Barrier Free Canada – Canada sans Barrriès is a national non partisan grass roots organization. We were founded in November 2014 with the mission to lobby the Canadian Government to enact legislation for a barrier free Canada.
Our main objective is to enable all Canadians with a disability, their friends, family, and associates to be able to speak up, speak out, and reach out! We’re working on ensuring that standards and regulations actually remove and prevent barriers. We believe in collaboration, communication, and cooperation among all stake holders and we do this through our efforts on social media, through coast to coast zoom conferences and tele town halls, and through face to face meetings if and whenever feasible.
On behalf of Barrier Free Canada, please accept our submission in response to the publication of the draft Canadian Radio-Television and Telecommunications Commission (CRTC) Accessibility Reporting Regulations.
The regulations outline that the plan must include information on how the company has identified, removed and prevented barriers in a number of areas.
It is very concerning however that the regulations do not specify the need for companies to identify concrete actions and timelines to remove barriers in either the accessibility plan and the progress report. This should be explicitly required in the regulations.
Accessibility plans should also include the identification of an individual within the organization assigned to ensure the removal of the barriers as well as the timelines under which the barriers will be removed.
In addition to outlining how the company consulted with persons with disabilities in the development of the accessibility plan, the regulations should also outline how the input received from these consultations was used to inform the accessibility plan. This is particularly important should consultations identified concrete barriers for which the company is not moving forward to remove them.
In the regulations, companies are only required to publish their most recent accessibility plan and progress report. In order to promote transparency and the measurement of progress, all plans and reports should be retained in the same digital platform as the most recent report and plan.
The CRTC´s draft regulations specify when accessibility plans should be published, with deadlines of June 1, 2023 and June 1, 2024 depending on the size of the company. After these deadlines, a progress report is required each year.
The timelines outlined in the draft regulations are simply too long, with 2 to 3 years being unnecessarily long to develop and publicize an accessibility plan. It is important to note that the plan does not need to resolve any actual accessibility barriers, but rather speak to how the company plans to do so. We believe that a deadline of June 1, 2022 is reasonable for all companies to publish their accessibility plan, recognizing that the true work or identifying, removing and preventing barriers should not be delayed further.
The regulations further specify the need for companies to create feedback processes to allow Canadians to give companies feedback about their accessibility. The timelines identified for the publication of these processes is also unnecessarily long, and suggest a deadline of June 1, 2022 for all organizations to comply.
The regulations are silent on what companies are to do with feedback received. It is recommended that the regulations outline what companies are expected to do with the feedback received. At a minimum, all feedback should be made publicly available on the website of the company within 10 business days (while removing all personal information), along with the company´s response to the feedback. This is particularly important given the Accessible Canada Act requirement to consult persons with disabilities, which should not be limited to the development of the Accessibility Plans but extend in the implementation of the plans.
While we are pleased to note the inclusion in the regulations that a company must make its accessibility plan, feedback processes, progress report available in alternate formats, it is very concerning that there are no service standards required for this. It is requested that 10 business days be identified as the service standard for which alternate formats will be made available to ensure that companies develop these alternate formats in advance of any request.
Use of Clear, Simple and Concise Language
Where the use of clear, simple and concise language is noted for the various publications outlined in the regulations, it is requested that this be replaced with plain language in order to be consistent with the work underway within Accessibility Standards Canada to develop a standard on plain language.
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