the overall strategic direction that the Town of Goderich will follow to provide accessibility
supports to Ontarians with disabilities.
The requirements of the Regulation include:
- Establishment, implementation, maintenance and documentation of a multi-year
accessibility plan, which outlines the Town's strategy to prevent and remove
barriers and meet its requirements under the Regulation;
- Incorporation of accessibility criteria and features when procuring or acquiring
goods, services, or facilities. (Please refer to By-Law 38 of 2020);
- Training; and other specific requirements under the Information and
Communication, Employment and Transportation Standards.
Date of Policy
November 21, 2016
Policy Health & Safety
OH& S Act
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Policy Statement and Organizational Commitment
The Town is committed and guided by the four core principles of Dignity, Independence,
Integration and Equal Opportunity and supports the full inclusion of persons as set out in the
Canadian Charter of Rights and Freedoms, Ontario Human Rights Code, and the Accessibility for
Ontarians with Disabilities Act, 2005. The Town is committed to treating people with disabilities
in a way that allows them to maintain their dignity and independence. The Town will do so by
removing and preventing barriers to accessibility and meeting our accessibility requirements under
the Accessibility for Ontarians with Disability Act and Ontario's accessibility laws. The Town
shall use every effort to ensure that we meet the needs of people with disabilities, in a timely
manner, through the implementation of this policy.
Definitions:
"Accessible Formats" may include, but are not limited to, large print, recorded audio and
electronic formats, Braille and other formats usable by persons with disabilities;
"Accommodation" means the special arrangement made or assistance provided so that persons
with disabilities can participate in the experiences available to persons without disabilities.
Accommodation will vary depending on the person's unique needs;
"Communication Supports" may include, but are not limited to, captioning, alternative and
augmentative communication supports, plain language, sign language and other supports that
facilitate effective communications;
"Communications" means the interaction between two or more persons or entities, or any
combination of them, where information is provided, sent or received;
"Conversion Ready" means an electronic or digital format that facilitates conversion into an
accessible format;
"Designated Public Sector Organization" means every municipality and every person or
organization listed in Column 1 of Table 1 of Ontario Regulation 146/10 (Public Bodies and
Commission Public Bodies -- Definitions) made under the Public Service of Ontario Act, 2006
"IAP" means Individualized Accommodation Plan
"Information" includes data, facts and knowledge that exists in any format, including text, audio,
digital or images, and that conveys meaning.
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"Internet Website" means a collection of related web pages, images, videos or other digital assets
that are addressed relative to a common Uniform Resource Identifier (URI) and is accessible to
the public.
"Kiosk" means an interactive electronic terminal, including a point-of-sale device, intended for
public use that allows users to access one or more services or products or both.
"Mobility Aid" means a device used to facilitate the transport, in a seated posture, of a person
with a disability.
"Mobility Assistive Device" means a cane, walker, wheelchair, scooter or similar aid.
"New Internet Website" means either a website with a new domain name or a website with an
existing domain name undergoing a significant refresh.
"Redeployment" means the reassignment of employees to other departments or jobs within the
organization as an alternative to layoff, when a particular job or department has been eliminated.
"Unconvertible" means
(a) If it is not technically feasible to convert the information or communications;
(b) The technology to convert the information or communications is not readily available.
"Web Content Accessibility Guidelines" means the world wide web consortium
Recommendation entitled "Web Content Accessibility Guidelines (WCAG) 2.0".
General Provisions
Multi-Year Accessibility Plan
The Town of Goderich is part of the Huron County Accessibility Advisory Committee (HCAAC).
Each year, HCAAC updates its Multi-Year Accessibility Plan. Once adopted by Council, the
Town will post the information on the Town website and will provide it in alternative formats upon
request.
Procuring or Acquiring Goods, Services or Facilities
The Town will use accessibility criteria and features when procuring or acquiring goods, services
or facilities, except where it is not practical to do so (in which case, if requested, will provide an
explanation). Please refer to By-Law 38 of 2020.
Self-Service Kiosk
The Town shall have regard to the accessibility for persons with disabilities when designing,
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procuring or acquiring self-service kiosks.
Assistive Devices
The Town of Goderich will allow persons with disabilities to use their own personal assistive
devices to obtain, use or benefit from the services offered by the Town of Goderich.
Should a person with a disability be unable to access the Town's services through the use of their
own personal assistive device, the Town of Goderich will ensure the following measures:
- Determine if service is inaccessible, based upon individual requirements.
- Assess service delivery and potential service options to meet the needs of the individual.
- Notify person with disability of alternative service and how they can access the service,
temporarily or on a permanent basis.
Service Animals
For the purpose of this policy, a 'service animal' is defined as either:
- A "guide dog," as defined in section 1 of the Blind Persons Rights' Act; or
- A "service animal" for a person with a disability. For the purpose of this policy, an animal
is a service animal for a person with a disability,
o if it is readily apparent that the animal is used by the person for the reasons relating
to his or her disability; or
o if the person provides a letter from a physician or nurse confirming that the person
requires the animal for reasons relating to the disability.
The Town of Goderich will allow the person and the animal onto all Town of Goderich owned and
operated public facilities that are open to the public, and will ensure that the person is permitted to
keep the animal with him or her unless the animal is otherwise excluded by law.
If a service animal is excluded by law from the premises, the provider of goods or services shall
ensure that other measures are available to enable the person with a disability to obtain, use or
benefit from the provider's goods or services.
Support Persons
Support person means, in relation to a person with a disability, another person who accompanies
him or her in order to help with communication, mobility, personal care or medical needs or with
access to goods or services.
The Town of Goderich will allow people with disabilities, who require, to be accompanied by a
support person in all Town owned and operated public facilities. The Town of Goderich reserves
the right to request the person with a disability be accompanied by a support person, in the event
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that it is considered necessary to protect the health and safety of the person with a disability or
others on the premises.
The Town of Goderich will waive admission fees for support persons who accompany a person
with a disability, into facilities where admission is charged.
The member of public should notify a staff member about the presence of the support person.
If there is confidential information to be disclosed, consent must be received from the person with
the disability.
Training
The Town of Goderich is committed to training all staff and volunteers in accessible customer
service, other Ontario accessibility standards and aspects of the Ontario Human Rights Code that
relate to persons with disabilities.
In addition, the Town of Goderich will train:
a) Every person who deals with members of the public or other third parties on behalf of
the Town, whether the person does so as an employee, agent, volunteer or otherwise.
b) Every person who participates in developing the Town's policies, practices and
procedures governing the provision of goods or services to members of the public or
other third parties.
Training of our employees and volunteers on accessibility relates to their specific roles.
Training includes the requirements of this Policy and:
-
The purpose of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of
the Customer Service Standards
-
Town of Goderich policies related to the Customer Service Standards
-
How to interact and communicate with persons with various types of disability.
-
How to interact with persons with disabilities who use an assistive device or require the
assistance of a guide dog or other service animal or the assistance of a support person
-
How to use equipment or devices available on-site or otherwise that may help with the
provision of goods or services to a person with a disability.
-
What to do if a person with a particular type of disability is having difficulty accessing the
provider's goods or services.
The Town of Goderich trains every employee as soon as practicable after being hired and provides
training in respect of any changes to the policies.
The Town of Goderich logs and retains records which record the details of the training provided,
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as well as the name of the person(s) and date the training was completed.
The Town of Goderich will customize the training going forward, based on the actual experiences,
usage of the persons with disability in Town of Goderich owned or operated facilities and
legislative requirements as they come down from the province.
Information and Communication Standard
The Town will create, provide and receive information and communications in ways that are
accessible to people with disabilities.
If the Town determines that it is not technically feasible to convert the information or
communications or the technology to convert the information or communication is not readily
available, we will be obligated to provide the person that requires the information with:
a) an explanation as to why the information or communications are unconvertible; and
b) a summary of the unconvertible information or communications.
Service Disruption
If, in order to obtain, use or benefit from a provider's goods or services, persons with disabilities
usually use particular facilities or services of the provider (for example, elevators) and if there is a
temporary disruption in those facilities or services in whole or in part, the Town of Goderich shall
give notice of the disruption to the public.
Notice of the disruption must include information about the reason for the disruption, its
anticipated duration and a description of alternate facilities or services, if any, that are available.
Notice will be given by posting the information at a conspicuous place on premises owned or
operated by the provider of goods or services, as well as by posting it on the Town of Goderich
website.
If the Town of Goderich Website should expect a temporary service disruption, advance notice
where possible, shall be provided on the website.
Emergency Information
If the Town prepares emergency procedures, plans or public safety information and makes the
information available to the public, we shall provide the information in an accessible format or
with appropriate communication supports, as soon as practicable, upon request.
Feedback
Should a member of the public wish to make a complaint regarding the service they have received:
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1. The member of the public with the complaint or concern should have a discussion with the
staff person at the Town of Goderich who is involved in the situation.
2. Should the discussion not resolve the complaint or the member of the public is uncomfortable
discussing the issue with the staff person, the member of the public shall fill out a complaint
form. The staff person can assist the member of the public with the complaint form in a manner
that takes into consideration their disability.
3. The information to be provided by the member of the public shall include their personal
contact information, the date, a description of the complaint, and what the member of the
public is requesting in order to resolve the complaint. This information shall be documented
on the complaint form.
4. The complaint shall be forwarded to the Supervisor and Senior Management Team member
responsible for the department, and the Chief Administrative Officer.
5. The department Supervisor and/or Senior Management Team member of that department will
attempt to resolve the complaint in a timely manner.
6. The member of the public will be contacted once a resolution has been reached.
Should a member of the public wish to provide the Town of Goderich with a suggestion on how
to improve our service:
1. The member of the public will inform staff member of the suggestion.
2. Staff member will assist member of the public in filling out the suggestion form, should they
require assistance.
3. Member of the public will be notified in a timely manner of how the Town of Goderich will
proceed with their suggestion.
4. Staff response should include: an explanation of how we will implement the suggestion, a
response indicating further investigation or an explanation why we are unable to implement
the suggestion.
The Town of Goderich welcomes feedback on how we provide accessible customer service.
Customer feedback will help us identify barriers and respond to concerns. All feedback including
complaints and suggestions shall be recorded on a complaint/comment form, and forwarded to
the Department head, Senior Management Team member for that department, and the Chief
Administrative Officer. The Town of Goderich ensures our feedback process is accessible to
people with disabilities by providing or arranging for accessible formats and communication
supports, on request.
-
Accessible Formats and Communication Supports
The Town shall be obligated to provide or arrange for accessible formats and communication
supports for persons with disabilities:
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a) Upon request in a timely manner that takes into account the persons' accessibility needs
due to a disability;
b) At a cost that is no more than the regular cost charged to other persons;
c) Consult with the person making the request and determine suitability of an accessible
format or communication support;
d) Notify the public about the availability of accessible formats and communication supports.
Alternate formats that should be considered by the Town of Goderich and the person with the
disability will include, but are not limited to:
Print Requests:
Requests for alternate formats should be honoured in the most practical manner depending on the
media chosen, the size and complexity of the document, the quality and source of the documents,
the feasibility of the request (including the cost) and the number of documents to be converted. It
should be noted that when request for one of these formats is received and deemed feasible, staff
should make every attempt to respond to the request in the most practical manner and to the
satisfaction of the requestor. If it is determined that the format requested is not feasible, then other
alternate methods of providing the information should be explored that will still meet the needs of
the requestor (e.g. Audio CD or explaining the information verbally etc.).
a) Employee receives request from member of the public for alternate format.
b) Employee fills out alternative format request form.
c) Forwards request onto the relevant department and the appropriate corporate
department;
d) The department head and the appropriate corporate department determine feasibility;
e) Proceeds with alternate format request.
f) If not feasible; contact individual with feasible solution.
ASL Interpreter Request:
a) Employee receives request from public for ASL Interpreter.
b) Employee fills out alternative format request form.
c) Forwards request onto the relevant department and the appropriate corporate
department.
d) The department contacts Canadian Hearing Society to make request.
e) Once Canadian Hearing Society confirms attendance of ASL Interpreter, the department
contacts individual.
f) If ASL Interpreter is not available, individual will be contacted with an alternate solution.
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Feasibility will be determined based upon cost in relation to size of document and time associated
with processing document requests.
The time frame attached to the conversion process varies depending on the media chosen, the size,
complexity, quality of source documents and number of documents to be converted. Documents
shall be returned in a timely manner depending on the factors previously noted.
Conversion shall be processed in-house wherever possible. When a member of the public requests
a piece of Town documentation in a multiple format, the department of origin shall be responsible
for the cost of the conversion, materials and distribution, not the public requestor.
In-house printing, where possible, should adhere to the CNIB's Clear Print Standards.
Website Accessibility
Internet websites and web content controlled directly by the Town of Goderich or through a
contractual relationship that allows for modification of the product shall conform to the World
Wide Web Consortium Web Content Accessibility Guidelines (WSAG) 2.0, at Level A and AA
in accordance with the schedule set out in the AODA Integrated Accessibility Standards.
Public Libraries
- Public Libraries shall provide access to or arrange for the provision of access to accessible
materials where they exist;
- Public Libraries shall make information about the availability of accessible materials
publicly available and shall provide information in accessible format or with appropriate
communication supports, upon request;
- Public Library Boards may provide accessible formats for archival materials, special
collections and rare books.
Design of Public Spaces
The Town of Goderich will meet accessibility laws when building or making major changes to
public spaces. Our public spaces include:
- Recreational trails/beach access routes
- Outdoor public eating areas like picnic areas
- Outdoor play spaces, like playgrounds
- Accessible off-street parking
- Accessible on-street parking
- Service-related elements like service counters and waiting areas
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Employment Standard
The Employment Standard builds upon the existing requirements under the Ontario Human Rights
Code in relation to how to accommodate individuals with disabilities throughout the job
application process and the employment relationship. It applies in respect to employees and does
not apply to volunteers and other non-paid individuals.
The Town of Goderich notifies employees, job applicants and the public that accommodations can
be made during recruitment and hiring. Applicants are notified when they are individually selected
to participate in an assessment or selection process that accommodations are available upon
request. The Town will consult with the applicants and provide or arrange for suitable
accommodation.
The Town notifies successful applicants of policies for accommodating employees with disabilities
when making offers of employment. Staff are advised that supports are available for those with
disabilities as soon as practicable after they begin their employment. Updated information is also
provided to employees whenever there is a change to existing policies on the provision of job
accommodation that take into account an employee's accessibility needs due to a disability.
The Town will consult with employees when arranging for the provision of suitable
accommodation in a manner that takes into account the accessibility needs due to disability. The
Town will consult with the person making the request in determining the suitability of an
accessible format or communication supports specifically for:
a) information that is needed in order to perform the employee's job; and
b) information that is generally available to employees in the workplace
Where needed, the Town will also provide customized emergency information to help an employee
with a disability during an emergency. With the employee's consent, the Health and Safety
Coordinator will provide workplace emergency information to a designated person who is
providing assistance to that employee during an emergency.
The Town will provide the information as soon as practicable after we become aware of the need
for accommodation due to the employee's disability.
Individualized workplace emergency response information will be reviewed:
a) when the employee moves to a different location in the organization;
b) when the employee's overall accommodations needs or plans are reviewed; and
c) when the employer reviews its general emergency response policies.
In addition to the above, the Town has a written process to develop individual accommodation
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plans for employees which is found within this Health and Safety Program. Furthermore, the
Town has a written process for employees who have been absent from work due to a disability and
may require disability-related accommodations in order to return to work (See Section 5.26 -
Return-to-Work Policy).
The Town's performance management, career development and redeployment processes take into
account the accessibility needs of all employees.
Recruitment
The Town shall notify employees and the public about the availability of accommodations for
applicants with disabilities:
- During the recruitment process when job applicants are individually selected to participate
in an assessment or selection process;
- If a selected applicant requests an accommodation, the Town shall consult with the
applicant and provide or arrange for the provision of a suitable accommodation that takes
into account the applicant's disability;
- Notify successful applicants of the policies for accommodating employees with disabilities.
Employee Notification
The Town shall inform its employees, volunteers, Co-Op Students and Council members of its
policies used to support its employees with disabilities, including but not limited to, policies on
the provision of job accommodations that take into account an employee's accessibility needs due
to a disability:
- As required to new employees as soon as practicable after they begin their employment;
- Whenever there is a change to existing policies on the provision of job accommodations
that take into account an employee's accessibility needs due to a disability.
Accessible Formats
In addition, and where an employee, volunteer, Co-Op Student and Council member with a
disability requests, the Town will consult with the employee, volunteer, Co-Op Student and
Council member to provide or arrange for the provision of accessible formats and communication
supports for:
- information that is needed in order to perform the employees, volunteers, Co-Op Students
or Council member's job/work;
- information that is generally available to employees in the workplace; and
- consult with the employee making the request in determining the suitability of an accessible
format or communication support.
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Individual Accommodation Plan (IAP)
The Town shall have in place a written process for the development of a documented individual
accommodation plan for employees with a disability. Process to include:
- The employee's participation in the development of the IAP;
- Assessment on an individual basis;
- Identification of accommodations to be provided;
- Timelines for the provision of accommodations;
- The Town may request an evaluation by outside medical or other expert, at our expense, to
assist with determining accommodation and how to achieve accommodation;
- Employee may request the participation of a representative from their bargaining agent,
where represented, or otherwise a representative from the workplace not from a bargaining
agent;
- Steps taken to protect the privacy of the employee's personal information;
- Frequency with which the IAP will be reviewed and updated and the manner in which it
will be done;
- If denied, the reasons for denial are to be provided to the employee;
- A format that takes into account the employee's disability needs;
- If requested, any information regarding accessible formats and communication supports
provided;
- Identification of any other accommodation that is to be provided.
Return to Work
The Town will have in place a return to work process for employees who have been absent from
work due to a disability and require disability-related accommodations in order to return to work.
Such processes must be documented and must outline the steps that the Town will take to facilitate
the return to work and include an individual accommodation plan.
Performance Management, Career Development and Advancement, and Redeployment
The Town will take into account the accommodation needs and/or individual accommodation
plans of employees when:
- Using performance management processes;
- Providing career development and advancement information;
- Using redeployment procedures.
Workplace Emergency Response Information
The Town shall provide individualized workplace emergency response information to employees
who have a disability:
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- If the disability is such that the individualized information is necessary and the employer
is aware of the need for accommodation due to the employee's disability;
- If the employee who receives an individual workplace emergency response information
requires assistance and with the employee's consent, the Town shall provide the workplace
emergency information to the person designated by the Town to provide assistance to the
employee;
- As soon as practicable after becoming aware of the need for accommodation due to the
employee's disability;
- And will review the individualized workplace emergency response information when the
employee moves to a different location in the organization, when overall accommodations
needs or plans are reviewed and when the employer reviews its general emergency
response policies.
Transportation Standard
The Transportation Standard will make it easier for people to travel in Ontario, including persons
with disabilities, older Ontarians and families traveling with children in strollers.
The Town does not have a public transit system, but is responsible for issuing taxi licenses,
therefore has obligations under the Transportation Standard.
The Town shall:
- Consult with persons with disabilities and the public to determine proportion of accessible
taxicabs required in the community, including steps to meet the need;
- Ensure taxicabs do not charge a higher fare or additional fee to persons with disabilities;
- Ensure taxicabs do not charge a fee for storage of assistive devices;
- Ensure taxicabs have appropriate information displayed both the rear bumper and available
in an accessible format to passengers.
Evaluation
An annual review of the policy will be conducted by the JHSC and the Safety Coordinator.
Required Forms
TG21 - Individual Emergency Workplace Response Plan
Appendix C: Memo for Sign-Off by Newly Hired Staff, Volunteers, Co-Op Students or Town
Council members - Added November 21, 2016; Revised January 2023
Revision History of this Policy
September 23, 2013 - Complete program revision and re-issue using new format.
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November 21, 2016 - Program revision as a result of the Legislature's June 8 changes to the AODA
Accessible Customer Service Standard and the Integrated Accessibility Standards. These changes
came out of a recommendation from the Standards Development Committee which reviewed the
AODA legislation 5 years after it came into effect. The changes came into effect on July 1, 2016
and the policy has now added volunteers, Co-Op Students and Council members to the Training,
Employee Notification and Accessible Formats section.
February 2023 - Program revision to include training and feedback processes; employment
standards
Standard/Legislation
Accessibility for Ontarians with Disabilities Act
This section of the Health and Safety Program, defined as Section 5.26 "Integrated Accessibility
Standards" is publicly available. Accessible formats are available upon request.