Disability related policies & practices (AODA) TABLE OF CONTENTS Executive Summary ------------------------------------------------------------------------------1 Accessibility Standard for Customer Service -------------------------------------------1 Communication ________________________________________________2 Assistive devices _______________________________________________2 Service animals ________________________________________________2 Support persons ________________________________________________2 Notice of temporary disruption _____________________________________2 Feedback process ______________________________________________3 Training ______________________________________________________3 Notice of availability _____________________________________________4 Modifications to this or other policies ________________________________4 Online reporting ________________________________________________4 Integrated Accessibility Standards Regulation (IASR) -------------------------------5 NowPac Commitment____________________________________________5 General Requirements. __________________________________________5 Employment Standard ___________________________________________8 Information and Communication Standard ____________________________8 Employment Standard (2016) _____________________________________9 Information and Communication Standard (2016) _____________________11 Disability related policies & practices Executive Summary This document summarizes NowPac’s policies and practices regarding persons with disabilities and is structured to follow the requirements of the Accessibility for Ontarians with Disabilities Act (AODA). NowPac’s policies and practices have been developed to be consistent with the principles of: Dignity Independence Integration1, and Equal opportunity NowPac Commitment NowPac is committed to excellence in serving all customers and staff including those with disabilities. It is NowPac’s goal to meet or exceed the requirements of the Government of Ontario’s AODA Customer Service Standard and the Integrated Accessibility Standards Regulation and NowPac commits to meeting the accessibility needs of people with disabilities in a timely manner. At this time (May 7, 2015) NowPac has successfully addressed all relevant requirements of the AODA including those due January 2016. This plan is available upon request, and in an accessible format if required. This plan will be reviewed and updated, if required, on an annual basis. Any questions or comments should be addressed to one of the following: email: accessibility@nowpac.com phone: 416 321 5799 ext. 314 mail: Director of Operations 780 Tapscott Road, Unit #5 Scarborough, ON, M1X 1A3 1 except when alternate measures are necessary to meet the needs of a person with disabilities Last update: May 7, 2015 Customer Service Standard Accessibility Standard for Customer Service NowPac is committed to excellence in serving all customers including people with disabilities. This section summarizes NowPac’s policies and practices regarding the provision of goods and services to people with disabilities. While NowPac does not provide goods or services directly to the public it does do so on a business to business basis and it is NowPac’s goal to meet or exceed the requirements of the AODA Accessibility Standard for Customer Service. This plan is available to customers upon request, and in an accessible format if required. NowPac staff have reviewed the AODA website and used the online wizard to determine requirements. Our Customer Service Standard obligations as determined by the AODA wizard are outlined below: As per the Customer Service requirements, NowPac’s plan addresses the following requirements obtained from the MCSS website: Last update: May 25, 2015 Page 1 of 11 Customer Service Standard Communication Policy: NowPac staff will communicate with people with disabilities in ways that take into account their disability. Practice: Current communication methods include voice, email, mail and web site access. Alternatives to each communication method will be made available upon request and staff will be trained regarding these alternatives and the use of plain language. Assistive devices Policy: Assistive devices are allowed on NowPac premises. NowPac will ensure that staff are trained and familiar with the various assistive devices that may be used by customers with disabilities while accessing our goods or services. This training is part of the Customer Service training provided to all staff at NowPac. Practice: All NowPac staff are provided class room based Customer Service Training. During the course of this training they are made familiar with various types of assistive devices customers may use and how best to interact with those customers and their devices. Service animals Policy: Service animals are allowed on NowPac premises, where allowed by law. Practice: Service animals are allowed on our premises except for the plant and warehouse areas. This limitation is the result of Ontario Food Premises Regulation 562; Sec. 59e. Support persons Policy: A person with a disability who is accompanied by a support person is allowed to have that person accompany them on our premises. Practice: NowPac does not charge for access. A support person will be provided the same privileges as any other customer visiting our premises. Notice of temporary disruption Policy: In the event of a planned or unexpected disruption to services or facilities for customers with disabilities NowPac will notify customers promptly. This clearly posted notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if available. Last update: May 25, 2015 Page 2 of 11 Customer Service Standard Practice: The notice will be placed on the NowPac website, on bulletin boards in the plant, kitchen and office areas, and at both the front door to the office space and the loading dock reception area. Feedback process Policy: Customers who wish to provide feedback on the way NowPac provides goods and services to people with disabilities can notify NowPac’s designated contact person either verbally, by email, by mail or via NowPac’s web site on the “AODA” page. Practice: All feedback, including complaints, will be directed to NowPac’s designated contact person for review and response. Should a response be requested in an accessible format NowPac will contact the customer to determine an appropriate response format. Customers can expect to hear back within ten business days. email: accessibility@nowpac.com phone: 416 321 5799 ext. 314 mail: Director of Operations 780 Tapscott Road, Unit #5 Scarborough, ON, M1X 1A3 Training Policy: NowPac will provide training to employees and others who deal with the public or other third parties on our behalf. Training will also be provided to people involved in the development of policies, plans, practices and procedures related to the provision of our goods and services. Practice: Individuals in the following positions will be trained: 1. office staff 2. plant/production staff 3. warehouse staff 4. owners/management This training will be provided to all applicable NowPac staff and owners/management and to new staff as part of their NowPac orientation. Staff and owners/management will be trained when changes are made to NowPac’s accessible customer service plan. Records will be kept outlining who received training and when it was done. Training will include: 1. An overview of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard 2. NowPac’s plan related to the customer service standard. 3. How to interact and communicate with people with various types of disabilities Last update: May 25, 2015 Page 3 of 11 Customer Service Standard 4. How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person 5. What to do if a person with a disability is having difficulty in accessing NowPac’s goods and services As of May 7, 2015 all NowPac staff, owners and management had been trained. Notice of availability Policy: NowPac’s Customer Service plan is available upon request, in an accessible format if required. Practice: NowPac will notify the public that our policies are available upon request by posting a notice to this effect on the company website and in the reception area at the Tapscott Rd. location and at the Kenway Dr. location. Modifications to this or other policies Policy: Any policy of NowPac that does not respect and promote the dignity and independence of people with disabilities will be modified or removed. NowPac’s policy is to meet or exceed AODA based requirements. Online reporting NowPac has successfully completed the required online reporting to the Government of Ontario regarding its Customer Service Plan. Last update: May 25, 2015 Page 4 of 11 Integrated Accessibility Standards Regulation Plan Integrated Accessibility Standards Regulation (IASR) This section summarizes NowPac’s policies and practices regarding achieving accessibility by meeting the requirements of the AODA’s IASR. NowPac Commitment NowPac is committed to excellence in serving all customers and staff including those with disabilities. It is NowPac’s goal to meet or exceed the requirements of the Government of Ontario’s AODA Integrated Accessibility Standards Regulation. NowPac commits to meeting the accessibility needs of people with disabilities in a timely manner. General Requirements. 1. Accessibility Policies 1.1.Determine requirements NowPac staff have reviewed the AODA website and used the online wizard to determine requirements. Our immediate obligations as determined by the AODA wizard are provided below: Last updated May 25, 2015 Page 5 of 11 Integrated Accessibility Standards Regulation Plan Our subsequent obligations, effective January 1, 2016 are provided below: Based upon these results we have committed to meeting, and have met, all requirements up to and including those due by January 1, 20162. 1.2.Develop policies NowPac commitment - as provided above NowPac policies This document describes the IASR policies developed by NowPac; Customer Service policies are provided earlier in this document. These policies meet the IASR requirements and will be reviewed and updated, if required, on an annual basis. 1.3.Make available This document is available on our website and on bulletin boards at our locations. Upon request, this document will be made available in an accessible format. 1.4.Follow up NowPac’s Customer Service Plan and IASR based policies will be reviewed and updated, if required, on an annual basis. 2. Multi-year accessibility plans 2.1.Assess NowPac We have reviewed current business practices at NowPac with respect to possible barriers to persons with disabilities. We believe that by meeting the accessibility requirements of the IASR we will have removed those barriers we are aware of, save for those facing persons with a mobility impairment. NowPac is not legally obligated to 2 NowPac’s new website is going live June 1, 2015 and the draft site has passed the WCAG AA standard Last updated May 25, 2015 Page 6 of 11 Integrated Accessibility Standards Regulation Plan transform its locations but is aware of this issue and is committed to implementing a solution. 2.2.Develop our plan NowPac has meet the IASR obligations: the requirements were determined, a time line developed to meet these requirements and staff allocated to work on this matter. As of May 7, 2015 all IASR requirements applicable to NowPac have been met. 2.3.Follow up NowPac’s Customer Service Plan and IASR based policies will be reviewed and updated, if required, on an annual basis. 2.4.Make available Policy: The NowPac AODA plan (the Customer Service and IASR plan) is publicly available. Practice: This document is available on our website and on bulletin boards at our locations. Upon request, this document will be provided in an accessible format. 3. Self Service kiosks Policy: NowPac does not use, nor does it plan to use self service kiosks. Practice: No action is required. 4. Training Policy: NowPac will provide training to employees and others who deal with the public or other third parties on our behalf. Training will also be provided to people involved in the development of policies, plans, practices and procedures related to the provision of our goods and services. Practice: Individuals in the following positions will be trained: 1. office staff 2. plant/production staff 3. warehouse staff 4. owners/management This training will be provided to all applicable NowPac staff and owners/management and to new staff as part of their NowPac orientation. Staff and owners/management will be trained whenever changes are made to NowPac’s IASR based policies and/or practices. Records will be kept outlining who received training and when they did so. Last updated May 25, 2015 Page 7 of 11 Integrated Accessibility Standards Regulation Plan Employment Standard Workplace Emergency Response Information This section summarizes NowPac’s policy regarding the provision of a workplace emergency response to customers with disabilities AND individualized emergency response plans for employees with disabilities. NowPac is constantly reviewing and updating its emergency procedures and staff will be advised of updates as they occur. The plan is available to customers upon request, and in an accessible format if required. Customer Emergency Plan • For visitors who may be at our premises when an emergency occurs, the NowPac employee who is hosting the visitor with a disability will be responsible for their safety. NowPac staff will be trained in the required emergency procedures. • For persons with vision impairment, hearing impairment and mobility impairment, the responsible NowPac employee will lead the person with a disability to a designated safe location as per the NowPac SOP PRE-004-6 and GEN-007-1. Individualized Emergency Response Plan for employees • When NowPac is aware of an employee with a disability who might need help in an emergency an individualized emergency response plan will be created for that employee taking into account the employees disability and their input to the plan. • With the employee’s consent, this plan will be shared with a person(s) designated to help them in an emergency. • For employees with vision impairment, hearing impairment or mobility impairment, the designated NowPac employee will assist the person with a disability to reach a designated safe location as per the NowPac SOP PRE-004-6 and GEN-007-1 • A copy of the individualized emergency response plan will be provided to the employee, in an accessible format if required. Information and Communication Standard 1. Feedback Policy: Employees and/or customers providing feedback will be provided accessible formats or communication supports if required and requested. Practice: Feedback processes will be available in accessible formats. Communication supports will be provided upon request. Feedback is currently possible via: Last updated May 25, 2015 Page 8 of 11 Integrated Accessibility Standards Regulation Plan email: accessibility@nowpac.com phone: 416 321 5799 ext. 314 mail: Director of Operations 780 Tapscott Road, Unit #5 Scarborough, ON, M1X 1A3 2. Accessible Formats and Communication Supports Policy: NowPac’s communications shall, upon request, be provided in an accessible manner, at no incremental cost. Practice: NowPac will, upon request, consult with the requesting person to ensure that communications are provided in an accessible format, including the provision of communication supports if required. 3. Accessible websites and web content Policy: NowPac’s website will meet the current requirements of the AODA. Practice: NowPac’s website and web content now meets W3C WCAG2.0 AA requirements. NowPac will test its web site and content after any significant content change to ensure the W3C guidelines are met. The test will be done using the W3C Validator. Once passed, a W3C badge will be placed on the site to confirm compliance. Employment Standard (2016) 1. Recruitment Policy: NowPac will notify both internal and external job applicants that, upon request and when needed, accommodations for disabilities will be provided to support their participation throughout the entire recruitment process. Practice: A. NowPac will notify job applicants that accommodations are available upon request. This notification will be included as part of the job posting. B. When an applicant is selected to participate in a second recruitment stage, i.e. an interview, and the applicant has requested an accommodation, NowPac will consult with the applicant and arrange an appropriate accommodation. C. Upon making an offer of employment NowPac will notify the applicant of NowPac’s policies for accommodating employees with disabilities. 2. Information for employees Policy: NowPac will notify all employees of policies supporting employees with disabilities. Last updated May 25, 2015 Page 9 of 11 Integrated Accessibility Standards Regulation Plan Practice: NowPac will make available to all employees its disability related policies. This information will be provided to new employees as part of their orientation. Any changes to existing policies will be communicated to all employees. 3. Processes to accommodate employees Policy: NowPac will work with any employee with a disability to develop an individual accommodation plan. Practice; NowPac will work with any employee with a disability to assess their accommodation needs, develop an accommodation plan and document the plan in an accessible format. To the greatest degree possible, this will be done while protecting the privacy of the employee. 4. Return to work Policy: NowPac will accommodate employees who are returning to work after being absent due to a disability and need a related accommodation to return to work. Practice: Upon an employee returning to work after being absent due to a disability and needing a related accommodation to return to work, NowPac will work with that employee to determine what form of accommodation is required and create an accommodation plan accordingly. 5. Performance Management Policy: All NowPac employees will be treated equally regarding Performance Management. Practice: Individual accommodation plans will be taken into account when evaluating an employee’s performance. Performance Management documents and feedback will be provided in an accessible manner as per the individual’s accommodation plan. 6. Career Development Policy: All NowPac employees will be treated equally regarding Career Development opportunities, subject to Performance Management evaluations. Practice: Employees with disabilities will have an individual Accommodation Plan developed for them. One of the goals of this plan is to help that employee succeed at NowPac. 7. Redeployment Policy: All NowPac employees will be treated equally regarding any job changes including redeployment. Practice: In the event of a job change for an employee with disabilities that employee’s accommodation plan will be reviewed, with the employee, to ensure that it still meets the employee’s requirements going forward. Last updated May 25, 2015 Page 10 of 11 Integrated Accessibility Standards Regulation Plan Information and Communication Standard (2016) 1. Accessible formats and communication supports Policy: Upon request NowPac will provide an employee with a disability information needed to perform the employees job and information generally available to other NowPac employees in an accessible format, with communication supports, as required, based upon consultation with that employee. Practice: When an employee requests that information be provided in an accessible format and/or with communication supports, NowPac will meet with that employee to determine the most appropriate accommodation, and will then provide the subject information accordingly. Last updated May 25, 2015 Page 11 of 11