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Findings and Recommendations: Harmonize Standards

Harmonization of the existing standards — both the customer service regulation and the four proposed standards — is an immediate priority that should be undertaken prior to releasing the remaining accessibility standards regulations. The purpose of harmonization is to ensure that the five standards are viewed holistically, making it easier to understand how they fit together and how to comply.

The disability community and the obligated sectors both repeatedly expressed concerns about the lack of harmonization. The standards that have been developed cut across and intersect with one another — and with other pieces of legislation. There are many who believe that the “silo” approach of having five separate standards development committees has resulted in gaps, discrepancies and overlapping details. The review was told that the absence of coordination of requirements and timing across the standards will make it difficult to comply with the regulations and communicate expectations with respect to priorities and timeframes.

A common problem cited concerns the issue of training. Although all standards call for training, little guidance is provided on the training requirements, the training programs available or their relation to each other. Placing the onus on organizations to decipher the necessary training requirements under each standard will lead to time-consuming, costly and duplicated efforts.

As this report is written, neither the content nor the timelines of four of the five standards have been released. It is my understanding that the government is working on the information and communications, transportation and employment standards, and that the built environment committee will soon be considering comments from the public review. I am also aware that while my review has been underway, stakeholders have been advising the government directly about the need to harmonize the standards before the regulations are completed.

Harmonization is consistent with the principles of the government’s Open for Business initiative. It will address many of the issues raised about the need to simplify the process for complying. A harmonization strategy recognizes the fact that many organizations in Ontario in both the private and public sectors and regardless of their size must comply with several, if not all, of the five standards.

Stakeholders have raised important questions that the government should consider before releasing the final standards in regulation. I shared these concerns in a letter to the Minister of Community and Social Services dated November 18, 2009. There are many ways that the government can accomplish harmonization and I believe that this must be done prior to the standards being released.