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What Barriers Do Students with Disabilities Face in Post-Secondary Education in Ontario? Send Us Feedback on Our Draft Framework for a Post-Secondary Education Accessibility Standard

Accessibility for Ontarians with Disabilities Act Alliance Update United for a Barrier-Free Society for All People with Disabilities
http://Web: www.aodaalliance.org Email: aodafeedback@gmail.com Twitter: @aodaalliance Facebook: http://www.facebook.com/aodaalliance/

March 11, 2020

SUMMARY

Well, were at it once again! We want and need your feedback! This time, its all about barriers impeding students with disabilities in post-secondary education in Ontario.

Two years ago, the Ontario Government appointed an advisory Standards Development Committee to prepare recommendations on what should be included in an accessibility standard to be enacted under the Accessibility for Ontarians with Disabilities Act, to tear down the barriers that impede students with disabilities in post-secondary education in Ontario. That includes such things as colleges and universities in Ontario.

We want to present ideas to that Standards Development Committee on what it should recommend. We are preparing a Framework for what the Post-Secondary Education Accessibility Standard should include. Below we set out a draft of that Framework, showing our work to date.

This draft Framework is about 38 pages long. The first 22 pages list recommendations on 16 different topics. After that, there is a 16 page appendix with specific proposals for accessibility of the built environment in post-secondary education organizations. If you dont have time to read it all, wed welcome your feedback on any parts of it that you have time to review.

Please look it over and send us your comments by April 3, 2020. What do you like in it? What are we missing? What should we change?

Please email us your thoughts by April 1, 2020. Write us at aodafeedback@gmail.com The more specific you can be, the better!

Please dont use track changes to give us feedback, as it can present accessibility problems. Instead, send us an email with your comments. You can mention the number of the recommendation on which you are commenting, or cut and paste the passage on which you are commenting.

Once we get your feedback, we will finalize this Framework, make it public, and send it to the Post-Secondary Education Standards Development Committee.

This is the third such Framework weve prepared in the past 8 or 9 months. Last fall we prepared a detailed Framework on what the promised accessibility standard should include that will cover education in Ontario schools between kindergarten and Grade 12. We have submitted it to the K-12 Education Standards Development Committee.

Last month, we made public our Framework of what should be included in the promised Health Care Accessibility Standard. We have submitted that to the Health Care Standards Development Committee.

These Frameworks are our latest effort to try to provide constructive and leading-edge suggestions on how the Ontario Government could show strong new leadership on accessibility for over 2.6 million Ontarians with disabilities. We hope and trust that those Standards Development Committees found our proposals helpful. We thank everyone who has taken the time to give us feedback up to now as we worked on these important briefs.

To learn about our decade-long campaign to get the Ontario Government to take effective action under the AODA to address accessibility barriers that impede students with disabilities in Ontario’s education system, visit our websites Education page. To learn about our decade-long campaign for similar action under the AODA to address the disability barriers that impede patients with disabilities in Ontarios health care system, take a look at our websites Health Care page.

An inexcusable 405 days have now gone by since the Ford Government received the final report on the implementation and enforcement of the Accessibility for Ontarians with Disabilities Act that was prepared by former Lieutenant Governor David Onley. We are still waiting for the Ford Government to come up with a comprehensive and effective plan of new measures to implement the Onley Reports recommendations, needed to substantially strengthen the AODAs implementation and enforcement. To date, all the Government has offered Ontarians with disabilities is thin gruel.

MORE DETAILS

Accessibility for Ontarians with Disabilities Act Alliance
United for a Barrier-Free Society for All People with Disabilities www.aodaalliance.org Email: aodafeedback@gmail.com Twitter: @aodaalliance

Draft Only
A Framework for the Post-Secondary Education Accessibility Standard

March 11, 2020

Prepared by the Accessibility for Ontarians with Disabilities Act Alliance

Note: This is only a draft. It is still a work in progress. Feedback on it is welcome. By April 3, 2020, please send feedback to aodafeedback@gmail.com Please do not use track changes to provide feedback.

Introduction — What is This Proposed Framework?

Students with disabilities face too many barriers at all levels of Ontario’s post-secondary education system. To address this, the Ontario Government has agreed to create an Education Accessibility Standard under the Accessibility for Ontarians with Disabilities Act (AODA). In 2018, the Ontario Government appointed two committees to make recommendations on what the Education Accessibility Standard should include: The K-12 Education Standards Development Committee was appointed for making recommendations on what that accessibility standard should include to address barriers in Ontario’s publicly-funded schools from Kindergarten to Grade 12. The Post-Secondary Education Standards Development Committee was appointed to make recommendations for what that accessibility standard should include to address barriers in Ontario’s post-secondary education institutions, e.g. colleges and universities.

Under the AODA, an accessibility standard is an enforceable regulation. It has the force of law. It spells out the disability barriers that are to be removed or prevented in a sector of society. It identifies the policies, practices or other measures an organization must implement to remove or prevent those barriers, and the timelines required for these actions.

In this Framework, the AODA Alliance outlines the key ingredients and aims for the promised Education Accessibility Standard in the area of post-secondary education. On October 10, 2019, the AODA Alliance made public a Framework for what the Education Accessibility Standard should include to remove and prevent barriers in Ontarios publicly-funded schools from kindergarten to Grade 12. This new Framework builds on and expands upon ideas in that earlier document, and adds additional ideas, all tailored to apply to the post-secondary education context.

Where this Framework states that a post-secondary education organization should or similar wording, this means by this that the Education Accessibility Standard should include a provision that requires the post-secondary education organization to take the step we describe.

To be effective, the Education Accessibility Standard must do much more than require organizations to have a policy on accessibility and to train its employees on that policy. Organizations want and need to know specifically what they must do to comply.

Under the AODA, a Standards Development Committees job is to recommend the contents of an AODA accessibility standard. It should recommend the specific measures, practices and policies that an accessibility standard should require an organization to implement. If a Standards Development Committee chooses to also recommend some non-regulatory measures, that is beyond the Committees core mandate. It should not detract or distract from fulfilling that core mandate. For example, the 2018 final recommendations of the Transportation Standards Development Committee largely focused on recommendations of other measures, outside the revision of the 2011 Transportation Accessibility Standard that that Committee was assigned to review. A recommended practice that are not enshrined in an accessibility standard as a regulation, are not binding on an obligated organization. They cannot be enforced.

It is especially important for the post-secondary education sector to become accessible to students with disabilities. A good post-secondary education is very important for getting a good job, or indeed getting a job at all. This is even more important for people with disabilities. People with disabilities chronically face a substantially higher unemployment rate than the public does as a whole. Barriers in the post-secondary education system can only make this situation worse. A strong and effective post-secondary Education Accessibility Standard is therefore an important measure for increasing employment opportunities for people with disabilities.

1. What Should the Long-Term Objectives of the Post-Secondary Education Accessibility Standard Be?

#1 The purpose of the Education Accessibility Standard should be to ensure that by 2025, post-secondary education in Ontario will be fully accessible and barrier-free for students with disabilities:

A) By removing and preventingaccessibility barriers impeding students with disabilities from fully participating in, being fully included in, and fully benefitting from all aspects of post-secondary education in Ontario, and

B) By providing a prompt, accessible, fair, effective and user-friendly process for students with disabilities to learn about and seek programs, services, supports, accommodations and
placements tailored to the individualstrengths and needs of each student with disabilities.

c) Eliminating or substantially reducing the need for students with disabilities to have to fight against post-secondary education accessibility barriers, one at a time, and the need for post-secondary education organizations to have to re-invent the accessibility wheel one education program at a time.

2. A Vision of An Accessible Post-Secondary Education System

The Post-Secondary Education Accessibility Standard should begin by setting out a vision of what an accessible post-secondary education system should include. It should include the following:

#2.1 The post-secondary education system will be designed and operated from top to bottom for all of its students, including students with all kinds of disabilities, as disability is defined in the Ontario Human Rights Code, the AODA and/or the Canadian Charter of Rights and Freedoms.

#2.2 The post-secondary education system will no longer be designed and operated from the starting point of aiming to serve the fictional “average” student or students who have no disabilities. Instead, it will be designed and operated to serve all students, including students with disabilities.

#2.3 The built environment in post-secondary education organizations such as colleges and universities, and the furniture and equipment on those premises (such as gym equipment) will all be fully accessible to people with disabilities and will be designed based on the principle of universal design. Where education programs or trips take place outside the post-secondary education organization premises, these will be held at locations that are disability-accessible, unless it is impossible to do so without undue hardship.

#2.4 Courses taught to students, including the curriculum and lesson plans, as well as informal learning activities, will fully incorporate principles of Universal Design in Learning (UDL), and where needed, differential instruction, so that they are inclusive for students with disabilities.

#2.5 Instructional materials used in post-secondary education organizations will be readily and promptly available in formats that are fully accessible to students with disabilities (such as those with print disabilities) who need to use them and will be available in accessible formats when needed, at no extra charge to the student.

#2.6 All digital technology and content used in Ontario’s post-secondary education organizations such as hardware, software and online learning, used in class or from home, will be fully accessible and will fully embody the principle of universal design. Professors and other instructors working with students with disabilities will be properly trained to use the accessibility features of that hardware, software and online learning technology.

#2.7 Inclusion and Universal Design in Learning will extend beyond formal classroom learning to other educational activities, such as experiential learning opportunities.

#2.8 Students with disabilities will have prompt access to the up-to-date adaptive technology and specialized supports they need, and training on how to use it, to best enable them to fully take part in and benefit from post-secondary education related programming. Students with disabilities will have the unobstructed right to bring a qualified service animal with them to post-secondary education programs and activities.

#2.9 Professors and other instructional staff will be fully trained to serve all students, and not just students who have no disabilities. They will be fully trained in such things as Universal Design in Learning and differential instruction.

#2.10 Tests and other forms of evaluation at post-secondary education organizations will be designed based on principles of universal design and Universal Design in Learning, so that they will be barrier-free for students with disabilities and will provide a fair and accurate assessment of their progress.

#2.11 Students with disabilities will encounter a pro-actively welcoming environment at post-secondary education organizations to facilitate their full participation, and a welcoming environment in which they can seek and receive accommodations for their disabilities where needed.

#2.12 Application processes and forms, admission criteria, admission tests or other admission screening to get into any post-secondary education program will be barrier-free for students with disabilities.

#2.13 Students with disabilities will have prompt, effective and easy access to user-friendly information in multiple languages about the post-secondary educational opportunities, options, programs, services, supports and accommodations available for them and their disability, and about the process for them to seek these.

#2.14 Where a student with a disability believes that a post-secondary education organization is not effectively meeting the student’s disability-related needs, (or if the student believes that the post-secondary education organization is not providing an educational program, service, support or accommodation which it had agreed to provide, the student will have access to a prompt, fair, open and arms-length review process, including an offer of a voluntary Alternative Resolution Process if needed. It will be conducted by someone with expertise in the education of students with disabilities who was not involved in the original decision or activity, and who does not oversee the work of those involved in the student’s direct education.

#2.15 There will be no bureaucratic, procedural or policy barriers that will impede the effective placement and accommodation of individual students with disabilities in post-secondary education organizations.

#2.16 Major new Government strategies or initiatives in Ontario’s post-secondary education system, whether adopted by the Ontario Government or otherwise, will be proactively designed from the start to fully include the needs of students with disabilities.

#2.17 Those officials who are responsible in the Ontario Government and within post-secondary education organizations for leading, overseeing and operating Ontario’s post-secondary education system will have strong and specific requirements to address disability accessibility and inclusion in their mandates and will be accountable for their work on this.

3. General Provisions that the Post-Secondary Education Accessibility Standard Should Include

#3.1 The Post-Secondary accessibility standard should cover and apply to disability barriers in all post-secondary education programs in Ontario, and not only to those offered in or by a college or university. Whether or not the terms of reference for the Post-Secondary Standards Development Committee only focus on post-secondary education offered in a college or university, the same barriers and solutions almost always apply to post-secondary education, whether it is offered by a college or university or by some other post-secondary education organization.

For example, for students with disabilities who are studying law, they can encounter the same disability barriers at an Ontario law school, situated in a university, or when they undertake the Bar Admissions Course, which the Law Society of Ontario offers. To train to be a lawyer in Ontario, a student must get a law degree from a law school and then pass the Law Society of Ontarios Bar course and examinations. Accordingly, the Post-Secondary Standards Development Committee should make recommendations regarding any post-secondary programs, whether or not they are offered in a college or university.

#3.2 Where this accessibility standard refers to “students with disabilities “, this should include any student who has any kind of disability, including, for example, any kind of physical, mental, sensory, learning, intellectual, mental health, communication, neurological, neurobehavioural or other kind of disability within the meaning of the Ontario Human Rights Code, the Accessibility for Ontarians with Disabilities Act or the Canadian Charter of Rights and Freedoms.

#3.3 Each post-secondary education organization should be required to establish a permanent committee of its governing board to be called the “Accessibility Committee”. This Accessibility Committee should have responsibility and authority to oversee the organizations compliance with the Accessibility for Ontarians with Disabilities Act and with the requirements of the Ontario Human Rights Code and the Canadian Charter of Rights and Freedoms in so far as they guarantee the right of students with disabilities to fully participate in and fully benefit from the education programs and opportunities that the organization provides.

#3.4 Each post-secondary education organization should be required to establish in each faculty or program, a faculty or program Accessibility Committee. It should include representatives from the facultys or programs instructors, management, staff and students with disabilities. Its mandate should be to identify barriers in the school and its programs and to make recommendations for accessibility improvements to be shared with the faculty, program and post-secondary education organizations senior management and governing board.

#3.5 Each post-secondary education organization should be required to establish or designate the position of Chief Accessibility/Inclusion Officer, reporting to the CEO, with a mandate and responsibility to ensure proper leadership on the organizations accessibility and inclusion obligations under the Ontario Human Rights Code, the Canadian Charter of Rights and Freedoms and the Accessibility for Ontarians with Disabilities Act, including the requirements set by this accessibility standard. This responsibility may be assigned to an existing senior management official.

#3.6 Each post-secondary education organization should set up and maintain a network of teaching and other staff with disabilities, and a network of students with disabilities, to get input on accessibility issues at the organization.

#3.7 Beyond the specific measures on removing and preventing barriers set out in the Post-Secondary Education Accessibility /Standard and in other AODA accessibility standards, each post-secondary education organization should be required to systematically review its educational programming, services, facilities, premises and equipment to identify recurring accessibility barriers within that organization that can impede the full and effective participation and inclusion of students with disabilities. A comprehensive plan for removing and preventing these accessibility barriers should be developed, implemented and made public with clear time lines, clear assignment of responsibilities for action, monitoring for progress, and reporting to the organizations governing board and senior management. It should include actions on barriers identified by the organizations faculty or program Accessibility Committees established under this standard. This plan should aim at all accessibility barriers that can impede students with disabilities from full inclusion in the education and other programs and activities at that organization, whether or not they are specifically identified in the Education Accessibility Standard or in any other specific accessibility standards enacted under the AODA.

#3.8 Each post-secondary education organization should have an explicit duty to create a welcoming environment for students with disabilities, to seek accommodations for their disabilities.

#3.9 To further ensure the effective accommodation of students with disabilities and the entrenchment of accessibility at the front lines, while creating and developing expertise in this area, each post-secondary education organization Shall implement the following:

a) in a small post-secondary education organization, such as one that offers only one program, one senior employee within the organization who reports to the organizations chief executive officer, dean or director, should be designated as that organizations Disability Accessibility and Accommodation Coordinator/Champion. Their responsibility is to serve as the one-stop-shopping point person for students with disabilities seeking accommodations, and being the employee to lead efforts at the organization towards incorporating accessibility into plans and decisions from the top down.

b) In a large post-secondary education organization, such as a college or university that has several faculties or programs, each faculty or program should designate a comparable Disability Accessibility and Accommodation Coordinator/Champion with similar responsibilities within that faculty or program.

c) A larger post-secondary education organization that has more than one Disability Accessibility and Accommodation Coordinator/Champion should network these individuals so they can pool expertise and resources.

d) The Council of Ontario Universities and comparable associations of other categories of post-secondary education organizations should establish networks of Disability Accessibility and Accommodation Coordinators/Champions to pool their expertise and resources.

e) Where a post-secondary education organization has an existing support/service centre for students with disabilities it may help serve these roles, but in the case of a larger post-secondary education organization, there should be a Disability Accessibility and Accommodation Coordinator/Champion designated in each faculty or program.

#3.10 Each post-secondary education organization should develop and implement human resources policies targeted at full accessibility and inclusion, such as making knowledge and experience on implementing inclusion an important hiring and promotions criterion especially for senior management.

4. The Right of Students with Disabilities to Know About Disability-Related Programs, Services, and Supports at Post-Secondary Education Organizations, and How to Access Them

Barrier: Students with disabilities can at times find it difficult to get easily accessed and accessible information from post-secondary education organizations and from the Ontario Government on education options, services and supports available for students with disabilities in post-secondary education organizations and how to access them.

#4.1 Each post-secondary education organization should provide the public, including students with disabilities, with easily-located, timely and effective information, in accessible formats, on the available services, programs and supports for students with disabilities and how to access them. Each post-secondary education organization should ensure that students with disabilities are informed, as early as possible, in a readily-accessible and understandable way, about important information such as:

a) That the post-secondary education organization recognizes that it has a duty to ensure that a student with a disability has the right to full participation in and full inclusion in all the post-secondary education organizations programming, and has the right to be accommodated in connection with those programs under the Ontario Human Rights Code and Canadian Charter of Rights and Freedoms. This applies to students with any and every kind of disability.

b) About the menu of options, placements, programs, services, supports and accommodations for students with disabilities available at the post-secondary education organization.

c) About which persons and which office to approach at the post-secondary education organization to get this information, to request placements, programs, supports, services or accommodations for students with disabilities, or to raise concerns about whether the post-secondary education organization is effectively meeting the students education needs.

d) The processes and procedures at the post-secondary education organization for students with disabilities to request disability-related services, supports or accommodations.

#4.2 Each post-secondary education organization should develop, implement and make public an action plan to substantially improve its provision of the important information, described above, to students with disabilities including any who are applying for admission to the post-secondary education organization:

a) This plans objective should be to ensure that all students with disabilities get the information they need to ensure that students of all abilities can fully participate in and benefit from the educational and other opportunities available at the post-secondary education organization.

b) Each post-secondary education organization should ensure that all of this important information is fully and readily accessible in a prompt and timely way to all students with disabilities and applicants for admission, in accessible formats and in jargon-free plain language. in a diverse range of languages. It should be easy to find this information. Among other things, this information should be posted on the post-secondary education organizations website, in a prominent place that is easy to find, with a link to it prominently on the post-secondary education organizations home page. A post-secondary education organization should not simply rely on its website to share this information.

c) Each post-secondary education organization should create a user-friendly package of information to be provided to applicants or prospective applicants for admission to any program at the post-secondary education organization. It should emphasize the need to alert the post-secondary education organization as early as possible to any disability accommodation needs.

5. Ensuring that Students Have a Fair and Effective Process for Raising Concerns About a Post-Secondary Education Organizations Accommodation of the Disability-Related Needs of Students with Disabilities

Barrier: The need for consistent and effective processes within a post-secondary education organization to ensure an easily-accessed and fair procedure to enable students with disabilities to seek and receive needed disability supports and accommodations, and for raising disability-related concerns.

#5.1 Each post-secondary education organization should establish and maintain an effective, fair and user-friendly process for students with disabilities to request and effectively take part in the development and implementation of plans for meeting and accommodating their disability-related needs.

#5.2 As part of this process, students with disabilities should be invited to take part in a joint in-person or virtual meeting to plan for their disability-related supports and accommodations. The student should be invited to bring to the table any supports and professionals that can assist them.

#5.3 If the student had an Individual Education Plan (IEP) from an Ontario school, or a finding by an Ontario school boards Identification and Placement Review Committee (IPRC) that identified them as having a disability (exceptionality), then the post-secondary education organization should treat that as sufficient proof that the student has a disability, without requiring further proof, unless the post-secondary education organization has independent proof showing that the student no longer has that disability. In that case, the post-secondary education organization shall provide the student with that proof and shall provide the student with an opportunity to demonstrate that they have a disability-related accommodation need. If the student had a specific disability-related accommodation while in school, the post-secondary education organization shall treat that as strong proof that they still have the same accommodation need at the post-secondary education organization, unless the post-secondary education organization has convincing proof that this need no longer exists or that an alternative and equally effective accommodation should be preferred.

#5.4 If a post-secondary education organization decides not to provide a requested disability accommodation, service, or support for a student that the student requested, or to meet a disability-related need that the student identified, the post-secondary education organization should promptly provide written reasons for that refusal.

#5.5 If students with disabilities disagree with any aspect of a post-secondary education organizations decision on a request for accommodation, or believe that the post-secondary education organization has not provided supports or accommodations to which it had agreed, the organization should make available a respectful, non-adversarial internal review process for hearing, mediating and deciding on the students concerns. The Post-Secondary Education Accessibility Standard should set out the specifics of this review process. This review process should include the following:

a) It should be very prompt. Arrangements for a student’s accommodations should be finalized as quickly as possible, so that the students needs are promptly met.

b) No proposed services, supports or accommodations that the post-secondary education organization is prepared to offer should be withheld from a student pending a review. The student should not feel pressured not to seek this review, lest they be placed in a position of educational disadvantage during the review process.

c) The review process should be fair. The post-secondary education organization should let the student know all of its issues or concerns with the students request or concerns, and give the student a fair chance to voice their concerns.

d) The review should be by a person or persons who are independent and impartial. They should have expertise in the education of students with disabilities. They should not have taken part in any of the earlier discussions or decisions at that post-secondary education organization regarding the services, supports or accommodations for that child.

e) At the review, every effort should be made to mediate and resolve any disagreements between the student and the post-secondary education organization. If the matter cannot be resolved by agreement, there should be an option for a qualified person who is outside the post-secondary education organization to be appointed at no charge to the student, to consider the review, along prompt timelines.

f) At the review, written reasons should be given for the decision, especially if any of the students requests or concerns are not accepted.

6. Expediting the Early Identification and Accommodation of Students with Disabilities’ Needs

Barrier: Students with disabilities can face delays and administrative/bureaucratic impediments to ensuring that they get all needed disability-related supports and accommodations. This comes in no small part from the fact that post-secondary education organizations are often large organizations with administrative responsibilities distributed over a number of departments and individuals. The effective accommodation of students is far easier to achieve when requests for accommodation are presented and considered as early as possible.

#6.1 The Post-Secondary Education Accessibility Standard should require specific measures to tear down administrative, bureaucratic and other barriers to reduce delays for identifying, seeking and securing needed disability supports and accommodations. For example:

a) post-secondary education organizations should be required to notify all students who apply for admission to any program or who seek information about programs to which they might apply, about the availability of disability-related supports and accommodation and the process for seeking them.

b) The post-secondary education organizations interactive voice response system for receiving incoming phone calls should announce to all callers the organizations commitment to accommodate students with disabilities and the number to press to get introductory information about how to seek such.

c) Programming handouts and broadcast email communications to incoming students should include similar general information.

d) the post-secondary education organizations broadcast email announcements and other communications to the student population should include summary information to this effect with relevant links.

e) Classroom instructors should make announcements in their first week of classes to this effect.

7. Ensuring Digital Accessibility

Barrier: Post-secondary education organizations using classroom technology, such as hardware, software, online learning systems, online courses and internal or external websites that lack digital accessibility; post-secondary education organizations policies and practices that can be obstacles to using adaptive technology designed for people with disabilities; Insufficient staff and instructor training and familiarity with creating accessible documents, with the use of accessibility features of mainstream technology, and with disability-specific adaptive technology.

#7.1 Each post-secondary education organization should ensure that:

a) Educational and information equipment and technology, including hardware, software, and tablet/mobile apps deployed in educational settings should be designed and configured based on universal design principles, to ensure that students with disabilities can fully use them.

b) A post-secondary education organizations Learning Management Systems (LMS) should be accessible to staff and students with disabilities, including those who use adaptive technology. They should have all accessibility features turned on and available to ensure that information posted through them will be accessible to students with disabilities, including those using adaptive technology such as screen readers or voice recognition tools. Each post-secondary education organization should ensure that no instructor or other staff is able to turn off any feature of the LMS that is accessible in favour of one that is not.

c) Each post-secondary education organizations internal and external websites and intranet content, including internet content available to students for learning purposes, including all online learning programs, should be fully accessible, with all new information posted on them to be fully accessible.

d) Electronic documents created at the post-secondary education organization for use in education and other programming and activities should be created in accessible formats unless there is a compelling and unavoidable reason making it impossible to do so. PDF format should be avoided. If a PDF document is created, an alternate version of the content should be simultaneously provided and posted in an accessible Microsoft Word or HTML format.

e) Software used to produce a post-secondary education organizations key documents for use by students should be designed to ensure that they produce these documents in accessible formats.

f) Textbooks and learning software should be procured only if they include full information technology accessibility. Any textbook used in any learning environment must be accessible to instructors and students with disabilities at the time of procurement. Here again, PDF should not be used unless an accessible alternative format such as MS Word is also simultaneously available. For example, if a textbook is available in EPUB format, the textbooks must meet the international standard for that file format. For EPUB it is the W3C Digital Publishing Guidelines currently under review. If a textbook is available in print, the publisher should be required to provide the digital version of the textbook in an accessible format at the same time the print version is delivered to the school/Board.

#7.2 Each post-secondary education organization should establish, implement, publicize and enforce information technology procurement accessibility requirements, to ensure that no technology is purchased unless it ensures full digital accessibility. Digital and information technology accessibility should be included in all Requests for Proposal (RFP) or other tenders for sale of products and services to a post-secondary education organization. It should be a condition of any such procurement that the vender will promptly remediate any accessibility shortcomings at its own expense.

#7.3 Each post-secondary education organization shall ensure that its instructional staff are fully trained in the creation of accessible electronic documents and online content for use by students, and shall periodically and randomly spot-check such documents to assist in ensuring that instructional staff are effectively trained and up-to-date in this area.

#7.4 Each post-secondary education organization shall review its policies and practices to identify, remove and prevent any barriers to the accessibility of its online and digital content that students might use as part of their educational activities.

#7.5 Each post-secondary education organization shall ensure that its information technology support and help staff includes specialists in access technology, and that students with disabilities get prompt access to IT support when needed.

8. Ensuring Universal Design in Learning and Differentiated Instruction Are Used in All Teaching Activities, Both Online and in Classroom Learning

Barrier: Too often, the curricula and lesson plans used in post-secondary education organizations were not designed and delivered based on principles of accessibility, Universal Design in Learning (UDL) and differentiated instruction (DI). Universal design in learning takes the principles of universal design (designing buildings and products so all can use them) and transfers them to the teaching and learning realm. It focuses on ways to ensure that an education program, course or other learning activity is designed to meet the learning needs of all learners, not just those with no disabilities. To provide the starkest example, a drama teacher who has a class play the game Charades is not using UDL principles if their class includes a blind student, for who that activity would be entirely inaccessible.

It may be easier to entrench UDL and differentiated instruction in the K-12 school system. To teach in our publicly-funded schools, a teacher must first complete recognized programs in a teachers college. If those teachers colleges were to make UDL and differentiated instructions core competencys that they taught all of their students, Ontario could end up with schools staffed with teachers that are equipped to teach using these principles. Existing teachers could and should be trained in UDL and differentiated instruction during their PD days.

In contrast, to get a job as an instructor or professor at an Ontario post-secondary education organization, a person does not need to have successfully completed any prior course or training on how to teach. That makes it much more challenging to embed UDL and differentiated instruction principles in the teaching activities at Ontarios post-secondary education organizations.

Principles of UDL and differentiated instruction can be effectively deployed in a manner that respects the academic freedom of those who teach in post-secondary education organizations. Those such as tenured university professors remain free to choose what ideas they wish to convey. UDL and differentiated instruction aim to ensure that all students can effectively learn that content to ultimately serve the goal of academic freedom.

The intent/rationale of the following recommendations is to entrench universal design in learning and differentiated instruction in the curricula and teaching at post-secondary education organizations.

#8.1 Each post-secondary education organization should adopt and publicize a policy committing to the goals and deployment of universal design in learning (UDL) and differentiated instruction (DI) in its education programs, including in the design and delivery of its curricula.

#8.2 Each post-secondary education organization should develop and implement a plan to ensure that all teachers and teaching staff understand, and effectively and consistently use, principles of Universal Design in Learning and differentiated instruction when preparing and delivering courses and other educational programming, to effectively address the spectrum of different learning needs and styles of their students. For example:

a) Each post-secondary education organization should develop, implement and monitor a comprehensive plan to train its instructional staff on using UDL and DI principles when preparing and delivering courses and course content in order to effectively meet their students spectrum of different learning needs and styles.

b) Each post-secondary education organization should include knowledge of UDL and differentiated instruction principles as an important criterion when recruiting or promoting instructional staff.

c) Each post-secondary education organization should ensure that teachers are provided with appropriate resources and support to successfully implement their UDL and DI training. Each post-secondary education organization should monitor how effectively UDL and differentiated instruction are incorporated into their education programs on the front lines.

d) Each post-secondary education organization should provide teaching coaches with expertise in UDL and DI to support instructional staff.

#8.3 The Ontario Government should create templates or models for the foregoing training so that each post-secondary education organization does not have to reinvent the wheel in this context.

9. Removing Attitudinal Barriers Against Students with Disabilities

Barrier: Stereotypes, lack of knowledge and other attitudes among some staff at post-secondary education organizations and among some other students, that do not recognize the right and benefits of students with disabilities to get a full and equal education.

#9.1 To help reduce or eliminate attitudinal barriers that can impede students with disabilities each post-secondary education organization should:

a) Develop and implement a multi-year strategy to publicize the organizations commitment to and the benefits of inclusion and full participation of students with disabilities.

b) Post around the post-secondary education organization announcements of the post-secondary education organizations commitment to inclusion of students with disabilities, and the benefits this brings to all students.

c) Provide specific training to all front-line staff (not limited to instructional staff) on the importance of inclusion.

d) Implement human resources policies and practices to expand school board staff knowledge and skills regarding inclusion.

10. Ensuring Accessibility of Instructional Materials that Students with Disabilities Use

Barrier: Instructional materials, such as textbooks and other instructional materials and teaching resources that are not provided at the same time in an accessible format for students with disabilities. This is not limited to digital materials, referred to earlier in this Framework.

Section 15 of the Integrated Accessibility Standards Regulation, enacted in June 2011, and in force for school boards since 2013 or 2015 (depending on their size) requires education organizations to provide instructional materials on request in an accessible format, and to make this part of their procurement of such resources. However, this provision has not been effective and sufficient to effectively ensure that students with disabilities face no barriers in this context. Therefore, much stronger measures are needed.

#10.1 To ensure that instructional materials are fully accessible on a timely basis to students with disabilities such as vision loss and those with learning disabilities that affect reading, each post-secondary education organization should:

a) Promptly survey students with disabilities who need accessible instructional materials, and their instructional staff, to get their front-line experiences on whether they get timely access to accessible instructional materials, and to get specifics on where this has been most lacking.

b) Establish a dedicated resource within the post-secondary education organization, or shared among post-secondary education organizations, to convert instructional materials to an accessible format, where needed, on a timely basis. A student should not be required to show proof that they own a hard copy of an item to be able to get it in an accessible format.

c) Review its procurement practices to ensure that any new instructional materials that are acquired are fully accessible or conversion-ready and monitor to ensure that this is always done in practice. A condition of procurement should be a requirement that the supplier or vendor must remediate any inaccessible materials at its own expense.

#10.2 The Education Accessibility Standard should require the Ontario Government to implement, monitor and publicly report on province-wide strategies to ensure the procurement of and use of accessible instructional materials across post-secondary education organizations.

11. Ensuring Barrier-Free Post-Secondary Program Admission Requirements

Barrier: Admission requirements to a post-secondary program that unintentionally or inadvertently impede access to the program for otherwise-qualified students with disabilities.

The intention/rationale of these recommendations is to ensure that students with disabilities can have their eligibility for admission to a post-secondary program fairly and accurately assessed.

#11.1 Every post-secondary education organization shall review its admission criteria for gaining admission to any of its post-secondary education programs, to identify any barriers that would impede otherwise-qualified students with disabilities from admission, and shall adjust those criteria to either:

a) Remove the admission criteria that constitute a barrier to admission, or

b) Provide an alternative method for assessing students with disabilities for admission to the program.

12. Ensuring Student Testing/Assessment is Free of Disability Barriers

Barrier: Tests or other performance assessments of students that are not designed in a way that ensures that students with disabilities are fairly and accurately assessed.

Throughout the post-secondary education system, students take tests, submit papers, and undertake other assessments of their academic performance. There have been no mandatory provincial requirements of which we are aware to ensure that the ways students’ performance is tested or assessed are barrier-free for students with disabilities, and to ensure a fair and accurate assessment of their performance.

#12.1 The Post-Secondary Education Accessibility Standard should set requirements for proper approaches to ensure tests and other methods of performance evaluation provide a fair, accurate and barrier-free assessment of students with disabilities, and on when and how to provide an alternative evaluation method.

#12.2 To ensure that a school board fairly and accurately assesses the performance of students with disabilities, each post-secondary education organization should:

a) Have a policy that commits to ensure that testing and other assessments of students’ performance and learning are designed to be barrier-free for students with disabilities.

b) Give its instructional staff training resources on how to ensure a test or other assessment method is a fair, accurate and barrier-free assessment for students with disabilities in their class, and where needed, how to provide an alternative evaluation method.

c) Monitor implementation of these.

13. Ensuring Students with Disabilities Have the Technology and Other Supports They Need for Effective Learning

Barrier: Policy and bureaucratic impediments to students with disabilities getting the adaptive technology and other supports they need for learning at a post-secondary education organization.

There are inconsistent practices around Ontario for making available to students with disabilities the adaptive technology and support services they need, and the training required to be able to effectively use that equipment.

#13.1 The Post-Secondary Education Accessibility Standard should require that procedural, bureaucratic and other barriers to the acquisition, training and use of needed adaptive equipment and technology at school should be eliminated. It should require the establishment of a prompt, standardized and consistent provincial system for the procurement and deployment of accessible technology to post-secondary students with disabilities that ensures access to the most appropriate and up-to-date technology that is available on the market.

#13.2 The Post-Secondary Education Accessibility Standard should provide that each post-secondary education organization should ensure that students with disabilities are able to bring a trained service animal to their premises as a disability accommodation.

14. Removing Barriers to Participation in Experiential Learning

Barrier: Experiential learning programs that do not ensure that accessible and inclusive experiential learning placements are made available to students with disabilities, and insufficient supports to help organizations, providing experiential learning placements, to facilitate the placement of students with disabilities.

#14.1 To ensure that students with disabilities can fully participate in a post-secondary education organizations experiential learning programs, each such organization should:

a) Review its experiential learning programs to identify and remove any accessibility barriers.

b) Put in place a process to affirmatively reach out to potential placement organizations in order to ensure that there will be a range of accessible placement opportunities in which students with disabilities can participate.

c) Ensure that its partner organizations that accept its students for experiential learning placements are effectively informed of their duty to accommodate the learning needs of students with disabilities.

d) Create and share supports and advice for placement organizations who need assistance to ensure that students with disabilities can fully participate in their experiential learning placements.

e) Monitor placement organizations to ensure they have someone in place to ensure that students with disabilities are effectively accommodated, and to ensure that effective accommodation was provided during each placement of a student with a disability who needed accommodation.

f) Survey students with disabilities and experiential learning placement organizations at the end of any experiential learning placements to see if their disability-related needs were effectively accommodated.

#14.2 The Ontario Government should provide templates for these policies and measures. It should also prepare and make available training videos for post-secondary education organizations and organizations offering experiential learning programs to guide them on accommodating students with disabilities in experiential learning placements.

15. The Need to Harness the Experience and Expertise of People with Disabilities Working in Post-Secondary Education Organizations to Expedite the Removal and Prevention of Barriers Facing Students with Disabilities

Barrier: People with disabilities working in post-secondary education organizations too often face accessibility barriers in the workplace that also hurt students with disabilities.

The intent/rationale of the following recommendations is to ensure that the experience and expertise of people with disabilities working in post-secondary education organizations is effectively harnessed to help root out the accessibility barriers that impede students with disabilities. This is because workplace disability barriers and education service disability barriers often are the same or substantially overlap.

#15-1. Each post-secondary education organization should be required to establish a committee of those employees and volunteers with disabilities who wish to voluntarily join it, to give the organizations senior management feedback on the barriers in the organization that could impede employees or students with disabilities.

16. Ensuring a Fully Accessible Built Environment at Post-Secondary Education Organizations

The intent/rationale of these recommendations is to ensure that as soon as possible, and no later than January 1, 2025, the built environment in the post-secondary education system and the equipment on those premises (such as gym equipment) would all be fully accessible to people with disabilities and would be designed based on the principle of universal design. Where post-secondary education programs or trips take place outside the post-secondary education organization, these will be held at locations that are disability-accessible. The intent/rationale is also to ensure that no public money is used to create new barriers or perpetuate existing barriers in the post-secondary education system.

There can be costs associated with these measures. The Government will need to determine how much it is prepared to spend, and which of these requirements it would thereby adopt. A Standards Development Committee cannot and should not pre-decide that for the Government.

There is a far greater cost of not imposing these requirements. If the built environment at post-secondary education organizations remains inaccessible, or new post-secondary facilities are built with new barriers, there will be later retrofit costs and litigation costs in response to human rights cases.

Providing a barrier-free built environment in post-secondary education organizations benefits everyone. It ensures that all students of all ages and abilities can come to learn there. It enables people with disabilities to be employed in all jobs throughout the post-secondary education organization. It enables the premises of the post-secondary education organization, a public facility, to be used for other important public uses, such as being rented for conferences.

These recommendations do not include specific technical requirements, such as the precise width of doorways or other paths of travel. These recommendations set out the barriers to be addressed and the specific measures to address them. If the Government of Ontario adopts these, it would have to then proceed to set technical requirements where possible. Barriers:

1. Too often, the built environment at post-secondary education organizations has physical barriers that can partially or totally impede some students with disabilities from being able to enter or independently move around.

2. The Ontario Building Code and existing accessibility standards do not set out all the modern and sufficient accessibility requirements for the built environment in Ontario. The Government of Ontario has no accessibility standard for the built environment in post-secondary education organizations. The Government has not agreed to develop a Built Environment Accessibility Standard to substantially strengthen the general accessibility provisions for society as a whole in the Ontario Building Code.

Accordingly, it is left to each post-secondary education organization to come up with its own designs to address accessibility in the built environment at its premises. This is highly inefficient and wasteful.

The AODA Alliance has illustrated this in two widely-viewed online videos that focus on the built environment at two post-secondary education organizations, chosen because they are typical, not worse than others:

a) the new Culinary Arts Centre at Centennial College: https://www.youtube.com/watch?v=Dgfrum7e-_0&t=87s

b) The new Student Learning Centre at Ryerson University: https://youtu.be/4oe4xiKknt0

3. The Ontario Government does not ensure that public money is never used to create or perpetuate disability barriers in the built environment.

Recommendations

Examples of these requirements are set out in the Appendix to this Framework, below.

#16.1 The Post-Secondary Education Accessibility Standard should set out specific requirements for accessibility in the built environment at post-secondary education organizations and other locations where post-secondary education programs are to be offered. These should meet the accessibility requirements of the Ontario Human Rights Code and the Canadian Charter of Rights and Freedoms and should meet the needs of all disabilities and not only people with mobility disabilities. These should include:

a) Specific requirements to be included in a new facility to be built.

b) Requirements to be included in a renovation of or addition to an existing post-secondary facility, and

c) Retrofit requirements for an existing post-secondary facility, even if it is not slated for a major renovation or addition, to the extent that they are readily achievable and important to ensure the facilitys accessibility.

#16.2 Each post-secondary education organization should develop a plan to ensure that the built environment of its educational facilities becomes fully accessible to people with disabilities as soon as reasonably possible, and in any event, no later than January 1, 2025. As part of this:

a) As a first step, each post-secondary education organization should develop a plan for making as many of its facilities disability-accessible within its current financial context. Accessibility does not only include the needs of people with mobility disabilities. It includes the needs of people with other disabilities such as people with vision and/or hearing loss, autism, intellectual or developmental disabilities, learning disabilities or mental health disorders.

b) Each post-secondary education organization should identify which of its existing facilities can be more easily made accessible, and which facilities would require substantially more extensive action to be made physically accessible. An interim plan should be developed to show what progress towards full physical accessibility can be made by first addressing facilities that would require less money to be made physically more accessible, and the most high-impact facilities.

#16.3 The post-secondary education organizations review of its built environment shall include a thorough review of the campuss overall layout. Where navigation around the campus, or from building to building, lacks the needed and appropriate cues for people with vision loss or other disabilities, proper way-finding, including tactile walking surface indicators, will be installed to facilitate the ease of safe navigation around the campus

#16.4 When a post-secondary education organization seeks to retain or hire design professionals, such as architects, interior designers or landscape architects, for the design of a new facility or an existing facilitys retrofit or renovation, or for any other infrastructure project, the post-secondary education organization should include in any Request for Proposal (RFP) a mandatory requirement that the design professional must have sufficient demonstrated expertise in accessibility design, and not simply knowledge about compliance with the Ontario Building Code or the AODA. This includes the accessibility needs of people with all kinds of disabilities, and not just those with mobility impairments.

#16.5 When a post-secondary education organization is planning to construct a new facility, or to expand or renovate an existing facility or other infrastructure, a suitably qualified accessibility consultant should be directly retained by the post-secondary education organization (and not by a private architecture firm) to advise on the project from the outset, with their unedited advice being transmitted directly to the post-secondary education organization and not only to the private design professionals who are retained to design the project. Completing the 8 day training course on accessibility offered by the Rick Hansen Foundation should not be treated as either necessary or sufficient for this purpose, as that course is substantially inadequate and has significant problems.

#16.6 The post-secondary education organization should have design specifications or plans for any new construction or major renovations of any of its facilities reviewed by its boards Accessibility Committee and by representatives of its students and employees with disabilities. If the post-secondary education organization rejects any of their recommendations regarding the projects accessibility it shall provide written reasons for its decision to do so.

#16.7 Where possible, a post-secondary education organization should not renovate an existing facility that lacks disability accessibility, unless the organization has a plan to also make that facility accessible. For example, a post-secondary education organization should not spend public money to renovate the second storey of a facility which lacks accessibility to the second storey, if the organization does not have a plan to make that second storey disability-accessible. Very pressing health and safety concerns should be the only reason for any exception to this.

#16.8 Each post-secondary education organization should only hold off-site educational events at venues whose built environment is accessible, unless to do so would be impossible without undue hardship.

#16.9 To ensure that gym, sports, athletic equipment and other like equipment and facilities are accessible for students with disabilities, the Post-Secondary Education Accessibility Standard should set out specific technical accessibility requirements for new or existing outdoor or indoor gym,, sports, athletic and other like equipment, drawing on accessibility standards and best practices in other jurisdictions, if sufficient, so that each post-secondary education organization does not have to re-invent the accessibility wheel.

#16.10 Each post-secondary education organization should:

a) Take an inventory of the accessibility of its existing indoor and outdoor gym, sports, athletic and like equipment and spaces, and make this public, including posting this information online.

b) Adopt a plan to remediate the accessibility of existing gym, sports, athletic or other like equipment or spaces, in consultation with students with disabilities.

c) Ensure that a qualified accessibility expert is engaged to ensure that the purchase of new equipment or remediation of existing equipment or spaces is properly conducted, with their advice being given directly to the post-secondary education organization.

#16.11 The Ontario Government should be required to revise its funding formula or criteria for construction of facilities at a post-secondary education organization to ensure that it requires and does not obstruct the inclusion of all needed accessibility features in that construction project.

Appendix 1 Specific Accessible Design Requirements for the Built Environment Proposed For the Post-Secondary Education Accessibility Standard

The following design features should be required by the Post-Secondary Education Accessibility Standard and in any new construction or renovation at a post-secondary education organization. Where an existing post-secondary facility is undergoing no renovation, any of the following measures which are readily achievable should be required. To fill in the specifics, the Ontario Government should enact technical requirements for the following, as binding enforceable rules, not as voluntary guidelines:

Usable Accessible Design for Outdoor or Exterior Site Elements

1. Access to the site for pedestrians
Clear, intuitive connection to the accessible entrance
a. A tactile raised line map shall be provided at the main entry points adjacent to the accessible path of travel but with enough space to ensure users do not block the path for others
b. Path of travel from each sidewalk connects to an accessible entrance with few to no joints to avoid bumps. The primary paths shall be wide enough to allow two-way traffic with a clear width that allows two people using wheelchairs or guide dogs to pass each other. For secondary paths where a single path is used, passing spaces shall be provided at regular intervals and at all decision points. The height difference from the sidewalk to the entrance will not require a ramp or stairs. The path will provide drainage slopes only and ensure no puddles form on the path. Paths will be heated during winter months using heat from the school or other renewable energy sources.
c. Bike parking shall be adjacent to the entry path. Riders shall be required to dismount and not ride on the pedestrian routes. Bike parking shall provide horizontal storage with enough space to ensure users and parked bikes do not block the path for others. The ground surface below the bikes shall be colour contrasted and textured to be distinct from the pedestrian path.
d. Rest areas and benches with clear floor space for at least two assistive mobility devices or strollers or a mix of both shall be provided. Benches shall be colour contrasted, have back and arm rests and provide transfer seating options at both ends of the bench. These shall be provided every 30m along the path placed adjoining. The bench and space for assistive devices are not to block the path. If the path to the main entrance is less than 30m at least one rest area shall be provided along the route. If the drop-off area is in a different location than the pedestrian route from the sidewalk, an interior rest area shall be provided with clear sightlines to the drop-off area. If the drop-off area is more than 20m from the closest accessible entrance an exterior accessible heated shelter shall be provided for those awaiting pick-up. The ground surface below the rest areas shall be colour contrasted and textured to be distinct from the pedestrian path it abuts
e. Tactile directional indicators shall be provided where large open paved areas happen along the route, or where walking paths are not readily navigable by persons with vision loss, due to a lack of reliable shorelines and landmarks. f. Accessible pedestrian directional signage at decision points
g. Lighting levels shall be bright and even enough to avoid shadows and ensure its easy to see the features and to keep people safe. h. Accessible duress stations (Emergency safety zones in public spaces)
i. Heated walkways shall be used where possible to ensure the path is always clear of snow and ice

1. Access to the site for vehicles
a. Clear, intuitive connection to the drop-off and accessible parking
b. Passenger drop-off shall include space for driveway, layby, access aisle (painted with non-slip paint), and a drop curb (to provide a smooth transition) for the full length of the drop off. This edge shall be identified and protected with high colour contrasted tactile attention indicators and bollards to stop cars, so people with vision loss or those not paying attention get a warning before walking into the car area. Sidewalk slopes shall provide drainage in all directions for the full length of the dropped curb
c. Overhead protection shall be provided by a canopy that allows for a clearance for raised vans or buses and shall provide as much overhead protection as possible for people who may need more time to load or off-load
d. Heated walkways from the drop-off and parking shall be used to ensure the path is always clear of snow and ice
e. A tactile walking directional indicator path shall lead from the drop-off area to the closest accessible entrance to the building (typically the main entrance)
f. A parking surface will only be steep enough to provide drainage in all directions. The drainage will be designed to prevent puddles from forming at the parking or along the pedestrian route from the parking
g. Parking design should include potential expansion plans for future growth and/or to address increased need for accessible parking
h. Parking access aisles shall connect to the sidewalk with a curb cut that leads to the closest accessible entrance to the building (so that no one needs to travel along the driveway behind parked cars or in the path of car traffic)
i. Lighting levels shall be bright and even enough to avoid shadows and to ensure its easy to see obstacles and to keep people safe.
j. If there is more than one parking lot, each site shall have a distinctive colour and shape symbol associated with it that will be used on all directional signage especially along pedestrian routes.

3. Parking
a. The provision of parking spaces near the entrance to a facility is important to accommodate persons with a varying range of abilities as well as persons with limited mobility. Medical conditions, such as anemia, arthritis or heart conditions, using crutches or the physical act of pushing a wheelchair, all can make it difficult to travel long distances. Minimizing travel distances is particularly important outdoors, where weather conditions and ground surfaces can make travel difficult and hazardous.
b. The sizes of accessible parking stalls are important. A person using a mobility aid such as a wheelchair requires a wider parking space to accommodate the manoeuvring of the wheelchair beside the car or van. A van may also require additional space to deploy a lift or ramp out the side or back door. An individual would require space for the deployment of the lift itself as well as additional space to manoeuvre on/off the lift.
c. Heights of passage along the driving routes to accessible parking is a factor. Accessible vans may have a raised roof resulting in the need for additional overhead clearance. Alternatively, the floor of the van may be lowered, resulting in lower capacity to travel over for speed bumps and pavement slope transitions.
d. Wherever possible, parking signs shall be located away from pedestrian routes, because they can constitute an overhead and/or protruding hazard. All parking signage shall be placed at the end of the parking space in a bollard barricade to stop cars, trucks or vans from parking over and blocking the sidewalk.

4. A Buildings exterior doors
a. Level areas on both sides of a buildings exterior door shall allow the clear floor space for a large scooter or mobility device or several strollers to be at the door. Exterior surface slope shall only provide drainage away from the building.
b. 100% of a buildings exterior doors will be accessible with level thresholds, colour contrast, accessible door hardware and in-door windows or side windows (where security allows) so those approaching the door can see if someone is on the other side of the door
c. Main entry doors at the front of the building and the door closest to the parking lot (if not the same) to be obvious, prominent and will have automatic sliders with overhead sensors. Placing power door operator buttons correctly is difficult and often creates barriers especially within the vestibule
d. Accessible security access for after hours or if used all day with 2-way video for those who are deaf and/or scrolling voice to text messaging
e. All exit doors shall be accessible with a level threshold and clear floor space on either side of the door. The exterior shall include a paved accessible path leading away from the building

Accessible Design for Interior Building Elements

1. Entrances
a. All entrances used by staff and/or the public shall be accessible and comply with this section. In a retrofit situation where it is technically infeasible to make all staff and public entrances accessible, at least 50% of all staff and public entrances shall be accessible and comply with this section. In a retrofit situation where it is technically infeasible to make all public entrances accessible, the primary entrances used by staff and the public shall be accessible. 2. Door
a. Doors shall be sufficiently wide enough to accommodate stretchers, wheelchairs or assistive scooters, pushing strollers, or making a delivery
b. Threshold at the doors base shall be level to allow a trip free and wheel friendly passage. c. Heavy doors and those with auto closers shall provide automatic door openers. d. Room entrances shall have doors.
e. Direction of door swing shall be chosen to enhance the usability and limit the hazard to others of the door opening.
f. Sliding doors can be easier for some individuals to operate, and can also require less wheelchair manoeuvring space. g. Doors that require two hands to operate will not be used. h. Revolving doors are not accessible.
i. Full glass doors are not to be used as they represent a hazard.
j. Colour-contrasting will be provided on door frames, door handles as well as the door edges.
k. Door handles and locks will be operable by using a closed fist, and not require fine finger control, tight grasping, pinching, or twisting of the wrist to operate

3. Gates, Turnstiles and Openings
a. Gates and turnstiles should be designed to accommodate the full range of users that may pass through them. Single-bar gates designed to be at a convenient waist height for ambulatory persons are at neck and face height for children and chest height for persons who use wheelchairs or scooters.
b. Revolving turnstiles should not be used as they are a physical impossibility for a person in a wheelchair to negotiate. They are also difficult for persons using canes or crutches, or persons with poor balance.
c. All controlled entry points will provide an accessible width to allow passage of wheelchairs, other mobility devices, strollers, walkers or delivery carts.

4. Windows, Glazed Screens and Sidelights
a. Broad expanses of glass should not be used for walls, beside doors and as doors can be difficult to detect. This may be a particular concern to persons with vision loss/no vision. It is also possible for anyone to walk into a clear sheet of glazing especially if they are distracted or in a hurry.
b. Window sill heights and operating controls for opening windows or closing blinds should be accessible…located on a path of travel, with clear floor space, within reach of a shorter or seated user, colour contrasted and not require punching or twisting to operate.

5. Interior Layout
a. The main office where visitors and others need to report to upon entering the building shall always be located on the same level as the entrance, as close to the entrance as possible. If the path of travel to the office crosses a large open area, a tactile directional indicator path shall lead from the main entrance(s) to the office ID signage next to the office door.
b. As much as possible, classrooms and or public destinations shall be on the ground floor. Where this is not possible, at least 2 elevators should be provided to access all other levels. Where the building is long and spread out, travel distance to elevators should be considered to reduce extra time needed for students and staff or others who use the elevators instead of the stairs. If feature stairs (staircases included in whole or in part for design aesthetics) are included, elevators shall be co-located and just as prominent as the stairs
c. Corridors should meet at 90 degree angles. Floor layouts from floor to floor should be consistent and predictable so the room number line up and are the same with the floors above and below along with the washrooms
d. Multi-stall washrooms shall always place the womens washroom on the right and the mens washroom on the left. No labyrinth entrances shall be used. Universal washrooms shall be co-located immediately adjacent to the stall washrooms, in a location that is consistent and predictable throughout the building

6. Facilities
a. The entry doors to each type of facility within a building should be accessible, colour contrasted, obvious and prominent and designed as part of the wayfinding system including accessible signage that is co-located with power door openers controls.
b. Tactile attention indicator tile will be placed on the floor in front of the accessible ID signage at each room or facility type. Where a room or facility entrance is placed off of a large interior open area

7. Elevators

a. Elevator Doors will provide a clear width to allow a stretcher and larger mobility devices to get in and out b. Doors will have sensors so doors will auto open if the doorway is blocked
c. Elevators will be installed in pairs so that when one is out of service for repair or maintenance, there is an alternative available.
d. Elevators will be sized at allow at least two mobility device users and two non-mobility devices users to be in the elevator at the same time. This should also allow for a wide stretcher in case of emergency.
e. Assistive listening will be available in each elevator to help make the audible announcements heard by those using hearing aids
f. Emergency button on the elevators control panel will also provide 2-way communication with video and scrolling text and a keyboard for people who are deaf or who have other communication disabilities
g. Inside the elevators will be additional horizontal buttons on the side wall in case there is not enough room for a person using a mobility aid to push the typical vertical buttons along the wall beside the door. If there are only two floors the elevator will only provide the door open, close and emergency call buttons and the elevator will automatically move to the floor it is not on.
h. The words spoken in the elevators voice announcement of the floor will be the same as the braille and print floor markings, so the button shows 1 as a number, 1 in braille and the voice says first floor not G for Ground with M in braille and voice says first floor.)
i. Ensure the star symbol for each elevator matches ground level appropriate to the elevator. The star symbol indicates the floor the elevator will return to in an emergency. This means users in the elevator will open closest to the available accessible exit. If the entrance on the north side is on the second floor, the star symbol in that elevator will be next to the button that says 2. If the entrance on the south side of the building is on the 1st floor, the star symbol will be next to the button that says 1.
j. The voice on the elevator shall be set at a volume that is audible above typical noise levels while the elevator is in use, so that people on the elevator can easily hear the audible floor announcements.
k. Lighting levels inside the elevator will match the lighting at the elevator lobbies. Lighting will be measured at the ground level
l. Elevators will provide colour contrast between the floor and the walls inside the cab and between the frame of the door or the doors with the wall surrounding in the elevator lobbies. Vinyl peel and stick sheets or paint will be used to cover the shiny metal which creates glare. Vinyl sheets will be plain to ensure the door looks like a door, and not like advertising
m. In a retrofit situation where adding 2 elevators is not technically possible without undue hardship, platform lifts may be considered. Elevators that are used by all facility users are preferred to platform lifts which tend to segregate persons with disabilities and which limit space at entrance and stair locations. Furthermore, independent access is often compromised by such platform lifts,, because platform lifts are often require a key to operate. Whenever possible, integrated elevator access should be incorporated to avoid the use of lifts.

8. Ramps
a. A properly designed ramp can provide wait-free access for those using wheelchairs or scooters, pushing strollers or moving packages on a trolley or those who are using sign language to communicate and dont want to stop talking as they climb stairs.
b. A ramps textured surfaces, edge protection and handrails all provide important safety features.
c. On outdoor ramps, heated surfaces shall be provided to address the safety concerns associated with snow and ice.
d. Ramps shall only be used where the height difference between levels is no more than 1m (4ft). Longer ramps take up too much space and are too tiring for many users. Where a height difference is more than 1m in height, elevators will be provided instead.
e. Landings will be sized to allow a large mobility device or scooter to make a 360 degree turn and/or for two people with mobility assistive devices or guide dogs to pass
f. Slopes inside the building will be no higher than is permitted for exterior ramps in the AODA Design of Public Spaces Standard, to ensure usability without making the ramp too long.
g. Curved ramps will not be used, because the cross slope at the turn is hard to navigate and a tipping hazard for many people.
h. Colour and texture contrast will be provided to differentiate the full slope from any level landings. Tactile attention domes shall not be used at ramps, because they are meant only for stairs and for drop-off edges like at stages

9. Stairs
a. Stairs that are comfortable for many adults may be challenging for children, shorter persons seniors or persons of short stature.
b. The leading edge of each step (aka nosing) shall not present tripping hazards, particularly to persons with prosthetic devices or those using canes and will have a bright colour contrast to the rest of the horizontal step surface.
c. Each stair in a staircase will use the same height and depth, to avoid creating tripping hazards
d. The rise between stairs will always be smooth, so that shoes will not catch on an abrupt edge causing a tripping hazard. These spaces will always be closed as open stairs create a tripping hazard.
e. The top of all stair entry points will have a tactile attention indicator surface, to ensure the drop-off is identified for those who are blind or distracted.
f. Handrails will aid all users navigating stairways safely. Handrails will be provided on both sides of all stairs, and will be provided at both the traditional height as well as a second lower rail for children or people who are shorter. These will be in a high colour contrasting colour and round in shape, without sharp edges or interruptions. Rails shall always be at a right angle to the stairs, and shall never be itched at an angle.
g. g) Spiral, curved or irregular staircases shall never be created, as they are a serious tripping hazard.

10. Washroom Facilities
a. Washroom facilities will accommodate the range of people that will use the space. Although many persons with disabilities use toilet facilities independently, some may require assistance. Where the individual providing assistance is of the opposite gender then typical gender-specific washrooms are awkward, and so an individual washroom is required.
b. Parents and caregivers with small children and strollers also benefit from a large, individual washroom with toilet and change facilities contained within the same space.
c. Circumstances such as wet surfaces and the act of transferring between toilet and wheelchair or scooter can make toilet facilities accident-prone areas. An individual falling in a washroom with a door that swings inward could prevent his or her own rescuers from opening the door. Due to the risk of accidents, emergency call buttons are vital in all washrooms.
d. The appropriate design of all features will ensure the usability and safety of all toilet facilities.
e. The identification of washrooms will include pictograms for children or people who cannot read. All signage will include braille that translates the text on the print sign, and not only the room number.
f. There are three types of washrooms. Single use accessible washrooms, single use universal washrooms, and multi-use stalled washrooms. The number and types of washrooms used in a facility will be determined by the number of users. There will always at least be one universal washroom.
g. All washrooms will have doors with power door opening buttons. No door washrooms will be hard to identify for people who have vision loss.
i. In stall washrooms with urinals, all urinals will be accessible with lower rim heights. Universal washrooms will have an upper rim at the same height as typical non-accessible urinals to avoid the mess taller users can make. All urinals will provide vertical grab bars which are colour contrasted to the walls. Where dividers between urinals are used, the dividers will be colour contrasted to the walls as well.
h. Stall washrooms accessible sized stalls At least 2 accessible stalls shall be provided in each washroom to avoid long wait times. Facilities with accessible education programs that include a large percentage of people with mobility disabilities should have all stalls sized to accommodate a turn circle and the transfer space beside the toilet.
i. All washrooms near rooms that will be used for public events shall include a baby change table that is accessible to all users, not placed inside a stall. It shall be colour contrasted with the surroundings and usable for those in a seated mobility device and or of shorter stature.
ii. At least one universal washroom will include an adult sized change table, with the washroom located near appropriate facilities in the facility and any public event spaces. These are important for some adults with disabilities and for children with disabilities who are too large for the baby change tables. This helps prevent anyone from needing to be changed lying on a bathroom floor.
iii. Where shower stalls are provided, these shall include accessible sized stalls.
iv. Portable Toilets at Special Events shall all be accessible. At least one will include an adult sized change table. i. Washroom Stalls:
i. Manoeuvrability of a wheelchair or scooter is the principal consideration in the design of an accessible stall. The increased size of the stall is required to ensure there is sufficient space to facilitate proper placement of a wheelchair or scooter to accommodate a person transferring transfer onto the toilet from their mobility device. There may also be instances where an individual requires assistance. Thus, the stall will have to accommodate a second person. Stall Door swings are normally outward for safety reasons and space considerations. However, this makes it difficult to close the door once inside. A handle mounted part way along the door makes it easier for someone inside the stall to close the door behind them. Minimum requirements for non-accessible toilet stalls are included to ensure that persons who do not use wheelchairs or scooters can be adequately accommodated within any toilet stall. Universal features include accessible hardware and a minimum stall width to accommodate persons of large stature or parents with small children.

j. Toilets:
i. Automatic flush controls are preferred. If flushing mechanisms are not automated, flushing controls shall be on the transfer side of the toilet, with colour contrasted and lever style handles.

k. Sinks:
i. Each accessible sink shall be on an accessible path of travel that other people, using other sinks or features (like hand-dryers), are not positioned to block. Automated sink controls are preferred. While faucets with remote-eye technology may initially confuse some individuals, their ease of use is notable. Individuals with hand strength or dexterity difficulties can use lever-style handles. For an individual in a wheelchair and younger children, a lower counter height and clearance for knees under the counter are required. The insulating of hot water pipes shall be assured to protect the legs of an individual using a wheelchair. This is particularly important when a disability impairs sensation such that the individual would not sense that their legs were being burned. The combination of shallow sinks and higher water pressures can cause unacceptable splashing at lavatories.
ii. Powered hand-dryers shall make minimum noise, to avoid being a barrier to people with vision loss or those with sensory integration issues for whom loud blasting sound can make a bathroom unusable. l. Urinals:
i. Each urinal needs to be on an accessible path of travel with clear floor space in front of each accessible urinal to provide the manoeuvring space for a mobility device. Grab bars shall be provided to assist individuals rising from a seated position and others to steady themselves. Floor-mounted urinals accommodate children and persons of short stature as well as enabling easier access to drain personal care devices. Flush controls, where used, will be automatic preferred. Strong colour contrasts shall be provided between the urinal, the wall and the floor to assist persons with vision loss/no vision. m. Showers
i. Where showers are provided, roll-in or curbless shower stalls shall be provided to eliminate the hazard of stepping over a threshold and are essential for persons with disabilities who use wheelchairs or other mobility devices in the shower. Grab bars and non-slip materials shall be included as safety measures that will support any individual. Hand-held shower heads or a water-resistant folding bench shall be included to assist people with disabilities. These are also convenient for others. Equipment that has contrasting colour from the shower stall shall be included to assist individuals with vision loss/no vision.

11. Drinking Fountains
a. Drinking fountain height should accommodate shorter persons, and that of a person using a wheelchair or scooter. Potentially conflicting with this, the height should strive to attempt to accommodate individuals who have difficulty bending and who would require a higher fountain. Where feasible, this may require more than one fountain, at different heights. The operating system shall account for limited hand strength or dexterity. Fountains will be recessed, to avoid protruding into the path of travel. Angled recessed alcove designs allow more flexibility and require less precision by a person using a wheelchair or scooter. Providing accessible signage with a tactile attention indicator tile will help those who with vision loss to find the fountain.

12. Performance Stages
a. Elevated platforms, such as stage areas, speaker podiums, etc., shall be accessible to all. A clear accessible route will be provided along the same path of access for those who are not using mobility assistive devices as those who do. Lifts will not be used to access stage or raised platforms, unless the facility is retrofitting an existing stage and it is not technically possible to provide access by other means.
b. The stage shall include safety features to assist persons with vision loss or those momentarily blinded by stage lights from falling off the edge of a raised stage, such as a colour contrasted raised lip along the edge of the stage.
c. Lecterns shall be accessible with an adjustable height surface, knee space and accessible audio visual (AV) and information technology (IT) equipment. Lecterns shall have a microphone that is connected to an assistive listening system, such as a hearing loop. The office and/or presentation area will have assistive listening units available for those who may request them, for example people who are hard of hearing but not yet wearing hearing aids.
d. Lighting shall be adjustable to allow for a minimum of lighting in the public seating area and back stage to allow those who need to move or leave with sufficient lighting at floor level to be safe

13. Offices, Work Areas, and Meeting Rooms
a. Offices providing services or programs to the public will be accessible to all, regardless of mobility or functional needs. Offices and related support areas shall be accessible to staff and visitors with disabilities.
b. All people, but particularly those with hearing loss/persons who are hard-of-hearing, will benefit from having a quiet acoustic environment – background noise from mechanical equipment such as fans, shall be designed to be minimal. Telephone equipment that supports the needs of individuals with hearing and vision loss shall be available.
c. The provision of assistive speaking devices is important for the range of individuals who may have difficulty with low vocal volume thus affecting production of normal audible levels of sound. Where offices and work areas and small meeting rooms do not have assistive listening, such as hearing loops permanently installed, portable assistive hearing loops shall be available at the office
d. Tables and workstations shall provide the knee space requirements of an individual in a mobility assistive device. Adjustable height tables allow for a full range of user needs. Circulation areas shall accommodate the spatial needs of mobility equipment as large as scooters to ensure all areas and facilities in the space can be reached with appropriate manoeuvring and turning spaces.
e. Natural coloured task lighting, such as that provided through halogen bulbs, shall be used wherever possible to facilitate use by all, especially persons with low vision.
f. In locations where reflective glare may be problematic, such as large expanses of glass with reflective flooring, blinds that can be louvered upwards shall be provided. Controls for blinds shall be accessible to all and usable with a closed fist without pinching or twisting

14. Outdoor Athletic and Recreational Facilities
a. Areas for outdoor recreation, leisure and active sport participation shall be designed to be available to people of a spectrum of abilities.
b. Outdoor spaces will allow persons with a disability to be active participants, as well as spectators, volunteers and members of staff. Spaces will be accessible including boardwalks, trails and footbridges, pathways, parks, parkettes and playgrounds, parks, parkettes and playgrounds, grandstand and other viewing areas, and playing fields
c. Assistive listening will be provided where game or other announcements will be made for all areas including the change room, player, coach and public areas.
d. Noise cancelling headphones shall be available to those with sensory disabilities.
e. Outdoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities undergoing rehabilitation.
f. Seating and like facilities shall be inclusive and allow for all members of a disabled sports team to sit together in an integrated way that does not segregate anyone.
g. Seating and facilities will be inclusive and allow for all members of a sports team of people with disabilities to sit together in an integrated way that does not segregate anyone.

15. Arenas, Halls and Other Indoor Recreational Facilities
a. Areas for recreation, leisure and active sport participation will be accessible to all members of the community.
b. Assistive listening will be provided where game or other announcements will be made for all areas including the change room, player, coach and public areas.
c. Noise cancelling headphones will be available to those with sensory disabilities.
d. Access will be provided throughout outdoor facilities including: playing fields and other sports facilities, all activity areas, outdoor trails, swimming areas, play spaces, lockers, dressing/change rooms and showers.
e. Interior access will be provided to halls, arenas, and other sports facilities, including access to the site, all activity spaces, gymnasia, fitness facilities, lockers, dressing/change rooms and showers.
f. Spaces will allow people with disabilities to be active participants, as well as spectators, volunteers and members of staff.
g. Indoor exercise equipment will include options for those with a variety of disabilities including those with temporary disabilities who are undergoing rehabilitation.
h. Seating and facilities will be inclusive and allow for all members of a sports team of people with disabilities to sit together in an integrated way that does not segregate or stigmatize anyone.

16. Swimming Pools
a. Primary considerations for accommodating persons who have mobility impairments include accessible change facilities and a means of access into the water. Ramped access into the water is preferred over lift access, as it promotes integration (everyone will use the ramp) and independence.
b. Persons with low vision benefit from colour and textural surfaces that are detectable and safe for both bare feet or those wearing water shoes. These surfaces will be provided along primary routes of travel leading to access points such as pool access ladders and ramps.
c. Tactile surface markings and other barriers will be provided at potentially dangerous locations, such as the edge of the pool, at steps into the pool and at railings.

17. Cafeterias
a. Cafeteria serving lines and seating area designs shall reflect the lower sight lines, reduced reach, knee-space and manoeuvring requirements of a person using a wheelchair or scooter. Patrons using mobility devices may not be able to hold a tray or food items while supporting themselves on canes or while manoeuvring a wheelchair.
b. If tray slides are provided, they will be designed to move trays with minimal effort. c. Food signage will be accessible.
d. All areas where food is ordered and picked up will be designed to meet accessible service counter requirements
e. Self-serve food will be within the reach of people who are shorter or using seated mobility assistive devices
f. Where trays are provided, a tray cart that can be attached to seated assistive mobility devices or a staff assistant solution that is readily available shall be available on demand, because carrying trays and pushing a chair or operating a motorized assistive device can be difficult or impossible

18. Libraries
a. All service counters shall provide accessibility features
b. Study carrels will accommodate the knee-space and armrest requirements of a person using a mobility device.
c. Computer catalogues, carrels and workstations will be provided at a range of heights, to accommodate persons who are standing or sitting, as well as people of different ages and sizes.
d. Workstations shall be equipped with assistive technology such as large displays, screen readers, to increase the accessibility of a library.
e. Book drop-off slots shall be at different heights for standing and seated use with accessible signage, to enhance usability.

19. Teaching Spaces and Classrooms
a. Students, instructors and staff with disabilities will have accessibility to teaching and classroom facilities, including teaching computer labs.
b. All teaching spaces and classrooms will provide power door operators and assistive listening systems such as hearing loops
c. Additional considerations may be necessary for spaces and/or features specifically designated for use by students with disabilities, such as accessibility standard accommodations for complex personal care needs.
d. Students instructors and staff with disabilities will be accommodated in all teaching spaces throughout the facility.
e. This accessibility will include the ability to enter and move freely throughout the space, as well as to use the various built-in elements within (i.e. blackboards and/or whiteboards, switches, computer stations, sinks, etc.).
f. Individuals with disabilities frequently use learning aids and other assistive devices that require a power supply. Additional electrical outlets shall be provided throughout teaching spaces to -accommodate the use of such equipment.
g. Except where it is impossible, fixtures, fittings, furniture and equipment will be specified for teaching spaces, which is usable by students, faculty, teaching assistants and staff with disabilities.
h. Providing only one size of seating does not reflect the diversity of body types of our society. Offering seats with an increased width and weight capacity is helpful for persons of large stature. Seating with increased legroom will better suit individuals that are taller. Removable armrests can be helpful for persons of larger stature as well as individuals using wheelchairs that prefer to transfer to the seat.

20. Laboratories
a. In addition to the requirements for classrooms, additional accessibility considerations may be necessary for spaces and/or features in laboratories.

21. Waiting and Queuing Areas
a. Queuing areas for information, tickets or services will permit persons who use wheelchairs, scooters and other mobility devices as well as for persons with a varying range of user ability to easily move through the line safely. All lines shall be accessible.
b. Waiting and queuing areas will provide space for mobility devices, such as wheelchairs and scooters. Queuing lines that turn corners or double back on themselves will provide adequate space to manoeuvre mobility devices. Handrails with high colour contrast will be provided along queuing lines, because they are a useful support for individuals and guidance for those with vision loss. Benches in waiting areas shall be provided for individuals who may have difficulty with standing for extended periods.
c. Assistive listening systems will be provided, such as hearing loops, will be provided along with accessible signage indicating this service is available.

22. Information, Reception and Service Counters
a. All information, reception and service counters will be accessible to the full range of visitors. Where adjustable height furniture is not used, a choice of fixed counter heights will provide a range of options for a variety of persons. Lowered sections will serve children, persons of short stature and persons using mobility devices such as a wheelchair or scooter. The choice of heights will also extend to any speaking ports and writing surfaces.
b. Counters will provide knee space under the counter to accommodate a person using a wheelchair or a scooter.
c. The provision of assistive speaking and listening devices is important for the range of individuals who may have difficulty with low vocal volume thus affecting production of normal audible levels of sound. The space where people are speaking will have appropriate acoustic treatment to ensure the best possible conditions for communication. Both the public and staff sides of the counter will have good lighting for the faces to help facilitate lip reading.
d. Colour contrast will be provided to delineate the public service counters and speaking ports for people with low vision.

23. Lockers
a. Lockers will be accessible with colour contrast and accessible signage
b. In change rooms an accessible bench will be provided in close proximity to lockers.
c. Lockers at lower heights serve the reach of short people or a person using a wheelchair or scooter.
d. The locker operating mechanisms will be at an appropriate height and operable by individuals with restrictions in hand dexterity (i.e. operable with a closed fist).

24. Storage, Shelving and Display Units
a. The heights of storage, shelving and display units will address a full range of vantage points including the lower sightlines of short people or a person using a wheelchair or scooter. The lower heights also serve the lower reach of these individuals.
b. Displays and storage along a path of travel that are too low can be problematic for individuals that have difficulty bending down or who are blind. If these protrude too much into the path of travel, each will protect people with the use of a trip free cane detectable guard.
c. Appropriate lighting and colour contrast is particularly important for persons with vision loss.
d. Signage provided will be accessible with braille, text, colour contrast and tactile features

25. Public Address Systems
a. Public address systems will be designed to best accommodate all users, especially those that may be hard of hearing. They will be easy to hear above the ambient background noise of the environment with no distortion or feedback. Background noise or music will be minimized.
b. Technology for visual equivalents of information being broadcast will be available for individuals with hearing loss/persons who are hard-of-hearing who may not hear an audible public address system.
c. Classrooms, library, hallways, and other areas will have assistive listening equipment that is tied into the general public address system.

26. Emergency Exits, Fire Evacuation and Areas of Rescue Assistance
a. In order to be accessible to all individuals, emergency exits will include the same accessibility features as other doors. The doors and routes will be marked in a way that is accessible to all individuals, including those who may have difficulty with literacy, such as persons speaking a different language.
b. Persons with vision loss/no vision will be provided a means to quickly locate exits audio or talking signs could assist.
c. In the event of fire when elevators cannot be used, areas of rescue assistance shall be provided especially for anyone who has difficulty traversing sets of stairs. Areas of rescue assistance will be provided on all floors above or below the ground floor. Exit stairs will provide an area of rescue assistance on the landing with at least two spaces for people with mobility assistive devices sized to ensure those spaces do not block the exit route for those using the stairs. The number of spaces necessary should be sized by the number of people on each floor. Each area of refuge will provide a 2-way communication system with both video and audio to allow those using the space to communicate that they are waiting there and to communicate with fire safety services and or security. All signage associated with the area of rescue assistance will be accessible and include braille for all controls and information.

27. Space and Reach Requirements
a. The dimensions and manoeuvring characteristics of wheelchairs, scooters and other mobility devices will allow for a full array of equipment that is used by individuals to access and use facilities, as well as the diverse range of user ability.

28. Ground and Floor Surfaces
a. Irregular surfaces, such as cobblestones or pea-gravel finished concrete, shall be avoided because they are difficult for both walking and pushing a wheelchair. Slippery surfaces are to be avoided because they are hazardous to all individuals and especially hazardous for seniors and others who may not be sure-footed.
b. Glare from polished floor surfaces is to be avoided because it can be uncomfortable for all users and can be a particular obstacle to persons with vision loss by obscuring important orientation and safety features. Pronounced colour contrast between walls and floor finishes are helpful for persons with vision loss, as are changes in colour/texture where a change in level or function occurs. c. Patterned floors should be avoided, as they can create visual confusion.
d. Thick pile carpeting is to be avoided as it makes pushing a wheelchair very difficult. Small and uneven changes in floor level represent a further barrier to using a wheelchair and present a tripping hazard to ambulatory persons.
e. Openings in any ground or floor surface such as grates or grilles are to be avoided because they can catch canes or wheelchair wheels. ?
29. Universal Design Practices Beyond Typical Accessibility Requirements
a. Areas of refuge should be provided even when a building has a sprinkler system. b. No hangout steps* should ever be included in the building or facility.
c. Hangout steps are a socializing area that is sometimes used for presentations. It looks similar to bleachers. Each seating level is further away from the front and higher up but here people sit on the floor rather than on seats. Each seating level is about as deep as four stairs and about 3 stairs high. There is typically a regular staircase provided on one side that leads from the front or stage area to the back at the top. The stairs allow ambulatory people access to all levels of the seating areas, but the only seating spaces for those who use mobility assistive devices are at the front or at the top at the back but these are not integrated in any way with the other seating options.
d. There should never be stramps. A stramp is a stair case that someone has built a ramp running back and forth across it. These create accessibility problems rather than solving them.
e. Rest areas should be differentiated from walking surfaces or paths by texture- and colour-contrast f. Keypads angled to be usable from both a standing and a seated position g. Finishes
i. No floor-to-ceiling mirrors
ii. Colour luminance contrast between:
iii. Floor to wall
iv. Door or door frame to wall
v. Door hardware to door
vi. Controls to wall surfaces

h. Furniture Arrange seating in square arrangement so all participants can see each other for those who are lip reading or using sign language