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BFM Submits Final Comments on Proposed Accessible Employment Standard

Feb 10, 2017

Earlier today, Barrier-Free Manitoba submitted our final comments on the discussion paper on the proposed accessible employment standard. The discussion paper is a mere 13 pages long. Our response is a thorough one. It presents 19 detailed recommendations (listed below) for measures needed to build on the key strengths and address the many limitations of what was proposed. It runs to almost 100 pages.

We are pleased to post to for your review and consideration:

Full version (Word / PDF)
Executive Summary (Word / PDF)

It’s pretty clear that the barriers to labour market success faced by Manitobans with disabilities have been evident for decades. It’s also pretty clear that these barriers are pervasive and deeply ingrained in systems, policies and attitudes. Accordingly, persons with disabilities have among Manitoba’s lowest employment rates and highest unemployment rates. Both the importance of and the potential benefits that will come from a strong and effective accessible employment standard cannot be overstated.

The deadline for public comment on the discussion paper is February 15th. If you have not done so already, we strongly encourage you to send in your comments. If you support Barrier-Free Manitoba’s recommendations, please say so. If you have more or other recommendations to make, please offer them.

It is really important that the Accessibility Advisory Council and the government hear from you and others. So please send or call in your comments to:

    Disabilities Issues Office
    630 - 240 Graham Avenue
    Winnipeg MB R3C 0J7
    Phone: (204) 945-7613
    Toll Free: 1-800-282-8069, Ext. 7613

Your comments don’t need to be long ones. If you want, just call in and tell them how important equitable employment is to Manitobans with disabilities. For your reference and convenience, here are links to the 13-page discussion paper (Word / PDF)

List of Recommendations

BFM Recommendation 1: That, contingent on the accessible employment standard coming into force by January 1, 2018, 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 2: That the standard adopt the 20 or more employees as the benchmark for requiring that employers prepare written documentation of policies, practices and procedures related to accessible employment.

BFM Recommendation 3: That consideration be given to harmonizing Workers Compensation’s return to work requirements and those that will be established under Manitoba’s accessible employment standard.

BFM Recommendation 4: That the standard require that all employers develop, implement and maintain policies that:

  • Include a statement of the employer’s commitment to meet accessibility needs of persons with disabilities related to employment in a timely manner.
  • Include a statement of the employer’s commitment to the principle of universal design and to the proactive identification and removal of barriers to accessible employment as a basic part of its planning processes.
  • Govern how the employer achieves or will achieve employment accessibility through meeting its requirements under the standard.

BFM Recommendation 5: That the standard require that all employers ensure that training about accessible employment is provided to all employees, volunteers, and persons involved in policy development to whom the standard is relevant to the performance of their duties. The training must include:

  • A review of The Human Rights Code, the Accessibility for Manitobans Act and the standard.
  • A review of the employer’s accessible employment policies and procedures and how these apply to the performance of their duties.

BFM Recommendation 6: That, consistent with the Customer Service Standard, the standard require that all employers ensure that:

  • Training is provided to a person as soon as reasonably practicable after the person is assigned the applicable duties.
  • On-going training is provided in connection with changes to the employer’s policies and practices respecting accessible employment.

BFM Recommendation 7: That, consistent with the Customer Service Standard, all employers with 20 or more employees be required to document their training policy, including a summary of the content of the training and when training is to be provided.

BFM Recommendation 8: That the standard require that employers provide a basic orientation to the human right to accessible employment and to their accessible employment policies and practices to all existing staff and to all new personnel.

BFM Recommendation 9: That clear and proscriptive language is used in the next version of this standard to be developed by the Minister to describe the standard’s requirements.

BFM Recommendation 10: That focused research and stakeholder consultations on best practices related to accessible employment policies and practices be conducted and reported on to provide the basis for establishing specific requirements as part of the standard.

BFM Recommendation 11: That the standard be expanded to include requirements that employers provide information about employment opportunities to agencies and organizations that provide employment services to Manitobans with disabilities.

BFM Recommendation 12: That consideration be given to expanding the standard to address the process of removing and preventing barriers to effective workplace accommodation and accessibility in the collective bargaining process and in collective agreements. This process could:

  • Focus the attention of an employer and union involved in the process of bargaining a collective agreement towards identifying and removing existing barriers in the collective agreement, and preventing the creation of new barriers.
  • Require an arbitrator, undertaking binding arbitration of the collective agreement, to address identification and removal of existing barriers, and prevention of new barriers in the collective agreement, including inviting submissions from the union and employer on this topic during the arbitration process.

BFM Recommendation 13: That consideration be given to adjusting or expanding the standard to address the accessibility of volunteer and internship positions.

BFM Recommendation 14: That the standard be expanded to require employer participation in a measurement and monitoring system that provides the basis for assessing the standard’s impact and the province’s progress toward achieving a fully accessible labour market.

BFM Recommendation 15: That, following Ontario’s recent decision, the Government of Manitoba commit to the development of an accessible education standard under The Accessibility for Manitobans Act that covers settings from child care to post-secondary and adult education and that this standard be developed and implemented within the government’s current term in office.

BFM Recommendation 16: That the Government of Manitoba develop and adequately resource a robust implementation strategy that will provide increased support to employers and Manitobans with disabilities, facilitate greater awareness of the value of employing, retaining and promoting persons with disabilities and address other barriers to employment that will not be adequately addressed through employers’ development and implementation of accessible human resource policies and practices.

BFM Recommendation 17: That the Government of Manitoba review and commit to providing the level of resources needed to ensure the full and timely implementation of The Accessibility for Manitobans Act.

BFM Recommendation 18: That the Government of Manitoba provide financial and other resources to Manitoba’s disability communities to ensure their capacity to conduct independent research and to support their fair and equal participation in the implementation of The Accessibility for Manitobans Act.

BFM Recommendation 19: That the Government of Manitoba take immediate and dedicated action to develop clear plans for a strong and effective compliance regime under The Accessibility for Manitobans Act.


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