City of Toronto Accessibility Plan 2015 Progress Status Report

City of Toronto Accessibility Plan – 2015 Progress Status ReportJune 2, 2016

City of Toronto Accessibility Plan – 2015 Progress Status Report

Table of Contents

1Introduction

1.1Multi-Year Accessibility Plan, Annual Status Report

1.2New Elements in the Status Report on the Multi-Year Accessibility Plan

2City of Toronto Statement of Commitment to Creating an Accessible City

3Accessibility for Ontarians with Disabilities Act, Part VII, Municipal Accessibility Advisory Committees

4Accessibility Standards for Customer Service

5Integrated Accessibility Standards Regulation (IASR)

5.1General Requirements

5.2Information and Communications Standards

5.3Employment Standards

5.4Transportation Standards

5.5Design of Public Spaces Standards (DOPS)

6Compliance

7Reference Information

1Introduction

The Accessibility for Ontarians with Disabilities Act (AODA) called for the development of standards and regulations to make Ontario fully accessible to people with disabilities by the year 2025. In 2007 the Accessibility Standards for Customer Service (ASCS)regulationwas published as Ontario Regulation 429/07. In 2011 the Integrated Accessibility Standards Regulation (IASR) was published as Ontario Regulation 191/11 which was amended in 2012 by Ontario Regulation 413/12.

The IASR requires a multi-year Accessibility Plan. The City's multi-year Accessibility Plan outlines the overall strategies of how the City will meet accessibility standards in the AODA Integrated Accessibility Standards Regulation (IASR). The current plan covers the period from 2012 - 2016. It is a living document which will be reviewed and updated at least once every 5 years.

1.1Multi-Year Accessibility Plan, Annual Progress Status Report

This progress status report is a report on the progress of measures taken by the City of Toronto to implement the City's multi-year Accessibility Plan (2012 – 2016), which outlines the City's strategy to prevent and remove barriers and meet requirements of the Integrated Accessibility Standards Regulation (IASR) under the Accessibility for Ontarians with Disabilities Act (AODA).

1.2New Elements in the Status Report on the Multi-Year Accessibility Plan

Since the current multi-year Accessibility Plan was developed, the AODA Integrated Accessibility Standards Regulation was amended by Ontario Regulation 413/12 to include the Standards for the Design of Public Spaces, which came into effect for municipalities January 1, 2016. This status report includes efforts the City has undertaken to implement these requirements.

This status report also addresses requirements from the AODAthat are outside the scope of the IASR, namely municipal Accessibility Advisory Committees, and requirements of the AODA's Accessibility Standards for Customer Service. This will align progress tracking with reporting requirements to the Accessibility Directorate of Ontario, within the Ministry Economic Development, Employment and Infrastructure. The City of Toronto is required by legislationto review and update the multi-year Accessibility Plan at least once every 5 years. This process is currently underway and will include these new elements.

In addition to the legislated requirements, the Cityalso undertakes accessibility improvements that are not driven by legislation. A section has been added to report on progress of these items.

2City of Toronto Statement of Commitment to Creating an Accessible City

Passed by City Council in August 2009 [EX33.4], the City of Toronto published the following Statement of Commitment to Creating an Accessible City:

Diverse communities and groups make up the population of Toronto. The City of Toronto values the contributions made by all its people and believes that diversity among its people has strengthened Toronto.

The City of Toronto is committed to building an inclusive society and providing an accessible environment in which all individuals have access to the City’s services and programs in a way that respects the dignity and independence of people with disabilities.

The City of Toronto supports the goals of the Accessibility for Ontarians with Disabilities Act (AODA) and will establish policies, practices and procedures which are consistent with the accessibility standards established under the AODA, including accessible customer service, information and communication, employment, the built environment and transportation.

The City of Toronto will continue to prevent barriers by designing inclusively and supporting positive attitudes that address "ableism" - attitudes which devalue and limit the potential of persons with disabilities.

In working towards its goals under this Statement, the City of Toronto is committed to meeting the requirements of existing legislation and to its own policies and goals related to the identification, removal and prevention of barriers to people with disabilities and becoming a barrier free city.

3Accessibility for Ontarians with Disabilities Act, Part VII, Municipal Accessibility Advisory Committees

In accordance with Part VII of the Act, municipalities over 10,000 people must have an Accessibility Advisory Committee (AAC). The City of Toronto's AAC was renamed in July 2015 as the Disability, Access, and Inclusion Advisory Committee (DAIAC). Formerly known as the Disability Issues Committee, this committee has existed in various forms since 2001.

This advisory committee provides advice to City Council on the elimination of barriers faced by people with disabilities and acts as a liaison with external bodies on barriers to participation in public life and to the achievement of social, cultural and economic well-being of people with disabilities. The committee also provides advice to City Council about the requirements and implementation of accessibility standards and the preparation, implementation and effectiveness of accessibility reports as required by the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

4Accessibility Standards for Customer Service

(Implementation Date for all Accessible Customer Service requirements: January 1, 2010)

AODA Requirements / Implementation Status / Comments
Policy Requirements (ASCS Section 5)

Establish policies, practices, and procedures, consistent with principles of equality, integration, dignity, and independence, that govern provision of goods, and services to persons with disabilities (ASCS, S.3 (1)(2))
Allow people to use their own assistive devices when accessing goods, services (ASCS, S.3 (3))
Communicate in a manner that takes into account a person's disability (ASCS, S.3 (4))
Document and publish policies, practices and procedures, and provide in accessible format upon request (ASCS, S.3 (5))
Allow service animals, unless excluded by law. If excluded, provide alternate measures (ASCS, S.4 (2)(3))
Allow support persons. Where fees are charged, provide notice of any fees applicable to support persons (ASCS, S.4 (6))
Provide notice of service disruptions of any facilities or services usually used by persons with disabilities (e.g. elevators, lifts, accessible washrooms, accessible door openers)

Accessible Customer Service Policies are available to the public via Divisional public facing website portals.

/ COMPLIANT
Training (ASCS, Section 6)

Ensure training is provided on Accessible customer service requirements and city policies/practices/procedures to any person who deals with public or other third parties on behalf of the City, and to any person who participates in developing policies, practices and procedures governing provision of goods, services to people with disabilities
Update training when AODA Standards or policies change

Training commenced in 2009, and is ongoing, and tracked
Third parties are required to conduct their own training and sign a form declaring compliance with requirements of AODA legislation

/ COMPLIANT
Feedback Process (ASCS, Section 7)

Establish a feedback process for receiving and responding to feedback about the manner in which the City provides goods or services to people with disabilities, and make this process readily available to the public.

Via Toronto 311 the City has established an accessible feedback process and a system for receiving and responding to feedback. Divisions also have independent feedback mechanisms.

/ COMPLIANT
Availability of Documents (ASCS, Section 8 and 9)

Notify the public in a conspicuous place on premises or on the website, that accessibility policy and feedback process is available, and provide documents in an accessible format upon request

Policies and feedback processes are posted online.

/ COMPLIANT
Accessibility Report (ASCS, Section 11)

File accessibility report

Reports filed in 2010, 2013, 2015.
Customer Service reporting was combined with IASR reporting requirements from 2013 onward.

/ COMPLIANT

5Integrated Accessibility Standards Regulation (IASR)

5.1General Requirements

AODA Requirements / Implementation Status / Comments
Establishment of Accessibility Policies (IASR Section 3)
Implementation Date: January 1, 2013

Develop, implement and maintain policies governing how the organization achieves accessibility through meeting requirements in the IASR
Include a statement of organizational commitment to meet accessibility needs of persons with disabilities
Document policies and make them available to the public, and provide them in an accessible format upon request

The City's Statement of Commitment to Creating a Barrier Free City and accessibility policies are publically available and posted on the City's website, and available in alternate formats upon request.

/ COMPLIANT
Accessibility Plans (IASR Section 4)
Implementation Date: January 1, 2013

Establish, implement and maintain a multi-year accessibility plan which addresses strategies to prevent/remove barriers
Post multi-year plan on website
Review and update plan every 5 years
Post annual status report of progress
Make documents available to the public and available in an accessible format upon request

The City's multi-year Accessibility Plan for 2012 to 2016 is posted on the City's website
This is the annual progress status report on measures taken to implement the Accessibility Plan up to and including 2015
The Plan will be updated every 5 years,

/ COMPLIANT
Procuring or Acquiring Goods, Services or Facilities (IASR Section 5 and 6)
Implementation Date: January 1, 2013

Incorporate accessibility design, criteria and features when procuring or acquiring goods, services, facilities, and kiosks (including point-of-sale devices)
If not practicable to incorporate accessibility design, criteria and features, provide an explanation, upon request.

Guidelines and checklists are in place for meeting accessibility obligations in procurement
Accessibility language for procurement documents have been developed as resources for City employees

/ COMPLIANT
Training (IASR Section 7)
Implementation Date: January 1, 2014

Ensure training is provided as soon as practicable on IASR requirements and OHRC as it pertains to people with disabilities to all employees, volunteers, policy developers, other third parties providing service on behalf of the City
Update training when AODA Standards or policies change

Training has been provided since 2011 is ongoing, and tracked
Third parties are required to conduct their own training and sign a form declaring compliance with requirements of AODA legislation

/ COMPLIANT

5.2Information and Communications Standards

AODA Requirements / Implementation Status / Comments
Exceptions (IASR Section 9)

AODA Information and Communication Standards do not apply to products, product labels, unconvertible information, and information not under direct, or indirect control of the City (e.g. Twitter). Where unconvertible an explanation and summary of the unconvertible information must be provided.

City procedures are in place to provide an explanation and summary of any unconvertible information, on request

/ COMPLIANT
Feedback (IASR Section 11)
Implementation Date: January 1, 2014

Ensure all feedback processes are accessible to people with disabilities, by providing or arranging for the provision of accessible formats and communication supports, upon request
Notify the public that accessible formats or communication supports are available

311 Toronto provides a range of accessible feedback mechanisms
For some Divisions, 311 Toronto receives feedback and re-directs to the Division for response.

/ COMPLIANT
Accessible Formats and Communication Supports (IASR Section 12)
Implementation Date: January 1, 2015

Provide or arrange for provision of accessible formats and communication supports, upon request
Notify the public that accessible formats and communication supports are available
Consult with the person making the request to determine the suitability of the accessible format or communication support

City has a process to provide alternate formats via internally trained resources or third party vendor services.

/ COMPLIANT
Emergency Procedure, Plans or Public Safety Information (IASR Section 13)
Implementation Date: January 1, 2012

Provide publicly available emergency procedures, plans, or safety information in accessible formats or with communications supports, upon request

Office of Emergency Management (OEM) provides accessible formats for City emergency plans and procedures
Corporate facility Fire Safety Plans are available in electronic formats. State of Good Repair projects have been identified and implemented to upgrade systems to include visual alarms.
All facilities have Fire Wardens trained on responsibilities and able to assist staff or public

/ COMPLIANT
Accessible Website and Web Content (IASR Section 14)
Implementation Date: January 1, 2014 and January 1, 2021

New websites published after January 1, 2014 must meet Web Content Accessibility Guidelines WCAG Level A
By 2021 all websites and content must meet WCAG Level AA.
Applies to websites and web content, including web-based applications that an organization controls directly or through a contractual relationship
Applies to all content published on a website after January 1, 2012 (i.e., when new website is launched the requirement applies retroactively to all content that was published after 2012, e.g. PDFs)

City completed a Web Content Migration project and launched a Web Content Management tool in 2013, prior to the AODA deadline was in effect. The current website is accessible to WCAG Level AA, with a few exceptions
City is undertaking a new website that is anticipated to launch in 2017. The project will addressaccessibility of web applications and web content such as PDFs
Web Standards for accessible web design practices are in place

/ COMPLIANT

5.3Employment Standards

AODA Requirements / Implementation Status / Comments
Recruitment General (IASR Section 22)
Implementation Date: January 1, 2014

Notify employees and public about availability of accommodation for applicants with disabilities during the recruitment process

Internal and external job postings include a statement that the City provides equitable treatment and accommodation to ensure barrier free employment

/ COMPLIANT
Recruitment, assessment or selection process (IASR Section 23)
Implementation Date: January 1, 2014

Notify job applicants about availability of accommodation during the recruitment process, in relation to the materials or processes to be used
Consult with the applicant to determine suitable accommodation that takes into account accessibility needs due to a disability

When inviting both internal and external candidates to attend an interview or participate in a test, they are advised that requests for accommodation are accepted throughout the hiring process.

/ COMPLIANT
Notice to Successful Applicants (IASR Section 24)
Implementation Date: January 1, 2014

When making job offers, inform the successful applicant of policies for accommodating employees with disabilities

All permanent and temporary employees, both union and non-union are notified in job offers about policies and process for accommodating employees with disabilities

/ COMPLIANT
Informing Employees of Supports (IASR Section 25)
Implementation Date: January 1, 2014

Inform employees of policies used to support employees with disabilities including policies on the provision of job accommodations that take into account an employee's accessibility needs due to disability

Employees are informed about City's Accommodation Policy & Guidelines in job offer letters including promotions, mandatory training on the AODA, employee manuals and via the City intranet

/ COMPLIANT
Accessible Formats and Communication Supports for Employees (IASR Section 26)
Implementation Date: January 1, 2014

When requested, provide employees with accessible information and communication supports for information required to perform the job, and information generally available to employees in the workplace
Consult with the employee making the request to determine suitability of the format or communication support

Integrated as part of City's Accommodation Policy & Guidelines
HR supports candidates
Manager/supervisor respond to staff accommodation requests

/ COMPLIANT
Workplace Emergency Response Information (IASR Section 27)
Implementation Date: January 1, 2012

Provide individualized workplace emergency response information to employees with disabilities if the disability is such that individualized information is necessary and the employer is aware of the need for accommodation.
With employee's consent, provide workplace emergency response information to the person(s) designated by the City to provide assistance
Provide the information required as soon as practicable after becoming aware of the need for accommodation
Review the individualized workplace emergency response information,
when the employee moves to a different location in the organization
when the employee's overall accommodations needs or plans are reviewed; and
when the employer reviews its general emergency response policies

The process to provide individualized workplace emergency response information is part of City's Accommodation Policy & Guidelines, and referenced in City's Accommodation Request Form
The workbook and form are published on City's intranet

/ COMPLIANT
Documented Individual Accommodation Plans (IASR Section 28)
Implementation Date: January 1, 2014

Develop and have in place a written process for development of documented individual accommodation plans (IAP) for employees with disabilities that includes:

How staff requesting accommodation can participate in the development process of their accommodation plan.
The means by which the employee is assessed on an individual basis.
The manner in which the employer can request an evaluation by an outside medical or other expert, at the employer's expense, to assist the employer in determining if accommodation can be achieved and, if so, how accommodation can be achieved.
The manner in which the employee can request the participation of a representative from their bargaining agent, where the employee is represented by a bargaining agent, or other representative from the workplace, where the employee is not represented by a bargaining agent, in the development of the accommodation plan.
The steps taken to protect the privacy of the employee's personal information.
The frequency with which the individual accommodation plan will be reviewed and updated and the manner in which it will be done.
If an individual accommodation plan is denied, the manner in which the reasons for the denial will be provided to the employee.
The means of providing the individual accommodation plan in a format that takes into account the employee's accessibility needs due to disability.

If requested, include any information regarding accessible formats and communications supports provided
If required, include individualized workplace emergency response information
Identify any other accommodation that is to be provided.

The process to develop individual accommodation plans is Integrated as part of City's Accommodation Policy & Guidelines

/ COMPLIANT
Return to Work Process (IASR Section 29)
Implementation Date: January 1, 2014

Develop and have in place a return to work process for employees absent due to a disability who require disability-related accommodations in order to return to work
The process shall outline the steps the City will take to facilitate the return to work of employees who were absent due to a disability and shall use the Individual Accommodation Plan (IASR Section 28) as part of the process

The City has a return to work process that is implemented for non-union staff by a Long Term Disability insurance carrier. Unionized staff have a modified work program defined in Collective Agreements that meets this requirement

/ COMPLIANT
Performance Management (IASR Section 30)
Implementation Date: January 1, 2014

Take accessibility needs and Individual Accommodation Plans into account in the performance management process

Accessibility needs and Individual Accommodation Plans are taken into account in performance management

/ COMPLIANT
Career Development and Advancement (IASR Section 31)
Implementation Date: January 1, 2014

Take accessibility needs and Individual Accommodation Plans into account when providing career development and advancement to employees with disabilities

("Career development and enhancement" includes providing additional responsibilities in a current position and the movement of an employee from one job to another that may be higher pay, provide greater responsibility, or be at a higher level in the organization, and is usually based on merit or seniority) /

Accessibility needs and Individual Accommodation Plans are taken into account in career development and advancement

/ COMPLIANT
Redeployment (IASR Section 32)
Implementation Date: January 1, 2014

Take accessibility needs and Individual Accommodation Plans into account when redeploying employees with disabilities

Accessibility needs and Individual Accommodation Plans are taken into account when redeploying employees with disabilities

/ COMPLIANT

5.4Transportation Standards

Note: TTC is responsible for requirements of conventional and specialized transportation services and maintains their own multi-year Accessibility Plan and Progress Status Updates