Introduction

Under the Ontarians with Disabilities Act, 2001 (ODA), ministries are required to produce, and make available to the public, annual plans that recognize how ministries will identify and remove barriers to accessibility.

The ODA Accessibility Plan (the Plan) is an opportunity to showcase our ministry’s accomplishments and to demonstrate how we are modeling compliance with our regulated accessibility requirements.

In 2010, the Ministry of Labour began complying with the first accessibility standard established under the Accessibility for Ontarians with Disabilities Act (AODA) - Accessibility Standards for Customer Service. In 2011, the Integrated Accessibility Standards Regulation (IASR) was introduced, establishing phased-in requirements in the following accessibility standards:

  • information and communications
  • employment
  • transportation; and
  • design of public spaces

Each year, the Ontario Public Service (OPS) as an obligated organization, confirms its compliance with the requirements of these standards to the Accessibility Directorate of Ontario. The ODA Plan provides an opportunity for our ministry to go beyond confirming compliance with these regulated minimum requirements. Specifically, the Plan allows us to highlight the measures taken by our ministry to identify and remove barriers in the previous year while proposing measures for the coming year that will make our ministry more accessible.

The IASR establishes that obligated organizations shall create and maintain a multi-year accessibility plan (MYAP) that outlines the organization’s strategies to prevent and remove barriers to accessibility. To meet the MYAP requirement, the OPS released Leading the Way Forward in 2012.

Organizations are also required to develop an annual status report that highlights progress in advancing the MYAP strategy and in meeting the requirements of the IASR. In 2013, the OPS released its first Annual Status Report, highlighting progress made in 2012.

The Ministry of Labour’s 2014 ODA Plan demonstrates how the measures our ministry has taken and the measures we propose for the coming years support the key outcomes and deliverables of the of the MYAP.

To access the Ministry of Labour’s and other ministries’ 2014 ODA Accessibility Plans, visit Ontario.ca.

Section one: Measures taken by the Ministry of Labour in 2013-14

Customer service

OPS MYAP key outcome

People with disabilities who are OPS customers receive quality goods and services in a timely manner.

Measures taken by Ministry of Labour in 2013-14:

Commitment

Identify what accessible devices are available onsite to assist people with disabilities and ensure that staff knows how to use them.

Measures taken

Information on accessible devices and assistive technologies is shared with the Accessibility Council with the request to distribute it to their respective workplaces. This information includes the new centralized TTY software that enables the users to type messages back and forth to one another instead of talking and listening; the new centralized provision of assistive devices and technology by I&IT Centre of Excellence; and other I&IT products and services. A representative from the I&IT Centre of Excellence was invited to present to the Accessibility Council’s meeting on the resources, tools and services available to the ministries and answer questions from Council members.

Members of the Accessibility Council and OPSEU MERC Employment Accommodation Working Group separately visited the Wellness Resource Centre at 900 Bay St. and were acquainted with the latest accessible devices and assistive technology available.

The theme of the October 2014 Administrative Professionals Learning Program was Accessibility and Information Management. Over 160 administrative professionals had the opportunity to learn about a variety of accessibility topics including creating accessible documents using advanced MS Office products, TTY and assistive technology.

Commitment

Analyze accessibility feedback received.

Measures taken

The ministry has established a mailbox on the MOL’s internet site where members of the public can submit accessibility questions and inquiries. An average of 30 inquiries and feedback per month from internal and external stakeholders and the public are analyzed and any issues identified are addresses accordingly.

The MOL Engagement Framework has been aligned with and supports the objectives of inclusion, diversity, equity and accessibility. The Inclusion Lens is applied to the framework to ensure barrier free engagement. The capacity building plan for stakeholder engagement will include methods for seeking feedback from stakeholders on accessibility issues.

Commitment

Ensure notice of disruption policies are in place when services are unavailable.

Measures taken

Chapter 7 of the Ministry’s Business Continuity Plan (BCP) includes detailed policy and procedures regarding the AODA Customer Service Standard, application scenarios and various examples of business disruption notices/posters in both English and French. Annual training of the BCP leads includes a review of the AODA Customer Service Standard.

Commitment

Review ministry policies, decision-making processes and administrative procedures using the OPS Inclusion Lens.

Measures taken
  • Ministry continues to raise awareness on applying Inclusion Lens to policies, processes and procedures. Some examples of this application are:
  • The recruitment and hiring processes and practices in the ministry are being reviewed to identify and eliminate any barriers. Executive Recruitment Inclusion Lens is applied to senior management hiring in the ministry.
  • Employment accommodation practices and training are aligned with the principles of inclusion, flexibility and collaboration.
  • The Business Support Unit has implemented an ‘Inclusion Check’ as an integral part of the facilities project initiation process. All projects, large or small, are reviewed prior to initiation to ensure that the proposed work is code compliant, does not create new barriers, and opportunities to improve existing accessibility have been considered.
  • Some more examples of policies, processes and procedures where the inclusion lens were applied include: mandatory Health and Safety Awareness Training for the province; MOL Engagement Framework; planning stakeholder meetings; and contingency planning for the ministry.
Commitment

Encourage employees to identify barriers and provide recommendations on accessible services.

Measures taken

During the National Access Awareness week ministry employees received communications that aimed to raise awareness on accessibility and removing barriers. These communications include: learning about the National Awareness Access Week and accessibility in Ontario; an intranet story featuring an employee with visual impairment; and an article with tips on how to make office spaces more accessible.

Both the Accessibility Council and Diversity and Inclusion Council of the ministry participated in a presentation by the Ontario Human Rights Commission about their policy on competing human rights, where they learned about the complexities of competing human rights situations and strategies to deal with them.

The October 2014 Administrative Professionals Learning Program addressed a variety of practical accessibility topics and tools that the administrative staff can apply directly to their work.

On the International Repetitive Strain Injury (RSI) Awareness Day communication was posted on the intranet on RSI, OPS resources, and on tips to prevent these injuries.

Commitment

Ensure that diversity and accessibility leads complete the OPS Inclusion Lens train-the-trainer sessions.

Measures taken

Accessibility leads for the ministry attended the OPS Inclusion Lens train-the-trainer session offered by the Diversity Office, and are equipped to train staff upon request.

Commitment

Require 100% of ministry staff to have taken OPS Inclusion Lens training by December 31, 2014.

Measures taken

A targeted Inclusion Lens training session was delivered on January 14, 2014 where key participants from ministry divisions used relevant case studies to apply the lens. Since then Labour Relations Solution Division, Prevention Office and Policy Divisions have put together training and practical applications of the Lens.

Inclusion Lens training and awareness is provided to staff through various methods including online e-learning, in person sessions, during team meetings and orientation sessions.

Inclusion Lens training and practical application was offered at the October 2014 Administrative Professionals Learning Program where administrative professionals learn how to apply the lens when organizing events or public consultations.

The Inclusion Lens and the Executive Recruitment Inclusions Lens are distributed to all ministry managers as part of the manager’s toolkit along with other information on accessibility and inclusion. The toolkit is intended as resource for managers to bring inclusion lens training and discussions on its application to their teams.

Commitment

Review internal policies, procedures and practices to ensure that accessibility is considered whenever OPS business is conducted.

Measures taken

A new and improved Orientation Guide includes information and resources on Accessibility and Inclusion. All orientation sessions for the new employees in the Ministry have accessibility and inclusion topics in the agenda.

Inclusion Lens has been used to plan, implement, and valuate policies, processes and procedures in the ministry. See examples on page 7.

Information and Communications

MYAP key outcome

Information and Communications are available in accessible formats or with necessary supports to all OPS staff and customers.

Measures taken by Ministry of Labour in 2013-2014

Commitment

Continue to meet Web Content Accessibility Guidelines (WCAG) standards.

Measures taken

Ministry’s websites are more accessible to people with disabilities by meeting the WCAG 2.0 standards when creating new web content.

Commitment

Communicate the availability of accessible formats and communication supports to the public by January 1, 2014.

Measures taken

Information about the availability of the alternate accessible format on request is posted on the Ministry of Labour website. The ADM, Corporate Services and Chief Administrative Officer sent out a communication to all ministry staff on this new IASR requirement.

Commitment

Encourage ministry accessibility representatives to attend the Expo/JOIN conference in the Fall of 2013.

Measures taken

Two members of the ministry’s Accessibility Council attended the Expo/JOIN conference in November 2013.

Commitment

Update accessible format standards and templates based on best practices.

Measures taken

The procurement templates and other documents posted on the ministry intranet are reviewed and updated to accessible formats. Organizational Effectiveness Branch has revised some of the commonly used templates such as briefing notes and performance plan templates and made them accessible. The ministry will continue its effort to ensure these initiatives are replicated across the ministry.

Commitment

Train employees on the appropriate handling of requests for communication supports and alternate formats and the delivery of accessible events.

Measures taken

All ministry staff completed mandatory training on IASR Information and Communications. The e-learning course attendance was tracked though the Centre for Leadership and Learning (CFLL) and reports were shared with the ministry areas accordingly.

Training on accessible formats and events was provided at the October 2014 Administrative Professionals Learning Program.

The accessibility leads have attended the train the trainer course on accessible formats and can provide the training on accessible documents at source upon request. Two training sessions for the Prevention Office staff were delivered in October. This knowledge is also used to respond to questions and enquiries from across the ministry as required.

A plan is in place to make training on accessible documents available to all ministry staff.

Commitment

Using the OPS Inclusion Lens and I&IT Roadmap, Labour and Transportation Cluster (LTC) will establish new strategies for continuous adoption and integration of diversity/inclusion and accessibility.

Measures taken

Labour Transportation Cluster (LTC) participated in cross I&IT groups to ensure that as solutions and applications are developed by I&IT, diversity, inclusion, and accessibility considerations are built into the planning, development and implementation of the solutions and/or applications.

Using the OPS Inclusion Lens and I&IT Roadmap, new strategies for continuous adoption and integration of diversity/inclusion and accessibility were established throughout the LTC. Some examples include: offering employment accommodation to interview candidates; a clause added to employment letters to new employees; providing larger monitors for employees with sight accommodation needs; offering flexible work arrangements and ergonomic assessments as required.

The Cluster Architecture Office is working in partnership with the I&IT Accessibility Centre of Excellence to develop best practices for the inclusion of accessibility requirements into the OPS Enterprise Architecture review.

Employment

MYAP key outcome

OPS employees with disabilities participate fully and meaningfully in their employment.

Measures taken by Ministry of Labour in 2013-2014

Commitment

Increase awareness of employment accommodation directives, policies and plans with managers.

Measures taken

All managers completed the IASR Employment Standards mandatory training. This e-learning course gave managers a better understanding of the accommodation requirements of the IASR, Employment Standard and better equipped them to create a more accessible and inclusive workplace for all employees with disabilities.

All management groups in the ministry met with the employee accommodation lead to receive an overview on directives, policies and accommodation plans. A proactive approach has been implemented through the employee accommodation lead by reviewing attendance, sick leave usage and potential for return from LTIP. The accommodation lead contacted the managers to offer advice, coaching and assistance in obtaining helpful medical information and developing accommodation and return to work plans. This approach ensures that managers are aware of directives and policies and learn how to apply them to each unique and individual circumstance.

Commitment

Ensure the availability of accessible formats and communication supports for employees.

Measures taken

Ministry managers are aware of the requirements to provide accessible formats and communication supports to employees requiring this type of accommodation. This is done through corporately launched training, along with contacts and meetings with accommodation and accessibility leads for the ministry. Information on centralized I&IT provision of assistive technology is shared in the managers’ meetings and with the Accessibility Council.

Commitment

Support mentor/sponsor programs.

Measures taken

Ministry has successfully continued participation in partnership with Ministry of Municipal Affairs and Housing and Ministry of Environment and Climate Change in the 2013-2014 Diversity Mentoring Partnership Program. The program criteria were expanded to include employees under 35 and women in engineering. The program included 80 participants. The program launch event and the midpoint event incorporated orientation on the program and discussions on diversity, inclusion and accessibility facilitated by well-known and experienced diversity professionals. The new cycle started in October 1, 2014, and over 100 participants from the three Ministries embarked on the new mentoring experience.

Commitment

Share senior manager accessibility performance commitments with staff.

Measures taken

The DM, ADMs and Senior Management Committee have shared the performance commitments with the directors who have cascaded them down to the staff. The performance commitment menu and information prepared by the Diversity Office was shared with all managers in the ministry.

Commitment

Analyze 2014 Employee Engagement Survey results to assess potential barriers to employees with disabilities.

Measures taken

A qualitative and quantitative analysis of the Employee Engagement Survey results was conducted to assess potential barriers to employees with disabilities. Evaluation outputs include identification of priority improvement areas for employees who indicated they have a disability.

A year-to-year comparison of satisfaction with employment accommodation services shows improvement in this area. Ministry will continue to ensure employment accommodation strategy is a priority.

Commitment

Review 2013 management survey results and develop strategies to heighten knowledge and understanding of employment accommodations; this will include a training program for managers and an employee awareness campaign in 2014.

Measures taken

Based on the survey findings the ministry has established a joint OPSEU MERC Employment Accommodation Working Group. The goal of this collaborative effort is to ensure safe and successful accommodations and return to work through training and expert knowledge. The working group has jointly developed a training and awareness program that is being implemented.

Commitment

Revise performance plan template to include accessibility commitments for staff and managers

Measures taken

All ministry managers have mandatory diversity, inclusion, and/or accessibility commitments in their performance plans. The intent is for managers to share the performance commitment with their staff and to include a diversity/accessibility commitment in their staff’s performance plans.

Built Environment

MYAP key outcome

There is greater accessibility into, out of and around OPS facilities and public spaces.

Measures taken by Ministry of Labour in 2013- 2014

Commitment

Increase awareness of the OPS barrier-free requirements for government facilities.

Measures taken

The facilities manager for the ministry presented to the Accessibility Council on Barrier Free Design Guidelines and tips to make office environments more accessible.

Communication was sent to all ministry staff with tips to make office spaces more accessible.

Commitment

Prepare for January 1, 2015 IASR requirement on public spaces.

Measures taken

The Business Support Unit has implemented an ‘Inclusion Check’ as an integral part of the facilities project initiation process. All projects, large or small, are reviewed prior to initiation to ensure that the proposed work is code compliant, does not create new barriers, and opportunities to improve the accessibility of the existing space have been considered. The merits of these improvements are discussed with each project sponsor.

The ministry has provided training to key ministry staff on the new Built Environment requirement effective on January1, 2015.

Commitment

Increase manager awareness of built environment obligations in the IASR, Building Code Act and OPS barrier-free requirements for government facilities.

Measures taken

Built environment accessibility awareness article and tip sheets were distributed to all ministry staff. The facilities manager meets annually with the directors of most public facing program areas to ensure accommodation and accessibility requirements are met.

General Outcomes

MYAP key outcome

OPS staff are able to identify barriers to accessibility, in OPS policies, programs, services and facilities, and actively seek solutions to prevent or remove them on a continuing basis throughout the organization.

Measures taken by Ministry of Labour in 2013- 2014

Leadership

Commitment

Represent the needs of persons with disabilities at the Accessibility Council.

Measures taken

A ministry representative was identified to join the Disability Advisory Council (DAC) a group that provides a consumer perspective on the implementation of the IASR in the OPS. The DAC representative for the ministry is also part of the Accessibility Council.

Commitment

Establish regular meetings of the ministry’s Accessibility Council and senior management to provide ongoing input and advice.

Measures taken

The Accessibility Council for the ministry met quarterly to identify and address barriers to accessibility and share accessibility best practices.

The Accessibility Champion for the ministry has periodically provided updates to the Senior Management Committee meetings.

Commitment

Develop strategies that will assist the ministry meet its IASR obligations in areas such as web accessibility, procurement and public spaces.

Measures taken

Accessibility Council ensures compliance with IASR and Customer Service Standards and identifies any gaps in the ministry; shares best practices to remove barriers and raise accessibility awareness across the regions.

Other Measures
  • Ministry managers attended the “Blindspot: Hidden Biases of Good People” seminar by Dr. Mahzarin seminar delivered in partnership with Ministry of Municipal Affairs and Housing. Dr. Banaji provided evidence from both her research and her Implicit Association Test results to reveal the hidden biases and unconscious “truths” in our minds. The participants learned that even leaders, with best intentions, may unconsciously make decisions that have an unintended impact on diversity and inclusion in our workplaces. Dr. Banaji says that such unconscious thoughts can be overruled. She provided examples of ways to outsmart hidden biases by challenging assumptions and consciously working towards increasing awareness of hidden biases.
  • Training on accessible procurement is provided as needed to staff who are responsible for procurement in the ministry. Directors received information on procurement and accessibility through a monthly memo sent out by the Finance and Administrative Branch.
  • Ministry of Labour achieved Excellence Canada’s Progressive Excellence Program® (PEP) Healthy Workplace Level 4 certification in August 2014 and was presented with the Gold level award at the prestigious Canada Awards for Excellence on October 30, 2014. A supportive workplace culture that values Diversity, Inclusion and Accessibility are directly linked to a healthy workplace and MOL’s achievement of PEP® Healthy Workplace Level 4 certification recognizes the efforts and progress MOL has made in this capacity.

Section two: Measures proposed by the Ministry of Labour for 2015

Customer Service

MYAP Key Outcome

People with disabilities who are OPS customers receive quality goods and services in a timely manner.

Measures Proposed by Ministry of Labour for 2015 and 2016:

  • Build capacity and expertise in the ministry to create quality and timely alternative formats upon request to external and internal customers
  • Continue to monitor and improve the quality of services provided to customers with disabilities through various methods
  • Ensure Customer Service Standards in the Ministry are reviewed using the Inclusion Lens
  • The Stakeholder Engagement Strategy includes engagement techniques for reducing barriers and promoting inclusion

Information and Communications

MYAP key outcome

Information and Communications are available in accessible formats or with necessary supports to all OPS staff and customers.

Measures proposed by Ministry of Labour for 2015 and 2016:

  • Ministry staff are provided with training and resources to create accessible documents at source
  • Revise Intranet resources to ensure updated information on accessibility and practical resources are available
  • Five ministry representatives to attend Accessibility Expo annually and share the learning with their teams and the Accessibility Council
  • The Labour and Transportation Cluster will assess the following systems for the MOL to ensure conformance to appropriate accessibility employment standards:
    • Employment Protection for Foreign Nationals Worker (EPFNA).
    • Trust Management System
    • For all other projects, MOL business manager will work with MOL accessibility leads to ensure compliance requirements are defined
  • The Cluster will continue to improve AODA/ IASR IT Accessibility related guidance and information to OPS projects, through continued collaboration with Accessibility Centre of Excellence and other groups.

Employment

MYAP key outcome

OPS employees with disabilities participate fully and meaningfully in their employment.

Measures proposed by Ministry of Labour for 2015 and 2016:

  • Deputy Minister’s annual performance commitments identify accessibility in the ministry as a priority
  • Provide training to managers and employees on accommodation and return to work in collaboration with the OPSEU MERC Employment Accommodation Working Group
  • Orientation and on boarding of new managers and staff to include accessibility and inclusion learning tools
  • Accommodation and return to work plans in the ministry are monitored and updated according to timelines established in the plan

Built Environment

MYAP key outcome

There is greater accessibility into, out of and around OPS facilities and public spaces.

Measures proposed by Ministry of Labour for 2015 - 2016

  • Improve accessibility in the government facilities by installing door operators, and where possible investing in accessible washrooms and kitchens
  • The Business Support Unit will continue to use the ‘Inclusion Check’ for any project initiation to ensure that the proposed work is code compliant, does not create new barriers, and opportunities to improve existing accessibility have been considered.
  • Communications from the Business Support Unit on facilities and building to all staff is in accessible formats

General Outcomes

MYAP key outcome

OPS staff are able to identify barriers to accessibility in OPS policies, programs, services and facilities, and actively seek solutions to prevent or remove them on a continuing basis throughout the organization.

Measures proposed by Ministry of Labour for 2015 and 2016:

  • Strengthen the impact of the Accessibility Council for the ministry as a lead in connecting with every part of the ministry to increase awareness and remove barriers
  • Accessibility Council meets quarterly to discuss accessibility in the ministry

Section three: addressing the identification of barriers in legislation

In support of our commitment to improve accessibility for people with disabilities, the Ministry of Labour will continue to review government initiatives, including Acts, regulations, policies, programs, practices and services for the purposes of identifying and removing barriers.

Recognizing the importance of addressing accessibility barriers in laws that have a high impact on members of the public and persons with disabilities, the government is following a three-pronged strategy that prioritizes the review of high impact legislation including:

  1. Development of a standardized process and tools for identifying and addressing accessibility barriers;
  1. By the end of 2014, review of 51 targeted high-impact statutes that meet the following criteria:
    1. Statutes that affect persons with disabilities directly;
    2. Statutes that provide for the delivery of widely applicable services or programs;
    3. Statutes that provide benefits or protections; or
    4. Statutes that affect a democratic or civic right or duty; and
  1. Review procedural rules, policies and guidelines for select high-impact legislation, where necessary.

In 2013 the OPS made significant progress in conducting this phase of the review which is estimated to be completed by the end of 2014. The government has decided to review these statutes because it is anticipated that changes in these areas will have the highest impact on those Ontarians who have accessibility needs.

As part of the process, in 2014 the Ministry reviewed the following high impact statutes for accessibility barriers:

  • Employment Standards Act, 2000
  • Occupational Health and Safety Act
  • Workplace Safety and Insurance Act, 1997

As ministries complete their review of the 51 targeted high-impact statutes, the government will determine how to best coordinate the process for remedying barriers across government.

Initiatives Planned for 2015- 2016

In 2015-2016, based on the government’s direction, the Ministry will address any accessibility barriers that have been identified in the three high impact statutes set out above.

The Ministry will continue to report on the progress of the review and any proposed remedies through its annual accessibility plans.