Accessibility Procedures
Accessibility Procedures
- Introduction
- Morguard Accessibility Officers
- Morguard Compliance Officer
- Assistive Devices and Notification of Temporary Disruptions
- Accessible Public Spaces
- Communication and Interaction
- Service Animals
- Support Persons
- Feedback process
- Notice of Availability of Documents
- Training
- Record Keeping and Reporting
This document provides guidance to compliance with the Morguard Accessibility Plan and Policy by setting out procedures to be followed in generalized scenarios. Morguard employees should familiarize themselves with these procedures, and adhere to them in the applicable scenarios. This document is supplemental to the Morguard Accessibility Plan and Policy and the training provided to every employee pursuant thereto. In no way does this replace or supersede the Morguard Accessibility Plan and Policy or Morguard’s accessibility training. All applicable employees must read the Morguard Accessibility Plan and Policy and should strive to comply with it in spirit and letter. All applicable employees must also undergo Morguard’s accessibility training and adhere to the instructions provided therein.
Morguard’s Accessibility Plan and Policy can be accessed here.
Morguard’s accessibility training module can be accessed through the Morguard Learning Management System, “Pathway to Learning.”
2.0 Morguard Accessibility Officers
Morguard’s Accessibility Officers are tasked with aiding in Morguard’s compliance to the Morguard Accessibility Plan and Policy. Morguard’s Accessibility Officers are responsible for managing e-mail addresses to which feedback will be sent by the public regarding Morguard’s Accessibility Services. They will ensure that appropriate actions are taken in response to feedback, and inform the person who provided feedback of the steps that were taken. Morguard’s Accessibility Officers are:
Todd Febbo
Office/Industrial
T 905-281-5386
E
TFebbo@Morguard.com
John Barclay
Retail
T 905-281-5820
E
JBarclay@Morguard.com
Ruth Grabel
Residential
T 905-281-4864
E
RGrabel@Morguard.com
3.0 Morguard Compliance Officer
Morguard’s Compliance Officer is tasked with maintaining Morguard’s Accessibility Plan and Policy and ensuring continued compliance with the Accessibility for Ontarians with Disabilities Act, 2005 (the “AODA”), the Accessibility Standard for Customer Services (the “ASCS”), and the Integrated Accessibility Standards (the “IAS”). Any internal questions regarding Morguard’s obligations under the AODA, ASCS or IAS, and all feedback from the public regarding Morguard’s Accessibility Plan and Policy generally and/or Morguard’s legal compliance with the AODA, ASCS and IAS should be directed to the Compliance Officer. Morguard’s Compliance Officer is:
Beverley Flynn
T 905-281-5923
E
BFlynn@Morguard.com
4.0 Assistive Devices and Notification of Temporary Disruptions
If an individual is seeking to use an assistive device to gain access to Morguard’s goods or services, Morguard employees will allow that individual to do so. Examples include allowing individuals to use mobility devices to gain access to Morguard properties (e.g. wheelchairs, scooters, walkers, canes, crutches, etc.) or allowing individuals to use speech generating devices to communicate with Morguard employees. This list is by no means comprehensive, and is only provided by way of example. Please refer to the training documents for a more comprehensive list of assistive devices.
Morguard also supplies its own assistive devices at some locations. These primarily include, but are not necessarily limited to, wheelchairs, elevators, escalators, ramps, accessibility stalls in washrooms, and automatic doors at entrances. Employees should make efforts to familiarize themselves with the location of assistive devices provided by Morguard at the site or sites at which they work. Employees should be able to direct persons with disabilities to the location of assistive devices provided by Morguard and instruct them on their use.
If any assistive device or accessibility service is inaccessible or out of order due to an unplanned disruption, and there is no notice explaining the disruption, an employee who notices such situation should inform his or her manager or the individual responsible for providing notices at the location in question, as soon as is practicable. An employee should do the same if he or she receives information regarding disruptions to accessibility services or assistive devices from tenants or the public. If the information is provided to a manager, the manager should then contact the individual responsible for providing notices at the location in question, including as much information as is available about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that are available.
If the individual responsible for providing notices receives information about a disruption to services that lacks all or any of the required information, including the reason for the disruption, its anticipated duration, and/or a description of alternative facilities or services, he/she will use reasonable efforts to determine this information.
In the event of a disruption to accessibility services, whether planned or unplanned, the individual responsible for providing notices will, at minimum, arrange for someone to affix a notice at the entrances to the building or in another appropriate place such that the notice is conspicuous, including the reason for the disruption, its anticipated duration, and a description of alternative facilities or services, if any, that are available. Once full service is restored, he/she should ensure the notice is removed.
Notice should be given on the standard template: “Notice of Disruptions to Accessibility Services”.
All or any of these tasks may be delegated, as appropriate in the circumstances.
Any employee who arranges for an individual to visit a Morguard property, whether in connection with meetings, viewings, or otherwise, should confirm the status of accessibility services at that property, and alert that individual if there are any disruptions to those services.
Morguard is mandated to make certain public spaces accessible when they are newly built or substantially renovated. These spaces include outdoor paths (such as sidewalks), trails, play spaces and outdoor public eating areas; any service counters and waiting areas; and, any parking areas. To ensure that the technical requirements under AODA are achieved for such spaces, any employee involved in the planning, designing, building, or renovating of such spaces shall consult their operational vice-president, or a senior member of the corporate development department prior to undertaking such a project. Morguard also has a duty to properly maintain such accessible public spaces, and thus, if any accessible public space is unavailable, section 4.0 of these procedures should be followed as if such accessible public space were an assistive devise. In such circumstances, alternative accessible public space should be provided, where reasonably possible.
6.0 Communication and Interaction
Please refer to Morguard’s accessibility training for a more comprehensive discussion of communicating with persons with disabilities.
Whenever interacting with a customer or client, be patient, polite, and strive to communicate effectively. Speak directly to persons with disabilities, in a natural and clear manner. Do not interrupt or finish individuals’ statements. If you do not understand what an individual has said, politely ask the individual to repeat it, or rephrase what you heard and ask if you have understood it correctly.
Do not make assumptions about the disabilities an individual may or may not have. If you have any doubts about whether or not you are communicating effectively with an individual, do not hesitate to ask that individual. Allow him or her to provide feedback on your communication, and use best efforts to accommodate any requests for modification.
As much as possible, attempt to treat all customers alike, regardless of their disabilities; strive to recognize the dignity and independence of all individuals, while trying to accommodate their differences. Offer assistance, but do not provide it unless requested. Do not touch or handle an individual or his or her assistive device without first receiving permission from the individual.
If, after numerous attempts, communication between a Morguard employee and a person with a disability is unsuccessful, the employee should use best efforts to communicate to that person that he or she will seek assistance from another employee. The employee should then contact his or her manager, who will either attempt to communicate to that individual, or who will attempt to make alternate arrangements, such as soliciting the help of another Morguard employee who is better able to communicate with that individual. To aid in such efforts, managers should familiarize themselves with their employees’ aptitude for communicating with persons with disabilities, taking note of any special training or experience in that field.
Do not interfere, touch, or interact with service animals; remember that they are working animals, not pets.
Service animals are allowed on all Morguard properties that are open to the public or third parties, where they are not restricted by law. Such restrictions are rare, and are essentially limited to places where food is manufactured and prepared. Service animals are permitted, however, where food is purchased and sold, such as restaurants, food courts, and grocery stores. If an animal is restricted by law, offer to provide the goods or services in a part of the premise where the animal is not restricted. In the alternative, offer a safe location where the service animal can wait, and offer assistance to the person with a disability while he or she is separated from the service animal.
If you have any doubts about whether or not a service animal is allowed access, contact the Morguard Compliance Officer.
Support persons are allowed on all Morguard properties that are open to the public or third parties. When interacting with a person with a disability who is aided by a support person, speak directly to and address that person, rather than the support person.
Morguard’s Accessibility Officers are responsible for maintaining Morguard’s feedback process. They shall provide notice on the Morguard web-site of the existence of our feedback process, including their contact e-mail, as well as the format(s) in which feedback will be accepted. One or more of the following formats for providing feedback will be possible, as appropriate in the circumstances: in person, by telephone, in writing, and by e-mail. If such methods are not suitable, customers may request another format for providing feedback. The Accessibility Officers will use reasonable efforts to accommodate that request, and, in the alternative, will suggest a different format for providing feedback that takes into account the person’s disability.
If an employee is approached with feedback regarding the accessibility of our goods and services, that employee should immediately pass that information on to his or her manager, who should then inform Morguard’s Accessibility Officer.
If the feedback is a complaint, the manager will consider if immediate rectification of the problem is practicable. If practicable, the manager should take such steps as required to rectify the problem. The manager should then pass on the information to the Accessibility Officer, including the nature of the feedback, and what steps if any, were taken to rectify problems. If the problem is rectified, the manager will make reasonable efforts to inform the individual who lodged it.
If immediate rectification is impossible, impractical, or not required, the manager will inform the Accessibility Officer of the feedback. The Accessibility Officer will then determine what steps, if any, should be taken to address the feedback.
Any time a complaint is received and subsequently rectified or addressed by the Accessibility Officer, the Accessibility Officer will make reasonable efforts to inform the individual who lodged it.
The Accessibility Officer will file all feedback and provide it to the Compliance Officer upon request.
The Accessibility Officer may delegate all or any of these tasks as appropriate in the circumstances.
10.0 Notice of Availability of Documents
Morguard’s Compliance Officer will maintain a notice on Morguard’s web-site, informing individuals that the documents required by the ASCS, IAS and AODA are available upon request.
Documents that will be provided upon request include Morguard’s Accessibility Plan and Policy and a description of Morguard’s accessibility training, including a brief description of what it consists of, the dates on which it was provided, and the number of individuals to whom it was provided.
If a person with a disability requests a document that Morguard is required to provide by the ASCS, IAS and/or the AODA, the Compliance Officer will use reasonable efforts to provide the document, or the information contained therein, in the format requested by a person with a disability. If it is not feasible to convert the requested information into that format, Morguard will make reasonable efforts to accommodate the requestor’s needs in a manner that would make such information accessible.
In order to assist in providing these documents in a timely manner, Morguard’s Accessibility Plan and Policy will be maintained in three formats: a Word and/or PDF computer file, a large-text version of the same, and an audio recording.
All applicable employees must complete Morguard’s accessibility training. Morguard’s accessibility training consists of a review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005 the purpose and requirements of the Accessibility Standards for Customer Service, the Morguard Accessibility Plan and Policy, and these procedures. Specific instruction is provided on communication, assistive devices, service animals, support persons, and addressing difficulties in accessing Morguard’s goods and services. Morguard’s accessibility module can be accessed through the Morguard Learning Management System.
HR is tasked with maintaining a list of positions for which accessibility training is required and ensuring all individuals in such positions have received training.
12.0 Record Keeping and Reporting
Morguard’s Compliance Officer is responsible for all reporting as required by the AODA and the accessibility standards enacted pursuant thereto.
Specific requirements include:
- Maintenance and revision of Morguard’s Accessibility Plan and Policy and these procedures;
- Maintenance and revision of Morguard’s accessibility training, including a brief description of what it consists of, the dates on which it was provided, and the number of individuals to whom it was provided.
- Creation of the annual AODA report, ensuring that it is certified by a director, and submission to ONe-key Ontario by the required dates
- Creation of the annual AODA report, ensuring that it is certified by a director, and submission to ONe-key Ontario by the required dates