Home Employment Accessibility Standard

Employment Accessibility Standard

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• Introduction
• Employment accessibility standard
• Recruitment and hiring
• Accessibility at work
• Making the organization inclusive

Introduction

What is a standard?

A standard is a set of rules or guidelines. The Employment Accessibility Standard provides guidance on how to remove barriers for people with disabilities across the whole continuum of employment including hiring, training, retention and accommodations. These recommendations aim to support employers to develop inclusive work environments. After the Provincial Accessibility Committee finishes this standard, it will recommend the standard to the government.

B.C. Human Rights Code: In British Columbia (B.C.), the Human Rights Code prevails over other laws. The standards being developed would be in addition to the B.C. Human Rights Code

Who would the standard apply to?

The Provincial Accessibility Committee is an advisory committee to government. Part of its role is to develop and recommend accessibility standards. Government is responsible for deciding which recommendations should apply to which organizations.

Making our communities more accessible, inclusive and equitable is important for all of us. Generally, the Provincial Accessibility Committee believes that all organizations in B.C. have a role to play to help make our province more inclusive and accessible. The committee also believes that many of the recommendations in this document make sense for a range of types of organizations. They also recognize that some of these recommendations may not be appropriate for all organizations. The Provincial Accessibility Committee will use the feedback from people and organizations to inform its recommendations to government.

When will organizations need to comply with the standard?

Some of the elements of the standards may be simple and quick to implement but other elements may take more time. The Provincial Accessibility Committee is interested in phasing the requirements of the standards and believes that most or all organizations could become compliant within about two years from when a regulation comes into force. The Provincial Accessibility Committee is interested in understanding which elements of the standard could be done faster and which might take longer.

What are the next steps?

The input from this engagement will be used to help shape the standards that the Provincial Accessibility Committee will recommend to the Minister responsible for accessibility in 2025. Government will then decide whether to turn some or all of these recommendations into regulations.

Reconciliation

Accessibility standards will benefit all people in British Columbia including Indigenous Peoples. Indigenous Peoples are more likely to experience a disability. They may also face unique barriers that can magnify exclusion.

Indigenous Peoples and partners provided feedback during the development of the first two accessibility standards.

From these conversations, we have learned that many parts of the standard align with cultural beliefs of trusting and valuing the lived experience of others. We have also learned that standards may benefit those who have experienced trauma and the harms of colonialism.

There will be more opportunities for Indigenous Peoples and partners to provide feedback, including on the draft regulations.

Intersectionality

The standards recognize that the same barrier may be experienced differently by people based on their identity factors. Multiple forms of discrimination such as racism, sexism, ableism and homophobia may be active at the same time in a person’s life. When these types of discrimination intersect, they can compound the barriers a person faces.

Employment Accessibility Standard

The Provincial Accessibility Committee is proposing standards in 19 different topic areas.

What are accommodations?

Accommodations are adjustments that remove a barrier for a person with a disability

Some examples of accommodations are:

• Flexible work hours
• Work from home
• Accessible door openers
• Equipment such as screen reading software, ergonomic chairs or specialized keyboards
• ASL interpretation

Recruitment and hiring

Job description and profiles

Employers let people know about job opportunities in lots of different ways. This standard wants to make sure that job applicants with disabilities can decide if an employer will be inclusive and accessible for them.

Employers must make sure that job descriptions, profiles or public documents advertising jobs include links to the measures they are taking as part of the policies and practices section of this standard.

Example

A retail store welcomes applications from all backgrounds. They state on their career webpage:

We support a diverse workforce and encourage inclusion in the workplace. We welcome applications from people from all backgrounds. If you are an applicant with a disability that requires a reasonable accommodation during the recruitment process you can contact our accessibility representative at the email or number posted below. Our inclusion, diversity, equity and accessibility policy is on our website with more information.

Recruiting employees

Sometimes there are barriers for people with disabilities during the recruitment process.

During recruitment, employers need to let applicants know that reasonable accommodations are available for people with disabilities during all stages of the recruitment and selection process as well as in the role. When the employer lets applicants know that accommodations are available, they need to explain that asking for an accommodation will not impact whether the person gets the job. The employer also needs to share a list of ideas of accommodations.

If an applicant asks for an accommodation, the employer must

• Discuss and do their best to meet the needs of an accommodation
• Not request proof of a disability from an applicant

If the employer cannot provide an accommodation that was requested they need to record it as outlined in the Documentation section.

Example

Ted wants to apply for a job posting at a local college. Ted prefers to interview in person so that they can lipread. Ted was informed by the college during the application process that they can request an accommodation throughout the entire recruitment process. Ted contacts the college and makes the accommodation request. The college can provide the accommodation and makes sure all steps in the recruitment process are in person for Ted.

Accessibility at work

Onboarding

Organizations have different approaches to onboarding. Onboarding and orientation may range from a very short orientation to an extensive training program that immerses the employee in their new workplace.

Employers must:

• Make sure they take reasonable steps to provide an accommodation in a timely manner to an employee if requested
• Make sure that all essential communication about onboarding is consistent with the section on communications

If onboarding materials are already accessible because of an accommodation request, then these should be made available to all staff.

Examples

Antoine was recently hired at a technology organization as a data analyst. To complete their job efficiently, they have requested a larger screen. The larger screen allows Antoine to use magnification software for optimal job performance. The organization complied with Antoine’s request and provided them with a larger screen within the first few days of their employment.

Carrie has started work at a factory. The first day, there is a health and safety briefing. The briefing is provided both verbally and through a large print handout.

Communications

Employers communicate with their employees through meetings, letters, emails and informally. This standard topic seeks to make sure that employers provide timely information and communications that is accessible to all staff within the workplace and work environment.

Employers must make sure all essential communication:

• Is in a variety of formats including alternatives for auditory and visual information
• Is compatible with a variety of assistive devices
• Has any provisions for privacy, security and safety of communication equally available to all employees

Employers need to make sure essential communication can be changed by the employee. For example, an employee can make the font bigger in an email, repeat a section of a video or ask someone to repeat part of an essential presentation.

When an employee asks an employer for an accommodation in communication, an employer must:

• Provide communication materials in the requested accessible format if reasonably able to do so
• Provide accessible communication in a timely manner
• Make sure any communication that is changed into an accessible format has the same message and meaning as the original communication
• Work with the employee to make sure that the accessible format provided is suitable
• Make sure the employee receives further communication in the requested format
• Follow the Documentation sections if they cannot reasonably accommodate an employee’s communication preferences

If essential communication is made more accessible, then the accessible version should be made available to everyone.

Example

A call center has created a new emergency response plan. Fiona, an administrative officer, has been tasked with communicating the new plan out to the employees. To inform staff of the new emergency plan, Fiona has released the plan:

• In multiple media forms including written, spoken and video
• In a variety of ways such as posters around the office, an all-staff email and an online or in-person lunch and learn session.

An employee requested a large-print version of the plan, Fiona made sure to let everyone know that a large-print version was available.

Training

Sometimes training in the workplace creates barriers for people with disabilities. For example, a video without captions might not be accessible to a Deaf person. Employers need to make sure that barriers in training and education opportunities are identified, removed and prevented.

Employers need to offer accommodations to employees for training. If training is made more accessible because someone asks for an accommodation that accommodation should be made accessible to all employees. For example, if an employee requests training is made available in a Braille Ready Format (BRF), then the BRF file should be made available to all employees. This means that people with disabilities will not need to ask for accommodations if something already includes them.

Any new training that the employer buys or creates and any training that the employer says that people have to take needs to be inclusive. This means that this training is:

• In a variety of formats including alternatives for auditory and visual information
• Compatible with a variety of assistive devices

Employers need to make sure that this training can be changed by the employee. For example, an employee can make the font bigger in an email, repeat a section of a video or ask someone to repeat part of an essential presentation.

Example

Fatima does not require an accommodation for their daily job duties, but cannot understand training if the person speaks too fast. They have requested accommodations during training periods from their employer. The employer has made sure that Fatima has a written version of the training. All the other employees attending the training can also get this written version.

Physical and digital tools and technology

Every workplace is different and different equipment, tools and technology are needed to do different jobs. A tool or technology could include a hammer, scissors, a computer, a point-of-sale machine or a computer program.

To the point of undue hardship, employers need to identify, remove and prevent barriers to accessibility in all existing tools, technology, artificial intelligence (AI), information systems and equipment that employees are required to use. Where it is possible, employers should provide alternatives so employees can have a choice of tools and technology.

Employers need to make sure that any accessibility features of tools and equipment can be turned on by any employee. When they are buying new tools, employers need to think about accessibility.

Some tools and technology are used in recruiting and managing employees. These tools should not be discriminatory.

Example

An accounting firm is deploying new AI tools for hiring and talent management. The algorithm for recruitment includes data on their current top performers. The firm is aware of biases in AI, so they make sure that the algorithm does not exclude candidates who, for example, attended women’s colleges or have interruptions in their work history, which excludes people who have taken leave such as medical or parenting leave.

What is artificial intelligence?

Artificial intelligence generally means that a computer is completing a task that is usually done by a person—for example, recognizing facial expressions during a video interview.

An algorithm is a set of steps for a computer to accomplish a task—for example, searching for certain words in a group of resumes. 

Workplace emergency response

Sometimes there can be barriers in the workplace for a person during emergencies.

When employers plan for emergencies, they need to:

• Plan how to remove barriers for employees with disabilities in all elements of the workplace
• Identify different ways of letting people know there is an emergency, like alarms with flashing lights for people who are Deaf
• Think about people with different kinds of disabilities and what they need in emergencies
• Work together with employees with disabilities

Emergency planning must go beyond leaving people with a disability in refuge areas. This could include but is not limited to: investigating other options for evacuation, establishing a communication protocol to ensure that emergency responders are alerted or placing equipment in refuge areas to support people during an emergency.

Employers must make sure they ask new employees whether they will need individual accommodations during a workplace emergency. If an employee needs accommodations in an emergency, then the employer must:

• Work with the employee to create an emergency plan
• Make sure the plan remains confidential unless it needs to be shared with other employees to carry out the plan
• Follow the Documentation and Evidence sections of this standard if they cannot reasonably accommodate an employee’s emergency planning preferences

Example

Ingrid started at new job at a local distribution company. During the onboarding process, their supervisor reviewed the company’s fire safety plan with Ingrid. The fire safety plan uses audible alarms. This creates a barrier for Ingrid. The supervisor and Ingrid agree to develop an individual emergency plan for Ingrid. This plan would have designated employees alert Ingrid to a fire alarm when sounding. Ingrid consents to sharing their emergency plan with the employees who will assist them.

Stay at work/return to work

What are stay-at-work/return-to-work plans?

Stay-at-work plans are tools for managers to proactively help ill or injured workers, or workers who acquire a disability, remain in productive employment in a timely and safe manner

Return-to-work plans are proactive tools for managers to help injured and, where appropriate, ill workers, as well as workers with disabilities, return to work after an absence if it is safe to do so

Sometimes an employee might be injured or have a medical condition that means they might need some extra support to stay at work or they might need to take time off work and return to work later.

The standards would ask employers to have a policy about stay-at-work/return-to-work procedures. The policy needs to include employees with disabilities and needs to note that that different situations need different solutions and timelines. The policy also needs to explain how:

• Employers and employees will work together to develop an individual plan that meets the employee’s needs
• Unions will be included, where the workplace is unionized
• Individual plans can be adjusted and reviewed
• The employee can let the employer know how best to communicate if they are away from the workplace
• Being away from the workplace will not affect access to advancement opportunities

The employer needs to share the stay-at-work/return-to-work policy with all employees. Managers and supervisors need to have training on the stay-at-work/return-to-work policy, so they know how to follow the policy.

The individual stay-at-work plan needs to:

• Support employees to let the employer know if their accommodation needs change
• Identify support for the employee
• Acknowledge that employees might need to take time off work
• Use individual accommodation plans as described in the accommodation section where needed

The individual return-to-work plan needs to:

• Identify support for the employee
• Let employees know when and how communications will occur
• Let employees know about changes that have happened in the workplace and any support provided to adjust when the employee comes back to work
• Use individual accommodation plans as described in the accommodation section where needed

Example

Don has been off work for over a month due to medical complications. They’re returning to work next week and require a temporary accommodation in the form of a modified work schedule. Don’s supervisor has worked with them to develop a return-to-work plan that recognizes their accommodation needs. For the first four weeks, Don will work a modified work week and then add more work hours over the following weeks until they can return to their full work schedule.

Redeployment

Some employers have a policy or process that describes when and how employees might need to work in a different role or location. For this standard, we have described this as a redeployment policy or process.

Employers who have a redeployment policy or process must make sure it includes:

• The needs of employees with disabilities
• How individual accommodation plans will be followed
• How employees, and union representatives (where appropriate) will be consulted

If an employee with an individual accommodation plan is moved into a new role or location with significant changes, then the individual accommodation plan might need to change. Employers need to make sure there is time to understand the accommodation requirements before any formal assessment of performance. This extra time should not impact any trial periods.

Example

The local library has opened a new branch in the community. Lisa is an employee at the library and has been asked to move their position to the new branch. As part of the redeployment to this new position, Lisa has been assured the current individual accommodation plan they have with the library will follow them to the new branch. Lisa’s manager has given them an extra four weeks to make sure their individual accommodation plan is working before their annual performance review.

Active offer of accommodation

Many employees do not know that they are allowed to ask for accommodations at work. By asking employees if they need an accommodation on a regular basis, employers can help create a culture of inclusion for people with disabilities. Sometimes an employee might not need an accommodation for most of their job but might need a barrier removed in certain circumstances.

Employers need to ask if employees need an accommodation on an annual basis and when:

• Offering the job
• The employee starts in the role
• Describing the workplace emergency response
• Redeploying the employee or asking the employee to perform a duty that is not part of their regularly scheduled duties or at a different location
• Starting to address performance concerns
• Offering any training
• Organizing all extraordinary work functions like events or organized social gatherings

When employers ask about accommodations, they should provide a list of potential examples.

Example

A company holds an annual celebration for all its employees at a local restaurant. Lisa has never been able to attend, as the venue does not have an accessible washroom. Before they organize the event this year, the company asks employees if they would need any accommodations to attend the event. Lisa lets them know about other restaurants that are accessible. The company organizes their next event at one of these restaurants and Lisa is finally able to attend.

What is an active offer?

An active offer is a message that an organization will provide accommodations as best they can when someone asks for them.

This can include asking:

• Is there anything I can do to make your experience more accessible today?
• It is important to us that our event and materials are fully accessible to everyone. If you require any assistance, please contact us.

Accommodations

This standard topic seeks to identify, remove and prevent barriers for people with disabilities to access accommodations. Removing barriers creates the opportunity for an employee to participate in meaningful, productive work that respects the employee’s abilities and limitations, while contributing to a business or an organization.

Employers need to have a written process about individual accommodation plans for employees with disabilities that is available to all employees. This written process needs to include information about how:

• An employee can take part in their individual accommodation plan
• Employees can ask to have a union or non-union representative take part in the development of their individual accommodation plan
• The union is involved (in unionized environments)
• Employees privacy will be protected
• Changes can be made to the individual accommodation plan
• The employer will let employees know if an accommodation has not been accepted
• The individual accommodation plan will be part of parts of employment (e.g. onboarding, performance evaluation, policies regarding leave, etc.)
• Employees will be protected from any negative impacts from asking for an accommodation

An individual accommodation plan needs to be in a format that takes into account any accessibility needs of the employee.

Employers and employees need to work together on individual accommodation plans.

Employers should not unreasonably ask for expert evidence for accommodation requests. This means that if the cost and operational impact is minimal then the employer must not require evidence of a disability. The employer can ask for expert evidence when:

• They need help to find the right accommodation
• There are reasonable health and safety concerns

If the employer does ask for expert evidence, the employer and employee should work together to choose the right expert. The employer needs to pay for any costs associated with this. The standard defines expert broadly. An expert could include:

• Accredited medical practitioner (for example, general practitioner, nurse practitioner, specialist, etc.)
• Paramedical services (for example, acupuncturist, chiropractor, naturopathic physician, physiotherapist, etc.)
• Licensed practitioners (for example, clinical counsellor, social worker, audiologist, etc.)
• For Indigenous individuals, a person identified as supporting health and well-being within an Indigenous organization or Nation
• Representatives with disability organizations including people with disabilities

Example

A large non-profit organization has decided to consult with an expert while creating an accommodation plan for an employee. The cost of the expert is paid by the organization. The organization talks to the employee about who might be best to support the individual accommodation plan. Together, they choose to reach out to an occupational therapist who works with the employee.

Disclosure of disability

This standard topic seeks to balance the need for people to have privacy while also equipping employers to ask questions that support people with disabilities.

Employers’ questions can focus on:

• Workplace barriers
• Workplace accommodation
• Restrictions on activities
• Job function
• Ability to perform job duties
• Health and safety
• Performance concerns

If an employee starts performing very differently, employers need to ask if an accommodation need has arisen.

If an employee shares their disability with their employer, then employers must keep the information private. The employer should also ask the employee how often the employee would like to check-in about accommodation needs.

Sometimes as part of inclusion, diversity, equity and/or accessibility initiatives, employers may ask if an employee identifies as having a disability, but employees do not have to answer. The employer does not have the right to ask an employee’s specific diagnosis except for ensuring fitness to work and health and safety.

Example

Laura applied for a job posting and has been granted an interview. They have both a visible and invisible disability. They’re a wheelchair user. As this is a visible disability, Laura chooses to disclose their disability to the organization before the interview. They disclose their mobility needs to the hiring manager to make sure the interview location is accessible. Laura also has an invisible disability. They choose not to disclose their invisible disability, as it will not impact the duties for the position for which they’re interviewing.

Employee development

What is employee development?

Employee development is all of the activities related to monitoring and improving employee performance, productivity and effectiveness, with the goal of helping them succeed

If an employer has a policy or process about employee development, then it needs to recognize that barriers in the workplace sometimes impact performance. The policy or process also needs to recognize that individual accommodation plans can be successful or may have gaps in addressing barriers.

Employers must make sure all communication regarding employee development is available in an accessible format for each of an employee’s needs.

Where needed, employers must make sure that an individual accommodation plan is in place and enough time has passed to understand if the accommodations are working before they assess the employee’s performance.

Employees should not be punished if their performance is impacted because the employer has not provided an agreed-upon accommodation.

When an employer denies an opportunity for development, they need to provide a written explanation to the employee.

Example

Emily works for a recreation center. Their latest performance review outlined concerns with their work performance. Upon further discussion with their manager, it was established Emily requires an accommodation they did not know was available to them. A new performance review will be scheduled for Emily after a grace period that allows them to perform their job for several weeks with the new accommodation.

Discipline

If an employer has a discipline process or policy, they must make sure it:

• Is available to employees in an accessible format
• Considers accommodation needs and individual accommodation plans of employees
• Includes consultation with employees or employee representatives on request

Example

Tristano’s manager had requested a formal disciplinary review to address misconduct allegations against Tristano. The discipline process includes Tristano’s individual accommodation plan, which requires a representative to be with them during moments of high stress, as it creates communication barriers for them.

Making the organization inclusive 

What are barriers?

A barrier is anything that stops someone from being able to participate in a full and equal way in their community.

Barriers can be caused by:

• Environments
• Attitudes
• Practices and policies
• Information and communication
• Technology

Policies and practices

Policies can show an organization’s commitments and intentions. To create an accessible workplace for all, an organization’s policies should support accessibility and the inclusion of workers with disabilities.

This standard topic seeks to make sure that employers are aware of their general obligations and understand when to identify, remove and prevent barriers as a responsible employer by ensuring that employees have equitable experiences and opportunities in the workplace and work environment.

Employers must find ways to improve employment accessibility throughout the organization. Employers must share information about their work to make things more accessible so that everyone can see the types of things they are doing. This needs to be shared in their job descriptions and/or profiles—see section on job descriptions and profiles.

Employers must:

• Actively discuss accessibility needs with all their employees
• Provide a feedback mechanism for employees to comment on accessibility
• Protect employees who identify accessibility barriers and report accessibility discrimination issues
• Make sure that people who make decisions for the organization know about progress on accessible employment.

Employees must:

• Work with the employer to identify and reasonably prevent barriers in the workplace
• Enter the accommodation process with honest intent (act in good faith)

Example

A local mall is reviewing its employment procedures to identify accessibility barriers for their existing and future employees. They have organized to meet with employees to discuss accessibility needs and better understand the organization’s level of accessibility. During their consultation, the organization discovered that some of their existing policies create barriers for employment and their employees. The organization commits to reviewing the existing policies and amending them to meet the organization’s accessibility goals.

Unions

Some workplaces are unionized. Unions play an important role in making sure employment is accessible. The purpose of this standard is to make sure unions and professional organizations support persons with disabilities by providing accessible accommodation in the workplace.

If the collective agreement creates barriers for a person with disabilities, the employer and the employee’s union representative will consult each other to discuss how to reduce the barriers. Employers and unions must work together to promote and update accessibility policies and procedures.

What is a union?

Unions are organizations of employees that are formed to help navigate the relationship between employees and the employer

Collective agreements are negotiated between unions and employers to outline the terms and conditions of employment

Example

Zafar broke their leg in a sporting accident and has requested a meeting with their supervisor to ask for a workplace accommodation. Zafar has asked that a union member join the meeting to discuss their individual accommodation plan. Both Zafar’s supervisor and union representative attend the meeting. Together, they find a way to accommodate Zafar.

Leave, benefits and compensation

What are leave, benefits and compensation?

Leave is time away from work such as vacation or sick days 

Benefits are non-monetary rewards or provisions offered to employees in addition to their compensation, such as health insurance, retirement plans and paid time off

Compensation is payment given to employees for their work, typically in the form of wages or salaries

Employers must:

• Make sure the leave, benefits and compensation packages are inclusive and meet the needs of all employees including those with disabilities
• Regularly check with employees if the benefits they provide have barriers for people with disabilities
• Not ask for extra medical documentation to access benefits apart from the information required by the benefits provider

When they choose a benefits package, employers must make sure that employees with disabilities are able to join the plan offered to all other employees.

When they are compensating employees, employers need to make sure employees are not discriminated against due to disabilities. Employers can consider skill, effort, responsibility and seniority when deciding pay, but they cannot pay people less because they have a disability. 

Example

The benefits package of a grocery store chain is up for re-negotiation. Prior to negotiating with their benefits provider, management collaborates with employees to discuss their accessibility needs and any barriers employees might encounter while trying to access benefits. The resulting employee feedback is then used by management to inform the decision of choosing a benefit package that considers the needs of all employees.

Occupational organizations

Some employers require their employees to be members of occupational organizations. When an employer requires an employee to be a member of an occupational organization, they need to provide accommodations required to be a member.

What is an occupational organization?

An organization other than a trade union or employer’s organization, in which membership is required to carry on a trade, occupation or profession

Example:

John is an employee of a local charity. As part of this job, the employer wants John to belong to an organization that brings together professional fundraisers to learn from each other. John’s employer ensures that all communications sent by the occupational organization to John are in an accessible format and compatible with John’s screen reader.

Documentation

In this standard there are times when we require organizations to write information down and save it. The formal information that organizations need to write down and save is called documentation. The circumstances when organizations need to document a situation has been described in each section of this document. For example, in the section about recruiting employees, if an employer cannot provide the accommodation requested by an applicant, then they need to document the situation.

Documenting information helps organizations keep a formal description or record of a situation. Documentation is important because it helps keep organizations and people accountable.

Documentation about a situation needs to include:

• Information about what happened with the organization and a person
• Reasons why the organization was not able to offer accommodations to a person
• Different options that the organization offered to a person
• Whether a person agreed to the different accommodations that the organization offered

Organizations are in charge of documenting information about a situation and storing the information safely. Organizations also need to:

• Share documentation with the person it is about, in a way that is accessible to them (as much as possible)
• Tell people that they can ask for documentation about their situation

Example

Demetri works at a distribution center. They’ve had an injury and cannot climb stairs. This creates a barrier for them, as an area of their work is only accessible by stairs. Demetri requested a stair chairlift be installed to accommodate their needs. The organization denied this request citing undue financial hardship. As an alternative, the organization offered to reassign some of Demitri’s duties. Demetri would like a copy of the report for their records and requested the documentation from their manager. The manager provided Demitri with the requested documentation.

Support to implement these recommendations

The Provincial Accessibility Committee wants to make sure that organizations have the information and guidance they need to implement any regulations that arise from these standards. The Provincial Accessibility Committee is interested in understanding the type of resources that would help organizations. This could include things like checklists, model policies, training and other supports. 

Next steps

Thank you for reviewing these recommendations. There are lots of ways for you to provide your feedback. Please visit: engage.gov.bc.ca/accessiblebcactstandards for more information.

The Provincial Accessibility Committee will use all of the input provided to inform its final recommendations to government.