Accessibility Policy

1. Purpose

This policy establishes clear guidelines and expectations for staff to ensure consistent, compliant, and accountable delivery of accessible services and a barrier‑free workplace. It aligns with the Fort Erie Public Library Board’s mission, values, and legal obligations under the Accessibility for Ontarians with Disabilities Act (AODA) and the Ontario Human Rights Code.

2. Scope

Applies to all employees, volunteers, contractors, interns, and any person acting on behalf of the Fort Erie Public Library Board (the Library) while performing duties within the Library’s authority, irrespective of work location.

4. Definitions

• Accessible Communication Supports - Tools or methods that help people understand information, such as captions on videos, sign‑language interpretation, easy‑to‑read (plain‑language) documents, picture boards, speech‑to‑text software, or any other aid that makes communication clearer for someone with a disability.
• Accessible Formats - Versions of a document or piece of content that are designed so people with disabilities can use them. Examples include large‑print paper, audio recordings, electronic files that work with screen‑readers (tagged PDFs, HTML), Braille, and any other format that a person can read, hear, or interact with comfortably.
• Disability - Any physical, mental, sensory, or developmental condition that makes it harder for a person to do everyday activities. This includes visible conditions (like blindness or the need for a wheelchair) and invisible ones (such as learning differences, chronic pain, anxiety, or autism). Disabilities can be permanent, temporary, or fluctuate over time. Information about any person’s disability is personal and private and must be treated confidentially.
• Internet Website - A collection of web pages, images, videos, or other digital material that anyone on the public internet can visit.
• Intranet Website - A private set of web pages that only people inside the organization (staff, volunteers, contractors) can access. It’s used for internal information, tools, and collaboration.
• Medical Aid - means an assistive device including respirators and portable oxygen supplies.
• Mobility Assistive Device - a cane, walker or similar aid.
• Personal Assistive Devices - any aids including communication, cognition, and personal mobility, medical or technical aids that are used to increase, maintain, or improve the functional abilities of persons with disabilities. Assistive devices include, but are not limited to: wheelchairs, walkers, speech synthesizers, TTYs (Telephone Typewriters or Telephone Teletypes), computer technologies, canes and hearing devices.
• Performance Management - activities related to assessing and improving staff performance, productivity and effectiveness, with the goal of facilitating staff member success.
• Redeployment - the reassignment of a staff member to another job within the Library as an alternative to layoff, when a particular job has been eliminated by the Library.
• Reasonable accommodation - any adjustment or modification that allows an employee with a disability to perform the essential duties of their job, without causing undue hardship to the library.
• Service Animal - An animal that a person with a disability relies on to perform tasks related to that disability (for example, a guide dog that helps a blind person navigate). The animal is not a pet; it is trained to provide a specific service. Documentation from a qualified health professional may be requested to confirm the animal’s role.
• Support Person - Someone who accompanies a person with a disability to help with communication, mobility, personal care, or accessing services. This could be a family member, friend, interpreter, caregiver, or any individual the patron chooses to assist them.
• WCAG 2.1 Level AA - internationally recognized standards developed by the World Wide Web Consortium (W3C) to ensure that digital content is accessible to all users, including those with disabilities.

4. Policy Statement

The Library is committed to providing an inclusive workplace that meets or exceeds AODA standards. All staff members have the right to work in an environment that accommodates their disability‑related needs, protects their privacy, and promotes equal opportunity for career growth.

All staff must:

• Provide Accessible Services - Deliver information, resources, and assistance in accessible formats or with appropriate communication supports upon request.
• Maintain Confidentiality - Treat all disability‑related information as confidential and share it only with personnel directly involved in implementing accommodations.
• Participate in Training - Complete mandatory accessibility awareness training within the first month of employment and refresher training every three years.
• Support Emergency Preparedness - Ensure emergency procedures, plans, and safety information are available in accessible formats and that individualized emergency response plans are developed when needed.

Multi-Year Plan

The Fort Erie Public Library Board and the Chief Executive Officer (CEO) will draft and make public a Multi-Year Accessibility Plan. The CEO will make public annual progress reports outlining steps taken to meet the goals and objectives of the Multi-Year Plan. The Multi-Year Accessibility Plan will be made public within 30 days of Board Approval, and the annual progress report will be posted by January 1 of each year.

Recruitment & Selection

The Library will provide accommodations in its recruitment process upon request. The Library will be transparent about the availability of accommodations for applicants with disabilities in its screening and interview processes. Information such as accessibility of the interview location, plain text job description, and relevant policies will be proactively provided to all candidates.

• Accessible Job Advertisements - All job postings will be posted in accessible formats (e.g., plain‑language text, tagged PDFs) and will include a statement inviting candidates to request accommodations during the application process.
• Accommodation Request Process - Applicants may request accommodation at any stage of recruitment by contacting HR (email access@fepl.ca). Requests will be acknowledged within 2 business days and handled confidentially. Requests may be anonymized and aggregated for reporting purposes.
• Interview Accommodations - Interview locations will be physically accessible. If a candidate requires assistive technology, a sign‑language interpreter, or extra time, the interview panel will arrange these supports prior to the interview date.
• Selection Criteria Transparency - Selection criteria will be posted with each vacancy and explained in plain language. Any essential functions will be clearly identified, and reasonable adjustments may be made to enable candidates to demonstrate their abilities.
• Offers of Employment - The Library will notify successful applicants of its policies for accommodating staff with disabilities when making offers of employment.

Onboarding & Orientation

• Accessibility Orientation - New hires receive a brief session on workplace accessibility policies and how to request accommodations.
• Assistive‑Technology Setup - IT will coordinate with the employee to install screen‑readers, magnification software, alternative input devices, or any other required tools before the employee’s start date.
• Mandatory Training - All staff and volunteers that are in direct contact with patrons shall be trained in the various aspects of accessible customer service delivery and integrated accessibility standards within 30 days of their start date. This training will be repeated every three years.

Ongoing Employment

The Library will provide supports for staff and volunteers. We will notify staff of our policies, including those for providing accommodations. Staff will be provided with updated information when there is a change to existing policies.

To ensure we provide appropriate support, any staff member needing an accommodation must formally request it through our standard process. These supports will be provided in a reasonable timeframe after the request is received.

Examples of supports include:

Workplace Emergency Response Information

Workplace Emergency procedures, plans and safety information will be available in an accessible format or via accessible communication support.

Staff or volunteers with disabilities who may require additional help in an emergency are encouraged to identify their accessibility needs to their supervisor so that an Individualized Emergency Response & Accommodation Plan can be created. This information will remain confidential.

Accessible Formats and Communication Supports for Staff

The Library will ensure all workers have information that is needed to perform their duties; as well as information that is generally available to staff in the workplace.

Request Process

When a staff member with a disability requests accessible formats or communication supports, Management will consult with the staff member and provide or arrange for suitable accommodation. The process and accommodations will be documented and placed in the employee’s HR file. Reasonable accommodations will be put into effect as soon as feasible, generally within ten business days after a mutually agreed‑upon solution has been identified. Each accommodation will be reassessed on an annual basis, or sooner if the employee’s circumstances evolve, to confirm that it remains effective and appropriate.

Performance Management & Career Development

• Equitable Evaluation - Managers will assess performance based on the employee’s actual duties and the accommodations in place, ensuring that disability‑related factors do not unfairly affect ratings.
• Training & Promotion - All training programs, workshops, and promotional pathways will be offered in accessible formats. Employees requesting accommodations for these activities will receive them promptly.

Leave & Return to Work

• Sick/Medical Leave - Employees may use sick leave, short‑term disability, or other statutory leaves without penalty.
• Return‑to‑Work Plans - When an employee returns after a disability‑related absence, a written “Individualized Return‑to‑Work Accommodation Plan” will be co‑developed, detailing any temporary or permanent adjustments needed.
• Early & Safe Return to Work Compliance - When a mutually agreed upon plan is in place, the organization will follow the procedures set out in Ontario’s Early and Safe Return to Work legislation, ensuring that any modified duties, gradual hour programs, or workplace adjustments comply with the Act and its regulations.

Harassment, Discrimination, and Grievance Procedures

• Zero‑Tolerance Policy - Harassment or discrimination based on disability is prohibited.
• Reporting Mechanism - Employees can report concerns to their manager, HR, or the JH&SC. Confidential investigations will commence within 5 business days.
• Protection from Retaliation - Anyone who files a complaint or participates in an investigation is protected from retaliation.

Training

• Mandatory Accessibility Training - All staff (including volunteers and contractors) must complete an initial accessibility awareness module within the first month of hire and a refresher every three years.
• Specialized Training for Managers - Supervisors receive additional instruction on how to handle accommodation requests, conduct confidential discussions, and evaluate performance fairly, as well as the Library’s obligations under the Ontario Human Rights Code.

All training shall cover:

• An overview of the purposes of the AODA;
• An overview of Accessible Customer Service and Integrated Accessibility Standard requirements;
• Instruction on how to interact and communicate with patrons with various types of disabilities, including provision of alternate formats;
• Instruction on interacting with patrons with disabilities who use assistive devices or require the assistance of a Service Animal or a Support Person;
• Overview of the Library’s obligation to provide information in alternate formats and alternate communication supports upon request including:
• Review of different types of alternate formats;
• Review of alternate communication supports (sign language, gestures, boards with symbols, voice-synthesizers, etc.);
• Review of the Library’s alternate format service provider and process relating to securing information in alternate formats;
• Review of system used to request alternate formats;
• Instruction on what to do if a patron with a disability is having difficulty accessing Library services.

5. Responsibilities

• Board of Directors - Oversees overall compliance and approves policy updates.
• Chief Executive Officer (CEO) - Ensures enforcement, allocates resources, and publishes the Multi-Year Accessibility Plan and annual progress reports.
• Managers / Supervisors - Communicate expectations, facilitate accommodation requests, monitor adherence, and ensure staff receive required training.
• Staff - Follow the policy, request accommodations through the established process, and report any violations or barriers promptly.

6. Compliance & Consequences

Failure to comply with policy, or discrimination against employees receiving accommodations may result in disciplinary action up to and including termination, proportionate to the seriousness of the breach. All reports of non-compliance will be investigated promptly in line with the Library’s disciplinary procedures, and outcomes will be documented.

7. Communication

This policy will be distributed to all applicable parties via Rise. An updated copy of the Policy Manual will be located in Sharepoint and at the circulation desk. Updates will be communicated in a timely manner.

8. Related Documents

• Occupational Health and Safety Act
• Accessibility for Ontarians with Disabilities Act
• Workplace Safety and Insurance Act
• Employment Standards Act

9. Anticipated Review Date

This policy will be reviewed annually by the Chief Executive Officer unless there are changes to relevant legislation, in which case the policy will be reviewed immediately to ensure compliance. The next scheduled Board review is June 2027.