Open Up the Workplace to Disabled Employees, Clients and Building Users through Accessibility

If asked how many employees in the workplaces you manage have a bona fide disability at this time, would you be able to answer this question?  If asked, ten years from now, how many of the employees in the workplace(s) you manage will be at an age or state of health where they develop a disability, would this be readily apparent to your Building Management & Facility Management team? What percentage of the potential working population in Ontario has a disability, which workplaces have not even considered in the hiring process due to lack of accessibility?  Of that percentage, how many could potentially be high-level performing employees, who help the organization’s you manage succeed in the workplaces that rent or lease space within your buildings?

What is a bona fide disability?

These questions about disability often bring to mind the more obvious disabilities such as the employee in a wheelchair; the prospective employee with MS; the manager who works on the 36th floor who wears two hearing aides. But what about the aging tenant whose vision is slowly diminishing due to diabetes? Or the employee within your office tower with the more hidden disability such as moderate depression, who is struggling with way-finding within the building, mall or facility?

Current & prospective employees & clients with disabilities; How do your buildings support these groups?

Take a few minutes to think about “disabled” scenarios and consider if the workplace(s) owned and/or managed by your firm manage for these potential and current scenarios.  Do your buildings have a communication system,which allow users to gain access throughout the building taking into account any and all disabilities thatmay be encountered? As per the Accessibility for Ontarians with Disability Act (AODA) for Ontario, communication systems include the wayfinding and signage in the building and workplace, including those outside. Do your buildings have policies and procedural documents related to the AODA in place? Are forms & contracts all accessible? Could an employee of a workplace within your building, school, healthcare facility, industrial park or mall know if the building was closed due to a snow storm or an emergency before they attempt to access the workplace?  If I wanted to access the retail shops in the subfloor of your building and I used a specialized wheelchair, can you guarantee you can communicate what systems you have in place to accommodate me?

Time to get moving. The AODA is here & it will have a MAJOR impact on IFMA members in Ontario.

In the Province of Ontario, barriers to accessibility have been and will be addressed over the next number of years.  The question is, is your organization ready for this?  Do you & other stakeholders in your organization know about the AODA,  which was passed June 13th 2005?  If you and your team are not aware of or are vaguely aware of this Act and its implications, for both public and private industry, it is recommended both you and your Senior Management team gain an understanding of this rather quickly. The due dates for the required initial phases of the Act were January, 1st, 2010 for public businesses and January 1st, 2012 for all private businesses, including building owners and facility managers.

Some Details

The Act will:

  • make Ontario the first jurisdiction in Canada to develop, implement and enforce mandatory accessibility standards;
  • apply to both the private and public sectors; and,
  • (the Act and its ensuing Accessibility Standards) will make all of Ontario buildings, workplaces and public spaces accessible by 2025.

So why now?

The most significant reason why accessibility is top of the Province of Ontario’s  mind is that approximately 1.85 million people in Ontario have a disability currently (Statistics from the Ministry of Community and Social Services Ontario, 2009) AND over the next 20 years as the population ages, the number will rise to one in five Ontarians! This presents both a huge challenge and an enormous opportunity for you and your building(s) to be leading edge at best, and to meet the Regulations at the very least. This is a time when facility managers, operators, designers, architects, ergonomists, human resource managers, and purchasing agents should do things right, the first time, at the early blueprint phase of each project.

When the facts of disability statistics are paired with the shrinking skilled workforce in Ontario and Canada, it becomes the “perfect storm” for a shrinking base of excellent potential & current employees to draw from. As well, there will be further loss of valuable employees who develop disabilities, who can no longer gain access to the workplace, let alone contribute in a meaningful and productive way to the success of the businesses who work in the building(s), or facilities your firm owns and manages.

There are five standards or regulations that all sectors must comply with.  These are:

  • customer service;
  • employment;
  • information and communication;
  • transportation; and,
  • built environment (buildings and other structures).

The first regulation under the AODA that became law on January 1st, 2008 is the Customer Service Standard.  This law means that all businesses or organizations that provide goods or services to the public or to other third parties in Ontario are legally required to comply with the requirements of the standard.  In terms of timing, all public sector organizations must:

  • comply with the standard by January 1, 2010; and,
  • file their first accessibility report by March 31, 2010.

This means that all businesses in the public sector were legally required to file their first accessibility reports in March 31 2010.  As for the private sector and non-profit organizations, compliance with this Standard will be required January 1, 2012, with the first filing of the accessibility report by March 31st 2012.  It is important in the context of building ownership, management & facility management practices to ensure your client base (and your own businesses) are aware of this and are moving toward compliance with the regulations.

To define this further, “standards” which are referred to in this article and in the legislation are an “agreed way of doing business.”  They are the rules that businesses and organizations in Ontario will have to follow to identify, remove and prevent barriers for people with disabilities accessing any goods or services in your buildings and facilities.

Now that the Customer Service Standard is law, it is enforceable. Businesses and organizations in Ontario will have to adhere to the requirements of this standard, including filing a compliance report along the timelines stated by the Ministry.  And what will compliance look like for this first law?

Here is the list to get your building ownership/management/facility management practices started, both internally and in the service of your clients.

Accessibility Standards for Customer Service for people with various kinds of disabilities require you to:

  • Establish policies, practices and procedures on providing goods or services to people with disabilities;
  • Set a policy on allowing people to use their own personal assistive devices or other measures your organization offers (assistive devices, services or methods) to access your goods and services;
  • Use reasonable efforts to ensure that your policies, practices and procedures are consistent with the core principles of independence, dignity, integration and equality of opportunity;
  • Communicate with a person with a disability in a manner that takes into account his/her disability;
  • Train staff, volunteers, contractors and any other people, who interact with the public or other third parties on your behalf, on a number of topics as outlined in the customer service standard;
  • Train staff, volunteers, contractors and any other people, who are involved in developing your policies, practices and procedures, on the provision of goods or services on a number of topics as outlined in the customer service standard;
  • Allow people with disabilities to be accompanied by their guide dog or service animal in those areas of the premises you own or operate that are open to the public, unless the animal is excluded by another law. If a service animal is excluded by law, use other measures to provide services to the person with a disability;
  • Permit people with disabilities who use a support person to bring that person with them while accessing goods or services in premises open to the public or third parties;
  • Where admission fees are charged, provide notice ahead of time on what admission, if any, would be charged for a support person of a person with a disability;
  • Provide notice when facilities or services that people with disabilities rely on to access or use your goods or services are temporarily disrupted;
  • Establish a process for people to provide feedback on how you provide goods or services to people with disabilities and how you will respond to any feedback and take action on any complaints. Make the information about your feedback process readily available to the public.


AND if your buildings/facilities house designated public sector organizations, or have 20 or more employees, you & your clients have additional responsibilities which include:

  • Document in writing the accessible customer service policies, practices & procedures;
  • Notify your customers that these documents are available upon request; and,
  • Provide information in the required document(s), when providing them to a person with a disability, in a format that takes into account their disability.


If you are not certain what to do next, the following is what we are recommending to our clients.

  • ensure you have a qualified professional in place with expertise in this area. Be very careful as there are suddenly “accessibility experts” appearing from everywhere. Be sure to ask for their qualifications, formal educational background, and number of years of experience in this field before engaging with an “expert”);have the accessibility consultant come speak to you and your client group about the requirements and next steps relative to complying with this legislation. This discussion should consider how to fold this legislation into related current and future operational imperatives in each workplace, facility and building your firm manages; and,
  • perform a validated audit of what is currently in place relative to the legislation.  This should be followed by a  “Next Steps Report” relative to compliance and reporting requirements, then a project management system. 

The Accessibility Standards for Customer Service is an important law, which ultimately will benefit employers and businesses in Ontario in significant & long term ways. Understanding this and upcoming laws, as well as AODA on the part of building owners/managers and facility managers should now form a critical part of your knowledge base.  Your internal stakeholders & executive boards need your guidance and information about this legislation and future legislation related to accessibility.  Arming yourselves with this knowledge and teaming with qualified accessibility/ergonomic design experts will be an important first step in ensuring you limit business liability and ensure more Ontarians have access to contribute positively to all workplaces in Ontario.


Olga Dosis is Senior Accessibility Consultant with Optimal Performance Consultants.  Olga holds a Masters Degree in Psychology & a Masters Degree in Critical Disability Studies.  With more than 20 years experience working in this field, Olga analyzes & synthesizes cross disability issues & conducts environmental scans to develop realistic strategic action plans for organizations. Contact

Jane Sleeth is Managing Director & Senior Ergonomic Consultant with Optimal Performance Consultants, an Ergonomic, Accessibility and Disability Prevention firm located across Canada. Jane and her team of consultants most recently completed a building & accessibility audit for the LCBO with recommendations, which will ensure the LCBO meets the Ontario standards for Communication and Building Design.  Contact