ONTARIO ACCESSIBILITY

Ontario Accessibility at Behr Process LLC

AODA Statement of Commitment to Accessibility

August 17, 2020

Behr Process Canada Ltd is committed to providing a barrier-free environment for all stakeholders, including our clients, employees, job applicants, suppliers, and any visitors who may enter our premises, access our information, or use our services. As an organization, we respect and uphold the requirements set forth under the Accessibility for Ontarians with Disabilities Act, 2005, and its associated regulations.

Behr Process Canada Ltd understands that we have a responsibility for ensuring a safe, dignified, and welcoming environment for everyone. We are committed to ensuring our organization’s compliance by incorporating accessibility legislation into our policies, procedures, equipment requirements, training, and best practices. We will review these policies and practices annually, as organizational changes occur, or in anticipation of compliance deadlines. In addition, we will strive to meet the needs of individuals with disabilities in a timely and effective manner.

Providing an accessible and barrier-free environment is a shared effort, and we are committed as an organization to working with the necessary parties to make accessibility for all a reality. For more detailed information on our accessibility policies, plans, and training programs, please contact our People Services Dep.

Sincerely,
Helene Bilodeau
Consultant, People Services, Canada 403-273-0226 ext.5228

AODA – Integrated Accessibility Standards Regulation (IASR) Customer Service Policy

Intent

All goods and services provided by Behr Paint Company (“Behr Canada Ltd”, “Behr Paint Company”, “Behr”, Company”) will follow the principles of dignity, independence, integration, and equal opportunity.

This policy meets the requirements of the customer service standards included in the Integrated Accessibility Standards Regulationunder theAccessibility for Ontarians with Disabilities Act, 2005.It applies to the provision of goods and services to the public or other third parties, not to the goods themselves.

Definitions

Assistive Device – is a technical aid, communication device or other instrument that is used to maintain or improve the functional abilities of people with disabilities. Personal assistive devices are typically devices that customers bring with them such as a wheelchair, walker or a personal oxygen tank that might assist in hearing, seeing, communicating, moving, breathing, remembering and/or reading.

Disability – the term disability as defined by the Accessibility for Ontarians with Disabilities Act, 2005,and the Ontario Human Rights Code,refers to:

• any degree of physical disability, infirmity, malformation or disfigurement that is caused by bodily injury, birth defect or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
• a condition of mental impairment or a developmental disability;
• a learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
• a mental disorder; or
• an injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.

Guide Dog – is a highly-trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety and increased independence for people who are blind.

Service Animal – A service animal for a person with a disability if:

1. The animal can be readily identified as one that is being used by the person for reasons relating to the person’s disability, as a result of visual indicators such as the vest or harness worn by the animal; or
2. The person provides documentation from a member of one of the following regulated health professional colleges confirming that the person requires the animal for reasons relating to the disability:
   • College of Audiologists and Speech-Language Pathologists of Ontario;
   • College of Chiropractors of Ontario;
   • College of Nurses of Ontario;
   • College of Occupational Therapists of Ontario;
   • College of Optometrists of Ontario;
   • College of Physicians and Surgeons of Ontario;
   • College of Physiotherapists of Ontario;
   • College of Psychologists of Ontario; or
   • College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario.

Support Person – In relation to a person with a disability, another person who accompanies them in order to help with communication, mobility, personal care, medical needs, or access to goods and services.

Guidelines

The Provision of Goods and Services to Persons with Disabilities

Behr will make every reasonable effort to ensure that its policies, practices and procedures are consistent with the principles of dignity, independence, integration and equal opportunity by:

• ensuring that all customers receive the same value and quality;
• allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services as long as this does not present a safety risk;
• using alternative methods when possible to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
• taking into account individual accommodation needs when providing goods and services; and
• communicating in a manner that takes into account the customer's disability.

The Use of Assistive Devices

Customer’s own assistive device(s):

Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the company.

In cases where the assistive device presents a health and safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services, up to the point of undue hardship.

For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank might involve ensuring the customer is in a location that would be considered safe for both the customer and business.

Alternatively, where elevators are not present and where a customer requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.

Guide Dogs, Service Animals and Service Dogs

A customer with a disability who is accompanied by a guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs or service animals.

Staff may respectfully ask if an animal is a service animal and will not ask the nature of the person’s disability or purpose of the animal.

Food Service Areas:

A customer with a disability who is accompanied by guide dog or service animal will be allowed access to food service areas that are open to the public unless otherwise excluded by law.

Other types of service animals are only permitted into areas where food is served, sold, or offered for sale due to the Health Protection and Promotion Act, Ontario Regulation 493/17.

Exclusion Guidelines:

If a customer’s guide dog or service animal is excluded by law (see applicable laws below), Behr Process Canada Ltd will offer alternative methods to enable the person with a disability to access goods and services, when possible. For example, the company might accommodate a customer’s disability by securing the animal in a safe location and offering the assistance of an employee to facilitate the delivery of goods and services.

Applicable Laws:

Food Safety and Quality Act, 2001, Ontario Regulation 31/05: Animals not intended for slaughter or to be euthanized are not allowed in any area or room of a meat plant. An exception is made for service dogs to allow them in those areas of a meat plant where food is served, sold, or offered for sale to customers and in those areas that do not contain animals or animal parts and are not used for the receiving, processing, packaging, labeling, shipping, handling, or storing of animals or parts of animals.

Dog Owners’ Liability Act, 2005: If there is a conflict between a provision of this legislation or of a regulation under this or any other act relating to banned breeds (such as pit bulls) and a provision of a by-law passed by a municipality relating to these breeds, the provision that is more restrictive in relation to controls or bans on these breeds prevails. Staff will respectfully explain that the service animal must be removed from the public area due to a municipal by-law and make alternate arrangements or provide the service outside the public area.

Recognizing a Guide Dog, Service Dog and/or Service Animal:

If it is not readily apparent that the animal is being used by the customer for reasons relating to his or her disability, Behr may request verification from the customer.

Care and Control of the Animal:

The customer that is accompanied by a guide dog or a service animal is responsible for maintaining care and control of the animal at all time.

Allergies and Other Health and Safety Concerns:

If a health and safety concern presents itself, for example, in the form of a severe allergy to the animal, Behr Process Canada Ltd will make all reasonable efforts to meet the needs of all individuals. Pursuant to the company’s obligations under the Human Rights Code and the Occupational Health and Safety Act, each customer’s accommodation needs will be considered on a case-by-case basis, up to the point of undue hardship.

Due diligence needs to be paid to address health and safety requirements. For example, if a person’s health and safety could be seriously affected by the presence of a service animal on the premises open to the public, management must fully analyse all options for safely accommodating the service animal. Options could include creating distance between the two individuals to eliminate in-person contact, changing the time the two individuals receive service, or using air purifiers and other measures that could allow the person to use their service animal on the premises.

In very exceptional circumstances where a service animal becomes out of control, causing a clear disruption or a threat to the health and safety of others, and the animal’s behaviour is not corrected by the owner, a person with a disability can be asked to remove their service animal from the premises.

As a courtesy, particularly if the person and service animal have been in attendance on the premises for a long time, staff may ask whether the animal requires water, may designate an area in which the service animal can relieve itself, or ask whether the staff can be of assistance pertaining to the service animal.

Support Persons:

If a customer with a disability is accompanied by a support person, Behr will ensure that both persons are allowed to enter the premises together and that the customer is not prevented from having access to the support person.

There may be times where seating and availability prevent the customer and support person from sitting beside each other. In these situations, Behr will make every reasonable attempt to resolve the issue.

In situations where confidential information might be discussed, consent will be obtained from the customer before any potentially confidential information is mentioned.

Admission Fees:

Where the company requires a support person to accompany a person with a disability, and where the person with a disability has agreed to the accompaniment, the company will not charge the support person any fees or fares.

Notice of Disruptions in Service:

Service disruptions may occur due to reasons that may or may not be within the control or knowledge of Behr. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use Behr's goods or services, reasonable efforts will be made to provide advance notice. In some circumstances such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

Notifications will Include:

Service disruptions may occur for reasons that may or may not be within the control or knowledge of Behr Process Canada Ltd. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use goods or services, reasonable efforts will be made to provide advance notice. In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible.

If a notification needs to be posted, the following information will be included unless it is not readily available or known:

• Goods or services that are disrupted or unavailable;
• Reason for the disruption;
• Anticipated duration; and
• A description of alternative services or options.

Notifications Options:

When disruptions occur Behr will provide notice by:

• posting notices in conspicuous places including at the point of disruption, at the main entrance and the nearest accessible entrance to the service disruption.
• contacting customers with appointments;
• verbally notifying customers when they are making a reservation or appointment; or
• by any other method that may be reasonable under the circumstances.

Customer Feedback:

Behr shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers and notice of the process will be made available by way of website. Click Here to access our Feedback form, or visit our Contact Us page for alternate methods of providing feedback such as verbally (in person or by telephone) or written (hand written, delivered, or email), will be available upon request.

Submitting Feedback:

Customers can submit feedback by:

Mail:
People Service Dept.
Behr Canada Ltd
#110 - 600 Barlow Square SE,
Calgary, Alberta
T2C 5T7
Phone:403-273-0226 ext. 5228

In Person:
Distribution Manager
Behr Canada Ltd
40 Herford Street – Unit #20
Brampton, ON
L6Y 0N3
Phone: 905-822-1686 ext. 4682

Email: AODA@behr.ca

Customers who wish to provide feedback by completing an onsite customer feedback form or verbally can do so to People Service Dept or Distribution Manager.

Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.

Training

Training will be provided to:

• Every employee of or a volunteer with Behr;
• Every person who participates in developing the policies of Behr; and
• Every other person who provides goods, services, or facilities on behalf of Behr.

Training Provisions:

Regardless of the format, training will cover the following:

• A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005;
• A review of the requirements of the customer service standards;
• Instructions on how to interact and communicate with people with various types of disabilities;
• Instructions on how to interact with people with disabilities who:
  • Use assistive devices;
  • Require the assistance of a guide dog or other service animal; or
  • Require the use of a support person (including the handling of admission fees);
• Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities;
• Instructions on what to do if a person with a disability is having difficulty accessing our services; and
• Policies, procedures, and practices of the company pertaining to providing accessible customer service to customers with disabilities.

Training Schedule:

Behr will provide training as soon as practicable. Training will be provided to new employees, volunteers, agents and/or contractor who deal with the public or act on our behalf during orientation or the first 6 months of employment. Revised training will be provided in the event of changes to legislation, procedures policies, or practices.

Record of Training:

Behr will keep a record of training that includes the dates training was provided and the number of employees who attended the training.

Notice of Availability and Format of Documents:

Behr Process Canada Ltd shall notify customers that the documents related to the customer service standards are available upon request and in a format that takes into account the customer’s disability. Notification will be given by posting the information in a conspicuous place owned and operated by Behr Process Canada Ltd, the website of Behr Process Canada Ltd, and any other reasonable method.

Administration:

If you have any questions or concerns about this policy or its related procedures, please contact:

People Service Dept.
Behr Canada Ltd
2750 Centre Avenue NE
Calgary, Alberta
T2C 4G8
Phone: 403-273-0226 ext. 5228
 

Distribution Manager
Behr Canada Ltd
40 Herford Street – Unit #20
Brampton, ON
L6Y 0N3
Phone: 905-822-1686 ext. 4682

Email: AODA@behr.ca

This policy and its related procedures will be reviewed as required in the event of legislative changes.

AODA – Integrated Accessibility Standards Regulation (IASR) Employment Policy

Intent

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Employment Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of accessible employment services for persons with disabilities.

All employment services provided by Behr shall follow the principles of dignity, independence, integration and equal opportunity.

Definitions

Accessible Formats – Include but are not limited to large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Performance Management – Activities related to assessing and improving employee performance, productivity and effectiveness with the goal of facilitating employee success.

Redeployment – The reassignment of employees to other departments or jobs within the organization as an alternative to layoff, when a particular job or department has been eliminated by the organization.

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following:

A. General Requirements

General requirements that apply across all of the five (5) standards (information and communication, employment, transportation, design of public spaces, and customer service) are outlined as follows.

Establishment of Accessibility Policies and Plans

Behr Paint Company (“Behr Canada Ltd”, “Behr Paint Company”, “Behr”, “Company”) will develop, implement and maintain policies governing how it will achieve accessibility through these requirements.

Training Requirements

Behr Process Canada Ltd will provide training for its employees and volunteers regarding the IASR and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will also be provided to individuals who are responsible for developing Behr Process Canada Ltd's policies, and all other persons who provide goods, services or facilities on behalf of Behr Process Canada Ltd.

Training will be provided as soon as is reasonably practicable, but no later than 6 months after the start of employment. Training will be provided on an ongoing basis to new employees and as changes to Behr Process Canada Ltd's accessibility policies occur.

Recruitment, Assessment and Selection

Behr will notify employees and the public about the availability of accommodation for job applicants who have disabilities. Applicants will be informed that these accommodations are available, upon request, for the interview process and for other candidate selection methods. Where an accommodation is requested, Behr will consult with the applicant and provide or arrange for suitable accommodation.

Successful applicants will be made aware of Behr’s policies and supports for accommodating people with disabilities.

Accessible Formats and Communication Supports for Employees

Behr will ensure that employees are aware of our policies for employees with disabilities and any changes to these policies as they occur.

If an employee with a disability requests it, Behr will provide or arrange for the provision of accessible formats and communication supports for the following:

• Information needed in order to perform his/her job; and
• Information that is generally available to all employees in the workplace.

Behr Paint Company will consult with the employee making the request to determine the best way to provide the accessible format or communication support.

Workplace Emergency Response Information

Where required, Behr will create individual workplace emergency response information for employees with disabilities. This information will take into account the unique challenges created by the individual’s disability and the physical nature of the workplace, and will be created in consultation with the employee.

This information will be reviewed when:

• The employee moves to a different physical location in the organization;
• The employee’s overall accommodation needs or plans are reviewed; and/or
• Behr reviews general emergency response policies.

Performance Management and Career Development and Advancement

Behr will consider the accessibility needs of employees with disabilities when implementing performance management processes, or when offering career development or advancement opportunities.

Individual accommodation plans will be consulted, as required.

Redeployment

The accessibility needs of employees with disabilities will be taken into account in the event of redeployment.

Individual accommodation plans will be consulted, as required.

Review

This policy will be reviewed regularly to ensure that it is reflective of Behr’s current practices as well as legislative requirements.

AODA – Integrated Accessibility Standards Regulation (IASR) Information and Communications Policy

Intent

This policy is intended to meet the requirements of the Integrated Accessibility Standards, Ontario Regulation 191/11 for the Information and Communications Standard set forth under the Accessibility for Ontarians with Disabilities Act, 2005. This policy applies to the provision of information and communications services and materials for people with disabilities.

All information and communications materials and services provided by Behr Process Canada Ltd shall follow the principles of dignity, independence, integration and equal opportunity.

Definitions

Accessible Formats – Include but are not limited to large print, recorded audio and electronic formats, braille and other formats usable by persons with disabilities.

Communication Supports – Include but are not limited to captioning, alternative and augmentative communication supports, plain language, sign language and other supports that facilitate effective communications.

Conversion Ready – An electronic or digital format that facilitates conversion into an acceptable format.

General Principles

In accordance with the Integrated Accessibility Standards, Ontario Regulation 191/11, this policy addresses the following: