Cat. No. TU1-21E-PDF
ISSN 2817-1608
1 Effective date
This plan came into effect on 30 December 2022.
2 Application
This plan applies to all employees of the Transportation Safety Board of Canada (TSB).
3 General
The Manager, Administration, is designated to receive feedback on barriers and the Accessibility Plan 2022–2025.
General enquiries
Transportation Safety Board of Canada
Place du Centre, 4th floor
200 Promenade du Portage
Gatineau QC K1A 1K8
tsb.gc.ca/eng/contactez-contact/index.html
Local number: 819-994-3741
Toll-free in Canada: 1-800-387-3557
From outside Canada: +1 819-994-3741
TDD: 819-953-7287
Members of the media may contact Media Relations
tsb.gc.ca/eng/medias-media/contact.html
819-360-4376
media@tsb.gc.ca
3.1 Executive summary
The TSB’s Accessibility Plan 2022–25 seeks to build a culture of inclusiveness that promotes diversity and combats discrimination by identifying and removing existing barriers and preventing future barriers in the workplace.
While this first version of the Plan focuses on the priority areas outlined in the Accessible Canada Act (ACA), the Plan is an evergreen document, where proposed solutions under each area can evolve as barriers are identified, to ensure it remains current and relevant as we respond to the needs of our employees.
The TSB encourages all members of the organization, its stakeholders, and its partners to challenge the status quo, innovate, and take calculated risks to bring meaningful impacts through co-development of and collaboration and consultation on policies, programs, practices, and service delivery. Accordingly, people with disabilities are actively invited to participate in these processes in accordance with the Accessibility Strategy for the Public Service of Canada, also called “Nothing Without Us.”
As part of the development of this Plan, three consultation sessions were held over the summer and fall of 2022. TSB employees with an interest in identifying and removing barriers in the workplace, as well as external partners with an interest in issues affecting persons with disabilities, were invited to participate in these sessions to ensure that as many voices could be heard as possible and that persons with disabilities were given maximum opportunities to participate.
3.2 Accessibility statement
The TSB complies with regulatory requirements, strives to reflect the workforce demographics in Canadian society, and takes actions indicated in the TSB Employment Equity Plan 2020–21 to 2022–23 to reduce the identified representation gaps for people with disabilities.
The TSB recognizes that, beyond regulatory compliance, there are opportunities for accessibility improvement, such as the need for intentional inclusion and appropriate accommodation, in a more structured approach, and the continued need to combat discrimination and harassment resulting from stigma and misunderstanding. It also recognizes that eliminating barriers brings benefits to all.
The TSB wishes to move beyond a culture of compliance so that persons with disabilities have the same opportunities as their colleagues to thrive in their careers. To bring meaningful change, we need to support and keep each other accountable for the roles and responsibilities presented in the Plan.
To enable collaboration between employees and managers to identify barriers and find solutions that work for the specific situation, the TSB will adopt the GC Workplace Accessibility Passport which uses the “Yes by Default” approach, places the employee at the centre of the accommodation process, includes and structures the information needed by the manager to make decisions, and streamlines information transfer between the TSB and other departments.
4 Mandatory areas under section 5 of the Accessible Canada Act (ACA)
The proposed solutions identified in this Plan result from consultations within the organization and have been submitted for review and additional input by an external partner. They represent a stepping stone upon which all employees, managers, executives and partners can collaborate and engage at every step of the Plan’s progression, leading to the cementing of an inclusive departmental culture.
Consultations provided opportunities to discuss barriers based on the seven areas identified in the Accessible Canada Act (ACA), and proposed solutions on how to remove them while also identifying proposed methods to prevent further barriers.
4.1 Employment
General: In the Employment area, participants discussed external examples : Ableism, biases in the hiring process, fear of negative judgment and repercussions, lack of accessibility for the tools used in hiring and available during employment, unwillingness to provide reasonable accommodationsFootnote 1, of assistive tools or technologies to help the person be effective, negative attitudes within the work environment (ex: a person may be denied resources because the manager does not believe they have a learning disability), lack of relevant systems, services and policiesFootnote 2. They were then invited to identify barriers present within the organization.
Consultation participants identified the following barriers and proposed avenues of resolution:
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4.1.1Public Service Performance Management
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4.1.1.1Barrier details: The performance evaluation process is anxiety-inducing which would affect people with cognitive/emotional limitations in a disproportionate way.
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4.1.1.2Proposed solution: Include resources to support managers with the call letter, so that they have the tools to take their employees’ needs into consideration in the process and to support managers’ own stress about the process.
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4.1.2Manager awareness of accessibility issues
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4.1.2.1Barrier details: Managers generally have low awareness of accessibility issues, especially of the non-visible type (such as cognitive or emotional). Do managers know when/where adaptation can be provided? Do they take accessibility into account? These factors can contribute to anxiety for both managers and employees.
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4.1.2.2Proposed solution: Increase awareness of accessibility issues via the Beacon, COO Townhalls and other internal communication tools such as lunchtime discussions, posters and advertising the point of contact for accessibility questions. Consider including more formal training on accessibility in the departmental training portal (internally referred to as “LMS365”).
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4.1.3Hybrid meetings
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4.1.3.1Barrier details: As offices reopen, meetings are conducted in hybrid mode incorporating video feed from individual participants at home and “full-room” for participants at the office. Keeping the room camera at the “panoramic zoom” setting makes it difficult to see faces in detail, which is needed for persons with some disabilities who rely on interpreting facial expressions and reading lips.
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4.1.3.2Proposed solution: Resolve the technical issues affecting the “zoom to speaker” feature of the recently purchased videoconferencing equipment. Pending this, educate and encourage personnel on good practices. Include such practices in standard meeting invitations and introductions.
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4.1.4Timeliness-focused environment
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4.1.4.1Barrier details: The TSB is a small, nimble organization requiring tight response deadlines of its employees. Adaptations for people who need more time are necessary while independence is valued.
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4.1.4.2Proposed solution: While participants could not provide an easy solution to this operational requirement, managers are to be encouraged to discuss adaptation with their employees, including for conditions that may require the allocation of additional time to complete discrete tasks while balancing operational constraints.
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4.1.54Bias in hiring processes
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4.1.5.1Barrier details: Although a review is underway to reduce the number of investigative positions requiring medicals, there are still positions requiring specific qualifications as determined by Treasury Board qualification standards and/or collective agreements. What about situations where employees originally meet all requirements upon hiring, but then lose a qualification? Additionally, some administrative-type positions are advertised with “possibility of being deployed to major occurrences”, which can generate anxiety and lead people to not apply, despite the very low risk of being deployed.
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4.1.5.2Proposed solution: To address accessibility-related issues where possible, continue to review merit criteria, staffing assessment tools and related processes to ensure they are inclusive and do not create systemic barriers as integrated in the TSB Employment Equity Plan. Review and remove unnecessarily restrictive criteria prior to advertising staffing opportunities. In the case of positions requiring specific qualifications where the incumbent no longer meets due to an accessibility-related issue, promote flexibility and accommodation measures to the extent possible. As the PSC brings forward updated policies to adhere to upcoming legislative measures in the PSEA concerning bias in hiring processes, the TSB will continue to adjust its staffing-related policies, tools and processes to support an accessible workplace.
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4.1.6VidCruiter
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4.1.6.1Barrier details: The TSB uses VidCruiter to conduct and manage some of its hiring processes (use of the tool is not mandatory); the tool does not currently allow for closed captioning, which makes it difficult for hearing impaired evaluators to assess candidates, as they generally speak faster when recording their video interview, making it difficult to read lips.
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4.1.6.2Proposed solution: Ask PSPC to request the addition of closed captioning feature to VidCruiter either integrated by the supplier or via the adjunct of a third party-provided feature.
4.2 The built environment
General: Participants were presented with structural/space design accessibility issue examples : lack of wheelchair ramp or elevator and not providing modified equipment that allows the disabled person to perform in the positionFootnote 3. From there, they were invited to identify barriers present in TSB facilities and to propose solutions.
Consultation participants identified the following barriers and proposed avenues of resolution:
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4.2.1Some locations do not meet the minimal accessibility standards.
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4.2.1.1Barrier details: PSPC conducted accessibility assessments for all ten locations where TSB has offices, using the 2018 Accessibility Standard. While most identified issues have been corrected, the Dorval office is in a building where retrofit would be too onerous to implement and a couple of locations, while meeting most of the standard, have some less-critical issues remaining that cannot be resolved until a full interior rebuild is conducted (hallway width in Dartmouth, high-bay secondary access in the TSB Engineering Laboratory).
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4.2.1.2Proposed solution: Where critical accessibility standard requirements cannot be implemented, work with PSPC to identify new locations to be configured in accordance with the latest accessibility standards. For other locations, continue to work with PSPC, building custodians and owners to achieve as much compliance as feasible, to identify remaining gaps and explore alternatives to make reasonable accommodations in the existing location.
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4.2.2The accessibility standards may not meet all individual requirements.
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4.2.2.1Barrier details: In TSB facilities meeting the latest accessibility standards, it is still possible that an individual’s specific needs are not met.
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4.2.2.2Proposed solution: Proactively discuss individual accessibility-related requirements with new employees at onboarding, consider filling out a GC Workplace Accessibility Passport if one does not yet exist for the individual. Accommodations personnel should work hand-in-hand with individuals having accessibility issues, their managers and TSB partners to identify possible solutions, obtain funding and bring changes to the TSB physical assets to resolve identified barriers.
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4.2.3Floorplate size
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4.2.3.1Barrier details: At Head Office, the available office space means that most offices are not in close proximity to the elevators and emergency exits, potentially affecting those with chronic fatigue or other issues affecting their walking ability.
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4.2.3.2Proposed solution: Identify and reserve office spaces with the closest proximity to elevators and emergency exits for personnel or visitors who need to limit their walking. Ensure that Building Emergency Evacuation Team members survey identified office spaces when executing an evacuation so that the individuals receive the required assistance in an emergency.
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4.2.4Noise level/visual distraction
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4.2.4.1Barrier details: In open-plan office setups, surrounding activity/movement and noise levels can affect concentration, especially for individuals who have ADD/ADHD or other cognitive impairments. In a hybrid workplace, the conduct of multiple MS Teams meetings around the individual can exacerbate the noise level as people tend to speak louder in videoconferences.
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4.2.4.2Proposed solution: Include a minimum of self-isolation/concentration spaces in the implementation of hybrid workplaces within existing facilities. Where possible, provide a variety of accessible setups so that individuals can choose which one best fits their situation. Proactively design new facilities with a variety of accessible setups.
4.3 Information and communication technologies (ICT)
General: Participants were presented with accessibility issue examples : Inability to use a phone due to hearing issues, lack of Braille printed items for blind personsFootnote 4.
Consultation participants identified the following barriers and proposed avenues of resolution:
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4.3.1MS Teams auto transcription
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4.3.1.1Barrier description: The current instantaneous transcription function in MS Teams requires manual adjustment of the language being spoken. As the transcription function cannot differentiate between languages, it becomes useless in fully bilingual meetings.
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4.3.1.2Proposed solution: Work with Microsoft as part of the government contract to bring on new features to MS Teams via upgrades to the tools’ functionality
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4.3.2Lack of awareness about available accessibility hardware and software tools such as Microsoft suite
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4.3.2.1Barrier description: TSB provides assistive technology that is readily available, but many do not know what technological solution would work for them.
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4.3.2.2Proposed solution: Promote the availability of services provided by the Accessibility, Accommodation and Adaptive Computer Technology program.
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4.3.3Treasury Board Secretariat (TBS) accessibility standards for Government of Canada websites and accessibility features in commercial off-the-shelf software (COTS) are not necessarily applied to internal documents/software.
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4.3.3.1Barrier description: While accessibility standards are known and used for public-facing TSB communication products, and the Communications team is aware and uses accessibility functions of COTS for most internal communications products, such availability is not widely known, leading to many internal documents not leveraging available accessibility functions and not being formatted appropriately so that those can work. On purchasing COTS, the TSB relies on SSC Standing Offers and Supply Arrangements that include accessibility requirements; accessibility requirements are not necessarily indicated on Statements of Work (SOWs) for in-house software development.
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4.3.3.2Proposed solution: Develop short training / awareness sessions on accessibility functions of software, make them available through LMS365 and advertise their availability so that personnel learn how to format their general documents/correspondence to allow their use. Increase general awareness of the need to format documents for accessibility. Use development software that includes accessibility functions right in the package for in-house software development. Include accessibility requirements in future SOWs to formalize the obligation from a contracting perspective.
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4.3.4ICT instruction manuals
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4.3.4.1Barrier description: Hardware and Software User Manuals are not necessarily bilingual or in an accessible format (those from major companies are, others are “hit and miss”).
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4.3.4.2Proposed solution: Leverage PSPC/SSC procurement vehicles to purchase ICT, as they include accessibility requirements for accompanying operating manuals. Where those vehicles are not available, include an assessment criterion related to the provision of instruction manuals in an accessible format. For in-house software development, specify in the SOW that user manuals must be provided in bilingual, accessible format.
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4.3.5Hybrid meetings organization and preparatory documents
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4.3.5.1Barrier description: While comfort level and experience are easing the effectiveness of online meetings, there remains a cognitive-load penalty of not being face-to-face, and participants should consider the limitations of tools such as MS Teams (auto-transcription cannot work when there are overlapping discussions, provides inaccurate subtitles when speech is not clear, etc.)
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4.3.5.2Proposed solution: To reduce cognitive-load issues, meeting organizers should provide supporting documentation well in advance so that participants can prepare using accessibility tools as required. Familiarization sessions on best practices for hybrid meetings and accessibility functions are provided on an individual basis by the Admin Division.
4.4 Communication, other than ICT
Participants were provided advance reading to familiarize themselves with the topic to be discussedFootnote 5. Within that document, lack of Braille printed items for blind persons, and language that is too technical for persons with cognitive impairments were submitted as examples for discussion.
Consultation participants identified the following barriers and proposed avenues of resolution.
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4.4.1Non-official communication products
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4.4.1.1Barrier description: There are no mandatory requirements for the application of accessibility standards in non-official communication products (ex: emails sent out to TSB personnel) and there is limited awareness of easy ways to make those products more accessible (ex: how to insert a “Make accessible” button in PDF or MS365 documents).
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4.4.1.2Proposed solution: Have an expert from Communications who is familiar with making documents accessible provide all staff awareness sessions to increase awareness of accessibility issues and of easy ways to make all communications more accessible, with the goal to imprint accessibility in employees’ mindset.
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4.4.2Complexity of language
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4.4.2.1Barrier description: Documents for internal as well as external readers are often complex and technical. Those that use unclear or insufficient headings, poor syntax, jargon, or many or non-standard abbreviations, for example, are difficult to understand, making the information and ideas in them inaccessible, especially to readers who are not specialists in the topic.
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4.4.2.2Proposed solution: Remind authors that non-specialist readers will likely read their documents and that these documents must therefore contain the information those readers need to understand them. Involve editors as early as possible in the draft to provide advice on clear language. Encourage authors and reviewers to use correct technical terms rather than jargon and avoid making texts so concise that they become unclear. Instruct authors in how to use the TSB English Style Guide and the TSB Index of Abbreviations to make their documents accessible to internal as well as external readers.
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4.4.3Templates and unstructured content
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4.4.3.1Barrier description: With the exception of those made by Communications Branch (Publishing), templates used for internal and external documents—even those provided to the TSB by other government departments—are rarely accessible. They lack structured headings or they implement headings improperly; tables are not logically (accessibly) structured; captions are not used or are not clear or complete; alternative text for images (or “alt text”, a short written description of an image) is rarely applied. Source documents that are incorrectly made are also difficult and time-consuming to convert to accessible HTML.
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4.4.3.2Proposed solution: Provide templates that meet accessibility requirements and train authors how to make them. Provide guidance on the construction of accessible tables and methods to describe images in a clear, succinct and complete manner, and constantly apply this process. Increase awareness of the issue through quick-tips and inclusion in training for new investigators. Implement an informal “peer-review” system to check document structure at the same time as the application of technical accessibility tools within the document.
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4.4.4Active offer
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4.4.4.1Barrier description: Accommodation measures are not necessarily offered proactively. The onboarding process does not formally have an active offer of accommodation measures, and there is no formal periodic review of the measures to ensure they continue supported/adapted.
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4.4.4.2Proposed solution: HR will add a standardized clause in the Letters of Offer about the GC Workplace Accessibility Passport and encourage discussion. Admin will add “discuss required accommodations measures/GC Workplace accessibility passport” to the onboarding procedures. Add periodic reminders for Administration to reach-out for review of measures.
4.5 The procurement of goods, services, and facilities
Participants started with a general discussion on directories of accessible / accessibility-related products and services, the need to consult end-users, applying Government of Canada accessibility standards and universal design principles. The discussion was then steered towards actual barriers within the TSB.
Consultation participants identified the following barriers and proposed avenues of resolution:
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4.5.1Strict TBS policies and PSPC products, processes, and services
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4.5.1.1Barrier description: The federal government procurement environment and its processes are strictly regulated via Treasury Board Secretariat (TBS) policies and Public Service Procurement Canada (PSPC) products, processes, and services.
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4.5.1.2Proposed solution: Procurement staff to take training and be aware of accessibility statements applied at PSPC, and to apply such. Continue to implement PSPC accessibility tools and clauses to TSB internally driven procurement products and processes as appropriate.
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4.5.2Lack of diversity promotion
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4.5.2.1Barrier description: Professional services offerings that the TSB can access through the Centralized Professional Services System (CPSS) may not necessarily identify/promote resources issued from diversity. PSPC has integrated accessibility/diversity consideration and promotion in their goods procurement processes since 2019 but integration in services procurement processes is so far left up to departments.
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4.5.2.2Proposed solution: Include the attestation to accessibility consideration in its internal processes and examine/enhance the internal list of criteria related to diversity and accessibility criteria. Include the enhanced list of criteria in all applicable professional service solicitations to incite vendors to propose consultant issued from various groups/with various accessibility challenges. Identify available training related to accessibility with a focus on procurement/contracting, to be offered to procurement officers.
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4.5.3Process/organizational complexity and resistance to change
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4.5.3.1Barrier description: Contracting documents and processes have very specific organizational requirement and mandatory clauses, making them difficult to understand even for trained procurement personnel. This puts them in “very difficult to comprehend” territory for lay people, even more so for people with cognitive disabilities. The whole system has high inertia, making for strong resistance to change by various stakeholders.
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4.5.3.2Proposed solution: Run a pilot project on a low-complexity goods procurement to further explore accessibility obstacles. Include accessibility and diversity best practices from HR processes into evaluation criteria for professional services. Provide advice to clients on available clauses promoting accessibility in contracts. Explore the availability of directories of businesses supporting accessibility
4.6 The design and delivery of programs and services
Participants were provided with the following are examples of barriers to initiate discussions :
- Not enough time allowed for disabled persons to complete tasks
- Not taking advantage of central agency-funded programs to provide disabled persons with accommodations allowing them to excel in their rolesFootnote 6.
The participants then discussed how these examples would apply within the TSB operational context – the TSB has a single operationally-focused business line that implies some bona fide operational requirements limiting the resolution of accessibility barriers, particularly for the field phase of investigations. The discussion then focused on how to lift barriers related to support provided by Communications and Corporate Services.
Consultation participants identified the following barriers and proposed avenues of resolution:
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4.6.1Public-facing website
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4.6.1.1Barrier description: The TSB public-facing website meets Government of Canada accessibility standards, except with respect to the treatment of images, which is inconsistent, especially on older reports. It is not possible to apply long descriptions to some complex images, but they are supported by the context and descriptive captions.
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4.6.1.2Proposed solution: Perform an accessibility audit on the website. Add an accessibility statement describing the standards and tools applied to investigation reports and the website in general. Train and require authors to apply alt text or long descriptions to images in materials destined for the website. In the event that the website is converted to a content management system, ensure that its procurement has a mandatory accessibility requirement.
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4.6.2Media relations and press conferences
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4.6.2.1Barrier description: It was noted that the TSB press conferences are not provided in alternative formats (ASL while live, closed captioning of saved video on YouTube). Some, but not all other TSB videos posted on YouTube include closed captioning.
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4.6.2.2Proposed solution: Apply the Guidelines on Making Communications Products and Activities Accessible when planning press conferences: plan for and implement closed captioning on press conference video and other video materials posted to YouTube and to the TSB website, and continue to provide transcripts of audio-visual material on the website.
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4.6.3Use of tools to enhance accessibility
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4.6.3.1Barrier description: When conducting hybrid meetings or using software tools to prepare reports, policy or guidance, personnel are not using available tools to enhance accessibility. Furthermore, limited bandwidth from TSB office locations can affect video feed when meeting in MS Teams for design and delivery of programs and services, limiting capacity to read lips/facial expressions.
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4.6.3.2Proposed solution: Increase awareness of accessibility tools by including a short descriptor of their availability at the start of meetings. Identify/promote online training already available for the Microsoft suite of products in use within the TSB. It was noted that screen-sharing documents in MS Teams reduces video feed clarity – increase awareness of trying to circumvent this limitation.
4.7 Transportation
General: In the Transportation area, participants discussed external examples : lack of accessible ramps, curbs, crosswalks and sidewalks, poor vehicle design, absence of elevators, non-existent or inaccessible signage and wayfinding, office space that is difficult to understand or navigate, and the fact that many policy analyses ignore the fact that most travelers with disabilities make the majority of their trips in private vehicles and rely heavily on walking to facilitate their use of all modes of travelFootnote 7. The goal is to enable everyone to live independently.
Following this, a general discussion ensued on the reasons why transportation is a significant accessibility issue: having no car, no or limited transportation, no one on whom to depend, desire to be autonomous and avoid asking for help, disability making it hard to use available transportation or the equipment does not fit in it.
Consultation participants identified the following barriers that are present within TSB and discussed possible solutions for each:
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4.7.1Vehicle purchase analysis
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4.7.1.1Barrier description: No consideration for adapted vehicles when purchasing. The operational requirements to deploy to remote, off-road locations and meeting Greening Government objectives drive the need more than having accessible vehicles.
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4.7.1.2Proposed solution: Add accessibility as a factor to consider when making purchasing analysis, to be balanced with other operational requirements. Increase awareness of the availability of the option to rent adapted vehicles when accessibility is a requirement.
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4.7.2Cognitive charge
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4.7.2.1Barrier description: Tools to alleviate cognitive charge while operating vehicles are not necessarily available as imbedded vehicle option or add-on accessory.
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4.7.2.2Proposed solution: Ensure equipment alleviating cognitive charge is provided with the vehicle, either as embedded vehicle equipment (cruise control, line keep assist, etc.) or as add-ons to use one’s mobile phone as an aide (secure cell phone mount).
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4.7.2Accessible parking
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4.7.2.1Barrier description: Availability of accessible parking options for employees and visitors varies by office location and is undocumented.
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4.7.2.2Proposed solution: Survey Head Office and each regional office to identify parking availability and location of nearest accessible parking options. Add this information to base office information package.
5 Feedback
5.1 Contact
External stakeholders and people with disabilities who encounter workplace barriers at TSB workplaces are encouraged to contact the Manager, Administration, and provide their feedback for consideration.
Enquiries may be submitted using the TSB’s “Contact us” form on the General enquiries page at tsb.gc.ca/eng/contactez-contact/index.html or in writing to:
Transportation Safety Board of Canada
Place du Centre, 4th floor
200 Promenade du Portage
Gatineau QC K1A 1K8
Local number: 819-994-3741
Toll-free in Canada: 1-800-387-3557
From outside Canada: +1 819-994-3741
TDD: 819-953-7287
The Manager, Administration, will respond within ten working days to any feedback requests made by members of the public. As a minimum, responses will identify the relevant information from the TSB Accessibility Plan, refer to it when necessary, and provide guidance on the subsequent suitable steps.
5.2 Reports
The TSB will release annual progress reports that inform the public of the status of the Accessibility Plan execution. The progress reports are used to identify, remove and prevent barriers in the priority areas of the Accessible Canada Act and will be published by 31 December of any year that the Accessibility Plan is not updated.
The progress reports will detail the feedback received from persons with disabilities, how that feedback was taken into consideration, and how persons with disabilities were consulted.
6 Consultations
The TSB conducted three consultation sessions, inviting all TSB employees with an interest in making the overall environment more accessible through the identification and removal of barriers. Invitations to participate in the consultations were sent via multiple channels targeting TSB employees (townhalls, The Beacon, Carousel and at management meetings). To maintain privacy, the messages were aimed at all employees “with an interest in accessibility.”
All consultations were conducted in hybrid mode, allowing both in-person and virtual participation via MS Teams. Consultations focused on identifying barriers in the seven areas identified in Section 5 of the ACA, and suggestions to remove those barriers. Section 4 of this Plan reflect the results of consultations.
7 Budget and resource allocation
For the first Plan, the focus on next steps will be on assessing the feasibility of proposed solutions, prioritizing and establishing timelines for proposed actions, and identifying, documenting and seeking resources based on the priorities.
Create and maintain a log to track requests for workplace accommodations and their resolution timeline while maintaining TSB’s historically low informal resolution wait times.