Regulations under the Accessibility for Ontarians with Disabilities Act changed on July 1, 2016. The Accessibility Standards for Customer Service were revoked, and a modified version of those standards has been incorporated into the Integrated Accessibility Standards. As a result, organizations must implement the following changes:

  1. Employee Training Standards – All members of an organization now need to be trained on accessible customer service and how to interact with people with different disabilities.
  2. Feedback – Public feedback processes for customer service accessibility are now more robust. The feedback process must be accessible to people with disabilities, and must be provided in alternative accessible formats, and/or with communication supports, upon request.
  3. Policies – Large organizations are now required to notify customers that their accessible customer service policies and temporary disruptions policies are available upon request. This notice can be given by posting the policies in a conspicuous place or on the organization’s website.
  4. Support Persons – Before requiring a person with a disability to be accompanied by a support person for health and safety reasons, an organization must first consult with the person who has the disability, review all available evidence, and consider reasonable alternatives.
  5. Service Animals – Organizations may continue to request documentation to confirm that a person with a disability requires the use of a service animal, but this documentation may now come from a wider variety of regulated health professionals, including audiologists, speech-language pathologists, chiropractors, nurses, occupational therapists, optometrists, physicians, surgeons, physiotherapists, psychologists, psychotherapists and mental health therapists.

Organizations should also be aware that, for the purposes of the customer service standards, the definition of a “large organization” has changed from “20 or more employees” to “50 or more employees”. Organizations with more than 20, but less than 50, employees are no longer required to document certain policies and practices. However, an employer who already has documented policies and procedures in place should keep them in place, and should continue to update them.

To date, enforcement measures have been limited, but there are signs that they are increasing. For example, last fall, the Ministry of Economic Development and Growth announced AODA compliance audits targeting large retail organizations with 500 or more employees. It is therefore increasingly important to ensure your organization is compliant.

For general background on the evolution of AODA requirements, see our previous posts here and here.