The Guide to Accessibility for Intercity Bus Services

Available on the Internet at www.tc.gc.ca/eng/policy/acc-accf-menu.htm and in alternate formats

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Table of Contents

Section 1 - Intent of the Guide Section 2 - Definitions Section 3 - Making Reservations and Buying Tickets 3.1 Telecommunication systems for reservations and information 3.2 Personal Care Attendants Section 4 - Arrival and Terminal Navigation 4.3 Signage in bus terminals 4.4 Public telephones in bus terminals 4.5 Public announcements in bus terminals 4.6 Arrival and departure monitors and other electronic signage in bus terminals 4.7 Transportation-related dispensing machines and automated information kiosks 4.8 Rest areas and courtesy seating in bus terminals 4.9 Relieving areas for service animals at bus terminals Section 5 - Boarding and Disembarking from the Bus 5.1 Carriage of service animals 5.2.2 Design load for lifts, ramps and stowage areas 5.4.1 Signage

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Section 6 - The Journey 6.1 Courtesy seating for persons with disabilities 6.3 On-board announcements Section 7 - Bus Terminals and Equipment 7.1 Building or retrofitting terminals Section 8 - Operator Communication and Employee Training 8.2 Provision of transportation-related information in multiple formats 8.3 Web site accessibility 8.4 Training 8.5 Consultation Section 9 - Complaints 9.1 Damaged or lost mobility aids Appendix 1 - Principles of Universal Design Appendix 2 - Partial list of items included in CAN/CSA B651-04 Accessible Design for the Built Environment . . . 29 32 35 . . . . 23 . 21 . . 18

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Section 1 - Intent of the Guide

This Guide is intended to be read in conjunction with the Intercity Bus Code of Practice. This Guide has been developed to help intercity bus operators implement the provisions of the Intercity Bus Code of Practice and thereby make their operations more accessible for persons with disabilities. Each section of the Guide begins by stating the provision in the Intercity Bus Code of Practice, followed by a Rationale section that provides insight into the obstacles that the criteria are meant to address. The rest of the Guide provides technical and community resources that can be used to find effective ways to improve accessibility. It should be noted that this Guide was developed as a practical information resource and is not intended to restrict or specify any operational decisions to be taken during implementation of the Code. Inclusion of products or services in this Guide is for information purposes only and is not meant to suggest that Transport Canada endorses the use of any particular product or service. Those subject to the Code are encouraged to consult this Guide. For the convenience of the intercity bus industry, some of the guidance provided under the Guide for Passenger Terminal Accessibility and the Guide to Removing Communication Barriers for Travellers with Disabilities (both published by the Canadian Transportation Agency) are included in this Guide, as well as information specific to intercity buses. Users are encouraged to also consult these Guides, as needed at www.otc-cta.gc.ca/doc.php?sid=1019&lang=eng and at www.otccta.gc.ca/doc.php?did=43&lang=eng.

Section 2 Definitions
Definitions of relevant terms are contained in Section 2 of the Intercity Bus Code of Practice.

Section 3 - Making Reservations and Buying Tickets

Code provision

3.1 Telecommunication systems for reservations and information

Operators using telephone lines for reservations or information at bus terminals will provide an equal level of service to passengers with disabilities through the use of alternative communication systems, such as a TTY line, e-mail or facsimile. Operators will offer to describe the services provided to persons with disabilities and any conditions that apply with respect to those services. Guide to Accessibility for Intercity Bus Services Page 4 of 36

Rationale Due to the various telecommunication tools used by different travellers, alternatives to a voice telephone line, such as a TTY line, e-mail or web-based reservation or information systems are often prerequisites for direct communication with some travellers with disabilities. Guidelines TTY numbers need to be publicized wherever voice telephone numbers are printed so that travellers who are deaf or hard of hearing can also take advantage of promotions and specials available to other travellers. An automated messaging system may be a quick and convenient way to book a trip or provide information, but can also create barriers to effective communication for travellers with hearing, speech or cognitive disabilities and for many seniors. Travellers with disabilities may also have questions or reservation requirements that cannot be addressed within the standard options provided. Communicating with a live operator will assure travellers that their questions are answered adequately and that their reservations have been completed successfully. Tips on TTY Etiquette: o When contacting the customer, let the TTY ring at least 10 times. When it is answered, tell the customer why you are calling and provide them with your own name, as well as your companys name. o Use xxx when you make an error instead of trying to re-type the word. Type at the same speed as the customer. Use abbreviations only if the customer does. o Write hold please while putting a customer on hold so they know what is happening. o After each message type GA for Go Ahead. This tells people that you are done typing your message. o SK means Stop Keying. It expresses that the conversation is about to end. Type SK when you want to end a message. o Common ways to say goodbye include bye for now, bfn, or byebye. Technical information Definitions for TTYs/TDDs and telephone relay services can be found in Section 4.4 Public telephones in bus terminals. Suppliers The Canadian Hearing Societys web site offers an online store at the address www.chs.ca/estore2/. The web page includes pictures, as well as product information and prices.

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Ultratec Inc. 450 Science Drive Madison, WI 53711 1-800-482-2424 (V/TTY) www.ultratec.com/ Krown Manufacturing, Inc. 3408 Indale Road Fort Worth, TX 76116 Voice: (817) 738-2485 TTY/TDD: (817) 738-8993 Fax: (817) 738-1970 www.krownmfg.com/us/ Clarity Products Inc. 4289 Bonny Oaks Drive Chattanooga, TN 37406 1-800-426-3738 http://clarityproducts.com/

Code provision

3.2 Personal Care Attendants

On request, an operator will provide a personal care attendant with a free transportation ticket to be used by this attendant accompanying a person with a disability on scheduled services. An operator will accept the determination made by or on behalf of a person with a disability that the person does not require a personal care attendant during travel. However, a person wishing to travel with a personal care attendant must provide a letter from a health care professional, or a disability travel card issued by a recognized organization representing consumers with disabilities which uses a health care professional in assessing that a person cannot travel independently. An operator will acknowledge its acceptance that a person requires a personal care attendant by issuing an entitlement card or some other form of acknowledgement in writing. This acknowledgement can then be used by the person for any future bus travel on scheduled services with any operator covered by this Code. A person with a disability who requires a personal care attendant when travelling within the province of Qubec must submit an application form to lAssociation des propritaires dautobus du Qubec (APAQ) to obtain the Qubec Intercity Bus Service Attendant Card. This card is recognized by operators providing intercity bus service within the province of Quebec only, and is for the use of persons with significant and permanent disabilities.

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Rationale Some passengers with disabilities cannot travel independently and therefore need the assistance of a personal care attendant who will provide personal assistance the operator cannot. These services include: transactions at the ticket counter; moving to and from the boarding area; stowing and retrieving baggage; eating; administering medication; using the facilities of an on-board washroom or a washroom at a stop; assembling and disassembling a mobility aid at locations other than bus terminals; and making contact for assistance on behalf of a passenger with a disability. Guidelines Most passengers travelling with a personal care attendant are capable of making their own decisions. As such, any questions of preference or decisions required should be directed to the passenger and not to the personal care attendant unless otherwise informed. Generally, if the passenger has proof that he/she cannot travel independently, the passengers choice of personal care attendant will be accepted and it will be assumed that the personal care attendant can provide the assistance the passenger requires as noted above.

Section 4 - Arrival and Terminal Navigation

Code provision

4.3 Signage in bus terminals

Signage in all public areas of bus terminals should be accessible to all passengers and follow the Canadian General Standards Board Passenger Information Symbols Standard (CAN/CGSB-109.4-2000) and the Canadian Transportation Agencys Communication Code of Practice. Generally, signs in all areas used by the travelling public, such as washrooms, emergency exits, elevators, stairwells, doors or passageways off main corridors should include Braille and tactile symbols.

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Rationale Accessible signs improve access to key orientation information for all travellers, and particularly persons with disabilities. Placing signs at eye-level allows passengers who have low vision to read the signs at close range and provides a better viewing angle for persons who use wheelchairs. Proper colour contrast improves signage visibility for all users and is critical for persons with low vision or colour-blindness. Signs supplemented with Braille or tactile symbols allow passengers with visual impairments to travel more independently. Clear signage is also of great importance to persons who have difficulty communicating verbally or who cannot hear public announcements. Guidelines Tips for Creating Accessible Signage: Consistent symbols, colours, and formats on signs make it easier for people to understand where they need to go. Colour combinations of yellow/grey, yellow/white, blue/green, black/violet, and red/black do not provide an adequate contrast. Red and black is the most difficult colour combination for people with any type of visual impairment to interpret. Amber and black is the preferred colour combination for electronic signs with LED readouts. When tactile signs are installed in an entrance with no doorway, they should be located to the right of the entrance, not in the interior of the entrance. Technical Information The ideal contrast between two colours is 70 percent. You can refer to the back insert of Going Places Access Needs of Visually Impaired Travellers in Transportation Terminals: Design Guidelines by the CNIB, which contains a colour differential chart from 3M. This chart makes it easy to compare two colours to see if they meet the 70 percent contrast level. Sections 2.3 and 9 of this document also contain advice on creating accessible signage. See the CNIB's web page at http://webstore.cnib.ca/item_detail.aspx?ItemCode=COM1010010001. Many electronic LED signs come with a "tricolour" option which allows red, green, or amber to be used to represent the sign's text or symbols. Altering the colour from red to amber and avoiding scrolling or flashing text will make the text much easier to read for travellers with visual impairments, including colour blindness. Signs used for washrooms, emergency exits, elevators, stairwells, doors or passageways off main corridors and for gate, track or departure area numbers should include Braille and tactile symbols. For those signs that do not include text, tactile symbols should be used. Signs should also be provided at other key decision-making points and should be positioned at eye level (1.5 metres +/- 25mm above the floor), wherever possible. Signs should also be positioned to avoid shadow areas and glare. Where an overhead sign is used, it should be placed at a height of 2.03 metres +/25mm so that it can easily be seen by a person in a wheelchair. Guide to Accessibility for Intercity Bus Services Page 8 of 36

Signs located at a doorway should be on the wall to the right of the door, with the centre at a height of 1.5 metres +/-25 mm above the floor. The font for letters should be sans serif (Arial, Universe, Helvetica and Zurich are examples of sans serif fonts) and numbers should be arabic. Letters and numbers should have at least a width-to-height ratio between 3:5 and 1:1 and a strokewidth-to-height ratio between 1:5 and 1:10. Tactile signs (where letters, numbers and symbols can be read by touch) are to be used for general orientation and specific information signage. When tactile signs or markers are used, letters, numbers, symbols and pictographs should be raised at least 0.8 mm and should be between 16 mm and 50 mm high. If a tactile sign is mounted on a wall, its centre should be 1.5 metres +/- 25 mm above the floor. Braille signs are to conform to the standards of the Canadian Braille Authority in English and to Braille intgral, which meets the standards of the Comit interministriel sur la normalisation du Braille in French. The following chart shows accessible viewing distances for signs using lettering, numbering and pictographs of different font sizes: Lettering minimum character height (in mm): 200mm 150mm 100mm 75mm 50mm 25mm 20mm Maximum viewing distance (in metres): 6 metres 4.6 metres 2.5 metres 2.3 metres 1.5 metres .75 metres .75 metres Sample sign location: terminal entrance station name, line name (for trains and subways) vehicle name (subways and buses) line transfer information route information, display maps doors, rooms washrooms with universal symbol

Suppliers The Canadian company Eye Catch Signs is a supplier of signs that include Braille and tactile markings. This company's web address is www.eyecatchsigns.com/en/home/default.aspx. Adaptive Micro Systems Incorporated supplies Alpha LED signs that come with the "tri-colour" option. PCM Electronic Signs is a Canadian company that sells Alpha equipment. See their web site at www.pcmsigns.com/Alpha.htm.

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Code provision

4.4 Public telephones in bus terminals

Operators will ensure that at least one public telephone, accessible to persons with visual impairment, speech impairment, or deaf, deafened or hard of hearing, and a telephone at appropriate height for a person seated in a mobility aid, will be provided at the ticket counter area or where banks of public telephones are found. Accessible telephones and TTYs should be clearly identified using the international symbol of access or the TTY symbol. Signs providing direction to public telephones should also provide direction to the nearest accessible telephone and TTY. Rationale Access to public telephones is an essential component of the trip experience. Persons with hearing or speech impairments require public TTYs. Persons using wheelchairs require telephones placed at lower levels, so that coin slots and other controls are within reach. When installing any new public phones, choosing equipment with the most accessible features will allow a broader diversity of travellers to use this equipment. Guidelines The Canadian Standards Associations (CSA) B651-04 Accessible Design for the Built Environment discusses the requirements for installing accessible public telephones and TTYs. To order this resource, please consult CSAs web site at http://shop.csa.ca/. Technical information Commonly-Used Assistive Devices and Technical Aids: o TTYs / TDDs or Textphones: a teletypewriter (TTY) or a telecommunications device for the deaf (TDD) that transmits written text via the telephone line primarily used by persons who are deaf, deafened or hard of hearing, persons who have a speech impairment and by people who wish to phone a deaf or hard of hearing person who uses a TTY. o Volume Control Phones: telephones that allow the user to adjust the volume of sound received through the telephone primarily used by persons who are hard of hearing. o Volume Control Telephones with Flux Coil: flux coils located in telephone receivers which convert magnetic energy into electrical energy that can then be picked up by hearing aids equipped with a telephone switch (T-switch), which amplifies sound primarily used by persons who wear hearing aids.

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Code provision

4.5 Public announcements in bus terminals

Public announcements should be provided in both audio and visual formats, if possible, in all passenger service areas inside terminals. These announcements include, but are not limited to: information concerning departure delays, gate assignments, and schedule or connection changes. Public announcements should be of good quality, in plain language, with clear enunciation and spoken slowly, as well as repeated. If only one means of announcement is used (only audio or only visual), the operator will provide the announcement in an appropriate manner to passengers with disabilities who have made such a request. Rationale Terminal announcements concerning changes to the travel itinerary are critical and can be last minute. Persons with hearing impairments may experience difficulty understanding the message. As such, providing both audio and visual announcements is beneficial to all travellers, as travel information will be better understood. Guidelines If public announcements in the terminal are limited to audio formats, special attention should be paid to those passengers with hearing impairments. If the traveller identifies a hearing impairment, it is suggested that a staff member be informed and tasked with ensuring that the passenger with the hearing impairment receives the information needed to complete his/her journey successfully. Where possible, the individual in question should be directed to the courtesy seating area, which should be near the check in counter/departure area and within view of any message display board. The person with the hearing impairment should be consulted as to what will be the most helpful form of assistance. Tips for creating clear public announcements: o Speak slowly. o Repeat messages to allow people to remember them more easily. o Use pre-recorded messages which are clearer to understand. o Reinforce the verbal announcements with a textual message on a display board, where possible and practical. o Minimize background noise as much as possible in areas where announcements are made. o Provide pens and paper at key points throughout the terminal to allow personnel to communicate announcements to travellers with hearing impairments. Guide to Accessibility for Intercity Bus Services Page 11 of 36

Suppliers Audiostat, by the Canadian company Smart Speaker, is an example of a product that can make public announcements clearer for all travellers. This technology changes the speaker volume depending on the current noise level in the terminal. A description of Audiostat can be found on the web page at www.minelec.com/SmartSpeaker.htm. Another example is the American company Innovative Electronic Designs. This company supplies public address systems that monitor noise in the facility, can self test to correct any errors that may exist in the system, and supply the announcement through a visual as well as verbal means. This companys web site is available at www.iedaudio.com/. Centrum Sound is an example of an American company that makes loudspeakers, amplifiers, and mixers, which help create clearer announcements. Product information under Sound Reinforcement Systems and Audio Products for Optimal Speech Intelligibility in Public Facilities is available from the web site at www.centrumsound.com/index.html.

Code provision

4.6 Arrival and departure monitors and other electronic signage in bus terminals
Where monitors are placed above eye level, a person seated in a mobility aid will be able to read them easily. The information displayed on the monitors should be in plain language. Rationale Placing monitors at eye level allows people using wheelchairs to see this information at a better viewing angle and allows people with low vision to read the screen at very close range. Proper colour-contrast for text improves clarity for all passengers and is especially important for passengers with low vision or colour-blindness. Clear visual information is also critical for people who cannot hear spoken announcements. Incorporating these universal design features gives everyone the opportunity to navigate a terminal independently where some people might otherwise require assistance from personnel. Guidelines Monitors or other electronic signs should also be positioned to avoid glare and provide a good colour contrast, such as a light colour on dark background or a dark colour on a light background, with light on dark being preferable. Red lettering on a black background should not be used and scrolling, flashing or dot matrix text should also be avoided. Eye level is 1.5 metres above the floor +/-25 mm. Where monitors are placed above eye level, they are to be placed at a height of 2.03 metres +/- 25 mm so that they can be seen easily by a person in a wheelchair. Guide to Accessibility for Intercity Bus Services Page 12 of 36

Code provision

4.7 Transportation-related dispensing machines and automated information kiosks

When dispensing machines or automated information kiosks are used to provide a transportation-related product or service, at least one of those machines will allow a person with a disability to use the machine independently. It will be identified with the international symbol of access. Where a transportation-related dispensing machine or information kiosk has not yet been made accessible, the operator will provide an equivalent level of service to those persons who are unable to use the machines independently. Rationale Automated information kiosks and ticket dispensers speed the flow of travel through the terminal. Accessible design allows persons with disabilities to use these machines to purchase tickets and find information individually and at their own pace. Technical information To learn more about the accessible features that are required for a similar automated technology, the automated banking machine, you can refer to the Canadian Standard Associations CAN/CSA B651.1-09 Barrier Free Design for Automated Banking Machines. See CSAs Product Information Store at http://shop.csa.ca/. Which button? Designing user friendly interfaces for people with visual impairments was created by the Royal National Institute for the Blind (RNIB). This document discusses the font style and size, the illumination of the keyboard and screen and the size of the keypad that should be used on all kiosks. It also explains the importance of increasing the amount of time allowed to complete the transaction and clearing the screen of clutter and flashing text. See the RNIB web site at www.rnib.org.uk/Pages/Home.aspx. Suppliers King Products and Solutions of Mississauga, Ontario, is an example of a Canadian company that sells accessible kiosks in the m200 and Touch web series. These kiosks offer audio output with volume control and the option to use the keyboard or smart card technology to complete a transaction. King Products and Solutions is available online at www.kingproducts.com/.

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Code provision

4.8 Rest areas and courtesy seating in bus terminals

Where queuing systems exist in areas such as ticket sale counters, arrival and departure areas, and long corridors and passages, courtesy seating for persons with disabilities will be provided. To the extent possible, these seats should be within viewing distance of information monitors and staff. Those seats should also be clearly identified by the universal symbol for courtesy seating and include wording such as Please offer these seats to people with disabilities. Rationale Persons with disabilities and seniors may be able to navigate terminal facilities well. However, standing in line or walking though long corridors will be easier if seating is provided through out the terminal. Designating seating within viewing distance of communication monitors or service personnel will allow travellers with disabilities to monitor changes to their travel itinerary or to contact personnel when they require assistance. Creating a designated seating area will also allow terminal staff to locate people who require additional assistance when boarding or who need to be informed of schedule changes. Guidelines Operators should consider the distance between rest areas and the size of terminal when considering the distance between designated seating areas. A range of seating will meet a variety of needs. For example, seats without armrests may more easily meet the needs of larger passengers while armrests may better serve the needs of persons who need to push themselves up from the seat.

Code provision

4.9 Relieving areas for service animals at bus terminals

Operators will ensure that an area is available for service animals to relieve themselves, with a safe, accessible path of travel between the terminal and the relieving area. This area will be adequately maintained. Staff and volunteers who interact with the public will be made aware of the location of a relieving area. Rationale Service animals accompanying their owners on trips will normally require a relieving area both at bus terminals and at non-terminal stops where passengers are provided the opportunity to disembark.

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Guidelines Service animals may have different preferences for surfaces for relieving themselves. Generally, gravel or grass works well in a relieving area as not all animals will relieve themselves on hard surfaces such as concrete. Other considerations for relieving areas include locating the area away from high traffic areas, providing a garbage can or other container for the hygienic disposal of waste, and providing a water source to facilitate the cleaning of the area by staff. In addition, operators may wish to consider providing plastic bags for cleanup. Signage should be provided which reminds users to clean up after their animals.

Section 5 - Boarding and Disembarking from the Bus

Code provision

5.1 Carriage of service animals

Operators will accept one certified service animal per passenger with a disability for carriage without charge and will permit the animal, if properly harnessed, to accompany the passenger on the bus. The service animal will remain on the floor at the passengers feet during travel. Passengers should note that they are required to produce written proof to the operator that the service animal has been trained and certified by a professional service animal institution. Rationale People who have a visual impairment often use service animals for wayfinding. However, they are also used for a variety of other tasks to assist persons with disabilities. Guidelines While many different types of animals are used by persons with disabilities to provide assistance in daily living, professional service animal training institutions in Canada only certify dogs as trained assistance animals. A trained and certified dog has been assessed for appropriate temperament and also been conditioned to operate effectively in crowded spaces, such as the situation would exist in a terminal or on a bus. A properly harnessed service animal is one that is under the control of its owner and thus can follow its owners direction both as a matter of course and during an emergency. The owner of the dog should be able to provide the operator with written proof that the animal has been trained and certified by a licensed facility.

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It is important to avoid any interaction with a service animal wearing a harness as the animal is working. Suppliers Here is a list of the most commonly known organizations in Canada that provide certification for service animals that have been professionally trained to travel safely in confined spaces and that have been accredited by the International Guide Dog Federation (IGDF) and/or the Assistance Dogs International (ADI): Alberta Guide Dog Services #303 6707 Elbow Drive SW Calgary, AB T2V 0E5 (403) 258-0819 www.albertaguidedog.com British Columbia Guide Dog Services 6050 44th Avenue Delta, BC V4K 3X7 (604) 940-4504 www.bcguidedog.com Pacific Assistance Dog Society 9048 Stormont Avenue Burnaby, BC V3N 4G6 (604) 527-0556 www.pads.ca/index.php Canadian Guide Dogs for the Blind National Office and Training Centre P.O. Box 280 4120 Rideau Valley Drive N. Manotick, ON K4M 1A3 (613) 692-7777 www.guidedogs.ca/ Lions Foundation of Canada Dog Guides P.O. Box 907 Oakville, ON L6J 5E8 (905) 842-2891 or 1-800-768-3030 http://dogguides.com/ Mira Fondation Inc. 1820, Rang Nord-Ouest Sainte-Madeleine QC J0H 1S0 (450) 795-3725 www.mira.ca/en/ Guide to Accessibility for Intercity Bus Services Page 16 of 36

Dogs with Wings Assistance Dog Society 11343 - 174 Street, N.W. Edmonton, AB T5S 0B7 (780) 944-8011 or 1-877-252-9433 www.dogswithwings.ca/ COPE Service Dogs P.O. Box 20035 Barrie, ON L4M 6E9 (705) 734-COPE (2673) www.copedogs.org/ National Service Dog P.O. Box 28009 Preston Postal Outlet Cambridge, ON N3H 5N4 (519) 623-4188 www.nsd.on.ca/

Code provision

5.2.2. Design load for lifts, ramps and stowage areas

The operator will accommodate lifting the combined weight of the person and wheelchair up to 600 lbs or 272 kg on vehicles purchased after April 1, 2011. Similarly, the operator will be able to store in the baggage compartment mobility aids that weigh up to 500 lbs or 227 kg. A ramp used for boarding and disembarking passengers on low floor buses will be able to bear a combined passenger and mobility aid load of up to 600 lbs or 272 kg. Rationale The use of ramps and lifts can greatly assist operators in loading and disembarking persons with mobility disabilities and their mobility aids, as well as reduce injuries to staff. Ramps and lifts also help to remove barriers to persons with disabilities by allowing them to travel with their mobility aids. Suppliers Inspired Solutions International is a company, which provides ramps that can be used to load scooters onto buses. Information on these products can be found at http://inspiredsolutionsinternational.com/. AlumiRamp engineers, manufactures, and delivers a full line of ramps designed to promote active lifestyles for people with limited mobility. Information on their products can be found at www.alumiramp.com/. Ez-Access, a division of Homecare Products Inc., provides a variety of portable mobility ramps and accessory products. For more information, please visit their web site at www.ezaccess.com/index.asp. Guide to Accessibility for Intercity Bus Services Page 17 of 36

Scooterville has a variety of products ranging from wheelchairs, wheeled walkers, auto lifts, wheelchair ramps, scooters, electric wheelchairs, lift chairs and stair lifts. For more information, please visit their web site at www.scooterville.com/.

Code provision

5.4 Features of accessible buses 5.4.1 Signage

Signage will avoid shadow areas and glare. Letters, numbers, symbols and pictographs will be glare-free and presented in contrasting colours. Rationale Persons with visual impairments can travel more independently if signage in a bus follows guidelines, which allow easy interpretation, no matter the level of visual impairment. Guidelines Letters, numbers, symbols and pictographs are to be glare-free and presented in high contrasting colours (i.e. a light colour on a dark background or a dark colour on a light background, with light on dark being preferable). When tactile signage or markers are used, letters, numbers, symbols and pictographs will be raised at least 0.8 mm and will be between 16 mm and 50 mm high.

Section 6 - The Journey

Code provision

6.1 Courtesy seating for persons with disabilities

Operators will designate the first row on both sides of the bus as courtesy seating for persons with disabilities who have difficulty moving within the bus. Signage depicting the universal symbol for courtesy seating and wording such as Please offer these seats to people with disabilities will be prominently displayed adjacent to these seats. The use of these seats will not incur any extra cost to the passenger. Rationale Providing courtesy seats to persons with disabilities on both sides of the bus will greatly assist passengers with disabilities who, while ambulatory, have difficulty moving within the bus.

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Guidelines It is assumed that other passengers may occupy these courtesy seats if persons with disabilities do not require them. However, if a person without a disability occupies the seat and a person with a disability requires the seat, the driver will request that the person without the disability move to another seat. Drivers are not expected to insist, as this is courtesy and not reserved seating. No items or other obstructions should be stored on the seats or in the leg space of this row on both sides of the bus. Suppliers Here is a sample of design firms that can produce courtesy seating decals: FloPrint Inc. 1785 Albert Street Regina, SK S4P 2S7 http://floprint.com/ StarMedia Communications 297 Barnett Street Montreal, QC H9G 1W7 www.starmedia.ca/ Clean Slate Studios 2-643 Albert Street Waterloo, ON N2L 3V5 www.cleanslatestudios.ca/ Annex Graphics 2496 Capilano Crescent Oakville, ON L6H 6L4 www.annexgraphics.com/ StreetArt Graphic Design Inc. 2585 Oshkin Court Mississauga, ON L5N 3Z3 (905) 812-1112

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Code provision

6.3 On-board announcements

Announcements will be made slowly, clearly and precisely and will be repeated at least once: at transfer and destination points; at unscheduled stops, such as those caused by mechanical breakdowns, weather delays or road blockage; at any stop requested to be announced by the passenger with a disability; concerning the length of time, including waiting time, at each scheduled or unscheduled stop; and concerning any schedule changes. Upon request, the operator will make alternate arrangements with a passenger who is hard of hearing or deaf to communicate the announcements prior to departure. Rationale Persons with hearing disabilities might need assistance to ensure they are aware of and understand on-board announcements. Guidelines If a person with a hearing disability is seated in a courtesy seat, he/she will be in the best position to hear and understand announcements made by the driver. In addition, the person seated in the courtesy seat can make it clear to the driver when an announcement has not been understood. If the person with the hearing disability lip-reads and, for safety reasons, the driver cannot turn towards the passenger, the driver may wish to make prior arrangements with a hearing passenger to communicate the announcements.

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Section 7 - Bus Terminals and Equipment

Code provision

7.1 Building or retrofitting terminals

Bus terminals will meet all of the accessibility requirements specified in any applicable federal, provincial or local building code. If a contract has been entered into whereby a bus will stop to board and disembark passengers or tickets will be sold at facilities that are not considered to be a terminal, such as a restaurant or a gas station, every effort will be made to ensure that these facilities are accessible to persons with disabilities, particularly those who use mobility aids. Terminal operators will address the needs of persons with disabilities by referring to the Canadian Standards Associations CAN/CSA-B651-04 Accessible Design for the Built Environment standard, which contains requirements for making buildings and other facilities accessible to persons with a variety of disabilities. In addition, operators will apply the seven (7) Principles of Universal Design (included in The Guide to Accessibility for Intercity Bus Services) during the planning and design stage of projects, including renovations and new construction. During the design phase of new construction and renovations, operators should also minimize reliance on directional signage and should incorporate other way-finding methods, such as the positioning of entrances and exits, the use of colour contrasting, pattern direction on floors or walls, tactile markings, acoustics and lighting. Rationale Some terminal buildings were constructed prior to an in-depth understanding of the design aspects, which would make them accessible for persons with disabilities. While adjustments can and should be made to accommodate persons with disabilities in these types of terminals, it seems reasonable to expect that in any construction, whether retrofit or new, design features, which would benefit persons with disabilities, should be taken into consideration. Guidelines During the planning stage of projects, operators are to apply the Principles of Universal Design. Universal design is the design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design. Appendix 1 contains a list of the Principles of Universal Design and their guidelines along with some examples of applications of the principles. Appendix 2 contains a partial list of items included in CAN/CSA-B651-04 Accessible Design for the Built Environment.

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Operators should consider using a universal design consultant or referring architects to resources on universal design when planning any new construction or renovation. Consultation with representatives of persons with disabilities during the design phase is often key to the overall success of the project. This will allow them to identify how universal design and wayfinding might most effectively be used in the terminal. Buildings should also be designed to minimize reliance on directional signage. Wayfinding considerations include, among other things, the positioning of entrances and exits, the use of colour contrasting, pattern direction on floors or walls, tactile markings, and the arrangement of architectural features, such as walls or columns, acoustics, and lighting. These features can help direct people to their intended destination. Technical information The CAN/CSA-B651-04 Accessible Design for the Built Environment specifies technical requirements on how to make buildings and other facilities accessible and safely usable by persons with physical, sensory, or cognitive disabilities. The standard can be found at http://shop.csa.ca/. The Center for Universal Design (CUD) is a national information, technical assistance, and research center that evaluates, develops and promotes accessible and universal design in housing, commercial and public facilities, etc. For more information, refer to www.ncsu.edu/project/design-projects/udi/. The City of Edmontons Advisory Board on Services for Persons with Disabilities has created a Checklist for Accessibility and Universal Design in Architecture, which is available, free of charge, on its web site. More information can be found on the Citys web site at www.edmonton.ca/. The City of Winnipeg has a universal design policy. Among other things, the policy includes a checklist that can be used as an assessment tool to evaluate how well the design of a building, product or service meets the criteria of universal design. More information can be found on the Citys web site at www.winnipeg.ca/ppd/Universal_Design.stm. The Universal Design Network provides on-line news about universal design and links to other universal design sites. For more information, refer to www.ihcdstore.org/universaldesign-net/. Clearing our Path: Recommendations on how to make public places accessible to people who are blind, visually impaired, and deafblind from The Canadian National Institute for the Blind, Ontario Division, provides guidance on wayfinding methods and design basics, such as lighting, colour and contrast, acoustics, detectable warning surfaces, signage and a variety of other topics. Copies can be obtained from the CNIB at www.cnib.ca/en/.

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Going Places: Access Needs of Visually Impaired Travellers in Transportation Terminals: Design Guidelines prepared for Transport Canadas Transportation Development Centre by the Canadian National Institute for the Blind contains useful tips to consider when designing a transportation terminal that will meet the needs of travellers who have a visual disability. Among other things, the manual describes features that are particularly important to passengers who are blind or have low vision, such as lighting, acoustics, textural information, cane detectability, etc. This document can be obtained through the Transportation Development Centre at www.tc.gc.ca/eng/innovation/tdc-summary-1290012940e-954.htm. The CNIB Center in Toronto has an accessible design service, which provides expertise in universal design, accessibility and adaptive technology. For more information, refer to www.cnib.ca/en/services/accessibilities/. Improving Transportation Information: Design Guidelines for Making Travel More Accessible contains information on such subjects as talking signs; auditory maps, which guide a person through an environment with an oral description that has been pre-recorded; colour; contrast; lighting; assistive techniques for a variety of disabilities; verbal landmarks; auditory pathways; tactile information; tactile maps; detectable warning surfaces, where information should be located; and some best practices on the part of transportation providers. This document also includes an information checklist for ensuring a terminal facility is accessible both inside and out. It can be obtained free of charge from Transport Canadas Transportation Development Centre. For more information, refer to www.tc.gc.ca/eng/innovation/tdc-summary-12700-12705e-786.htm.

Section 8 - Operator Communication and Employee Training

Code provision

8.2 Provision of transportation-related information in multiple formats

At bus terminals, operators will ensure that where information related to the successful execution of a trip is required, it is available to all passengers with disabilities in a format that is accessible to them. Rationale Not everyone is capable of reading traditional print. Certain individuals require large print to read written documents, while others use formats, such as electronic copy or Braille to access information independently.

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Technical information The Managers Guide to Multiple Format Production was produced for the Government of Canada through the Assistive Devices Industry Office of Industry Canada. It was created as a guide to make government publications easier to understand for persons who are print-disabled. It answers many questions about multiple formats and gives practical reasons why they should be provided. This guide emphasizes creating a full text template of the original document. It is located online at www.collectionscanada.gc.ca/accessinfo/005003-4200-e.html. The Canadian Braille Authoritys web site www.canadianbrailleauthority.ca/ contains the Unified English Braille Code (UEBC) Format Guidelines for producing Braille documents. The Canadian National Institute of the Blinds (CNIB) web site www.cnib.ca/en/ contains a link called Consumer Products & Assistive Technologies under the section Services that includes information about how machines that produce Braille (called Braille embossers) and computer screen reading technology operate. This site also includes references to companies that provide this equipment. Industry Canadas Accessible Procurement Toolkit discusses the technology needed to create Brailled documents using different equipment such as Braille embossers or text to Braille translators. For further information, see www.apt.gc.ca/. Suppliers To find a list of companies that produce communication products in multiple formats, go to Industry Canadas web site at www.at-links.gc.ca/as/zx20000E.asp click on Register, Update or View Assistive Device Companies, and then click on Multiple Format Companies.

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Code provision

8.3 Web site accessibility

By April 1, 2012, web sites of operators or the web site provided on an operators behalf by an association, are to be made accessible to persons with disabilities. Information provided on the Internet should be linked to text-based options for browsers used by persons with disabilities. The main page will allow easy navigation to the pages applicable to persons with disabilities. The content of these pages will include, but not be limited to services or policies related to: hours of operation; company policy and procedures for arranging accessible services; telephone number for passenger assistance and accessible services information for persons with disabilities; designated parking areas; designated embarking and disembarking areas; relieving areas for service animals; documentation for service animals; personal care attendants; maximum dimensions accepted for scooters and other large mobility aids as baggage; accessibility features of the buses; capacity for passengers to provide feedback to an operator on its services for persons with disabilities; complaint resolution service; and accessible ground transportation Rationale Creating an accessible web site will provide access to on-line information to a greater number of travellers. For example, persons with visual impairments who use screen readers or large print will be able to access web sites to obtain frequently updated information that they may not be able to access in print formats. Guidelines Web sites will be accessible to persons with disabilities by following the World Wide Web Consortium's (W3C) Web Content Accessibility Guidelines. W3C is an organization that creates universal guidelines to help make the Internet accessible to any online user. The W3C offers various levels of guidelines to make web sites accessible throughout the different stages of web site design.

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Tips for Building Accessible Web Sites: o Provide information such as schedules, available services, maps, and contact numbers on the web site. o Use cascading style sheets when possible. o Avoid using a lot of graphics or provide the option of viewing a text- only version. o Use plain text and a simple format. o Discuss accessibility features with persons with disabilities who are most likely to use the web site. o A prominent button on the home page with wording like Accessibility Features could be included to explain the accessibility features the web site contains and to assist persons with disabilities with navigation. Technical information Web Content Accessibility Guidelines 2.0 contain checkpoints to help web developers understand the most essential criteria when making or updating an accessible web site. For further information, see www.w3.org/TR/WCAG20/. For a full list of the strategies, guidelines, resources or other information supplied by the W3C, refer to the organizations Web Accessibility Initiative (WAI) Resources web page at www.w3.org/WAI/Resources/. A collection of information about evaluation, repair, and transformation tools to make web sites more accessible is available at www.w3.org/WAI/ER/tools/. A-Prompt is another software that evaluates web pages for accessibility barriers and provides fast and easy ways to make the necessary repairs. A-Prompt is developed and made available by the Adaptive Technology Resource Centre of the University of Toronto and is available free of charge at www.aprompt.ca/. The Treasury Board Secretariats Common Look and Feel 2.0 Self-Assessment Guide (www.tbs-sct.gc.ca/clf2-nsi2/index-eng.asp) is another useful tool that has been developed for Government of Canada departments and agencies to determine the compliance level of their Internet web sites with the Common Look and Feel Standards. Suppliers Industry Canada has a list of companies that consult on web site accessibility: go to the web site www.at-links.gc.ca/as/zx20000E.asp click on Register, Update or View Assistive Device Companies, and then click on Accessible Web Consultants. WebAim http://webaim.org/ offers training, evaluation and design and delivery of accessible web sites.

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Code provision

8.4 Training
Operators will ensure that their employees are familiar with the contents of this Code and are trained to assist persons with disabilities. In particular, employees and volunteers who interact with the public or make decisions in respect of services to passengers with disabilities, and employees and volunteers who may be required to provide physical assistance to passengers with disabilities, to handle mobility aids, or to assist with special equipment, will receive a level of training appropriate to the requirements of their functions, including sensitivity awareness training. Operators will use the Canadian Transportation Agencys Personnel Training for the Assistance of Persons with Disabilities Regulations as a guide for their training activities. Rationale A critical part of providing an accessible service to passengers with disabilities is a knowledgeable staff, volunteers and contractors trained to meet the needs of persons with disabilities in an efficient and effective manner while retaining the dignity and independence of passengers. Guidelines It is recommended that all employees, volunteers and contractors of the operator who provide transportation-related services and who may be required to interact with the public or to make decisions in respect of the carriage of persons with disabilities receive a level of training appropriate to the requirements of their function. It is also recommended that operators ensure that all their employees, volunteers and contractors receive periodic refresher training sessions appropriate to the requirements of their function. Technical information Operators should use the Canadian Transportation Agencys Personnel Training for the Assistance of Persons with Disabilities Regulations at http://lawslois.justice.gc.ca/eng/regulations/SOR-94-42/index.html as a guide for their training activities. This regulation requires that personnel who interact with the public or make decisions respecting the carriage of persons with disabilities know the service provider's policies and procedures with respect to persons with disabilities. Personnel must also receive general sensitivity training to be able to identify and respond to the needs of travellers with disabilities. Personnel who provide specialized services, such as physical assistance to persons with disabilities or handling mobility aids, must receive additional related training.

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Transport Canada has also produced a Disability Awareness Training Program entitled Getting on Board for transportation service providers operating within the national transportation system. The disability awareness training kit contains a training video with testimonials by persons with disabilities and scenarios depicting interaction between persons with disabilities and transportation industry employees; a disability awareness training manual; a workshop guide; and a guide to physically assisting persons with mobility disabilities. Copies of the Disability Awareness Training Program can be obtained at no charge from: Transport Canada Intergovernmental Affairs and Accessible Transportation (ACCF) 330 Sparks Street Ottawa, Ontario K1A 0N5 Telephone: 1-800-665-6478 E-mail: buscode@tc.gc.ca

Code provision

8.5 Consultation
Operators will have a means of consulting with persons with disabilities to identify and address their concerns on the accessibility of terminals and the bus services offered. This may be achieved by way of a committee, comment cards, on-line feedback forms or other consultation mechanisms. Rationale Persons with disabilities are in the best position to identify their needs. While participation from operators on the Minister of Transports Advisory Committee on Accessible Transportation (ACAT) can be an excellent way to gather this information, it is also suggested that operators might want to have a means by which they can regularly consult persons with disabilities who use their services regularly to identify more local and company-specific issues. Guidelines A prominent section inviting feedback from passengers with disabilities on accessible services provided could be included on the operators web site. If a local accessibility advisory committee is struck, the following suggestions are offered: o It is suggested that persons with disabilities who have used the companys service on a regular basis be those consulted, as they will be in the best position to provide relevant and specific feedback. o Consultation should occur at a level in the company where concerns can be addressed effectively. Thus, it might not be as effective to have a group of persons with disabilities being consulted at every terminal if terminal and service changes are handled at headquarters. In this case, one Guide to Accessibility for Intercity Bus Services Page 28 of 36

consultative group convened by the headquarters group might be more appropriate.

Section 9 - Complaints
Issues that persons with disabilities encounter during their journey can be addressed immediately if the passenger can communicate their concerns to helpful staff. This would facilitate their travel and prevent the lodging of a formal complaint later. Operators may wish to consider providing a business card with the name and phone number of an appropriate staff member who could assist a person with a disability en route. Code provision

9.1 Damaged or lost mobility aids

If a mobility aid is damaged during carriage or is lost, the operator will, without charge and as expeditiously as possible, provide a temporary replacement aid suitable to the owner at the destination. In addition to providing a temporary replacement aid, the operator will, at its expense: if the aid can be repaired promptly and adequately, immediately arrange for the prompt and adequate repair of the aid and expedite its return to the person; or if the aid is damaged and cannot be repaired or is lost, either replace the aid with one that is identical in all material respects (or with one that is different but satisfactory to the person) or reimburse the person for the full replacement cost of the aid regardless of the limits of liability respecting goods contained in any applicable tariff. If the operator provides a person with a temporary replacement aid, that person can continue to have the use of the replacement until the time their aid is returned to them (if the aid is to be repaired) or until a reasonable period for the replacement of the aid has elapsed (if the operator has taken steps to replace a damaged or lost aid or has reimbursed the person). All parties involved in the repair or replacement of the aid shall communicate regularly during this period to ensure that the needs of the passenger are met in a timely and appropriate manner. If damage to a mobility aid is clearly not due to negligence on the part of the operator, the operator will not be responsible for providing the services set out in this section. The operator will, however, ensure the passenger is not left unattended with a non-functioning mobility aid.

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Rationale Being able to travel independently for persons with disabilities can depend on a wellfunctioning and available mobility aid. A lost or damaged aid can severely compromise or prevent mobility. Thus, prompt attention to rectifying a problem inadvertently created by the operator is very important. Guidelines Mobility aids are generally customized or adjusted to suit the particular needs of a person with a mobility impairment and a temporary replacement will not usually be able to provide the exact type of support needed. While it is important to provide a temporary replacement of the aid that is lost or damaged, expeditious return or replacement of the persons permanent mobility aid is critical. Suppliers Here are some examples of suppliers and renters of mobility aids. Please note that this is not an exhaustive list. Brant Arts Dispensary 672 Brant Street Burlington, ON L7R 2H3 1-866-939-0002 www.brantarts.ca/ Eco Medical Equipment 18303 107 Avenue Edmonton, Alberta T5S 1K4 (780) 483-6232 www.ecomedical.ca/ Canadian Red Cross How we Help -Health Equipment Loan Program National Office 170 Metcalfe Street, Suite 300 Ottawa, Ontario K2P 2P2 (613) 740-1900 Fax: (613) 740-1911 www.redcross.ca/article.asp?id=000005&tid=003 Jean Coutu Health Homecare and Mobility Aids www.jeancoutu.com/ Uniprix UniSant Services Rental Program www.uniprix.com/en/

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Canada Care Medical Inc. 1644 Bank Street, Ottawa, ON K1V 7Y6 http://canadacaremedical.com/ MEDIchair 500 - 1121 Centre Street NW Calgary, AB T2E 7K6 www.medichair.com/ Medigas (division of Praxair Canada Inc) 4- 55 Frid Street Hamilton, ON L8P 4M3 www.medigas.com/ Quality Life Services Inc 980 Nairn Avenue Winnipeg, MB R2L 0Y2 www.qualitylifecares.com/

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Appendix 1 - Principles of Universal Design

Barrier-free design generally refers to design, which incorporates specific elements to make buildings more accessible, focussing on disability and accommodating persons with disabilities in the environment. In contrast, universal design results in design that is useable by the widest range of users, not just an "average" user. This means that a design is intended for use by all users, not just people with disabilities. For example, a lift at staircases is a barrier-free design solution which provides a means to change levels for people who use wheelchairs. A ramp or an elevator in addition to stairs however allows all people an alternative to using the staircase, including people who use wheelchairs and people with strollers or luggage. Universal design in terminals benefits all travellers, including people with disabilities, people who are elderly, people travelling with many suitcases, heavy luggage, luggage on wheels, and people travelling with young children in strollers. This may result in an increased use of public transportation as transportation becomes more accessible for all. The seven Principles of Universal Design can be used to evaluate existing designs or to guide the design process of new projects. The Center for Universal Design has developed guidelines to accompany the seven principles. These can be found on the Center's web site, www.ncsu.edu/www/ncsu/design/sod5/cud/ under the heading Publications. Below is a brief description of each Principle of Universal Design and its accompanying Guidelines.

PRINCIPLE ONE: Equitable Use

The design is useful and marketable to people with diverse abilities. Guidelines: 1a. Provide the same means of use for all users: identical whenever possible; equivalent when not. 1b. Avoid segregating or stigmatizing any users. 1c. Provisions for privacy, security, and safety should be equally available to all users. 1d. Make the design appealing to all users.

PRINCIPLE TWO: Flexibility in Use

The design accommodates a wide range of individual preferences and abilities. Guidelines: 2a. Provide choice in methods of use. 2b. Accommodate right- or left-handed access and use. 2c. Facilitate the user's accuracy and precision. Guide to Accessibility for Intercity Bus Services Page 32 of 36

2d. Provide adaptability to the user's pace.

PRINCIPLE THREE: Simple and Intuitive Use

Use of the design is easy to understand, regardless of the user's experience, knowledge, language skills, or current concentration level. Guidelines: 3a. Eliminate unnecessary complexity. 3b. Be consistent with user expectations and intuition. 3c. Accommodate a wide range of literacy and language skills. 3d. Arrange information consistent with its importance. 3e. Provide effective prompting and feedback during and after task completion.

PRINCIPLE FOUR: Perceptible Information

The design communicates necessary information effectively to the user, regardless of ambient conditions or the user's sensory abilities. Guidelines: 4a. Use different modes (pictorial, verbal, tactile) for redundant presentation of essential information. 4b. Provide adequate contrast between essential information and its surroundings. 4c. Maximize "legibility" of essential information. 4d. Differentiate elements in ways that can be described (i.e., make it easy to give instructions or directions). 4e. Provide compatibility with a variety of techniques or devices used by people with sensory limitations.

PRINCIPLE FIVE: Tolerance for Error

The design minimizes hazards and the adverse consequences of accidental or unintended actions. Guidelines: 5a. Arrange elements to minimize hazards and errors: most used elements, most accessible; hazardous elements eliminated, isolated, or shielded. 5b. Provide warnings of hazards and errors. 5c. Provide fail safe features. 5d. Discourage unconscious action in tasks that require vigilance.

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PRINCIPLE SIX: Low Physical Effort

The design can be used efficiently and comfortably and with a minimum of fatigue. Guidelines: 6a. Allow user to maintain a neutral body position. 6b. Use reasonable operating forces. 6c. Minimize repetitive actions. 6d. Minimize sustained physical effort.

PRINCIPLE SEVEN: Size and Space for Approach and Use

Appropriate size and space is provided for approach, reach, manipulation, and use regardless of user's body size, posture, or mobility. Guidelines: 7a. Provide a clear line of sight to important elements for any seated or standing user. 7b. Make reach to all components comfortable for any seated or standing user. 7c. Accommodate variations in hand and grip size. 7d. Provide adequate space for the use of assistive devices or personal assistance. The following are some examples of applications of the Principles of Universal Design: curb cuts aid many people including people who use wheelchairs, people with strollers, people with luggage on wheels; large print pamphlets and documents are easier to read by everyone; low buttons and slots on vending machines make them accessible to everyone including people in wheelchairs, children, and people of short stature; low floor buses are easier to use by everyone including children, seniors, and people carrying packages; and individual washroom facilities accommodate the needs of persons who use wheelchairs and/or attendants and also provide benefits to parents travelling with young children of the opposite sex, offering changing room facilities and amenities for families.

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Appendix 2 - Partial list of items included in CAN/CSA B651-04 Accessible Design for the Built Environment
General requirements
Area allowances (size of clear floor area) Operating controls (including height, operation, settings, displays, lighting, colour contrast, signage) Floor and ground surfaces (including changes in level, carpeting, gratings) Protrusion hazards (including protruding objects, width, height, overhead hazards)

Interior requirements
Circulation (including accessible routes, line-up guides, detectable floor and ground surfaces, hazard indicators, direction indicators, doors and doorways, handrails, stairs, ramps, elevating devices, emergency and security) Drinking fountains Washroom facilities (including stalls, urinals, lavatories, grab bars, and accessories) Communications (including assistive listening systems, public telephones, TTYs, and signage) Seating (including spaces at tables and counters, and rest area seating)

Vehicular access
Parking (including signage, designated parking, ticketing/payment machines and passenger pick-up areas)

Exterior requirements
Accessible routes Stairs Ramps Signage Lighting Pedestrian crossings Rest area seating

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Note: The annexes contain information on: Annex A: Environmental considerations (including wayfinding, acoustics, lighting and indoor air quality) Annex B: Anthropometrics Annex C: Wheeled mobility devices Annex D: Potential for slip of floor and tread finishes Annex E: Elevator requirements for persons with physical disabilities

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