In the third review of the AODA, the Honourable David Onley recommends needed improvements to the Act. One of these improvements is the need for a resource centre offering answers to people’s questions about AODA compliance. During the public meetings Onley held while preparing his review, attendees stated that many organizations would like to become more AODA compliant. However, many workers do not know how to apply the guidelines in AODA standards to their specific services or locations. As a result, Onley’s review recommends that the government develop an AODA resource centre for answering questions about AODA compliance.
An AODA Resource Centre
Review attendees state that staff members of many organizations often have specific questions about how to implement or interpret AODA standards. For instance, organizations may be uncertain about whether they should:
- Construct a steep ramp, or no ramp, if they have limited space
- Keep inaccessible copies of archived records on their websites, or remove them
- Use gravel or grass as a “hard surface” on a new accessible playground
In addition, attendees state that organizations are also requesting specific guidance about:
- How AODA standards relate to other laws, such as:
- The Ontario Human Rights Code
- The Ontario Building Code
- Whether the AODA’s definition of “barrier” mandates automatic doors at all hospital entrances
- How to fulfill Building Code requirements, measured in centimetres, using products measured in inches
- What “significant alterations” means in practice
- How to decide whether the Building Code would consider a renovation “extensive”
- Which groups or committees decide whether a building has heritage value and should not be renovated
- How a city can use its tax base to calculate how much money it needs to spend on accessibility
- How the AODA’s mandate to procure accessibly impacts the way a business buys or operates
- Understanding Web Content Accessibility Guidelines (WCAG) in practice, such as through:
- Videos showing how people use assistive technology to navigate websites
- How to display maps on a website in an accessible way
- Whether software that does not comply with WCAG constitutes an exception to web accessibility
Why a Trusted Response to these Questions is Needed
Currently, there is no official procedure for workers to ask and receive responses to questions about AODA compliance. As a result, workers may search for advice elsewhere. For instance, workers may contact consulting firms. However, the website of the Accessibility Directorate of Ontario (ADO) warns visitors that some consultants may provide inaccurate advice.
Alternatively, workers may implement solutions that do more harm than good. For example, the review describes an organization seeking guidance about whether captioning requirements applied to their online video archive. The organization did not know whether they would need to caption every video. This organization did not receive guidance from the ADO. As a result, they decided to remove all their videos from their website. Technically, this solution is AODA compliant. However, it means that the organization has stopped providing a service to the public. Furthermore, removing the videos may make the public believe that accessibility means low-quality service for everyone. Therefore, this solution is harmful to everyone involved in many ways.
Specific guidance from the ADO could have helped this organization keep their videos online while making them accessible. For instance, the ADO may have advised the organization that only videos created after a certain date needed captions. Similarly, the ADO could have offered support for staff to find captioning services or learn to caption themselves. Finally, if the ADO has existing resources on these topics, it could have directed the organization toward these resources. In short, a direct response to this organization’s question could have given them the support they needed. Therefore, Onley’s review recommends that the ADO should establish an AODA resource centre for responding to specific questions from organization staff.
How a Resource Centre could Provide Support
Furthermore, there could be one large centre supporting the whole province, or several smaller centres located throughout Ontario. The ADO could operate the centre(s), or delegate a non-governmental organization to do so. In either case, accessibility consultants could staff the centre(s) and respond to questions:
- In person
- By phone
- By email
In addition, the centre(s) could examine the questions people ask to find patterns. For instance, centre staff might receive similar questions from several organizations, or questions on the same topic. These related questions about AODA compliance would alert staff about areas where more support for AODA compliance is needed. Centre staff could then create resources or training modules about these topics, to help more people with the same questions.