Accessibility Policy – The Customer Service Standard

The Customer Service Standard as set out in the Accessibility for Manitobans Act (AMA) and the Accessibility for Ontarians Act (AODA) seeks to ensure that all people who seek to obtain, use or benefit from a good or service have the same opportunity to obtain, use or benefit from the good or service.

It is our aim and legal obligation to make our business accessible to the public. This includes members of the public with disabilities, or those for whom some element in our Company may create a barrier. This includes all divisions of PIL and all subsidiaries of PIL within Canada.


Disabilities can be physical, mental, intellectual or sensory. Some examples are impaired hearing, impaired vision, mobility-related issues, dexterity issues, and cognitive issues. It is important to remember that not all disabilities are visible.


Sometimes people with disabilities can access our business without any accommodations. Sometimes, there are barriers which prevent people with disabilities from accessing our business on an equal basis.

These barriers can take many forms. They can be physical barriers, such as clutter blocking a hallway, architectural barriers, such as stairs, communication barriers, such as signs which are confusing or too small, technological barriers, such as a website which cannot be used by a person using a screen reader, and attitudinal barriers, such as not understanding or respecting people with disabilities.

Our Commitment

It is our obligation, as a company, to:

  • identify barriers to accessible customer service;
  • remove barriers to accessible customer service;
  • prevent the creation of new barriers to accessible customer service; and seek to provide equivalent customer service to all customers, regardless of ability.

Identifying Barriers

We will undertake a review to determine existing barriers, and a plan for removing or avoiding those barriers. Managers who host external customers are encouraged to audit their location using our Checklist for Accessibility Form (Form-HR-5263) Employees should advise their Managers in writing of any barriers or potential barriers of which they are aware, or become aware at any time during their employment. Managers will forward to the Accessibility Manager, Samantha Rayburn for review using email address: [email protected]

Removing Barriers

It is our commitment to remove as many barriers to access as we reasonably can. If a barrier cannot be removed by reasonable means, we need to identify an alternate means by which to provide access. For example, if for some reason a document cannot be supplied in a format accessible to the customer, an employee may read the document to the customer, if that would allow the customer to access the information.

We cannot impose a fee or charge to provide an accommodation unless the accommodation could not be reasonably provided without it. In that case, the customer should be told of the fee or charge in advance in a manner which clearly explains why the fee or charge is necessary.

Removing Barriers – Specific Examples

Assistive devices

Some people may use or benefit from assistive devices to remove or reduce a barrier. These devices must be reasonably accommodated. For example, hallways accessible to the public should be clear of clutter so that a person using a wheelchair, scooter, walker or cane will not be impeded. Waiting rooms, reception areas, or other areas open to the public should be configured to allow for the use of a wheelchair, scooter, walker or cane. Documents should be created in a format that allows them to be read by a screen reader, so that they are accessible to people who are visually impaired.

Support People

A customer may be accompanied by a support person. The customer and support person must be allowed to access the premises together, and the customer should have access to the support person at all times while on Company premises. This means that any waiting room, meeting room or office where a customer is expected to be should be able to accommodate at the very least a Company representative, a customer, whether using a wheelchair or not, and a support person. Washroom facilities should allow for access by the customer accompanied by a support person.

Service Animals

A customer may be accompanied by a service animal in all public areas. Reception areas, and other areas open to the public should be designed with this in mind.


All documents should include the phrase “alternative formats available on request”. These alternative formats should be available in a larger font, plain font, plain language, and accessible to those using a screen reader. The Company website, Facebook page, or other on-line presence should be treated as a document, include the same phrase, and be available in the same formats.


All signs should be simple with large, clear lettering. If signs are posted in a public area, and the signs contain information that the public needs to know, consider making auditory announcements to the same effect periodically. For example, if customers need to take a number to be served, that should be announced periodically, and the number being served should be both visible visually and announced audibly.

All documents, policies, manuals, presentations and guidelines should be clearly marked advising customers and employees that alternative formats are available upon request.

Common Accessible/Alternative Formats

Accessible or alternative formats include a wide range of information formats including:

  • Accessible Adobe Acrobat PDF;
  • Audio Format;
  • Electronic Text;
  • HTML;
  • Large Print (16 point or larger, Sans Serif Font);
  • Accessible Websites (providing information on accessible websites).
  • Common modifications to documents to improve accessibility for person with visual disabilities include:
  • Changing font size and style;
  • Changing foreground and background colours;
  • Changing the spacing between characters, words and lines.

Future changes in technology and the communication needs of person with disabilities may result in changes to these procedures.

SolutionAir respects the rights of all persons to access information and will respond to requests for alternative formats promptly. Converting information and communications for individuals with disabilities will be given a high priority. The timeframe for alternative format conversions will vary depending on the format chosen, the size and complexity of the document, the quality of source documents, and the number of documents to be converted.

Those responsible for providing documents in alternative formats will keep the individual informed of the progress of their request.

SolutionAir will absorb all reasonable costs associated with converting and distributing our materials to alternative formats for individuals with disabilities. Individuals with disabilities will not be charged a greater cost for alternative formats that the cost charged to others for information or communication in ordinary formats.


SolutionAir will strive to make reasonable efforts to provide accessible information and communications to persons with disabilities, however exceptions exist. Exceptions include the following reasons:

  • It is not technically feasible to convert the information or communication;
  • The technology required to convert the information or communication is not readily available;
  • SolutionAir does not control the information directly or indirectly through a contractual relationship; or
  • The materials are exempt from the conversion requirements of the Standard.

If it has been determined that the information or communication cannot be converted into an alternative format or provided through communication supports the reasons for this will be explained to the person who is making the request. They will be provided with a summary of the information and/or communication being requested. The format of the summary will be determined in consultation with the individual and provided in a method that considers their disability.

Built Environment

We will undertake a review to determine existing barriers, and create a plan for removing or avoiding those barriers. Employees should advise their Managers in writing of any barriers or potential barriers of which they are aware, or become aware at any time during their employment. Managers will forward this to the Human Resources Department.

This includes:

  • ensuring hallways and passage ways are clear of debris so that they are wheelchair accessible.
  • considering the use of door levers instead of knobs, where automated door openers are not available.
  • ensure that where there are stairs, an alternate access is available (ramp, elevator, etc.), and a sign is posted near the stairs indicating where and how to access the alternate.
  • ensure that doorways, walks, ramps and parking areas are kept clear of snow or other blockages.
  • ensure a chair is available wherever members of the public are expected to spend time, so that customers can sit or stand as required.
  • ensure that public areas are configured to allow access by wheelchair, scooter, walker, cane or other assistive devices, as well as being able to accommodate a support person and/or service animal.
  • ensure washroom facilities are accessible.

Where Barrier Free Access is Temporarily Unavailable

Where any aspect of our operations that is intended to facilitate access is temporarily unavailable for use (for example, where an automatic door opener or elevator is out of service), a notice must be displayed indicating the reason for the unavailability, the estimated timeframe for when access will be restored, and details of any alternate means of access. Where possible, this information shall also be posted to our Company website. Any employee aware of this unavailability should immediately contact their Manager and their Manager will forward to the Human Resources Department.

A sample notice for inside Company premises is “This elevator is temporarily out of service. Please see reception for more information”. Reception should be advised that the notice is being posted and prepared to answer questions re alternate access.

A longer sample notice suitable for the website is “We apologize for the inconvenience, but our elevator is currently out of service. We expect service to be resumed Tuesday. In the meantime, any appointments booked to take place on the higher floors may be relocated to the main floor boardroom upon prior request.”

Tips for Interacting with Customers

When speaking to a customer, do not make assumptions about what people can or cannot do. If you are unsure, and need to know, ask “How can I help”?

Do not ask personal questions, unless the information is required in order to provide the service or product in question.

When dealing with a customer with a support person, speak to the customer, not the support person unless directed otherwise.

Employees serving customers directly should keep a pen and paper available to aid in communication.

When travelling alongside a person using a wheelchair, do not take control of the wheelchair without permission.

When speaking to someone who is using a service dog, do not pet or attempt to distract the dog. If allowed, the handler will advise.

A chair should be available to allow customers to stand or sit as necessary.


Any feedback you receive with respect to accessibility issues should be submitted in writing to your Manager and your Manager will forward to the Human Resources Department as soon as possible. As much detail as possible should be included: date, time location, name and contact information of anyone concerned (if possible), and a detailed description of the situation, the comments received and any action taken.

If a customer indicates that s/he would like to provide feedback or comments, please provide them with a copy of our “Feedback Form” located on our ISO (Form-HR-5262), and an opportunity to fill it out. Also direct the customer to the Company website which has a feedback functionality.

Human Resources will keep a written record of any actions taken in response to feedback. Such records shall be made available upon request.


SolutionAir will ensure that employees who are expected to interact with customers are trained in:

  • How to interact with persons disabled by barriers, including those who use assistive devices or who require the assistance of a support person or service animal;
  • How to use any equipment or assistive devices available in the workplace;
  • What to do if someone is having trouble accessing a good or service provide by our Company; and
  • A review of The Accessibility for Manitobans Act, The Accessibility for Ontarians Act, the Customer Service Standard Regulation, The Human Rights Code (Province specific).

This training shall be provided as part of a new employee’s orientation, or as soon as an employee is put into a position which requires interaction with the public. Existing employees who have not received such training shall be trained as soon as possible. Ongoing training will be given as our practices or policies evolve over time.

The Human Resources Department will keep a documentary record of our training policy, a summary of the content of training which is provided, and a record of when training is provided.

Public Events

Any public events which we organize or take part in should be accessible to people disabled by barriers. This means that notice of the event should be available in alternate formats and should indicate that relevant supports may be requested (sign language interpreter, ramp, etc.). Events should only be held in accessible venues.

Preventing the Creation of New Barriers

We will review any changes to the built environment, documentation, communications, website or other means of interacting with customers to ensure that new barriers are not inadvertently created. Employees should advise their Managers in writing of any potential barriers of which they are aware, or become aware at any time during their employment.

Availability of this Policy

Human Resources will make and maintain written copies of all measures, policies and practices established or implemented with respect to accessibility. This documentation must be made available upon request. Human Resources will ensure that the fact that this documentation is available upon request is posted in the Company’s premises where the public is likely to see it, as well as on the Company website.

Related documents

  • Customer Feedback Form (Form-HR-5262);
  • Checklist for Accessibility Form (Form-HR-5263)

Alternative formats available upon request.