FAQs

Information and Communications Standard

Customer Service Standard

Q: Do library student helpers, temporary employees, and volunteers need to be trained in providing accessible customer service?

A: Yes, as of July 1, 2016, under Section 80.49: Training for staff, etc. of the Customer Service Standard, training includes all organization:

  • employees
  • volunteers
  • policy developers
  • any other person who provides good, services, or facilities on behalf of the organization

Q: What’s required to authorize the use of a service animal?

A: Previously, a letter from a physician or nurse was required. As of July 1, 2016, under Section 80.47: Use of service animals and support persons of the Customer Service Standard, there is an expanded list of regulated health professionals who may authorize a service animal, including:

  • psychologists
  • psychotherapists
  • audiologists
  • speech pathologists
  • chiropractors
  • occupational therapists
  • optometrists
  • mental health therapists

Q: Can an organization require a person with a disability to be accompanied by a support person if deemed necessary to protect the health and safety of the person with a disability or of others on the premises?

A: As of July 1, 2016, under Section 80:47: Use of service animals and support persons of the Customer Service Standard, an organization must:

  • consult with the person with a disability and consider the health and safety implications based on available evidence
  • if there is no other reasonable way to protect the health and safety of the person or others on the premises, the presence of a support person may be required
  • where the presence of a support person is required, any applicable admission fee or fare must be waived for that person  

Q: Are any organizations exempt from documenting policies or keeping training records?

A: As of July 1 2016, under Section 2: Definitions of the Integrated Accessibility Standards Regulation’s General requirements, the definition of “small organization” has been changed from fewer than 20 employees to fewer than 50 employees. As such, a private or not-for-profit organization with one to 49 employees is no longer required to document policies or keep training records.

Q: What are current requirements for providing accessible formats and communication supports?

A: As of July 1, 2016, under Section 80.51: Format of documents of the Customer Service Standard, the organization must, on request, provide or arrange for provision of the document, or the information contained in the document in an accessible format or with communication support:

  1. in a timely manner that takes into account the person’s accessibility needs due to disability
  2. at a cost that is no more than the regular cost charged to other persons
  3. by consulting with the person making the request in determining the suitability of an accessible format or communication support

Q: What are some examples of accessible formats and communication supports?

A: Under Section 2: Definitions of the Information and Communications Standard’s General requirements,

Accessible formats (alternatives to standard print) may include, but are not limited to: 

  • large print
  • recorded audio and electronic formats
  • braille
  • text transcripts of audio or visual information

Communication supports (ways to help communication between people) may include, but are not limited to: 

  • captioning
  • alternative and augmentative communication supports
  • plain language
  • sign language

Information and Communications Standard (IASR)

Q: Do the IASR standards provide a standard for document accessibility similar to their use of the WCAG 2.0 as a best practice for web accessibility?

A: Beyond the accessible formats listed above, no accessible document definition or standard is given in the Integrated Accessibility Standards to guide document creation practices. However, the general principles of the Web Content Accessibility Guidelines (WCAG) 2.0 can be adapted to provide best practices for accessible document creation.

Q: What are some common document accessibility issues?

A: Common issues include:

  • use of bolding and font size to indicate headings rather than actual heading styles, making it harder for screen reader users to navigate documents
  • image files in documents lacking alternative text ‘tags,’ so image content cannot be deduced by screen reader users
  • insufficient contrast between text and background, or use of colour combinations individuals who are colour blind find difficult to distinguish
  • scanning a document into a PDF that makes it a ‘flat’ or no-text PDF, containing only image of text as opposed to actual text
    • flat PDFs cannot be accessed by screen reader users

Q: Do we have to provide accessible articles through the library catalogue and journal databases even if they haven’t been requested by a user?

A: Under Section 14: Accessible websites and web content of the Information and Communications Standard:

  • standard is limited to web content organization controls directly or through contractual relationship that allows for modification of product — leaving journal articles and other web-based electronic documents purchased from external vendors outside scope of this section
  • however, Section 5: Procuring or acquiring goods, services or facilities of IASR’s General requirements requires institutions to incorporate accessibility criteria and features when acquiring goods when practicable, so libraries should start thinking about accessibility considerations when purchasing content from software vendors and publishers

Q: What exactly does WCAG 2.0 Level AA require us to do with our website?

A: Visit Web Content Accessibility Guidelines (WCAG) 2.0 website to see guidelines listed under WCAG’s four principles that provide foundation for Web accessibility: 

  • perceivable
  • operable
  • understandable
  • robust

Q: Do documents and videos on electronic reserve and in University Learning Management Systems have to be made accessible under IASR web accessibility requirements?

A: If these resources are behind authentication, this is probably not the case because:

Q: We couldn’t revise our website to meet all the WCAG 2.0 guidelines by January 1, 2012. Should we be concerned?

A: According to Section 14: Accessible websites and web content of the Information and Communications Standard, web accessibility requirements apply only to areas where meeting them is practicable, meaning organizations may consider among other things: 

  • the availability of commercial software or tools or both
  • significant impact on an implementation timeline planned or initiated before January 1, 2012

This may allow a library to cite practicability in deciding not to automatically provide audio description or descriptive transcripts for web-based video because of lack of commercial software or tools for generating them.

Since the definition of practicability in Section 14 is somewhat open-ended, other factors could reasonably be considered as well: 

  • expense
  • staff resources
  • relative importance of document/multimedia content
  • whether content duplicated elsewhere in an accessible format

Ontario Human Rights legislation already includes an Undue Hardship Standard, stipulating that students with disabilities have a right to be accommodated up to the point of undue hardship for the institution; costs are cited as one factor in determining what constitutes undue hardship.

When considering if or how to integrate practicability into your web accessibility policy, it would be important to consult your AODA specialist to ensure that your practices are congruent with University policies.

Q: We’ve never received a request from a student with a disability to provide accessible versions of their course textbooks and training materials. Do we need to create an accessible format course materials service to comply with Section 17: Producers of educational or training material of the Information and Communications Standard?

A: Check your Library Accessibility Service’s alternate format web page, or the AccessAbility Services website for provision of textbooks and training materials for persons with disabilities.

Q: What if a person who is not registered with your University's AccessAbility Services asks for a print, digital or multimedia resource to be made accessible?

A: Immediate concern is verifying disability claim, a good discussion with AccessAbility Services or the AODA specialist.