Back to Accessibility at DARTS

Policy #

HR-24-013

Effective Date

April 27, 2026

Applies To

All employees (senior management, non-union, union) and subcontractors

Department Owner

Human Resources

Download a copy of this policy (Word document, 84 KB)

Preamble

DARTS is a non-profit specialized transit service with over 50 employees in Ontario. In accordance with the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and its regulations, and as part of our commitment to an accessible Ontario, DARTS has developed this Accessibility Policy.

This policy, along with our Statement of Commitment and Multi-Year Accessibility Plan, fulfills our legal obligations under the AODA for organizations of our size. It includes our organizational commitment to accessibility, our strategies for providing accessible services, and our ongoing compliance with the Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11) – which encompasses the Customer Service, Information and Communications, Employment, Transportation, and Design of Public Spaces Standards – as well as alignment with the principles of the Ontario Human Rights Code.

Note: The AODA standards do not substitute or limit our obligations under the Ontario Human Rights Code. DARTS recognizes that we must meet or exceed both the AODA requirements and our duty to accommodate individuals with disabilities to the point of undue hardship as mandated by the Human Rights Code. This policy is intended to be interpreted in a manner consistent with all applicable legislation, including the AODA and the Human Rights Code.

Purpose

The purpose of this policy is to ensure that persons with disabilities have equitable access to DARTS services, information, and employment opportunities, without barriers. A formal accessibility policy helps create equal opportunity for all and makes it easier for people with disabilities to engage with our organization. It guides DARTS in meeting its obligations under accessibility laws such as the AODA and the Ontario Human Rights Code, and in implementing best practices for inclusion and accommodation.

Statement of Commitment

DARTS is committed to upholding and, where possible, exceeding Ontario’s accessibility laws to remove barriers for people with disabilities. We will provide equal access to our services, information, and employment opportunities, and will treat people with disabilities with dignity and respect in a way that considers their individual needs and disabilities. We are committed to meeting the accessibility needs of persons with disabilities in a timely manner, as required by the AODA and related regulations. Our full Statement of Commitment is publicly available on our website and affirms our organization’s vision of an inclusive environment for people of all abilities.

Definitions

For the purpose of this policy, the following definitions apply:

Accessibility Plan

A plan that outlines the steps an organization is taking and will take to prevent and remove barriers to accessibility and meet AODA requirements. It includes timelines for implementing these steps.

Accessibility Policy

The formal rules and guidelines an organization puts in place to achieve its accessibility goals. This document constitutes DARTS’ Accessibility Policy.

AODA

The Accessibility for Ontarians with Disabilities Act, 2005. The AODA and its regulations establish standards in five key areas: Customer Service, Information and Communication, Employment, Transportation, and Design of Public Spaces.

Accessible Transportation Services (ATS)

Accessible Transportation Services (ATS) is a division of the City of Hamilton responsible for administering the eligibility, registration, and customer service functions related to specialized transit services. ATS determines eligibility for specialized transit, manages passenger registration and profiles, and provides ongoing customer support. DARTS delivers specialized transit services in coordination with ATS in accordance with applicable legislation, policies, and service agreements.

Barrier

Anything that prevents a person with a disability from fully participating in all aspects of society because of their disability. Barriers can be physical, architectural, information/communication, attitudinal, technological, or organizational (policy or practice).

Disability

As defined in the Ontario Human Rights Code, disability covers a broad range of conditions, including physical, sensory, intellectual, and mental health-related conditions. It includes, but is not limited to:

• Physical disabilities (e.g. paralysis, amputation, blindness, deafness, mobility impairments, epilepsy, etc.),
• Cognitive and intellectual or developmental disabilities,
• Learning disabilities or difficulties in understanding/using symbols or language,
• Mental health disorders, and
• Injuries or disabilities for which benefits were claimed under workplace safety legislation.

Mobility Device

A technical aid or equipment that people with mobility disabilities use to move around. Examples include wheelchairs, scooters, walkers, crutches, and canes.

Service Animal

In Ontario, a service animal is an animal trained to assist a person with a disability, recognized either by its visual appearance (vest/harness) or through documentation from a regulated health professional. ATS is responsible for ensuring that proper documentation is provided by passengers to meet the service animal designation – all other animals are considered pets. According to the Accessibility for Ontarians with Disabilities Act, 2005, service animals assist individuals with disabilities in daily activities or emergencies (e.g. guiding a person who is blind, alerting a person with diabetes to low blood sugar, protecting a person during a seizure). A service animal is permitted to accompany the person with a disability in areas open to the public, except where excluded by another law.

Reference: Travelling with Service Animals & Pets Policy (OP-25-011)

Support Person

An individual who accompanies a person with a disability to help with communication, mobility, personal care, medical needs or access to goods and services. A support person can be a paid professional, volunteer, family member, or friend.

(Note: Additional relevant terms can be found in the AODA and Ontario Human Rights Commission. DARTS adopts the definitions of disability and other terms as outlined in applicable legislation.)

Responsibilities

Employee Responsibilities

All DARTS personnel (including employees at all levels, volunteers, and contractors providing services on our behalf) are responsible for adhering to this Accessibility Policy and the commitments set out herein. This includes following accessible customer service principles, participating in required training, and consistently applying accessibility best practices in their roles.

DARTS Senior Management Responsibilities

DARTS senior management is responsible for leading by example in the administration of this policy and ensuring organizational compliance. Key responsibilities of management include:

• Developing, implementing, and maintaining a Multi-Year Accessibility Plan that conforms to this policy, and addresses identified barriers and requirements.
• Regularly reviewing and updating accessibility policies, plans, and initiatives as required by law or organizational changes. Changes to policies or practices will incorporate accessibility considerations and will be communicated to staff.
• Monitoring and evaluating the effectiveness of accessibility initiatives and staying informed about changes to applicable legislation or regulations.
• Reporting on performance related to established accessibility goals and targets (for example, in accessibility plan status reports or management reviews).
• Communicating this policy (including the Statement of Commitment and Multi-Year Accessibility Plan) to all staff and making it available to the public (e.g., posting on the DARTS website).
• Establishing and implementing training programs to ensure all employees, volunteers, and relevant subcontractors are educated on Ontario’s accessibility standards and on removing attitudinal barriers toward people with disabilities.
• Ensuring that when procuring goods, services, or facilities on behalf of DARTS, accessibility criteria are considered (in accordance with Accessibility for Ontarians with Disabilities Act, 2005 requirements and as further described below in Procurement).

Human Resources (HR) Responsibilities

The HR department (as the policy owner) will support management in policy administration, record-keeping (e.g. training records), and integration of accessibility in employment practices such as recruitment, accommodation, and return-to-work processes.

Third-Party Subcontractor and Service Provider Responsibilities

DARTS will ensure that subcontractors or service providers who interact with our clients or provide services on DARTS’ behalf are aware of our accessibility policies and have received appropriate AODA training. This is to guarantee that services provided to the public or our employees by any third party are consistent with DARTS’ accessibility standards and the AODA.

Procedure

DARTS will make every reasonable effort to meet the requirements of the AODA and all applicable standards under the Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11). The following sections outline how DARTS meets or will meet each of the five key areas of accessibility:

1. Customer Service

DARTS is committed to providing accessible customer service to people with disabilities in accordance with the Accessibility Standards for Customer Service (Ontario Reg. 429/07, now integrated into IASR). We will carry out our functions and responsibilities in the following ways, consistent with the key principles of dignity, independence, integration, and equal opportunity:

• Communication: We will communicate with people with disabilities in ways that consider their disability. Staff will be trained on how to interact and communicate with customers with various types of disabilities and will strive to adapt communication styles or use alternative methods as needed (for example, reading information aloud for a person with a visual impairment or exchanging written notes with a person who is Deaf). We will work with the individual with a disability to determine what method of communication works best for them.
• Assistive Devices: People with disabilities are welcome to use their ATS-approved personal assistive devices when accessing our services. This may include mobility aids (wheelchairs, walkers, scooters), hearing aids, white canes, communication boards, or other assistive technologies. DARTS staff are trained to support customers who use assistive devices. For instance, our Operators and customer service staff are trained on the accessibility equipment installed in DARTS vehicles (such as ramps, lifts, and securement devices) and how to assist safely with these devices. In the rare case where a person’s assistive device presents a significant and unavoidable health or safety concern or is not permitted by law (e.g. for safety reasons on certain equipment), DARTS will attempt to accommodate the person in another way and ensure they can still access our service.
• Service Animals: DARTS welcomes customers with disabilities who use service animals. Service animals are allowed to accompany the person with a disability on all DARTS vehicles and in areas of our premises open to the public, except where otherwise prohibited by law. If it is not immediately obvious that an animal is a service animal (always check passenger profiles and notes in Trapeze or when using a vehicle tablet), DARTS staff may ask for documentation from a regulated health professional confirming that the person requires the animal for reasons relating to a disability. Service animals travel free of charge on DARTS, and wherever possible we will ensure the person with a disability is able to remain with their service animal. Passengers are required to inform reservationists at the time of booking if they will be travelling with a service animal, to ensure appropriate vehicle scheduling and to help manage potential conflicts such as severe allergies.
• Support Persons: Any person with a disability who is accompanied by a support person will be permitted to have that support person accompany them on DARTS vehicles and premises. A support person might assist with communication, mobility, personal care, medical needs or with access to goods and services. DARTS does not charge fare or fees for support persons accompanying a passenger with a disability on our transit service. If any fare were normally required, we would waive it for the support person, as per AODA requirements and ATS policy. ATS posts a notice about the availability of support persons travelling at no cost on their website and in information provided to new registrants of the service (e.g. rider guides or eligibility letters). In certain situations, ATS may require that a person with a disability be accompanied by a support person for health or safety reasons. For example, if a person’s behaviour or medical condition during transit could pose a significant risk to themselves or others without assistance. Before making any such requirement, ATS will consult with the person to understand their needs, consider all available evidence, and determine if there is no other reasonable way to ensure safety. If ATS determines a support person is necessary for safe service, they will waive any fare for that support person (and will communicate the reasons for this decision to the customer).
• Notice of Temporary Disruptions: DARTS will notify customers promptly in the event of a planned or unexpected disruption. For example, if our phone booking system goes down or if certain DARTS vehicles are unavailable, we will post and broadcast a notice. The notice will include information about the reason for the disruption, its expected duration, and a description of alternative services available (if any). Notices will be made publicly available through appropriate channels, which may include our website, social media, automated telephone messages, and on-site postings at the affected location. We recognize the importance of providing as much advance notice as possible for planned interruptions and timely updates for unplanned ones.
• Feedback Process (Customer Feedback): DARTS welcomes feedback on how we provide accessible customer service. Receiving feedback allows us to identify areas for improvement and respond to concerns promptly. Feedback from customers or the public can be provided through multiple channels:
  • By phone: Customers may call DARTS at 905-529-1717 to provide feedback verbally. Our reservationists or staff will document the feedback.
  • By email: Feedback can be sent via email to info@dartstransit.com.
  • In writing: Individuals can mail or deliver written feedback to DARTS at 235 Birch Avenue, Hamilton, ON L8L 0B7.
  • Other formats: Upon request, we will arrange to receive feedback in accessible formats or using communication supports.

  All feedback, including complaints, will be directed to ATS or DARTS management review and action.

• Notice of Availability of Documents: DARTS notifies the public through our website that our accessibility-related documents (including this Accessibility Policy, our Statement of Commitment, and our Multi-Year Accessibility Plan, as well as any documentation required by the Customer Service Standard) are available upon request in accessible formats. Upon request, DARTS will provide any public document required by the Accessibility for Ontarians with Disabilities Act, 2005 (for example, our emergency procedures or public safety information, when required to be public) in an accessible format or with communication support, in a timely manner and at no additional cost. We will consult with the person making the request to determine a suitable format or support for them.

2. Information and Communications

DARTS is committed to making our information and communications accessible to people with disabilities. This fulfills the requirements of the Information and Communications Standards under the Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11) and ensures that all customers can receive and share information with us effectively.

• Accessible Formats and Communication Supports: Upon request, DARTS will provide or arrange for the provision of information in accessible formats (e.g. large print, braille, audio) or with communication supports (e.g. reading content aloud, using a relay service, plain language summaries) for persons with disabilities. This includes information about our organization, our services, and emergency or public safety information that we make available to the public. We will provide the requested information in a timely manner – as soon as practicable – taking into account the person’s accessibility needs, and at a cost no greater than the regular cost charged to others for the same information. We will consult with the individual to determine the most suitable format or support based on their needs. If a specific piece of information or communication is unconvertible (for example, a technical schematic that cannot be easily rendered in an alternate format), DARTS will provide the person with an explanation as to why it is unconvertible and provide a summary of the content instead.
• Accessible Websites and Web Content: DARTS understands the importance of accessible digital content. We will ensure that our internet website, including web-based booking portal and content, conforms to the Web Content Accessibility Guidelines (WCAG) 2.0 at Level AA, as required by the Accessibility for Ontarians with Disabilities Act, 2005’s Information and Communications Standards. (All new websites or significantly refreshed sites after 2014 must meet WCAG 2.0 AA, and as of January 1, 2021, all public websites and web content of large organizations must comply.) DARTS has already taken steps to meet these requirements by, for example, adopting an accessible web platform for our online portal and testing it for compliance. We will continually assess and improve the accessibility of our digital services, ensuring features like text alternatives for images, keyboard navigability, clear content structure, and sufficient color contrast are in place. We will also monitor for updated guidelines (such as WCAG 2.1) as part of our commitment to best practices in digital accessibility.
• Public Safety and Emergency Information: Any emergency procedures, public safety information, or emergency evacuation plans that DARTS makes available to the public will be provided in an accessible format or with appropriate communication supports upon request. For example, if DARTS publishes a safety guide for riders or emergency instructions in our vehicles, we will ensure that alternate formats are available (such as Braille or audio) for those who need them. Internally, we also ensure that employees with disabilities have individualized emergency response information (covered under Employment standards below).
• Feedback Processes: As noted in the Customer Service section, DARTS’ feedback processes (for customers and for employees) are accessible or will be made accessible upon request. This satisfies Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11) requirements that any process for receiving and responding to feedback is accessible. We ensure that individuals can provide feedback in various ways and request accessible formats for that process if needed.
• Communication Supports for Clients: Our primary client interactions are by telephone and through our online booking portal. We accommodate various communication needs in these channels. Staff are trained to speak clearly, listen patiently, and, if needed, communicate via email or text as an alternative. For clients with speech impairments, we welcome the use of speech-generating devices or having a support person communicate on their behalf (with consent). Our online portal is designed to be screen-reader compatible, and we provide user support over the phone for anyone having difficulty using it.
• Notice to the Public: We notify the public about the availability of accessible formats and communication supports. This notice is provided on our website. For instance, our website includes a statement that information about DARTS and our services is available in alternate formats upon request, with contact information to make such requests.

3. Employment

DARTS is committed to fair and accessible employment practices, as required by the Employment Standards under the IASR and consistent with the Ontario Human Rights Code’s duty to accommodate. We strive to remove barriers at all stages of the employment life cycle, from recruitment to career development, so that employees and job applicants with disabilities are supported.

Our employment-related accessibility measures include:

• Recruitment, Assessment, and Selection: DARTS notifies employees and the public of the availability of accommodations for applicants with disabilities in our recruitment process. Job postings on our website and external job boards include a statement that accommodations are available on request for candidates taking part in all aspects of the selection process. When contacting shortlisted candidates for interviews or assessments, we inform them that accommodations are available upon request. If a job applicant requests accommodation, DARTS will consult with them to arrange suitable accommodations in a manner that considers their needs (for example, providing extra time for a written test, ensuring interview locations are physically accessible, or offering alternative formats for interview materials). We ensure that HR personnel are trained on these processes.
• Notice to Successful Applicants: When making offers of employment, DARTS notifies the successful candidate of our policies on accommodating employees with disabilities. This is typically done in offer letters or orientation materials, reiterating that we will work with the new hire to address any accessibility needs in the workplace.
• Accommodation for Employees: As an employer, DARTS ensures that employees with disabilities are aware of our policies for supporting them. We inform all new and existing employees as soon as practicable about policies on job accommodations that consider disabilities.
• Accessible Formats and Communication Supports for Employees: If an employee with a disability needs information in an alternate format or requires communication support to do their job effectively or to access generally available workplace information, DARTS will provide or arrange for the provision of such accessible formats and supports. For instance, if an employee has low vision and needs documents in large print, or if an employee with a learning disability requests documents in digital text format that can be read by a screen reader, we will provide those. We will consult with the employee making the request to determine the suitability of any accessible format or communication support provided for workplace information.
• Individual Accommodation Plans: DARTS is committed to working collaboratively with employees with disabilities to develop individual accommodation plans. Accommodation plans are developed on an individualized basis in alignment with the requirements of the Integrated Accessibility Standards Regulation (IASR), Section 28. This includes the employee’s participation in the development of the plan, individual assessment of accommodation needs, identification of appropriate accommodations, and ongoing review and updates as required. Where applicable, the accommodation plan will include individualized workplace emergency response information (see below) and may outline accommodations such as assistive devices, schedule modifications, or building access improvements. DARTS ensures the confidentiality of personal information throughout this process. If an accommodation request cannot be accommodated as proposed, DARTS will communicate the reasons to the employee and will work with them to explore alternative accommodation solutions.
• Individual Emergency Response Information: In accordance with Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11) and as a good practice, DARTS provides individualized workplace emergency response information to employees who have disabilities, if the disability makes such information necessary (and if DARTS is aware of the need). For example, if an employee has a mobility impairment and may need assistance during a fire evacuation, we develop an emergency plan for that individual (with their input), such as assigning a “buddy” to assist or ensuring evacuation chairs are available. With the employee’s consent, this information will be shared with the person designated to assist them in an emergency. We review the individualized emergency response plans when the employee moves to a different location, when their overall accommodation needs or plans are reviewed, and when DARTS reviews its general emergency response policies.
• Return to Work Process: DARTS has a documented return-to-work process for employees who have been absent due to a disability and require disability-related accommodation to return to work. This process outlines the steps we take to facilitate a smooth return to work, including, for example, obtaining relevant medical information (with consent) about restrictions, developing a gradual return schedule if needed, implementing workplace accommodations, and involving the employee in planning. This process is distinct from (but complementary to) any WSIB return-to-work processes for work-related injuries.
• Performance Management, Career Development, and Redeployment: DARTS will ensure that accessibility needs of employees with disabilities, and any individual accommodation plans, are considered in our performance management processes, when providing career development and advancement opportunities, and during redeployment (reassignment to other roles). For example:
  • Performance Management: Supervisors and managers will be trained to provide performance feedback in a manner that accommodates an employee’s disability (e.g., allowing alternative demonstration of competencies if standard methods are not accessible, or providing documents in accessible formats for performance reviews) on an as-needed basis. We will not evaluate an employee’s performance in a way that overlooks accommodations they may require.
  • Career Development: When offering training, mentoring, or advancement opportunities, DARTS considers what accommodations employees with disabilities might need to participate fully (such as accessible training materials or adjustment of job duties to fit abilities and career goals).
  • Redeployment: If an employee with a disability is redeployed to another role, we ensure their accommodation needs are re-evaluated and met in the new role.

By incorporating these practices, DARTS ensures it not only meets the compliance deadlines and specifics of the AODA Employment Standards (most of which took effect by 2016 for large organizations) but also fulfills the ongoing duty to accommodate under the Human Rights Code.

4. Transportation (Specialized Transit Services)

As a specialized transit service provider (under contract for the City of Hamilton’s Accessible Transportation Services), DARTS is subject to the Transportation Standards in the AODA. We are committed to providing accessible transportation for people with disabilities and to complying with all requirements applicable to conventional and specialized transit services. Key aspects of our transportation-related accessibility policy include:

• Equitable Fares and Hours: DARTS follows direction from the City of Hamilton’s Accessible Transportation Services (ATS) to ensure that fares for our specialized transit rides are no higher than the fares for the equivalent conventional public transit in our area, and that the fare structure and payment options are comparable to those offered by the conventional transit system (Hamilton Street Railway (HSR)). This implements the fare parity requirements so that passengers with disabilities using DARTS are not charged more for transportation than they would pay on regular transit. DARTS also operates during the same days and hours as the conventional transit service, providing equivalent availability of service (with any exceptions mandated by the City’s service contract).
• Support Persons Ride Free: As noted under Customer Service section in this policy, DARTS transports support persons accompanying a person with a disability free of charge on all trips. Our client registration process (managed by ATS) can designate if a passenger requires a support person; however, even for occasional needs, Operators will not collect fare from an identified support person.
• Booking and Trip Scheduling: DARTS provides multiple accessible ways to book trips – via a phone reservation system with trained agents, and via an online booking portal that meets accessibility standards. We strive to accommodate same-day booking requests whenever possible. The AODA Transportation Standard requires that if a specialized transit service has an advance booking requirement, bookings should be allowed up to at least 3 hours before the end of the previous business day for next-day travel. DARTS meets or exceeds this requirement by permitting next-day bookings and, if capacity allows, by scheduling trips on the same day of service (for instance, to fill cancellations or unscheduled openings). We also allow passengers to book rides for companions (friends/family) to travel with them when space permits, and to bring dependent children, in accordance with the regulation. All booking methods are designed to be user-friendly and accessible (e.g., TTY via relay for phone bookings, and an accessible web interface for online bookings).
• Service Delays and Notifications: If a DARTS vehicle is running significantly behind schedule or if there is a delay of 30 minutes or more past the scheduled pickup time, DARTS will make efforts to inform the passenger of the delay and the estimated arrival time. Our dispatch system tracks vehicle timeliness and can trigger notifications. We may notify customers via an automated call or text message, or a live agent call, depending on the situation and the customer’s communication preferences. This practice ensures compliance with the requirement to inform passengers of prolonged delays and reflects our commitment to respectful, timely service.
• Passenger Assistance and Safety: All DARTS Operators and Call Centre personnel receive specialized training on serving riders with disabilities. This includes training on the safe use of accessible equipment and features on our vehicles (such as lifts, ramps, securement systems for wheelchairs and scooters, and passenger restraints). Operators are instructed to allow adequate time for passengers with disabilities to board, be secured (mobility devices properly fastened), and disembark safely. They will assist with safely storing mobility aids and no fees are ever charged for handling or storing mobility aids. Our Operators will also assist passengers with seatbelts, and with finding their seat or navigating to and from the vehicle as needed, while respecting each individual’s autonomy and preferences.
• Vehicle Accessibility Features: DARTS’ fleet is composed of accessible vehicles equipped to accommodate riders using wheelchairs and other mobility devices. Features include hydraulic lifts or low-floor ramp access, high-visibility step markings, and grab bars. We regularly maintain these features to ensure they remain in good working order. In the event an accessibility feature on a vehicle (e.g., a lift) is inoperable, we endeavor to repair it as soon as possible and not dispatch that vehicle for use by customers who would require the feature until it’s fixed. If a breakdown occurs during service, Operators are trained to find safe solutions (such as contacting the Call Centre for an alternate vehicle or assistance) and to keep the customer informed.
• Transit Stops / Pickup and Drop-off Locations: As a door-to-door service, DARTS picks up and drops off customers at predetermined addresses rather than fixed transit stops. However, if for some reason we cannot safely access a specific location (e.g., due to construction, inclement weather, or other temporary barrier), our Operator will take the passenger to the nearest safe location, and we will collaborate with Accessible Transportation Services to communicate with the passenger about the change. We rely on our Call Centre Agents to note any accessibility concerns at pickup/drop-off points (such as lack of curb cuts or construction zones) and convey that to Operators.
• No Refusal and Trip Restrictions: DARTS does not arbitrarily restrict the number of trips a person with a disability can request (no trip caps) and does not practice service denials based on disability. We operate under a policy of no trip refusals within our service area/hours except in circumstances beyond our control (like severe weather or emergencies affecting all service). In line with AODA, if demand exceeds capacity, we strive to manage wait-lists or negotiate alternate times rather than deny service outright.
• Emergency Preparedness: DARTS works with the City to ensure we have emergency plans for the safe evacuation or assistance of people with disabilities in our vehicles or facilities during emergencies. Emergency information relevant to riders (e.g., what to do if a vehicle breaks down or in a city-wide emergency) will be made available in accessible formats upon request. Operators are trained in emergency procedures, including how to evacuate passengers with various disabilities safely.
• Annual Public Consultation: Although DARTS is a contracted service provider, we participate in the City of Hamilton’s annual Transit Accessibility Public Meeting to consult with the community of persons with disabilities about our services. Input from these consultations helps guide improvements in both conventional and specialized transit. We consider community feedback an important part of our ongoing accessibility planning for transportation.

5. Design of Public Spaces (Built Environment)

The Design of Public Spaces Standards (Accessibility Standards for the Built Environment) under the Accessibility for Ontarians with Disabilities Act, 2005 apply to new construction and major modifications of certain public spaces. While much of DARTS’ service is mobile (transportation) and we do not maintain public infrastructure like transit stations, we are committed to ensuring that any public spaces under our control meet accessibility requirements.

• Accessible Public Spaces: Note that as of April 2, 2026, DARTS does not maintain or operate any publicly accessible spaces. In the event that DARTS maintains any public areas, for example, a reception area at our office, or waiting areas, parking lots, etc., they will be designed or upgraded in accordance with the AODA Design of Public Spaces Standards (Ontario Reg. 191/11, Part IV.1). This may include features such as:
  • Accessible Parking: If DARTS provides public parking at our facility, we will ensure enough designated accessible parking spaces (both for visitors with accessible parking permits and van-accessible spaces) are available, with proper signage and dimensions as prescribed by the standards. Note that DARTS, as of April 2, 2026, leases office and fleet and employee parking spaces from the City of Hamilton, who is responsible for meeting associated AODA requirements.
  • Waiting Areas: Where there is a waiting area for customers or visitors, and fixed seating is provided, we will ensure that a minimum of 3% of seating (and at least one seat) is accessible (space for a mobility device) as required.
  • Service Counters: Any service counters, reception desks, or check-in areas will be made accessible (including having at least one low-height counter section for people using wheelchairs or short stature and ensuring approach space is clear).
  • Exterior Paths of Travel: We ensure that any sidewalks or walkways on property that DARTS maintains are kept in good condition and meet width and slope requirements when renovated or built.
  • Doors and Entrances: Any public entrances to DARTS offices will have power-operated door openers or equivalent (unless exempt) and will meet required clear widths.
• Maintenance of Accessible Elements: DARTS will put procedures in place to prevent and address service disruptions in the accessible elements of our public spaces. For example, if an automatic door opener is malfunctioning or a ramp is under repair, we will expedite fixes and provide alternate measures (like temporary ramps or assistance at the door) in the interim. We will also provide notice of temporary disruptions as noted in the Customer Service section. Note that as of April 2, 2026, DARTS leases property from the City of Hamilton, who is responsible for maintaining accessible elements.
• Building Interiors: Although the Design of Public Spaces standard does not cover the interiors of buildings (those are generally covered by the Ontario Building Code requirements), DARTS will strive to ensure that our office interiors and any areas where we host employees or visitors that are under DARTS control, are accessible – this includes meeting or exceeding Building Code requirements for accessible washrooms, elevators (if applicable), corridors, lighting, signage, etc. We want to ensure employees, job candidates, and members of the public can access our premises without barriers.

(Note: As a non-profit organization rather than a public-sector organization, some specific technical requirements of the Design of Public Spaces Standards may not directly apply unless we are undertaking new construction or large renovations. However, DARTS is committed to applying these standards where reasonable as best practices for any facility upgrades.)

6. Procurement

(This section is primarily applicable to public sector organizations under the Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11), but DARTS recognizes the importance of considering accessibility in procurement as a best practice.)

When procuring or acquiring goods, services, or facilities, DARTS will incorporate accessibility criteria and features wherever practicable. This means that for significant purchases or contracts, we will evaluate whether the product or service is accessible for people with disabilities or can be made accessible. For example:

• When purchasing software or electronic systems (like scheduling software, telephone systems, or websites), we will choose options that meet accessibility standards (such as software that supports screen-readers and keyboard navigation).
• When acquiring vehicles, we require they meet accessible transit vehicle standards (like low-floor designs or lifts and appropriate securement systems).
• For physical goods such as office furniture or equipment, we will consider the needs of users with disabilities (e.g., adjustable workstations, ergonomic features).
• If we were to implement self-service kiosks (such as a check-in kiosk or payment station) in the future, we would ensure that accessibility features are included (e.g., an audio output for people with visual disabilities, height-adjustable or reachable components, an accessible touch screen interface). We currently do not use any self-service kiosks or public terminals in our operations (all customer interactions are via phone, online, or in-person with staff assistance), but this commitment is noted for any future consideration.

If it is not practicable for DARTS to incorporate specific accessibility criteria when procuring a good or service (for instance, if no accessible option is available on the market for a needed product), we will provide an explanation upon request, as required by the Integrated Accessibility Standards Regulation (IASR, Ontario Reg. 191/11). DARTS management and procurement staff will also keep abreast of accessible procurement guidelines and tools (such as checklists provided by the Ontario government for accessible purchasing) to continually improve this process.

7. Training

DARTS is committed to ensuring that all employees, volunteers, and necessary third parties receive training on Ontario’s accessibility laws and on the Ontario Human Rights Code as it pertains to people with disabilities. Training is a cornerstone of delivering accessible service and fostering an inclusive organizational culture.

Who is Trained: Every person who deals with the public or other third parties on behalf of DARTS, whether an employee, volunteer, or subcontractor, and every person who participates in developing DARTS’ policies, will receive training appropriate to their duties. In practical terms, all DARTS staff including Operators and Call Centre staff must complete accessibility training. We also ensure that any subcontracted Operators or service providers are either trained by DARTS or can demonstrate they have received equivalent AODA training.

Content of Training:

• The purpose of the AODA (2005) and an overview of the requirements of all applicable standards, including the Customer Service Standard and the Integrated Accessibility Standards (Information & Communication, Employment, Transportation, Design of Public Spaces).
• DARTS’ own accessibility policies and procedures related to the Customer Service Standard and other standards – for example, how we accommodate service animals and support persons, how to use our equipment, and how to report a disruption.
• How to interact and communicate with people with various types of disabilities. This includes understanding different disabilities (visible and non-visible) and practicing appropriate etiquette and language.
• How to interact with people who use assistive devices, or require the assistance of a service animal or support person. For instance, training covers not touching someone’s service animal without permission and how to guide someone with a visual impairment.
• How to use any equipment or devices available at DARTS that may help provide goods, services, or facilities to people with disabilities. In our context, this includes training Operators on vehicle lifts, ramps, securement straps, on-board communication devices, as well as office staff on devices like TTY or accessible software. (Currently, equipment includes our vehicle accessibility features and any adaptive tools in the office.)
• What to do if a person with a disability is having difficulty accessing our services. Staff are trained to recognize when a client is experiencing difficulty accessing a service (for example, when a client is unable to safely enter or exit a vehicle, has difficulty operating their mobility aid, or is unable to communicate booking or trip details). Staff must proactively offer appropriate assistance or alternatives, such as providing physical assistance within their training, allowing additional time for boarding, adjusting vehicle positioning, or using alternative communication methods to ensure the client can access the service safely and with dignity.
• The requirements of the Ontario Human Rights Code as they relate to people with disabilities. This portion of training explains the broader duty to accommodate, the concept of undue hardship, and the rights of people with disabilities in employment, services, and housing. It reinforces that AODA compliance is a floor, not a ceiling, and that DARTS must also meet human rights obligations in all its practices.

Timing of Training: Training is provided to each employee or volunteer as soon as practicable after they are hired or assigned applicable duties. In practice, new hires receive AODA/customer service training as part of orientation within their first weeks of employment. For Operators, detailed accessibility equipment training and sensitivity training is part of initial Operator training. We also provide training updates when there are changes to our accessibility policies or when new accessibility-related equipment or procedures are introduced.

Records: DARTS maintains records of the training provided, including dates and the number of individuals attending. This helps ensure all staff remain compliant and helps us with annual or biannual AODA compliance reporting to the government.

Continuous learning is encouraged – we may use resources like the Ontario government’s AccessForward modules or the Ontario Human Rights Commission’s online training, alongside in-person workshops. By educating our team, we enable them to provide the best possible service to customers with disabilities and to support colleagues with disabilities.

8. Changes to Existing Policies

DARTS is committed to ensuring all our policies uphold the principles of dignity, independence, integration, and equal opportunity for people with disabilities. Therefore, any DARTS policy that does not respect and promote these principles will be reviewed and modified or removed. Accessibility is a lens through which all organizational policies (not just this one) will be examined. We will not make decisions or create practices that contradict our accessibility commitments.

For example, if DARTS had an internal policy that unintentionally created a barrier (such as a rule about how employees must attend training sessions that didn’t accommodate those with disabilities), we would revise that policy to remove the barrier or provide an alternative. This commitment ensures that accessibility is integrated into our organizational culture and decision-making.

Furthermore, DARTS acknowledges that laws and best practices can evolve. We will monitor updates to accessibility legislation (AODA standards or related laws) and update this Accessibility Policy and our Multi-Year Plan accordingly. We will consult with stakeholders, including persons with disabilities, when making significant changes to our accessibility policies.

Finally, this Accessibility Policy and all related documents (such as the Multi-Year Accessibility Plan and training materials) are available to the public and will be provided in an accessible format on request at no charge. We include a notice of this availability, as mentioned, on our website and premises.

Associated Documents

• DARTS’ Statement of Commitment
• DARTS’ 5-Year Accessibility Plan
• The City of Hamilton Multi-Year Accessibility Plan

Policy Details

Date Drafted

December 24, 2024

Drafted By

Tina Sousa, Executive Assistant

Policy Replaces

N/A

Legislation

AODA Employment Standards
Ontario Human Rights Code

Revision Record

Revision record for Accessibility Policy HR-24-013

Date	Summary of Revision(s)
N/A	N/A

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