As mandated by the Ontario government, accessibility criteria and features must be incorporated into all purchasing practices. It is the responsibility of each employee purchasing a good, service, or facility to consider and apply the appropriate accessibility criteria to their purchasing decisions. If it is not practicable to incorporate accessibility criteria or features you must be ready to provide an explanation upon request.
When planning to make a purchase it is important to remember that 1/6 people in Ontario have a disability and that number is expected to grow to 1/5 in the next few years. Procuring accessible goods, services and facilities now is usually more economical than restructuring the goods, services or facilities to meet accessibility criteria afterward.
· Understand the Integrated Accessibility Standard Regulations pertaining to procurement and the terms related to it including “disability”, “accessibility” and “barrier”
· Consult the accessibility checklist
· If purchasing a kiosk (including digital multi-function copiers), consult the Georgia Tech Research Institute’s “Accessibility Assistant” at http://accessibility.gtri.gatech.edu/assistant/assistant_home.php
Under the Accessibility for Ontarians with Disabilities Act Integrated Accessibility Standards, “designated public sector organizations shall incorporate accessibility criteria and features when procuring or acquiring goods, services, or facilities, except where it is not practicable to do so.” The regulation also specifies that self-serve kiosks purchased after January 1, 2013 must incorporate accessibility features.
If it is not practicable to incorporate accessibility criteria and features into the good, service or facility you are purchasing, you are required to provide an explanation upon request. To view the Integrated Accessibility Standards Regulation in full please visit http://www.e-laws.gov.on.ca/html/source/regs/english/2011/elaws_src_regs_r11191_e.htm.
· Any degree of physical disability, infirmity, malformation or disfigurement.
· A condition of mental impairment or a developmental disability.
· A learning disability or a dysfunction in one or more of the processes involved in
understanding or using symbols or spoken language.
· A mental disorder.
· An injury or disability for which benefits were claimed or received under the insurance plan
established under the Workplace Safety & Insurance Act, 1997.
The definition includes disabilities of different severity, visible as well as non-visible disabilities, and disabilities the effects of which may come and go.
Accessibility (As defined in the Ontario Public Service Diversity and Inclusion Lexicon):
“A general term used to describe the degree of ease that something (e.g. device, service, environment) can be used and enjoyed by persons with a disability. The term implies conscious planning, design and/or effort to ensure it is barrier free to persons with a disability, and by extension, highly usable and practical for the general population as well.”
Barrier (As defined in the AODA, 2005) :
“Anything that prevents a person with a disability from fully participating in all aspects of society because of his or her disability, including a physical barrier, an architectural barrier, an information or communications barrier, an attitudinal barrier, a technological barrier, a policy or a practice.”
To ensure educators and staff are making purchases that meet AODA accessibility standards and abide by Laurier’s Procurement Policy, the following questions can be asked of producers to determine accessibility of materials:
Type of Purchase
ü Is the text book available in a pdf or e-text format?
ü When animation or video are used, are controls to navigate the key board easily operable?
ü Is there consistent key board navigation, including across operating systems and browsers?
ü Have videos been closed captioned?
ü Are described videos available?
ü Is the transcription of videos available?
ü Is there a strong colour contrast on both textual and visual elements?
ü Can material be zoomed to 400% preserving the readability of the content?
ü Can content and meaning be perceived by someone with colour blindness?
ü Can instructors identify screen reader accessible content and options when creating their assignments through the use of accessibility icons or identifiers?
ü If you have asked if materials are accessible, here are some probing questions to ensure materials are accessible or conversion ready:
o How have materials been tested?
o Have AODA standards and guidelines been followed in the production of materials?
o WLU uses Jaws (version 16), Zoomtext (version 10.1) and Kurzweil (version 14), have materials been tested with these adaptive software?
o Can material be forwarded to the Accessible Learning Centre for further testing?
o If the material is in progress of being made accessible, ask what final format will be provided and projected timeline for completion.
ü If dynamic study materials utilizing web content are used, are they accessible?
o How have they been tested for accessibility?
o If they are not accessible, what is the plan for alternative access (e.g., working with the Accessible Learning Centre)?
o Can solutions to web-based study questions or self-assessments be forwarded to Accessible Learning for formatting in a conversion-ready format?
ü Is there a technical contact person responsible for responding to accessibility issues available for consult? If so, who?
ü Can the good be used by someone:
o In a seated position
o Using one hand, with limited upper body strength or limited fine motor skills
ü Does the firm provide accessible customer service, as required under the Customer Service Standard?
ü Can the service provider accommodate the needs of people of all abilities? For example, if hiring someone to conduct research, do their surveys and interviews accommodate people with different types of abilities
ü Will the company use accessible signage, audio and/or print materials? For example, if you’re hiring an even coordinator, will they use high contrast signage for the event?
ü Can someone using a mobility aid, like a wheelchair or walker get around the facility?
ü Are signs placed at an accessible height?
ü Does the facility have emergency procedures to assist people with disabilities?
ü Can someone with a disability use the facility as quickly and easily as a person without a disability?
Toolkit for Purchasing Accessible Technology or Services for the Office Environment: http://www.apt.gc.ca/
Includes information about chairs, desks, office supplies, shelving, hardware, presentation materials, phones, fax machines, web-based applications and more.
Centre for Excellence in Universal Design IT Procurement toolkit: http://www.universaldesign.ie/useandapply/ict/itprocurementtoolkit
Georgia Tech Research Institute’s “Accessibility Assistant”: http://accessibility.gtri.gatech.edu/assistant/assistant_home.php
Includes information about kiosks, desktop all-in-one devices, digital multi-function copiers, laptops, point of sale machines and more.
Web Content Accessibility Guidelines: http://www.w3.org/WAI/intro/wcag
Authoring Tool Accessibility Guidelines: http://www.w3.org/WAI/intro/atag.php
User Agent Accessibility Guidelines: http://www.w3.org/WAI/intro/uaag.php
Frequently Asked Questions
Do the accessibility obligations apply to the procurement of all goods and services?
Yes. The accessibility obligations apply to the acquisition of all goods, services, and facilities regardless of value.
Do I have to apply accessible criteria to goods used by individual employees?
Yes, unless it is not practicable to do so. It is important to take into consideration the possibility that the employee using the purchased good may acquire a disability, or a person with a disability may later use said good. For example: In purchasing telephones, you might want to assess whether the equipment requires volume controls, clear display screens, and large buttons in order to make the telephones as accessible to as many users as possible. While the original user of the phone may not have a disability, the phone may be used by several different employees over the period of a few years. Please review the Employment Accommodation Policy and Procedure if you are procuring goods or services for use by an employee. Remember: Procuring accessible goods, services and facilities is usually more economical than restructuring the goods, services or facilities to meet accessibility criteria afterward.
Do I have to apply accessible criteria to goods used by the public?
Yes, it is especially important to apply accessibility criteria and features to goods, services and facilities used by the public as it is very likely that a member of the public who utilizes that good, service, or facility will have a disability. When determining your priorities for purchasing a new item remember that 1/6 (15.5%) of Canadians have a disability and that number is expected to grow to 1/5 (20%) over the next few years. Furthermore, by applying accessibility criteria and features other customers and members of the public benefit, including people pushing strollers and older adults. If it is not practicable to incorporate accessibility criteria and features you must be prepared to provide an explanation.
Am I required to document and retain information relating to my compliance with accessibility obligations?
No, however you may be asked to provide an explanation if for any reason you have not incorporated accessibility criteria and features in your procurement.
What do I do if I cannot find information about accessibility criteria related to the product, service, or facility that I am purchasing?
If it is not possible to apply the general criteria checklist and you need help finding additional accessibility criteria related to the product or service being procured, you may contact the Employment Equity and AODA Officer at firstname.lastname@example.org for assistance.
How do I know I am meeting my accessibility obligations in procurement?
Consider a few key questions: Do the goods, services or facilities you are planning to acquire create barriers to persons with disabilities? Can a person with a disability use the service at all? Can people with disabilities configure the item to meet their specific needs and preferences?
If you are hosting an event or providing a service or facility, consider offering a survey or questionnaire that includes a question about accessibility. This will give people the opportunity to let you know if you are meeting their accessibility needs.