Executive summary

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

Like all ministries, the Ministry of Labour (MOL) complies with the Accessibility Standards for Customer Service (ASCS) and the Integrated Accessibility Standards Regulation (IASR). These regulations establish phased-in requirements in the following accessibility standards:

  • Customer Service
  • Information and Communications
  • Employment
  • Transportation
  • Design of Public Spaces

In 2012, the Ontario Public Service (OPS) released its first multi-year accessibility plan (MYAP) entitled Accessibility in the Ontario Public Service: Leading the Way Forward. The Ministry of Labour’s 2015 ODA Plan, celebrates the tenth anniversary of the ODA and demonstrates how the measures taken in 2015 and proposed for 2016 support the key outcomes and deliverables of the OPS MYAP as we continue on our path to an accessible Ontario in 2025.

The Ministry of Labour’s 2015 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 MYAP.

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

Section one: report on measures taken by the Ministry of Labour in 2015

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 the Ministry of Labour (MOL) in 2015

Commitment one

Build capacity and expertise in the ministry to create quality and timely alternative formats upon request to external and internal customers.

Measures taken

The ministry has taken the initiative to train and share resources on how to create accessible documents with staff that regularly interact with internal and external stakeholders. Key employees were identified and provided with training by the OPS Diversity Office on how to create accessible documents.

Commitment two

Continue to monitor and improve the quality of services provided to customers with disabilities through various methods.

Measures taken

Customer Service Standards Audit process was reviewed and the following recommendations will be implemented next year:

  • Include a formal step in the MOL email audit process to validate that the message to employees is 100% accessible. The following requirements must be met prior to sending the message:
    • email set to HTML
    • sans Serif font (preferably Arial)
    • font size is 11 point or higher
    • automatic font on a white background

In addition to supporting inclusion and meeting accessibility requirements, this exercise may also improve results because individuals with vision impairments or screen readers may be equipped to respond faster and more effectively.

  • Measure the number of respondents who meet accessibility requirements and leverage best practices when auditing MOL employees on email response time. The following criteria will be considered as ‘requirements’:
    • email set to HTML
    • sans Serif font (preferably Arial)
    • font size is 11 point or higher
    • automatic font on a white background

The following criteria will be considered ‘best practices’:

  • use clear meaningful link names which describe the content rather than the full web address
  • include the message ‘If you have any accommodation needs or require communication support or alternate formats, please let me know’

This would require communication prior to conducting the audit so individuals are aware of expectations. A message will be sent to employees in early 2016 reminding them of the OPS Common Service Standards and this new requirement.

Commitment three

Ensure Customer Service Standards in the Ministry are reviewed using the Inclusion Lens.

Measures taken

Review of the Customer Service Standards through the inclusion lens resulted in auditing TTY (Text Telephone) lines as part of the Customer Service Audit. TTY is a special device that lets people who are hard of hearing or speech-impaired use the telephone to communicate, by allowing them to type messages back and forth to one another instead of talking and listening. A total of 322 calls were made including calls to 6 TTY phone numbers. 87.58% calls met the criteria of responding within three rings.

Commitment four

The Stakeholder Engagement Strategy includes engagement techniques for reducing barriers and promoting inclusion.

Measures taken

The MOL Stakeholder Engagement Framework was posted to the MOL website in January 2015. The purpose of the framework is to establish a shared understanding of the ministry’s vision for stakeholder engagement, and the principles, priorities and practices that will guide and align future activity across all MOL programs. It also serves as a reference tool that ministry staff can use when planning and undertaking engagement.

The Framework aims to achieve engagement that strengthens relationships with new and existing stakeholders and achieves better outcomes in the workplace. The framework’s goals support and promote accessibility by working to strengthen the engagement and outreach experience via enhanced planning and execution, alignment of approaches within the ministry, and by encouraging representation from underrepresented groups to keep pace with changes in Ontario workplaces.

The Framework specifically champions the principle of inclusivity and balance as a direct way to remind ministry staff to encourage involvement from the full range and diversity of stakeholders affected, remove barriers for those groups that are hardest to reach, and aim for fair and balanced participation. In addition, it promotes the principle of making engagement easy by being sensitive to different needs among stakeholders, and by allowing multiple methods of input when inviting stakeholders to participate in engagement activities.

Information and communications

OPS MYAP key outcome

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

Measures taken by the Ministry of Labour (MOL) in 2015

Commitment five

Ministry staff are provided with training and resources to create accessible documents at source.

Measures taken

Key staff that regularly create accessible documents were identified. Resources on creating accessible documents were shared with the group. In addition, they were invited to Accessible Documents Training Workshop provided by the OPS Diversity Office. Resources on how to create accessible documents were shared with the Ministry of Labour’s Accessibility Council Members as well as Ministry of Labour intranet coordinator.

Commitment six

Revise Intranet resources to ensure updated information on accessibility and practical resources are available.

Measures taken

MOL’s current intranet page contains resources on Creating Accessible Documents. Ministry of Labour’s Communications and Marketing Branch is already in the process of creating an Accessibility Hub for 2016. Intranet content review has been sent to appropriate content owners. The Accessibility Lead is currently working with the Communications and Marketing Branch to review the Accessibility Section of the Ministry of Labour’s Intranet Page.

Commitment seven

Five ministry representatives to attend Accessibility Expo annually and share the learning with their teams and the Accessibility Council.

Measures taken

Ministry of Labour has continued to send representatives to the Accessibility Expo each year including in 2015. This year’s Accessibility Expo took place on November 30, 2015. The theme of the conference was “Thinking Globally, Acting Locally.” Learning has been shared with team members within the Organizational Effectiveness Branch. Conference materials will be shared with council members at the next council meeting in 2016.

Each year since 2009, the OPS has offered an Accessibility Expo to engage OPS employees in leading-edge discussions on accessibility. In June 2015, in celebration of the 10th anniversary of the AODA, the OPS Diversity Office hosted the Accessibility Innovation Showcase 2015. This official Parapan American Games event was free and was open to the public. In August 2015, a session was held at the MaRS Discovery District, where attendees learned about innovative technology and assistive devices developed by Ontario companies that help improve the lives of people with disabilities. In addition, participants had a chance to watch a virtual Hackathon to break down accessibility barriers, meet para-athletes, listen to inspiring speakers and enjoy interactive exhibits.

Commitment eight

The Labour and Transportation I&IT Cluster (LTC) 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 I&IT projects, LTC staff will work with the MOL accessibility leads to ensure compliance requirements are defined.

Measures taken

LTC has developed and delivered enhanced MOL business applications in the 2015-2016 fiscal year:

  • EPFNA – fully tested and compliant with WCAG 2.0 requirements
  • Trust Management System – fully tested and compliant with WCAG 2.0 requirements

Each existing public facing Internet application will be (or has been) assessed and remediated if required, to ensure full compliance with the IASR and WCAG 2.0, prior to January 1, 2016.

  • eClaims – AODA compliance was completed in June, 2015. Web site was reassessed/retested to confirm compliance
  • Hours of Work (HOW) – remediation project is in place to address AODA related changes and to provide accessible version (HTML) of the documents attached to the HOW acknowledgement letter. Deployment occurred in December, 2015
  • Ministry of Labour external website is compliant; remediation efforts are focused on providing accessible version (HTML) for the PDF documents on the website. Remediation project deployment occured in December, 2015

LTC has continued to work with the Accessibility Lead and MOL Communications and Marketing Branch to ensure compliance requirements. The Cluster has continued to improve AODA/ IASR IT Accessibility related guidance and information to MOL I&IT projects, through continued collaboration with the Accessibility Centre of Excellence (ACOE) and the Accessibility Lead. The Cluster provided improved accessibility-related guidance to MOL business application solution projects through:

  • LTC’s project early engagement process (e.g. to assist project managers to understand and plan for accessibility-related requirements, deliverables and activities)
  • LTC’s Public-facing Web Accessibility Compliance Task Force (e.g. to ensure all MOL public-facing websites are compliant with WCAG 2.0 by January 1, 2016)
  • LTC’s continuing collaboration with the Accessibility Centre of Excellence (e.g. to provide MOL projects with improved accessibility-related guidance, methods, tools and support)
  • LTC’s continuing collaboration with the Ministry Accessibility Unit (e.g. to improve coordination of accessibility-related support services to projects)

Employment

OPS MYAP key outcome

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

Measures taken by the Ministry of Labour (MOL) in 2015

Commitment nine

Deputy Minister’s annual performance commitments identify accessibility in the ministry as a priority.

Measures taken

Taking Action on Accessibility is outlined as a key commitment for the Deputy Minister’s Annual Performance Plan. The commitment states:

MOL will continue to make accessibility a fundamental part of all Ministry business and demonstrate leadership in accessibility through promotion and implementation of a Ministry Accessibility Plan and engagement of the Ministry Accessibility Council. Use evidence to inform action, measure impact and report on progress on the Ministry’s plan.

In addition, the Deputy Minister continues to promote inclusion and diversity in Ministry core business and by creating awareness through various speaking engagements.

Commitment ten

Provide training to managers and employees on accommodation and return to work in collaboration with the OPSEU MERC Employment Accommodation Working Group.

Measures taken

Taking Action on Accessibility is outlined as a key commitment for the Deputy Minister’s Annual Performance Plan. The commitment states:

The OPSEU MERC Employment Accommodation Working Group has not met due to collective bargaining. The Employee Health, Safety and Wellness, Disability Support Services Branch, MGCS has continued to provide face to face Manager training on Employment Accommodation and Attendance Support.

Commitment eleven

Orientation and onboarding of new managers and staff to include accessibility and inclusion learning tools.

Measures taken

The MOL Orientation Guide for new managers and employees provides information about Diversity, Inclusion and Accessibility. The guide lists learning tools, courses and resources regarding accessibility and inclusion. The in-person orientation session also covered Diversity and Inclusion topics. Managers were provided with a Toolkit for Inclusion comprised of various diversity and inclusion related resources.

The Centre for Employee Health, Safety and Wellness, Disability Support Services Branch, MGCS has provided face to face Manager training on Employment Accommodation and Attendance Support to MOL Managers.

Build environment

OPS MYAP key outcome

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

Measures taken by the Ministry of Labour (MOL) in 2015

Commitment twelve

Improve accessibility in government facilities by installing door operators, and where possible investing in accessible washrooms and kitchens.

Measures taken

The Business Support Unit has improved accessibility in MOL facilities by installing door operators, and where possible investing in accessible washrooms and kitchens. Some examples of recent projects are:

  • installation of new offset hinges and lever handle locks to retrofit emergency exit doors to meet new building code barrier free access requirements for 7th, 9th and 10th floors at 400 University Avenue.
  • employment Practices Branch renovation at 400 University Avenue. Accommodations has been updated to be code compliant. Kitchen to be upgraded to AODA standard by end of February 2016.
  • 505 University Avenue 19th and 20th floors: Two accessible kitchens, full renovation and code compliant.
  • Whitby new built – Accessible Kitchen; AODA Code Compliant.
  • 1290 Central Parkway, Mississauga – partial renovation of expansion space on the 3rd floor.

The Business Support Unit is also working on other projects to ensure MOL facilities and public spaces are accessible. Some examples of current and planned projects in 2016 are:

  • 400 University Avenue 10th floor: renovation currently under way. Two existing kitchens to be enlarged and compliant to AODA.
  • Hamilton – 119 King St West 13 and 14th floor renovation. The business unit will upgrade any areas not in compliance.
  • 400 University Avenue 12th floor renovation. It will be designed to be code compliant including the addition of two compliant kitchens.
  • 400 University Avenue: Life-safety system currently being retrofitted / updated. It will include strobe-light fire alarms for the hearing impaired.
Commitment thirteen

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 considers opportunities to improve existing accessibility.

Measures taken

The Business Support Unit has continued to use the “Inclusion Check’ for any project initiation. The team strives to improve accessibility for all projects. Built Environment Code is kept in mind even for partial renovations where code compliance is not mandatory. For instance, door hinges have been upgraded to improve visibility for a recent minor renovation project. In addition, strobe lights for hearing impaired has been installed on a number of Ministry of Labour floors at 400 University.

Commitment fourteen

Staff Communications from the Business Support Unit on facilities related matters is in accessible formats.

Measures taken

Staff communications from the Business Support Unit on facilities related matters are sent in accessible formats (i.e. visible font, proper colour contrast and plain language).

General outcomes

OPS 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 the Ministry of Labour (MOL) in 2015

Commitment fifteen

Strengthen the impact of the Accessibility Council as the lead in connecting with every part of the ministry to increase awareness and remove barriers.

Measures taken

The Ministry has always consulted the Accessibility Council as the lead in connecting with every part of the ministry. The council members consult with program areas on Accessibility commitments and measures taken. The results of those consultations are included in the Annual Ministry Accessibility Plan. Council Members are also on the priority list for training on Built Environment Standards.

Commitment sixteen

Accessibility Council meets quarterly to discuss accessibility in the ministry.

Measures taken

The Accessibility Council met three times in person during 2015. The Council meets to discuss strategy or learn about new accessibility topics. The council has also been engaged through email communication and various other consultation processes.

Section two: report on measures proposed by the ministry for 2016

Customer service

OPS MYAP key outcome

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

Measures proposed by MOL for 2016

  • Build capacity and expertise in the ministry to create quality and timely alternative formats upon request to external and internal customers.
  • Include a formal step in the MOL customer service email audit process to validate that the message to employees is 100% accessible.
  • Measure the number of respondents who meet accessibility requirements and leverage best practices when auditing MOL employees on email response times during the Customer Service Audit.
  • Organizational Effectiveness Branch to use the ‘inclusion lens’ to review service standards
  • The Stakeholder Engagement Strategy to include engagement techniques for reducing barriers and promoting inclusion.

Information and communications

OPS MYAP key outcome

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

Measures proposed by MOL for 2016

  • Ensure MOL internet websites and web content meet the IASR standard of WCAG 2.0 Level AA by January 1, 2016.
  • Ministry of Labour should continue to send representatives to the Annual Accessibility Expo.
  • Creation and implementation of ministry wide Accessible Documents Training Strategy.
  • All intranet content to be fully accessible by June, 2016.
  • Creation of an “Accessibility Hub” on the MOL intranet page which will include comprehensive resources on “how to create accessible documents”.
  • Creation of a formal process for submitting accessible intranet content.
  • Presentation to all management teams about Creating Accessible Documents.

Employment

OPS MYAP key outcome

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

Measures proposed by MOL for 2016

  • Deputy Minister’s annual performance commitments identify accessibility in the ministry as a priority.
  • Orientation and on boarding of new staff to include accessibility documents training and inclusion learning tools.
  • Provide training to managers and employees on employment accommodation and return to work protocol.
  • Promote employment programs for persons with disabilities.

Built environment

OPS MYAP key outcome

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

Measures proposed by MOL for 2016

  • Improve accessibility in the government facilities by installing door operators, and investing in accessible washrooms and kitchens where renovations are scheduled.
  • 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 considers opportunities to improve existing accessibility.
  • Staff communications from the Business Support Unit on facilities related matters is in accessible formats.

General outcome

OPS 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 MOL for 2016

  • Maintain a strong profile for the Accessibility Council to increase awareness and remove barriers.
  • Continue to meet the Annual AODA Compliance Attestation standards.

Section three: addressing the identification of barriers in legislation

Introduction

The ODA establishes that a ministry’s accessibility plan shall include the measures in place to address the identification, removal and prevention of barriers to persons with disabilities in the Acts, regulations, policies, programs and services administered by the ministry.

In 2005, the government introduced the Accessibility for Ontarians with Disabilities Act, with the goal of making Ontario accessible by 2025. In support of this goal, the government subsequently committed to review Ontario legislation to identify and address accessibility barriers, and undertook a coordinated review of 51 statutes considered to have a high impact on persons with disabilities. This review has now been completed.

Our ministry remains committed to the goal of ensuring that Ontario legislation does not create barriers to persons with disabilities. We will continue to report through our accessibility plan, the actions taken to identify and remove barriers in ministry Acts, regulations, policies, programs and services and those to be reviewed in the coming year. The findings of the coordinated review of high impact statutes will inform our ministry’s approach to carry out this work.

Measures currently in place

The following measures are in place to assess our ministry’s proposals for policies and programs and services to determine their effect on persons with disabilities:

  • ODA Mailbox for Accessibility Inquiries provides information to any accessibility related questions.
  • OPS Inclusion Lens is used as a tool to remove accessibility barriers when existing Acts, regulations, policies, programs, practices and services undergo a policy review within the ministry.

Actions taken in the past year

In 2015, the Ministry of Labour took the following actions to address barriers in its Acts, regulations, policies, programs, practices and services in response to identified barriers:

  • As part of the process 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

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 Stakeholder Engagement Strategy included engagement techniques for reducing barriers and promoting inclusion.

The Business Support Unit has continued to use the “Inclusion Check’ for any building project initiated.

Upcoming plans for review

In the coming year, the Ministry of Labour will review practices and/or services listed below, for barriers to persons with disabilities:

  • the Ministry of Labour is working on creating a formal process for submitting accessible intranet content.
  • Customer Service Standards to be reviewed using the Inclusion Lens
  • the Ministry will continue to report on the progress of the review and any proposed remedies through its annual accessibility plans.