Accessibility Policy

RAILTERM’S AODA – INTEGRATED ACCESSIBILITY STANDARDS REGULATION (IASR) POLICY
(P-015)


Business Units Application:

All business units – Ontario

Control Number:

Version 1.01

Last Update:

April 18, 2019

Effective Date:

April 30, 2019

Approved by:

François Prénovost
Executive Vice President


1. Intent

This policy is intended to meet the requirements of the standards set forth under the Accessibility for Ontarians with Disabilities Act 2005 (AODA). RailTerm is committed to meeting the needs of individuals living with disabilities in a timely manner. RailTerm is committed to providing equal treatment to people with disabilities with respect to services, programs, goods and facilities, in a manner that respects their dignity and independence.

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

2. Statement of organizational commitment

RailTerm believes its workplaces, as well as its practices, should allow for equal access and participation for people with disabilities when reasonably feasible. RailTerm believes in integration and in a work environment that welcomes all employees, partners and clients.

RailTerm will provide, on request, information in an accessible format or with communication supports to people with disabilities, in a manner that takes into account their disability. RailTerm will also file an accessibility compliance report every three (3) years. This report will be available upon request in an accessible format.

3. Definitions

Accessible formats – include but are not limited to large print, recorded audio and electronic formats usable by persons with disabilities.

AODA – the Accessibility for Ontarians with Disabilities Act (AODA).

Barrier – a barrier is a circumstance or obstacle that keeps people apart. For people with disabilities, barriers can take many forms including attitudinal, communication, physical, policy, social and transportation.

Disability – a disability is a physical or mental condition that limits a person’s movements, senses or activities. The AODA uses the same definition of disability as the Ontario Human Rights Code.

IASR – the Integrated Accessibility Standards Regulation. The AODA has five standards which are included in the IASR. These include the customer service standard, employment standard, information and communication standard, design of public spaces standard, the transportation standard as well as some general requirements.

4. General provisions

4.1 Modifications to this policy

This policy will be reviewed and revised, as needed, to keep abreast with legal requirements. Employees will also be informed on an ongoing basis when changes are made to these policies, practices and procedures.

4.2 Establishment of multi-year accessibility plan

RailTerm will establish, implement, maintain and document a multi-year accessibility plan outlining its strategy to prevent barriers and meet its requirements under the IASR.

The accessibility plan will be:

  • Posted on RailTerm’s website;
  • Reviewed and updated at least once every five (5) years; and,
  • Made available in an accessible format, upon request.

4.3 Training

RailTerm is committed to training employees on Ontario’s accessibility laws and aspects of the Ontario Human Rights Code that relate to persons with disabilities. Employees will be trained on accessibility as it relates to their specific roles.

Training includes:

  • Information on the purposes of the AODA and its requirements;
  • How to interact and communicate with people with various types of disabilities;
  • How to interact with support persons and service animals;
  • What to do if a person with a disability is having difficulty accessing RailTerm’s information or facilities;
  • Information on RailTerm’s policies, practices and procedures relating to Ontarians with disabilities.

5. Customer service standards

5.1 Use of assistive devices

Persons with disabilities may use their own assistive devices as required when accessing RailTerm’s facilities or services it provides.

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 access to properties or services.

5.2 Support persons and service animals

RailTerm welcomes people with disabilities who are accompanied by a support person or service animal in office areas that are open to the public. Employees are trained on how to interact with people with service animals.

5.3 Facilities

RailTerm is committed to ensuring that its offices located in Ontario are welcoming and accessible to people with disabilities. RailTerm will provide, as needed, any necessary alternative to accommodate people with disabilities. Alternatives may include arranging meetings in alternate locations that are more accessible for people with disabilities.

6. Information and communication standard

RailTerm will communicate with people with disabilities in ways that take into account their disability. When requested, RailTerm will provide information about its organization and its services in accessible formats or with communication supports.

RailTerm will also meet website requirements in accordance with Ontario’s accessibility laws.

RailTerm welcomes feedback regarding how it provides programs and services to persons with disabilities.

This can be provided through the following methods:

  • E-mail: hr_dept@railterm.com
  • Mail: Attn: Human Resources, 10765 Côte-de-Liesse, Suite 201, Dorval, QC
  • Phone: 514-420-1204
  • Fax: 514-420-1218

7. Employment Standard

7.1 Recruitment, assessment and selection

Employees seeking employment with RailTerm will be informed that accommodations can be made during recruitment and hiring. Where an accommodation is requested, RailTerm will consult the applicant and provide or arrange for suitable accommodation.

7.2 Performance management and career development

RailTerm’s performance management and career development processes will also consider the accessibility needs of all employees.

7.3 Workplace emergency response plan

Where required, RailTerm will create an individual workplace emergency response plan in conjunction with the employee living with disabilities. This plan will take into account the unique challenges associated with the individual’s disability as well as the physical nature of the workplace.

7.4 Accessible formats and communication supports for employees

RailTerm will ensure that employees are well informed about its policies for employees with disabilities. Employees will also be informed on an ongoing basis when changes are made to these policies, practices and procedures.

If an employee with disability requests it, RailTerm will provide accessible formats and communication supports for the following:

  • Information needed in order to perform his/her job; and
  • Information that is generally accessible to all employees in the workplace.

RailTerm will consult the employee making the request to determine the best way to provide the accessible format or communication support.

8. Documented Individual Accommodation Plans (IAPs)

RailTerm will develop and document IAPs for employees with disabilities in accordance with the following process:

Step 1: Recognize the need for accommodation

This accommodation can be:

  • Requested by the employee through his/her manager or Human Resources;
  • Identified by the employee’s manager or Human Resources.

Step 2: Gather relevant information and assess needs

The employee is involved in the process:

  • RailTerm does not necessarily need or require details on the nature of the employee’s disability to provide accommodation. However, it is necessary for RailTerm to know about the employee’s functional abilities;
  • Human Resources may ask for a functional capacity assessment;
  • The employee, his/her manager and Human Resources will evaluate potential options to find the most suitable measure;
  • If necessary, RailTerm may involve a third-party expert to assist in the accommodation process.

Step 3: Write a formal Individual Accommodation Plan (IAP)

Once the appropriate accommodation has been identified, the accommodation details are written down in a formal plan including:

  • Accessible formats and communication supports, if requested;
  • Workplace emergency response information, if required;
  • Any other accommodation that is to be provided.

The employee’s personal information will be protected throughout the accommodation process. Accommodation plans will only be shared with those who require the information to execute or assist with the plan and only to the extend necessary for such assistance.

If RailTerm denies an accommodation, the employee will be provided with the reasons for the denial.

Step 4: Implement, monitor and review IAP

The employee and his/her manager shall monitor the accommodation to ensure it has effectively resolved the challenge.

If the accommodation is no longer appropriate, the employee and the manager can work together to gather information and reassess the employee’s needs so RailTerm can find the best accommodation measure (step 2). However, it is essential that Human Resources are informed if an accommodation reassessment is necessary so that proper and timely support is provided.

9. Return to Work (RTW)

RailTerm will adhere to the following process to support its employees who have been absent from work due to a disability and require accommodation to return to work:

Step 1: Initiate the RTW process
The employee reports his/her need for a disability leave to his/her manager or to Human Resources.

Step 2: Make and maintain contact with the employee on leave
The employee’s manager and Human Resources are together responsible for:

  • Maintaining regular contact with the employee;
  • Providing the employee with any return to work information;
  • Monitoring the employee’s progress until he/she is fit for work.

The employee is responsible for:

  • Obtaining and following the appropriate medical treatment;
  • Updating Human Resources about his/her progress;
  • Asking his/her healthcare professional for completion of a Functional Abilities Form (FAF) upon RailTerm’s request;
  • Providing his/her healthcare professional any relevant return to work information.

Step 3: Develop a RTW plan

The employee, his/her manager and Human Resources collaborate, with support from the healthcare professional, to develop a formal RTW plan, which is included in the employee’s Individual Accommodation Plan (IAP), if applicable:

  • If the employee has no residual functional limitations, he/she returns to his/her regular position with no accommodation required;
  • If the employee has temporary function limitations, he/she returns to a temporary modified work environment with accommodation or to a transitional position;
  • If the employee has lasting functional limitations, except for cases where accommodation cannot be accomplished without undue hardship, he/she returns to work with permanent accommodation or is permanently reassigned to another position.

Step 4: Monitor and evaluate the RTW process

The employee, his/her manager and Human Resources monitor and review the RTW process regularly until it has been completed. If the employee encounters challenges, the manager and Human Resources will evaluate if adjustments need to be made to the RTW plan and will implement them, if applicable.

GENERAL REQUIREMENTS
Accessibility RequirementPlan to meet requirementsKey-ResourceDeadlineCurrent Status
Development of accessibility policiesSr. Management review and approval. Director, HRMarch 31, 2019Completed
Distribution to all employeesDirector, HRApril 30, 2019Completed
Make policy available on Company websiteDirector, AdministrationNovember 30, 2019Completed
Training on IASR (including OHRC) and Customer Service StandardDirector, HROctober 31, 2018Completed
Director, HRMay 31, 2019Completed
Director, HRApril 30, 2019Completed
Information and Communications Standard
Accessibility RequirementPlan to meet requirementsKey-ResourceDeadlineCurrent Status
Accessible formats and communication supportsDistribute policies internallyDirector, HRApril 30, 2019Completed
Make policy available on Company websiteDirector, AdministrationNovember 30, 2019Completed
Accessible website and web contentIntegrate WCAG 2.0 Level A requirement in 2019 website overhaul. Ensure website is WCAG 2.0 Level AA compatibleDirector, AdministrationNovember 30, 2019Completed
Integrate WCAG 2.0 Level AADirector, AdministrationDecember 31, 2020
Employment Standard
Accessibility RequirementPlan to meet requirementsKey-ResourceDeadlineCurrent Status
Recruitment, assessment and selection processesAdd appropriate notes to career page and job postingsDirector, HROctober 31, 2018Completed
Integrate notes to job offers referring to available accommodation upon requestDirector, HRApril 30, 2019Completed
Accessible website and web contentIntegrate WCAG 2.0 Level A requirement in 2019 website overhaul. Ensure website is WCAG 2.0 Level AA compatibleDirector, AdministrationNovember 30, 2019Completed
Integrate WCAG 2.0 Level AADirector, AdministrationDecember 31, 2021Completed
Accessible formats and communication supports for employeesCirculate policies to current employeesDirector, HRApril 30, 2019
Integrate policies in HRIS onboarding processes for new employeesDirector, HRApril 30, 2019Completed
Documented individual accommodation plans (IAP)Document procedure to follow to create a IAP’sDirector, HRFebruary 18, 2019
Inform managers on the IAP creation procedureDirector, HRApril 30, 2019Completed
Return to work process (RTW)Document procedure to follow to create a IAP’sDirector, HRFebruary 18, 2019Completed
Inform managers on the RTW creation procedureDirector, HRApril 30, 2019Completed
Customer Service Standard
Accessibility RequirementPlan to meet requirementsKey-ResourceDeadlineCurrent Status
AODA provision of goods, services and facilities policies.
Service animals and support persons
Distribute policies internallyDirector, HRApril 30, 2019Completed
Make policy available on Company websiteDirector, AdministrationNovember 30, 2019Completed
Compliance Reporting
ActionDeadlineCurrent Status
Accessibility Compliance Report FilingJune 30, 2019Completed
Accessibility Compliance Report FilingDecember 31, 2020
Accessibility Compliance Report FilingDecember 31, 2023