Accessibility for Ontarians With Disabilities Act Policies

Accessible Customer Service

The purpose of this policy is to outline responsibilities of employees, volunteers and others who deal with the public or other third parties on behalf of Crawford Packaging in providing goods and services to people with disabilities in compliance with the Accessibility for Ontarians with Disabilities Act 2005 (AODA).

1. Principles

We will endeavor to ensure that policies and related practices and procedures are consistent with the following four (4) core principles:

Dignity Persons with a disability must be treated as valued clients as deserving of service as any other customer.

Equality of Opportunity – Persons with a disability should be given an opportunity equal to that given to others to obtain, use and benefit from our services.

Integration – Wherever possible, persons with a disability should benefit from our services in the same place and in the same or similar manner as any other customer.

In circumstances where integration does not serve the needs of the person with a disability, services will, to the extent possible, be provided in another way that considers the person’s individual needs.

Independence – Services must be provided in a way that respects the persons independence. To this end, we will always be willing to assist a person with a disability but will not do so without the express permission of the person.

2. Providing Goods and Service to People with Disabilities

We are committed to excellence in serving all customers including people with disabilities. This commitment is demonstrated in the areas of:

Communication – We communicate with people with disabilities in ways that take into account their disability and train our employees to do so.

Telephone Services – We train staff to communicate with customers over the telephone in clear and plain language and to speak clearly and slowly.

Assistive Devices – We are committed to serving people with disabilities who use assistive devices to obtain, use or benefit from our goods and services. We ensure that our employees are trained and familiar with various assistive devices that may be used by customers.

Billing – We are committed to providing accessible invoices to all our customers. Invoices will be provided in an alternative format upon request. We will answer any questions customers may have about the content of the invoice in person, by telephone or email.

Use of Service Animals – We are committed to welcoming visitors who are accompanied by a service animal on the parts of our premises that are open to the public and other third parties. We will also ensure that all employees, volunteers and others dealing with the public are properly trained in how to interact appropriately with a service animal.

Use of Support Persons – We are committed to welcoming visitors who are accompanied by a support person. At no time will a person with a disability who is accompanied by a support person be prevented from having access to his or her support person while on our premises.

Accessibility – Our Crawford Packaging offices are wheelchair accessible and have wheelchair accessible washrooms; staff must be aware of wheelchair accessible washrooms, so they can direct/assist those that require a wheelchair to the nearest accessible washroom.

3. Notice of Disruption

We provide customers with notice in the event of a planned or unexpected disruption regarding access to our facilities. This notice will include information about the reason for the disruption, its anticipated duration, and a description of alternative facilities or services if available.

4. Our Responsibilities

  • Ensuring compliance with the Ontario Regulation 429/07, Accessibility Standards for Customer Service;

  • Including accessibility in annual planning processes;

  • Ensuring all employee attendance at required training;

  • Providing notification of service disruptions;

  • Providing all documentation in appropriate formats upon request by a person with a disability;

  • Monitoring the progress of legislative requirements to ensure compliance;

  • Communicating all policies, procedures and practices to employees;

  • Coordinating and providing Accessible Customer Service training to comply with Ontario Regulation 429/07, Accessibility Standards for Customer Service;

  • Coordinating and maintaining training records;

  • Establishing and maintaining an ongoing training program to ensure all employees are trained in providing Accessible Customer Service as part of the corporate orientation process

5. Employee Training

We provide training to all employees, volunteers and others who deal with the public or other third parties on our behalf.  Training is developed and delivered in various formats.

Training includes the following:

  • The purposes of the Accessibility for Ontarians with Disabilities Act, 2005 and the requirements of the customer service standard.

  • How to interact and communicate with people with various types of disabilities.

  • How to interact with people with disabilities who use an assistive device or require the assistance of a service animal or a support person.

  • How to learn about the use of various assistive devices.

  • What to do if a person with a disability is having difficulty in accessing our goods and services

All employees will be trained on policies, practices and procedures that affect the way goods and services are provided to people with disabilities.

Employees will also be trained on an ongoing basis when changes are made to these policies, practices and procedures.

6. Training Documentation

Records of the training provided, including the training protocol, the dates on which the training is provided and the number of individuals to whom the training is provided will be maintained in accordance with the requirements of the Act.

7. Feedback Process

We have a goal of meeting and exceeding customer expectations while serving customers with disabilities. Comments on our services regarding how well those expectations are being met are welcome and appreciated. A Customer Feedback Form is available from our Customer Service department and can be emailed, mailed, or faxed as requested. The form can also be obtained in person by arranging an appointment. All feedback will be directed to Human Resources for review. Customers can expect to hear back within ten (10) business days.

AODA – Integrated Accessibility Standards Regulation (IASR) Employment Policy


This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of accessible employment services for persons with disabilities.

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


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

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, and other supports that facilitate effective communications.

Performance Management – Activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success.

Redeployment – The reassignment of employees to other departments or jobs within the organization as an alternative to layoff whenever possible.

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following:

  1. General Requirements

  2. Recruitment, Assessment and Selection

  3. Accessible Formats and Communication Supports for Employees

  4. Workplace Emergency Response Information

  5. Documented Individual Accommodation Plans

  6. Performance Management and Career Development and Advancement

  7. Return to Work

  8. Redeployment

  9. Review

1. General Requirements

General requirements that apply across all of the five (5) standards (information and communication, employment, transportation, design of public spaces, and customer service) are outlined as follows.

Establishment of Accessibility Policies and Plans

Crawford Packaging will develop, implement and maintain policies governing how it will achieve accessibility through these requirements.

Crawford Packaging will include a statement of its commitment to meeting the accessibility needs of persons with disabilities in a timely manner in its policies. These documents will be made publicly available in an accessible format, upon request.

Crawford Packaging will establish, implement, maintain and document a multi-year accessibility plan outlining its strategy to prevent and remove barriers and meet its requirements under the IASR. Accessibility plans will be made available in an accessible format, upon request, and will be posted on our website once completed.

Crawford Packaging will review and update its accessibility plan once every five (5) years. Annual status reports will be prepared that will report on the progress of the steps taken to implement Crawford Packaging’s accessibility plan. If requested, the report shall be created in an accessible format.

Crawford Packaging will incorporate accessibility criteria and features when procuring or acquiring goods, services or facilities whenever possible.

Training Requirements

Crawford Packaging will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Crawford Packaging’s policies, and all other persons who provide goods, services or facilities on behalf of Crawford Packaging.

Training will be provided during an employee’s new hire orientation. Training will also be provided on an ongoing basis as changes to Crawford Packaging’s accessibility policies occur.


Crawford Packaging will maintain records on the training provided, when it was provided and the number of employees that were trained.

2. Recruitment, Assessment and Selection

Crawford Packaging will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, Crawford Packaging will consult with the applicant and provide or arrange for suitable accommodation.

Successful applicants will be made aware of Crawford Packaging’s policies and supports for accommodating people with disabilities.

3. Accessible Formats and Communication Supports

If an employee with a disability requests it, Crawford Packaging will provide or arrange for the provision of accessible formats and communication supports for the following:

  • Information needed in order to perform his/her job; and

  • Information that is generally available to all employees in the workplace.

  • Crawford Packaging will consult with the employee making the request to determine the best way to provide the accessible format or communication support.

Crawford Packaging will ensure that our website and all web content published after January 1, 2012, conform to the Web Content Accessibility Guidelines (WCAG) 2.0 and will refer to the schedule set out in the IASR for specific compliance deadlines.

4. Workplace Emergency Response Information

Where required, Crawford Packaging will create individual workplace emergency response information for employees with disabilities. This information will take into account the unique challenges created by the individual’s disability and the physical nature of the workplace and will be created in consultation with the employee.

This information will be reviewed when:

  • The employee moves to a different physical location in the organization;

  • The employee’s overall accommodation needs, or plans are reviewed; and/or Crawford Packaging reviews general emergency response policies.

5. Documented Individual Accommodation Plans

Crawford Packaging must also develop and have in place written processes for documenting individual accommodation plans for employees with disabilities. The process for the development of these accommodation plans should include specific elements, including:

  • The ways in which the employee can participate in the development of the plan;

  • The means by which the employee is assessed on an individual basis;

  • The ways that an employer can request an evaluation by an outside medical expert, or other experts (at the employer’s expense) to determine if accommodation can be achieved, or how it can be achieved;

  • The steps taken to protect the privacy of the employee’s personal information;

  • The frequency with which the individual accommodation plan should be reviewed or updated and how it should be done;

  • The way in which the reasons for the denial of an individual accommodation plan will be provided to the employee; and

  • The means of providing the accommodation plan in an accessible format, based on the employee’s accessibility needs.

The individual accommodation will also:

  • Include information regarding accessible formats and communication supports upon request;

  • Where needed, include individualized workplace emergency response information; and

  • Outline all other accommodation provided.

6. Performance Management and Career Development and Advancement

Crawford Packaging will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities.

7. Return to Work

Crawford Packaging will develop and implement return to work processes for employees who are absent from work due to a disability and require disability- related accommodation(s) in order to return to work.

The return to work process will outline the steps Crawford Packaging will take to facilitate the employee’s return to work and shall use documented individual accommodation plans (as described in section 28 of the regulation).

8. Redeployment

The accessibility needs of employees with disabilities will be taken into account in the event of redeployment.

Individual accommodation plans will be consulted, as required.

9. Review

This policy will be reviewed regularly to ensure that it is reflective of Crawford Packaging’s current practices as well as legislative requirements.

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