Accessibility Policy

Access for Ontarians with Disabilities 

APPLIES TO:  All employees and contractors

Firmex values diversity and strives to make its services accessible to all clients. This policy is intended to meet the requirements of Accessibility Standards for Customer Service, Ontario Regulation 429/07 under the Accessibility for Ontarians with Disabilities Act, 2005.

All services provided by Firmex shall follow the principles of dignity, independence, integration and equal opportunity.

Scope

• This policy applies to the provision of services at premises owned/leased and operated by Firmex, and when the provision of services occurs off the premises of Firmex.
• This policy applies to employees, contractors, consultants and agents who deal with the public or other third parties and who act on behalf of Firmex.
• The section of this policy that addresses the use of guide dogs, service animals and service dogs only applies to the provision of services that take place at premises owned/leased and operated by Firmex. 
• This policy also applies to all persons who participate in the development of Firmex’s policies, practices and procedures governing the provision of services to members of the public or third parties.

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 clients bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/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, as reflected in Ontario Regulation 429/07, an animal is a service animal for a person with a disability if:

• It is readily apparent that the animal is used by the person for reasons relating to his or her disability; or
• If the person provides a letter from a physician or nurse confirming that the person requires the animal for reasons relating to the disability.

Service Dog, as reflected in Health Protection and Promotion Act, Ontario Regulation 562 a dog other than a guide dog for the blind is a service dog if:

• It is readily apparent to an average person that the dog functions as a service dog for a person with a medical disability;
• Or the person who requires the dog can provide on request a letter from a physician or nurse confirming that the person requires a service dog.

Support Person, as reflected in Ontario Regulation 429/07, 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.

General Principles

In accordance with the Accessibility Standards for Customer Service, Ontario Regulation 429/07, this policy addresses the following:

1. The Provision of Goods and Services to Persons with Disabilities;
2. The Use of Assistive Devices
3. The Use of Guide Dogs, Service Animals and Service Dogs
4. The Use of Support Persons
5. Notice of Service Disruptions
6. Customer Feedback
7. Training
8. Notice of Availability and Format of Required Documents

1. The Provision of Goods and Services to Persons with Disabilities

Firmex 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 clients receive the same value and quality;
• Allowing clients with disabilities to do things in their own ways, at their own pace when accessing services as long as this does not present a safety risk;
• Using alternative methods when possible to ensure that clients 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.

2. Assistive Devices

Persons with disabilities may use their own assistive devices as required when accessing services provided by Firmex.

3. Guide Dogs, Service Animals and Service Dogs

A customer with a disability who is accompanied by a guide dog, service animal or service dog will be allowed access to Firmex’s premises.

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

Applicable Laws pertaining to Firmex’s operations: 
Dog Owners’ Liability Act, Ontario: 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 pitbulls) 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, Service Dog and/or Service Animal:
If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, Firmex may request verification from the customer. Verification may include:

• A letter from a physician or nurse confirming that the person requires the animal for reasons related to the disability
• A valid identification card signed by the Attorney General of Canada; or,
• A certificate of training from a recognized guide dog or service animal training school.

Care and Control of the Animal: 

• The customer who is accompanied by a guide dog, service dog and/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), Firmex will make all reasonable efforts to meet the needs of all individuals.

4. Support Persons

• If a customer with a disability is accompanied by a support person, Firmex will ensure that the customer is not prevented from having access to the support person.
• In situations where confidential information might be discussed, consent will be obtained from the customer prior to any conversation where confidential information might be discussed. 

5. Notice of Disruptions in Service

In the event of any temporary disruptions to facilities or services that clients with disabilities rely on to access or use Firmex’s services (such as an elevator), 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.

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

• Services that are disrupted or unavailable
• Reason for the disruption
• Anticipated duration
• A description of alternative services or options

Notifications Options:

When disruptions occur Firmex 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 and/or on the Firmex website;
• Contacting clients with appointments;
• Verbally notifying clients when they are making an appointment; or
• By any other method that may be reasonable under the circumstances.

6. Feedback Process

Firmex shall provide clients with the opportunity to provide feedback on the service provided to clients with disabilities. Information about the feedback process will be readily available to all clients and notice of the process will be made available through Firmex’s website and by posting the notice in a visible location in Firmex’s reception areas. Feedback forms along with alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written, delivered, website or email), will be available upon request.

Submitting Feedback:
Clients can submit feedback to: Stephanie Stanko, HR Manager

Clients who wish to provide feedback by completing an onsite customer feedback form, or to provide feedback verbally, can do so to any Firmex’s employee. 

Clients who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.  

7. Training

Training will be provided to:

• All employees, contractors, consultants and agents who deal with the public or other third parties and who act on behalf of Firmex; and,
• Those who are involved in the development and approval of customer service policies, practices and procedures.

Training Provisions:

• As reflected in Ontario Regulation 429/07, 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 Accessibility Standards for Customer Service, Ontario Regulation 429/07.
  • 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, service dog or other service animal; 
• Require the use of a support person.
• 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 our services.
• Firmex’s policies, procedures and practices pertaining to providing accessible customer service to clients with disabilities.

Training Schedule:

• Firmex will provide training as soon as practicable. Training will be provided to new employees, contractors, consultants and/or agents who deal with the public or act on our behalf during orientation. Revised training will be provided in the event of changes to legislation, procedures and/or practices.

 Record of Training:

• Firmex will keep a record of training that includes the dates training was provided and the name of employees who attended the training.

8. Notice of Availability and Format of Documents

Firmex shall notify clients that the documents related to the Accessibility Standards for Customer Service 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 in Firmex’s premises as well as Firmex’s website.

If you have any questions or concerns about this policy or its related procedures please contact: Stephanie Stanko, HR Manager

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