Accessibility for Ontarians with Disabilities Act

PURPOSE AND STATEMENT OF COMMITTMENT

Trylon TSF is committed to ensuring equal access and participation for people with disabilities. We are committed to treating people with disabilities in a way that allows them to maintain their dignity and independence.

We believe in integration, and we are committed to meeting the needs of people with disabilities in a timely manner. We will do so by removing and preventing barriers to accessibility and by meeting our accessibility requirements under Ontario’s accessibility laws.

 

This commitment involves:

  • Ensuring awareness of disabilities that can potentially impact our customers, visitors or employees,
  • Understanding the different assistive devices that may be used and how those devices may impact their access,
  • Ensuring that we behave in a manner that takes into consideration an individual’s disabilities, such that access is equivalent to that of persons without disabilities,
  • That all Company employees who deal with customers, or are involved in the provision of Company goods and services, receive adequate training in the supporting legislation as well as in the appropriate procedures for dealing with these customers, and
  • That this training is refreshed periodically as the legislation changes, individual employee roles change and the Company periodically reviews its policies, procedures and accessibility plan.

SCOPE

This policy applies to all Ontario Trylon TSF employees, every person who participates in developing policies for Trylon TSF’s Ontario operations, and every person who provides goods, services or facilities on behalf of Trylon TSF in Ontario. 

This policy also applies to, and was written to comply with, all aspects of the Accessibility for Ontarian’s with Disabilities Act (AODA), including the Customer Service Standard, Information and Communication Standard, Employment Standard and the Design of Public Spaces Standard.

 

DEFINITIONS

Accessibility

The term accessibility means giving people of all abilities opportunities to participate fully in everyday life. It is used to describe how widely a service, product, device, or environment is available to as many people as possible. Accessibility can be seen as the ability to access and benefit from a system, service, product or environment.

Accessible Format

May include, but is not limited to, large print, recorded audio and electronic format, braille and any other format usable by a person with a disability.

Assistive Devices

Those devices utilized by disabled persons in order to improve their functionality.  Assistive devices can include canes, wheelchairs, hearing aids, support persons, service animals, and many others.

Barrier

Anything that keeps someone with a disability from fully participating in all aspects of society because of their disability.  Barriers can involve:

  • Attitude – the way people think,
  • Architectural / Structural – relate to design elements of a building,
  • Information – difficulties in receiving or conveying information,
  • Technology – technologies can prevent people from accessing information, and
  • Systemic – company policies and procedures can create barriers often unknowingly

Disability

Any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness:

  • includes diabetes, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical compensation,
  • 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 appliance or device

A condition of mental impairment, developmental disability or learning disability

Any injury or disability for which benefits were claimed or received under a provincial insurance plan

Equal Opportunity

People with Disabilities have an opportunity equal to that given to others to access our goods and services

Integration of Services

Service is provided in a way that allows the disabled person to benefit from the same services, in the same place and in the same way as other customers

 

GENERAL ACCESSIBILITY STANDARDS

Communication

Trylon strives to communicate with a person with a disability in a manner that takes into account the individual’s disability.

Accessibility Plan

Trylon has established and implemented an Accessibility Plan to outline Trylon’s strategy to prevent and remove barriers for a person with a disability and meet the requirements of the IAS. Trylon will maintain the Accessibility Plan in accordance with the requirements of the IAS and will review and update it at least once every five (5) years. The Accessibility Plan is posted on Trylon’s website and will be made available in an Accessible Format, upon request.

Training

Trylon will provide initial training, and ongoing training as required under the IAS, to all persons to whom this Policy applies. Training will be provided on:

  • The requirements of the IAS and the Policy.
  • Trylon’s obligations under the Human Rights Code as they relate to a person with a disability.

Trylon will ensure training is provided to all persons to whom this Policy applies as soon as practicable after the person is hired or otherwise retained. On-going training will also occur as changes are made to the Policy. Trylon will maintain records of the individuals to whom training is provided and when the training occurred.

INFORMATION AND COMMUNICATION STANDARDS

Feedback Procedure

Trylon will ensure its process for receiving and responding to feedback is accessible to a person with a disability by providing or arranging for the provision of Accessible Formats and Communications Supports, upon request. Trylon will notify the public of the availability of Accessible Formats and Communication Supports for feedback purposes.

Accessible Formats and Communication Supports

Upon request, Trylon will provide or arrange for the provision of Accessible Formats and Communication Supports to make its communication or information about its goods, services and/or facilities accessible to a person with a disability. Accessible Formats and Communication Supports will be provided in a timely manner and at a cost no more than the regular cost charged to any other person. Trylon will consult with the person making the request when determining the suitability of an Accessible Format or Communication Support. Trylon will also notify the public of the availability of Accessible Formats and Communication Supports.

Emergency Plans, Procedures and Public Safety Information

Trylon will provide any emergency plans, procedures or public safety information that it makes available to the public in an Accessible Format or with appropriate Communication Supports upon request and as soon as practicable.

Accessible Websites and Web Content

Trylon will ensure, where practicable, any New Internet Website and web content on such site(s) conforms with WCAG 2.0 Level A published prior to January 1, 2012.

Trylon will ensure, where practicable, any new website or content on that site(s) published after January 1, 2012 conforms with WCAG 2.0 Level AA to the extent required by the IAS. When determining whether meeting the requirements of this section are practicable Trylon will consider the availability of commercial software or tools required to achieve web accessibility; and the impact meeting the requirements of this section will have on any project planned before January 1, 2012.

The commitment to provide an accessible website and web content only applies to a website and web content Trylon controls directly or indirectly through a contractual relationship allowing for modification of the website or web content at issue.

EMPLOYMENT STANDARDS

The Employment Standards only apply to employees of Trylon. They do not apply to volunteers or other unpaid individuals or contractors.

Recruitment, Selection and Assessment

Trylon will notify the public and employees of the availability of accommodation during the recruitment process.

Trylon will notify job applicants who are individually selected to participate in an assessment or selection process that accommodation is available upon request if the applicant requires accommodation due to a disability.

If an applicant requests accommodation, Trylon will consult with the applicant and provide or arrange for the provision of a suitable accommodation in a manner that takes into account the applicant’s accessibility needs.

Notice to Successful Applicants

When making an offer of employment, Trylon will notify the successful applicant of Trylon’s policy on accommodating employees with a disability.

Informing Employees of Supports

Trylon will inform its employees of its policies on supporting an employee with a disability, including, but not limited to, its policy on the provision of job accommodation that takes into account an employee’s accessibility needs due to disability. This information will be provided to a new employee as soon as practicable after commencing employment.

Trylon will provide employees with updated information whenever there is a material change to its policies on the provision of job accommodation for an employee with a disability.

Accessible Formats and Communication Supports for Employees

Upon the request of an employee with a disability, Trylon will provide or arrange for the provision of Accessible Formats and Communication Supports to ensure information required by the employee to perform his or her job and/or information generally available to an employee in the workplace is accessible to the employee with a disability.

Trylon will consult with the employee making the request to determine the suitability of any Accessible Format or Communication Support. However, Trylon reserves the right to determine the Accessible Format or Communication Support provided.

Workplace Emergency Response Information

Trylon will provide individualized emergency response information to any employee who requires it as a result of a disability. This information will be provided as soon as practicable after Trylon becomes aware of the employee’s need for an individualized response.

Where the employee will require assistance in an emergency, and with the employee’s consent, Trylon will designate a colleague(s) to provide such individualized assistance and will provide the colleague(s) with the employee’s individualized emergency response information.

Trylon will review the individualized workplace emergency response information when (i) the employee moves to a different work location, (ii) the employee’s overall accommodation needs or plans are reviewed, and/or (iii) Trylon reviews its general emergency response policies.

For further information please see Trylon’s AODA Workplace Emergency Response Policy.

Individual Accommodation and Return to Work

Trylon has a written process for developing a documented individual accommodation plan for an employee with a disability. The process includes all elements required by the IAS.

Any individual accommodation plan prepared for an employee will include:

  • Information on Accessible Formats or Communication Supports provided to the employee.
  • Any individualized workplace emergency response plan developed for the employee.
  • Any other forms of accommodation being provided to the employee as a result of his or her disability.

Trylon also has a written process for any employee who may be returning to work following a disability-related leave of absence. The process includes the steps taken to facilitate the employee’s return to work and the development of any required individual accommodation plan on return.

For more information, please consult Trylon’s Individual Accommodation and Return to Work Policy.

Performance Management, Career Development and Advancement and Redeployment

Trylon will take an employee’s accessibility needs, and any individualized accommodation plan, into account in:

  • Conducting performance management.
  • Providing opportunities for career development and advancement.
  • Making redeployment decisions.

 

DESIGN OF PUBLIC SPACES STANDARDS

Trylon will comply with the accessibility requirements of the Design of Public Spaces Standards when redeveloping or constructing new public spaces on or after January 1, 2017. For further information on existing or planned projects to redevelop or construct new public spaces see Trylon’s Accessibility Plan.

 

GENERAL PROCEDURES

  1. Persons with disabilities are able to use their own assistive device, service animal or support person to access goods or services or any other measures Trylon TSF offers to enable them to access the goods or services.
  2. All Company employees should communicate with a person with disabilities in a manner which takes into account their disability and maintains their dignity.
  3. Any person with a disability will be able to bring their service animal with them into the premises where the public is allowed, except where an animal is otherwise excluded by law from the premises.
  4. Trylon TSF will provide notice when facilities or services that people with disabilities use to access goods or services are disrupted;
    1. In the notice, include information about the reason for the disruption, the expected duration and a description of alternate facilities if available
    2. Place notice in an obvious location on premises, as well as on website, and other key mechanisms for communicating with the public
  5. Trylon TSF will ensure there is a process to receive and respond to feedback about the way Trylon TSF provides goods or services to persons with disabilities, and that feedback is taken into consideration when reviewing such policy and related programs.

 

QUESTIONS ABOUT THIS POLICY

For more information about the Policy please contact Human Resources.

Trylon AODA Multi-Year Accessibility Plan

Initiative

IASR Requirement

Action

Status

Compliance Date

Update Website

Information and Communication Standard

3rd party provided an updated Trylon website with Accessibility features.

Completed

June 30, 2021

Information posted on website

Information and Communication Standard

Post Accessibility policy and Multi-Year Accessibility Plan on website

Ongoing

October 21, 2021

Individual Accommodation plans

Employment Standard

Updated individual accommodation plans

Ongoing

June 30, 2021

Feedback

Every obligated organization that has the processes for receiving and responding to feedback shall ensure that the processes are accessible to persons with disabilities by providing or arranging for accessible formats and communication s supports upon request.

1.       Determine current feedback systems

2.       Update current process to include website, email and phone.

Ongoing

June 30, 2021

Return to Work process

Every employer, other than an employer that is a small organization, (a) shall develop and have in place a return to work process for its employees who have been absent from work due to a disability and require disability related accommodations in order to return to work; and (b) shall document the process.

 

The return to work process shall, (a) outline the steps the employer will take to facilitate the return to work of employees

Review the Return to Work policy and procedure to ensure it is inclusive of employees with disabilities.

Revise as necessary and to ensure it meets or exceeds legislation.

Ongoing

June 30, 2021