OTTAWA POLICE SERVICES BOARD

COMMISSION DE SERVICES POLICIERS D’OTTAWA

 

The Trusted Leader in Policing

Le chef de file de confiance dans la police

REPORT

RAPPORT

 

DATE                              28 July 2014

 

TO/DEST.                       Ottawa Police Services Board

 

FROM/EXP.                   Policy & Governance Committee, Ottawa Police Services Board

 

SUBJECT/OBJET         UPDATED ACCESSIBILITY POLICY

 

 

RECOMMENDATION

 

That the Ottawa Police Services Board approve the new, updated Accessibility Policy attached as Annex A to replace the existing Board policies GA-14 and CR-14 on Accessibility Standards for Customer Service.

 

BACKGROUND

 

In December 2011 the Police Services Board approved policies on Accessibility Standards for Customer Service providing direction to the Board for its own members and employees, and to the Chief of Police for the Police Service.  The policies, GA-14 and CR-14 respectively, addressed the requirements of the “Accessibility Standards for Customer Service” Regulation, O Reg. 429/07, which was the first of five planned Standards to be issued by the Provincial Government in support of the Accessibility for Ontarians with Disabilities Act (AODA), S.O. 2005. 

 

In June 2011 the Province enacted a second Regulation to support the AODA, called the Integrated Accessibility Standards Regulation (IASR), O Reg. 191/11.  It contains standards on the following:  General; Information and Communications; Employment; Transportation; and Design of Public Spaces.  It also incorporates the requirements of the earlier Customer Service Standards regulation.  Consequently, a new Board policy has been prepared (attached as Annex A) to capture the requirements of the IASR and the provisions of the Board’s existing policies GA-14 and CR-14 on Accessibility Standards for Customer Service.

 

Under the AODA, police services are classified as Obligated Large Organizations (as opposed to municipalities, which are classified as Designated Public Sector Organizations).  Depending on how an organization is classified, there are different deadlines for compliance with various components of the IASR. 

 

The chart below sets out the various standards and compliance dates that apply for the Police Service; by extension, as the employer of the Police Service it is understood that the same deadlines apply to the Board.

 

 

Summary of IASR Clause

Compliance Date

3

Policies - develop, implement and maintain policies governing how the organization achieves or will achieve accessibility through meeting its requirements referred to in the IASR.

January 1, 2014

4

Multi-Year Accessibility Plan - establish, implement, maintain and document a multi-year accessibility plan outlining the organization’s strategy to prevent and remove barriers and meet its requirements under the IASR.

January 1, 2014

5

Procurement – procuring or acquiring goods, services or facilities

Not applicable

6

Self-Service Kiosks – designing, procuring or acquiring kiosks

January 1, 2014

7

Training – to all employees, volunteers, persons who participate in developing the organization’s policies, and all other persons who provide goods, services or facilities on behalf of the organization.

January 1, 2015

11

Feedback – processes for receiving and responding to feedback that are accessible to persons with disabilities.

January 1, 2015

12

Accessible Formats & Communication Supports – provide or arrange for the provision of accessible formats and communication supports.

January 1, 2016

13

Emergency Plans, procedures and public safety info – must be provided in an accessible format with appropriate communication supports.

January 1, 2012

14

Accessible Web – applicable to new websites and new content. Must be compliant with WCAG (World Wide Web Consortium Web Content Accessibility Guidelines) 2.0, Level A by 2014 and Level AA by 2021.

 

January 1, 2014

January 1, 2021

20-32

Employment – including recruitment, informing employees of supports, accessible formats and communication supports for employees, workplace emergency response information and individual accommodation plans for employees with disabilities, return to work process, performance management, career development and advancement, redeployment.

January 1, 2016

33-80

Transportation

Not applicable

80.1

Design of Public Spaces (Built Environment) - applicable for contracts signed after Jan. 1, 2012, and to construction after Jan. 1, 2017.

January 1, 2012

January 1, 2017

 

City of Ottawa Support

 

As is clear from the above table, there is a considerable amount of work to be done.  The City of Ottawa, as a Designated Organization under the AODA with earlier deadlines for compliance, has dedicated significant resources and worked hard over the past several years to ensure it is compliant with the legislation. It has established an Accessibility Unit managed by Robyn Guest, Program Manager, Policy Coordination, Outreach & Accessibility, City Manager’s Office.  Ms. Guest and the Accessibility Unit staff, along with Meg Steele, Legal Counsel, City of Ottawa, have been very helpful in assisting the Board and OPS to understand the requirements of the legislation and in drafting the Board policy, which is modelled on the City’s policy.  They have encouraged the Police Service to take advantage of their expertise and the many resources the City has already developed.  Some of these resource documents have been referenced in the Board policy.

 

The City also has an Accessibility Working Group with representation from all departments that meets regularly, and which has welcomed representatives from the Police Services Board and OPS to its group.  It is an excellent forum for staying informed about challenges and new developments, and for learning from the experiences of others. 

 

Finally, the City has developed in-class and online training required under the IASR and that training can be made available to the OPS and Board.  

 

Review of Policy

 

The Province is currently conducting a review of the Accessibility Standards for Customer Service and will likely be amending it in the coming months.  Rather than wait until these amendments are approved, it is proposed that the Board adopt its Accessibility Policy now and conduct a review of the policy in 2015, at which time any updates approved by the Province can be incorporated.

 

Reporting

 

As a large organization, the OPS must file a compliance report to the Province every three years, with the first report due by December 31, 2014.  The compliance report will also be submitted to the Board.

 

The policy also includes a requirement for the Chief to report annually to the Board on the Service’s progress towards meeting its multi-year plan. 

 

NEXT STEPS

 

Chief of Police Bordeleau has assigned Inspector Mark Ford to lead the OPS on the work that needs to be done to meet the IASR compliance requirements.  Inspector Ford has taken immediate action and assigned his team members to work with Ms. Guest and staff from the City of Ottawa’s Accessibility Office.  As previously noted, Ms. Guest has offered to share their expertise as well as City of Ottawa documents, tools and training.  OPS members are attending an AODA planning workshop in July and will have a high level work plan developed in September that will identify key deliverables and timelines.  Work will continue in the coming months, in consultation with the City staff and the Board Executive Director, to develop the multi-year accessibility plan, policies and procedures, and a plan for training OPS employees and volunteers.  Once the required multi-year plan is prepared, it will be submitted to the Board for approval. 

 

CONSULTATION

 

The Board’s Policy & Governance Committee met on 7 July 2014 to review and provide input into the policy.

 

In addition to the significant consultation that has already taken place with the City of Ottawa Accessibility Unit staff and legal counsel, which will continue, policies and multi-year plans of other large police services in Ontario were reviewed. 

 

FINANCIAL STATEMENT

 

The cost of implementing the work associated with the IASR is unknown at this time.  A clearer idea of cost implications should be known once the OPS work plan is developed.  A forecast of costs will be ready in time for inclusion in the 2015 OPS budget. 

 

CONCLUSION

 

The Board and Police Service are obligated to be in compliance with the Province’s Accessibility legislation and associated regulations by the deadlines specified in the IASR.  Some of the work has been completed, such as some training and websites for both the Board and Service that are fully compliant with World Wide Web Consortium Web Content Accessibility Guidelines (WCAG) 2.0, level AA.  Work is now underway to develop a comprehensive work plan for implementation of the remaining standards.  The Board will be kept informed of the Service’s progress in working to implement the requirements of the new Accessibility Policy.

 

 

 

 

____________________________________________

 

Submitted by the Policy & Governance Committee:

 

Carl Nicholson, Chair

Jim Durrell

Eli El-Chantiry (ex-officio)

 

Attach. (1)