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AODA Compliance Policy

*Note: This policy has been updated to reflect the July 1, 2018, changes to the regulations under Ontario’s Health Protection and Promotion Act.

Intent

This policy is intended to meet the requirements of the customer service standards included in the Integrated Accessibility Standards Regulation under the Accessibility for Ontarians with Disabilities Act, 2005. It applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
All goods and services provided by Priority Healthcare shall follow the principles of dignity, independence, integration, and equal opportunity.

Definitions

Assistive device: Is a technical aid, communication device, or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them, such as a wheelchair, walker, or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering, or reading.

Disability: The term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:

  • Any degree of physical disability, infirmity, malformation, or disfigurement that is caused by bodily injury, birth defect, or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
  • A condition of mental impairment or a developmental disability;
  • A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
  • A mental disorder; or
  • An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997

Guide dog: Is a highly trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety, and increased independence for people who are blind.

Service animal: An animal is a service animal for a person with a disability if:

  1. The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
  2. The person provides documentation from a member of one of the following regulated health professional colleges confirming that the person requires the animal for reasons relating to the disability:
    • College of Audiologists and Speech-Language Pathologists of Ontario;
    • College of Chiropractors of Ontario;
    • College of Nurses of Ontario;
    • College of Occupational Therapists of Ontario;
    • College of Optometrists of Ontario;
    • College of Physicians and Surgeons of Ontario;
    • College of Physiotherapists of Ontario;
    • College of Psychologists of Ontario; or
    • College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

Support person: A support person means, in relation to a person with a disability, another person who accompanies him or her in order to help with communication, mobility, personal care, medical needs, or access to goods and services.

Guidelines

The provision of goods and services to persons with disabilities

Priority Healthcare will make every reasonable effort to ensure that its policies, practices, and procedures are consistent with the principles of dignity, independence, integration, and equal opportunity by:

  • Ensuring that all customers receive the same value and quality;
  • Allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services, as long as this does not present a safety risk;
  • Using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
  • Taking into account individual needs when providing goods and services; and
  • Communicating in a manner that takes into account the customer’s disability.

The use of assitive devices

Customer’s Own Assistive Devices
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by Priority Healthcare.
In cases where the assistive device presents a safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services. For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank may involve ensuring the customer is in a location that would be considered safe for both the customer and business. Or, where elevators are not present and where an individual requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.

Guide dogs and services animals

A customer with a disability who is accompanied by guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs or service animals.

Food Service Areas
A customer with a disability who is accompanied by guide dog or service animal will be allowed access to food service areas that are open to the public unless otherwise excluded by law. Other types of service animals are not permitted into food service areas due to the Health Protection and Promotion Act, Ontario Regulation 493/17.

Exclusion Guidelines
If a guide dog or service animal is excluded by law (see applicable laws below), Priority Healthcare will offer alternative methods to enable the person with a disability to access goods and services, when possible (for example, securing the animal in a safe location and offering the guidance of an employee).

Applicable Laws
Food Safety and Quality Act, 2001, Ontario Regulation 31/05: Animals not intended for slaughter or to be euthanized are not allowed in any area or room of a meat plant. It also makes an exception for service dogs to allow them in those areas of a meat plant where food is served, sold, or offered for sale to customers and in those areas that do not contain animals or animal parts and are not used for the receiving, processing, packaging, labelling, shipping, handling, or storing of animals or parts of animals.

Dog Owners’ Liability Act: If there is a conflict between a provision of this act or of a regulation under this or any other act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails.

Recognizing a Guide Dog or Service Animal:
If it is not readily apparent that the animal is being used by the customer for reasons relating to their disability, Priority Healthcare may request verification from the customer.

Care and Control of the Animal:
The customer who is accompanied by a guide dog or service animal is responsible for maintaining care and control of the animal at all times.

Allergies
If a health and safety concern presents itself (for example, in the form of a severe allergy to the animal), Priority Healthcare will make all reasonable efforts to meet the needs of all individuals.

The use of support persons

If a customer with a disability is accompanied by a support person, Priority Healthcare will ensure that both persons may enter the premises together and that the customer is not prevented from having access to the support person.

There may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations, Priority Healthcare will make every reasonable attempt to resolve the issue.

In situations where confidential information might be discussed, consent will be obtained from the customer before any conversation where confidential information might be discussed.

Admission Fees
Where Priority Healthcare requires a support person to accompany a person with a disability, and where the person with a disability has agreed to the accompaniment, Priority Healthcare will not charge the support persons any fees or fares.

Notice of disruptions in service

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Priority Healthcare. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use goods or services of Priority Healthcare, reasonable efforts will be made to provide advance notice. In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

If a notification needs to be posted, the following information will be included unless it is not readily available or known:

  • Goods or services that are disrupted or unavailable;
  • Reason for the disruption;
  • Anticipated duration; and
  • A description of alternative services or options.

Notification Options
When disruptions occur, Priority Healthcare will provide notice by:

  • Posting notices in conspicuous places including at the point of disruption, at the main entrance, and the nearest accessible entrance to the service disruption or on the Priority Healthcare website;
  • Contacting customers with appointments;
  • Verbally notifying customers when they are making a reservation or appointment; or
  • By any other method that may be reasonable under the circumstances.

Customer Feedback

Priority Healthcare shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available by (insert how the process will be publicized). Feedback forms, along with alternate methods of providing feedback verbally (in person or by telephone) or written (handwritten, delivered, website, or e-mail), will be available upon request.

Submitting Feedback
Customers can submit feedback to:
John Nalli, Director
416-951-2759
2800 Skymark Ave, Suite 501, Mississauga, ON L4W 5A6
jnalli@priority-care.ca

Customers who wish to provide feedback by completing an onsite customer feedback form or verbally can do so to any Priority Healthcare employee.
Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

Training

Training will be provided to:

  • Every person who is an employee of or a volunteer with the provider.
  • Every person who participates in developing the provider’s policies.
  • Every other person who provides goods, services, or facilities on behalf of the provider.

Training Provisions
Regardless of the format, training will cover the following:

  • A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005;
  • A review of the requirements of the customer service standards;
  • Instructions on how to interact and communicate with people with various types of disabilities;
  • Instructions on how to interact with people with disabilities who:
    • Use assistive devices;
    • Require the assistance of a guide dog or other service animal; or
    • Require the use of a support person (including the handling of admission fees);
  • Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities;
  • Instructions on what to do if a person with a disability is having difficulty accessing your services; and
  • Policies, procedures, and practices of Priority Healthcare pertaining to providing accessible customer service to customers with disabilities.

Training Schedule
Priority Healthcare will provide training as soon as practicable. Training will be provided to new employees, volunteers, agents, and contractors during training period. Revised training will be provided in the event of changes to legislation, procedures, policies, or practices.

Record of Training
Priority Healthcare will keep a record of training that includes the dates training was provided and the number of employees who attended the training.

Notice of availability and format of documents

Priority Healthcare shall notify customers that the documents related to the customer service standards are available upon request and in a format that takes into account the customer’s disability. Notification will be given by posting the information in a conspicuous place owned and operated by Priority Healthcare, the website of Priority Healthcare, and any other reasonable method.

Administration

If you have any questions or concerns about this policy or its related procedures, please contact Human Resources.

This policy and its related procedures will be reviewed as required in the event of legislative changes or changes to company procedures.