When the Accessibility Standards for Customer Service regulation (“ASCS”) came into force under the Accessibility for Ontarians with Disabilities Act (“AODA”) on January 1, 2008, it focused on a single standard with a single compliance date which made compliance a relatively easy exercise for employers.
The Integrated Accessibility Standards regulation (“IAS”) came into force on July 1, 2011, and unlike the ASCS it deals with a variety of topics, including employment practices, website design, and information and communication. It also contains a broad range of compliance dates depending on the specific requirement, nature of the organization, and number of employees. Accordingly, it is important for employers to pay careful attention to upcoming requirements and develop appropriate plans for compliance.
For certain public sector organizations and all private sector employers with 50 or more employees, one of the next significant requirements relates to training. By January 1, 2015, these organizations must provide training on the employment, information, communication and public space requirements of the IAS that relate to their business. They also must provide training on the Ontario Human Rights Code’s disability- related requirements. This training must be provided to all of the organization’s employees and volunteers; those tasked with creating the organization’s policies; and anyone who provides goods, services or facilities on their behalf.
The IAS does not specify the manner in which the training must be provided. Organizations are encouraged to review the roles and responsibilities of their employees and develop training plans that are specifically tailored to their roles. This might mean that large employers choose to offer training over a few different sessions for their different employee groups.
“With less than five months remaining until the compliance deadline, it is important that employers begin to develop an IAS training plan if they have not yet done so.”
Employers also have some flexibility relating to the manner in which the IAS training sessions are delivered. They may choose to fold IAS sessions into those that they previously created for the ASCS, keeping in mind that a broader range of employees will likely need to receive the IAS training. Alternatively, an employer may offer stand alone IAS sessions, but choose to deliver some in-person sessions for employees whose work relates directly to the IAS requirements while using a web-based module for their other employees. As long as the content of the training meets the requirements, there is freedom to use a training style that works for the particular organization.
In addition to the initial training sessions held in advance of the January 1, 2015 compliance deadline, organizations are expected to provide ongoing training sessions as well. IAS training should be folded into the orientation plans for new employees and could also form part of the training provided to employees that move to a new role within the organization. Periodic sessions could also be used to refresh employee training or to share any changes to the organization’s existing accessibility policies.
Lastly, once an employer has met the training requirements of the IAS, it is important that they document their efforts should they be asked to demonstrate their compliance. This requires keeping records of training dates, participants and materials.
With less than five months remaining until the compliance deadline, it is important that employers begin to develop an IAS training plan if they have not yet done so. An effective and well-tailored training plan will ensure that employers are not just compliant, but also provide a meaningful training experience for their employees that can improve accessibility across all aspects of their organization.