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Dean Mayo Moran
University of Toronto Faculty of Law
27 King's College Circle
Toronto ON M5S 1A1
Dear Dean Moran,
Please find attached the submission of the Ontario Human Rights Commission (OHRC) regarding the Accessibility for Ontarians with Disabilities Act (AODA) 2013-14 Legislative Review.
While much has been accomplished with the coming into force of new regulated standards under the AODA, there is still a long way to go to meet the government’s commitment to make Ontario a barrier free reality for people with disabilities by 2025.
In its submission, the OHRC makes 14 recommendations in six key areas to help strengthen the AODA including:
Legislative harmonization: recognize the Human Rights Code duty to accommodate short of undue hardship under AODA regulations and promote awareness; apply integrated accessibility regulation provisions on Code primacy and training to customer service regulations; apply AODA planning, reporting and compliance requirements to Building Code accessibility provisions; include human rights accessibility principles under AODA regulations.
Strengthen standards: interpret AODA regulated exemptions with regard to the undue hardship standard.
Remove existing barriers: apply barrier identification and removal planning requirements to small organizations and to customer service regulation; include more retrofit requirements.
More transparent enforcement: release aggregate data on compliance status, including barrier removal plans, and enforcement measures taken, by organization class for both AODA and Building Code accessibility provisions; require organizations to also report aggregate data on complaints received.
Broader public profile and support: find more ways including through professional and trade schools and organizations; consult on and apply AODA standards to the needs of people with mental health disabilities and addictions; develop a provincial framework on accessibility.
More new standards: begin seeking input on other priority areas.
If you have any questions about the OHRC’s submission, please feel free to contact me.
Yours truly,
ORIGINAL SIGNED BY
Barbara Hall, B.A, LL.B, Ph.D (hon.)
Chief Commissioner
Copy Hon. Brad Duguid, Minister of Economic Development, Employment and Infrastructure
Hon. Madeleine Meilleur, Attorney General
Jim Sanders, Chair of the Accessibility Standards Advisory Council
David Lepofsky, Chair of the AODA Alliance