Policy Statement

INCOM Manufacturing Group is committed to providing quality goods and services that are accessible to all persons.

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Purpose

The Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”) is a Provincial Act with the purpose of developing, implementing and enforcing accessibility standards in order to achieve accessibility for persons with disabilities with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises.

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Under the AODA, Ontario Regulations 429/07 entitled “Accessibility Standards for Customer Service” came into force on January 1, 2008. That Regulation establishes accessibility standards specific to customer service for public sector organizations and other persons or organizations that provide goods and services to members of the public or other third parties.

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This policy is drafted in accordance with the Accessibility Standards for Customer Service (Ontario Regulation 429/07) and addresses the following:

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1. The provision of goods and services to persons with disabilities;

2. The use of assistive devices by persons with disabilities;

3. The use of service animals by persons with disabilities;

4. The use of support persons by persons with disabilities;

5. Notice of temporary disruptions in services and facilities;

6. Training;

7. Customer feedback regarding the provision of goods and services to persons with disabilities; and

8. Notice of availability and format of documents.

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Application

This policy applies to all persons who deal with members of the public including other third parties working on behalf of INCOM, whether the person does so as an employee, agent, or otherwise.

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Definitions

Assistive Device

A device used to assist persons with disabilities in carrying out activities or in accessing the services of persons or organizations covered by the Customer Service Standard.

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Disability

1. Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device,

2. A condition of mental impairment or a developmental disability,

3. A learning disability, or a dysfunction in one or more of the processes involved in  understanding or using symbols or spoken language,

4. A mental disorder, or

5. An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

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Guide Dog

A guide dog as defined in section 1 of the Blind Persons’ Rights Act is a dog trained as a guide for a blind person, and having qualifications prescribed by the regulations under the Blind Persons’ Rights Act.

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Regulated Health Professional

For the purpose of documentation confirming the needs for a service animal, documentation is acceptable from any of the following:

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• A member of the College of Audiologists and Speech-Language Pathologists of Ontario

• A member of the College of Chiropractors of Ontario

• A member of the College of Nurses of Ontario

• A member of the College of Occupational Therapists of Ontario

• A member of the College of Optometrists of Ontario

• A member of the College of Physicians and Surgeons of Ontario

• A member of the College of Physiotherapists of Ontario

• A member of the College of Psychologists of Ontario

• A member of the College of the Registered Psychotherapists and Registered Mental Health Therapists of Ontario

 

Service Animal

Any animal used by a person with a disability for reasons relating to the disability where it is readily apparent that the animal is used by the person for reasons relating to his or her disability; or where the person provides a letter from a regulated health professional confirming that he or she requires the animal for reasons relating to his or her disability; or a valid identification card signed by the Attorney General of Canada or a certificate of training from a recognized guide dog or service animal training school.

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Support Person

A person who accompanies a person with a disability in order to assist him or her with communication, mobility, personal care, medical needs or with access to goods or services.

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Procedures

General Principles

a. The Provision of Goods and Services to Persons with Disabilities

INCOM will use reasonable efforts to ensure that its policies, practices and procedures are consistent with the following principles:

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• INCOM’s goods and services are provided in a manner that respects the dignity and independence of persons with disabilities;

• The provision of INCOM’s goods and services to persons with disabilities are integrated with those provided to persons who do not have disabilities unless an alternative measure is necessary to enable a person with a disability to obtain, use or benefit from INCOM’s goods and services.

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b. Communication with Persons with Disabilities

INCOM will make reasonable efforts to publicize the availability of services for persons with disabilities. Company employees will make every reasonable effort to communicate effectively, and in an appropriate manner and format, with persons with a disability (or their support person) who have made their requirements known to INCOM.

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It is INCOM’s expectation that communications between Company Employees and the General Public will be conducted with dignity, respect and fairness by and for all parties.

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c. Notice of Temporary Disruptions in Services and Facilities

INCOM is aware that the operation of its services and facilities is important to all persons. However, temporary disruptions in INCOM’s services and facilities may occur due to reasons that may or may not be within INCOM’s control or knowledge.

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INCOM will make reasonable efforts to provide notice of the disruption to members of the public, including information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that may be available. INCOM will make reasonable effort to provide prior notice of planned disruption if possible, recognizing that in some circumstances such as in the situation of unplanned temporary disruption, advance notice will not be possible. In such cases, INCOM will provide notice as soon as possible.

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When temporary disruptions occur to INCOM’s services of facilities, INCOM will provide notice by posting the information on INCOM’s website, and/or by any other method that may be reasonable under the circumstances as soon as reasonably possible.

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d. Assistive Devices and other Measures that Assist with Accessibility

A person with a disability may provide his/her own assistive device for the purpose of obtaining, using and benefitting from INCOM’s goods and services. Exceptions may occur in situations where INCOM has determined that the assistive device may pose a risk to the health and safety of a person with a disability or the health and safety of others on the premises.

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In these situations and others, INCOM may offer a person with a disability other reasonable measures to assist him or her in obtaining, using and benefiting from INCOM’s goods and services, where INCOM has such other measures available. It should be noted that it is the responsibility of the person with a disability to ensure that his or her assistive device is operated in a safe and controlled manner at all times.

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e. Service Animal

Persons with a disability may enter premises owned and/or operated by INCOM accompanied by a service animal and keep the animal with them if the public has access to such premises and the animal is not otherwise excluded by law. If a service animal is excluded by law, INCOM will ensure that alternate means are available to enable the person with a disability to obtain, use or benefit from INCOM’s goods and services.

 

If it is not readily apparent that the animal is a service animal, INCOM may ask the person with a disability to provide documentation from a regulated health professional confirming that the person requires the animal for reasons relating to his or her disability.

 

It should be noted that it is the responsibility of the person with a disability to ensure that his or her service animal is kept in control at all times.

 

f. Support Persons

A person with a disability may enter premises owned and/or operated by INCOM with a support person and have access to the support person while on the premises.

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INCOM may require a person with a disability to be accompanied by a support person while on Company premises in situations where it is necessary to protect the health and safety of the person with a disability or the health and safety of others on the premises. Before making a decision, INCOM shall:

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• Consult with the person with a disability to understand their needs;

• Consider health and safety reasons based on available evidence;

• Determine if there is no other reasonable way to protect the health or safety of the person or others on the premises.

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A support person, when assisting a person with a disability to obtain, use or benefit from INCOM’s goods and services, will be permitted to attend at no charge where an admission fee is applicable.

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g. Feedback

INCOM is committed to providing high quality goods and services to all members of the public it serves. Feedback from the public is welcomed as it may identify areas that require change and encourage continuous service improvements.

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Feedback from a member of the public about the delivery of goods and services to persons with disabilities may be given by telephone, in person, in writing, in electronic format or through other methods.

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h. Training

INCOM will ensure that all persons to whom this policy applies receive training as required by the Accessibility Standards for Customer Service. The amount and format of training given will be tailored to suit each person’s interactions with the public and his or her involvement in the development of policies, procedures and practice pertaining to the provision of goods and services.

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The content of the training will include:

• A review of the purposes of the AODA;

• The requirements of the Accessibility Standards of Customer Service (Ontario Regulation 429/07);

• Instruction on INCOM’s current policies, procedures and practices pertaining to the provision of goods and services to persons with disabilities;

• How to interact and communicate with persons with various types of disabilities;

• What to do if a person with a particular type of disability is having difficulty accessing INCOM’s goods and services;

• How to interact with persons with disabilities who use assistive devices or who require the assistance of a support person or service animal; and

• Information about the equipment or devices available on INCOM’s premises that may help with the provision of goods or services to persons with disabilities.

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Timeline for Training

Training will be provided as soon as practicable upon an individual being assigned the applicable duties as well as on an ongoing basis as changes occur to INCOM’s policies, procedures and practices governing the provision of goods or services to persons with disabilities.

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Record of Training

INCOM will keep records of the training, including the date on which training is provided and the number of individuals to whom it is provided. The names of individuals trained will be recorded for training administration purposes, subject to the Municipal Freedom of Information and Protection of Privacy Act (“MFIPPA”).

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i. Availability and Format of Documents Required by the Accessibility Standards for Customer Service (Ontario Regulation 429/07)

All documents required by the Accessibility Standards for Customer Service, including INCOM’s accessible Customer Service policies, procedures and practices, notices of temporary disruptions, training records, and written feedback process are available upon request, subject to MFIPPA

 

When providing a document to a person with a disability, INCOM will make every reasonable effort to provide the document, or the information contained in the document, in a format that takes the person’s disability into account and within a reasonable timeframe.

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j. Notice of the Availability of Documents

Notice of the availability of all documents required by the Accessibility Standards for Customer Service will be posted on INCOM’s website and will be available at INCOM Administrative Office.

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Exclusions

Under the AODA, Ontario Regulations 429/07 entitled “Accessibility Standards for Customer Service” all persons, whether an employee, member of Council, agent, and all persons who participate in developing INCOM’s policies, practices and procedures governing the provision of goods and services to members of the public or other third parties are to be trained. Therefore, there are no exclusions at this time.

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References and Related Policies

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• “Accessible Customer Service Policy Required for the Implementation of the Accessibility for Ontarians with Disabilities Act (AODA 2005).”

• “Accessibility Standards for Customer Service, Summary of Requirements.” Access ON, Breaking Barriers Together

• “Compliance Manual: Accessibility Standards for Customer Service, Ontario Regulation 429/07.” Ministry of Community and Social Services

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Consequences of Non-Compliance

Failure to abide by this policy may result in progressive discipline, up to and including termination.

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Review Cycle

This policy will be reviewed annually by the Council, the C.A.O., the Senior Management Team and INCOM’s AODA committee.

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Cyril Dicks

December 5, 2022