Barrier Free Manitoba

The Accessibility Advisory Council released it's revised recommendations (Word / PDF) for the proposed Customer Service Standard, incorporating eight of BFM's call for improvements.

For the record, here is the Council's record of action on Barrier-Free Manitoba's recommendations:

BFM Recommendations Adopted (8)

BFM Recommendation 2: That the standard explicitly require that obligated organizations develop policies to:
• Identify barriers to accessible customer service;
• Remove barriers to accessible customer service;
• Prevent the creation of barriers to accessible customer service; and,
• Provide equivalent customer service.

BFM Recommendation 5: Contingent on the Customer Service Standard being made into regulation in the winter of 2014/15 that dates for compliance be set at:
• One year for the Government of Manitoba
• Two years for designated public sector organizations
• Three years for all other obligated organizations.

BFM Recommendation 8: That the standard adopt the 20 or more employees as the benchmark for requiring that obligated organizations prepare written documentation of policies, practices and procedures on accessible customer service and advising customers that these documents are available upon request. (Bold font is from M.Case)

BFM Recommendation 9: That the standard require that the policies, practices and procedures developed by obligated organizations are consistent with the principles of:
• Access: Persons should have barrier-free access to places, events and other functions that are generally available in the community;
• Equality: Persons should have barrier-free access to those things that will give them equality of opportunity and outcome;
• Universal design: Access should be provided in a manner that does not establish or perpetuate differences based on a person's disability;
• Systemic responsibility: The responsibility to prevent and remove barriers rests with the person or organization that is responsible for establishing or perpetuating the barrier.

BFM Recommendation 14: That the requirement to provide notice of temporary disruption of accessible customer services be revised to read:
The notice should be prominently displayed on the premises, on the provider’s website, if any, and other reasonable methods.

BFM Recommendation 15: That training requirements under the proposed customer service standard be initially limited to:
1. Every person who deals with members of the public or other third parties on behalf of the provider, whether the person does so as an employee, agent, volunteer or otherwise.
2. Every person who participates in developing the provider’s policies, practices and procedures governing the provision of goods or services to members of the public or other third parties.

BFM Recommendation 16: That the requirement to provide notice of customer service documents upon request be revised to read:
The notice should be prominently displayed on the premises, on the provider’s website, if any, and other reasonable methods.

BFM Recommendation 17: That the standard include the requirement that obligated organizations provide information in an accessible format at no cost to the person with a disability within a reasonable time after the person requests it.

BFM Recommendations Not Spoken To (4)

BFM Recommendation 4: That the purpose of the proposed standard be clearly described in the standard. To be reflective of the purpose of the AMA, we suggest the following:
The purpose of these standards is to prevent and remove barriers that disable people with respect to customer service and business practices.

BFM Recommendation 6: That the standard require that obligated organizations have and implement policies that allow and support the use of assistive devices by persons with disabilities.

BFM Recommendation 11: That the standard not include reference to a support person only be permitted to accompany a person with a disability to protect the health and safety of the person or others.

BFM Recommendation 12: That the standard not include reference to obligated organizations being able to require that a person with a disability be accompanied by a support person when on the premises.

BFM Recommendations Seemingly Not Adopted

BFM Recommendation 1: That the standard make explicit reference to its applicability to providers of information and facilities, in addition to providers of goods and services.

BFM Recommendation 3: That the standard explicitly require that obligated organizations provide alternative customer services until barriers are removed or equivalent service is available.

BFM Recommendation 7: That the standard require that obligated organizations have a policy that prohibits any added fee or surcharge being charged to persons with disabilities for accessible customer services and for alternative customer services until barriers are removed or equivalent service is available.

BFM Recommendation 10: That the standard prevent obligated organizations from charging any additional fees related to the use of a service animal.

BFM Recommendation 13: That the standard prohibit obligated organizations from charging an additional admittance fee for support persons who accompany persons with disabilities.