blindness, Comparison, Disability, Independent Mobility

Letter to MP Gord Johns, Re: Draft Service Dog Standards Now Before the Canadian General Standards Board

August 1, 2017

Gord Johns, MP
House of Commons
Ottawa ON K1A 0A6

Dear Mr. Johns:

Re: Draft Service Dog Standards Now Before the Canadian General Standards Board

I am writing to you as a concerned citizen with a vision-related disability and as a former guide dog user.

Several years ago, the Department of Veterans Affairs requested that training standards be implemented before they allocated $75,000 towards lifetime training and care for each service dog provided to our Canadian veterans.

Public Works Canada, through the Canadian General Standards Board (CGSB) formed a committee that has now drafted standards not just for veterans’ dogs, but standards to be applied to every service dog and guide dog in Canada.

In reviewing the draft standards, it is obvious that the CGSB has completely ignored the existing standards followed in over 40 countries, including Canada, as written by the International Guide Dog Federation (IGDF). These excellent standards are followed and committed to by 93 guide dog schools in 32 countries.

Further, rather than ensuring that any proposed standards were consistent with current human rights legislation, Canada’s Charter of Rights and Freedoms, or the United Nations Convention on the Rights of Persons with Disabilities, the CGSB has drafted standards that are completely contrary to any of them.

It should also be noted that Hon. Carla Qualtrough, Minister of Sports and Persons with Disabilities, is currently drafting a Canadians with Disabilities Act, which will certainly take into account all the documents mentioned above.

If guide dog users do not get an exemption from these draft standards, for our dogs from schools here, the USA, and elsewhere, we will be subject to regulations that degrade us, demean us, and take away our basic human rights as citizens of Canada, as well as tourists with vision loss who might visit our beautiful country from other nations.

Here are some examples drawn from the draft standards, which are very long and very, very detailed:
· Our guide dogs would, regardless of which IGDF-compliant school they’re from, have to be retested by government inspectors.
· Inspectors would have the right to visit our homes at any time, demand financial records, obtain veterinarians’ records, etc.
· Our guide dogs would be required to perform obedience drills out of harness and off-leash – things that they are simply never expected to do.
· We would also be required to carry an identification kit containing a photograph, full name, address, name of the guide dog school, and other personal information to be presented on demand to members of the public to prove the dog’s certification.

To see what a coalition of Dog Guide users across Canada are saying about this travesty,
Please visit our Blog Hands Off Our Harnesses at,
Follow us on Twitter with the Hashtags, #HOOH or #IGDFFreeChoice
Check us out on Facebook at,

I am asking you, as my Member of Parliament, to support me and all vision-impaired people in Canada, by making your voice heard to
a) Ask that all guide dogs from IGDF-compliant schools be exempted from the draft standards now under consideration by the CGSB, or
b) Simply see that the entire draft standard is scrapped.

Thank you,

Albert A. Ruel
702 Ironwood Ave
Parksville BC V9P 2S2
Cell: 250-240-2343

blindness, Independent Mobility

Re-Post: Blind Canadians’ Battle For Justice Needs Your Support.

Blind Canadians’ Battle For Justice Needs Your Support.

As a 50 year guide dog user I am disgusted how our protected rights are discounted. After experiencing a blatant taxi refusal and being told 15 cabs out of a fleet of 43 did not take guide dogs I felt it was vital we challenge this illegal violation of 3 laws designed to prevent exactly this scenario that the BCHRT has failed to honour.

In 1996, the Guide Animal Act of British Columbia replaced the Blind Person’s Rights Act and was updated in January, 2016 becoming The Guide Dog and Service Dog Act.
The Guide Dog Act guarantees freedom of movement absent of any barriers and is not
subject to “accommodation” or affected by the choice of mobility aid.

On Tuesday, September 19th at 10:00am the Victoria Court of Appeal will hear, over two hours, why stringent, clear protective access laws for blind citizens using guide dogs must be recognized, honoured and applied. This historic court hearing will benefit from an audience of conscientious citizens savvy to the need to protect the democratic cultural rights of the vulnerable and so your presence will make a difference.

Most of us are familiar with the importance of maintaining our legislated access rights. Most, but not all, encounters with access barriers have occurred over transportation and in particular, taxi companies. Despite clear legislation to ensure unimpeded access, guide dog users are still suffering illegal barriers. Unfortunately, at present, redress through the B.C.Human Rights Tribunal results in further injustice. It is vital we challenge this injustice to correct a bureaucratic error.

We, at the CFB, call on all of you who believe in Canadian justice to stand beside us over this difficult and hard fought appeal. Please remember that right of public access is a guaranteed right for all Canadians and to condone, accept or excuse any barrier limiting public access is a step towards conspicuous, deliberate prejudice.

We hope you are willing and able to stand with us in September at the Victoria court house when this important appeal is heard.

For further information or if we can be of help or advice please contact me at 250-479-2679, or the CFB line at 1-800-619-8789. e-mail:

Graeme McCreath, CFB Treasurer.

assistive technology, blindness, Disability, Independence, Low Vision, Resource

RNIB: Factsheet for employers and employment Professionals

Factsheet for employers and employment

Blind and partially sighted people at work
– Guidance and good practice for Risk

About this factsheet

This factsheet is for anyone who needs help with safety management in a place where blind or partially sighted people work. Blind and partially sighted people compete for, perform and succeed in a wide range of jobs. Many need little or no adjustment to their workplace or to working practices, and yet many employers worry about employing blind and partially sighted people, sometimes having concerns for their safety and for the safety of others.

This guidance has been compiled in consultation with: health and safety professionals; people in the workplace who assess the risks to employees; employers; and with blind and partially sighted people. We aim to help risk assessors by providing the information they need to reach decisions, and ensure a safe environment with safe working guidelines.


1. The need for Guidance
2. Blind and partially sighted people at work
3. The process of Risk Assessment
4. Key points for Risk Assessment
5. Common issues

5.1 Dealing with Guide Dogs
5.2 Mobility and travel
5.3 Lighting
5.4 Trip hazards
5.5 Lone working
5.6 Evacuating the building
5.7 Stairs
5.8 Safe use of computer systems
5.9 Machinery
5.10 Caring for others

6. References
7. Sources of help and further information

1. The need for guidance

Carrying out a risk assessment of the workplace or an activity for blind or partially sighted people doesn’t have to be difficult, but it can sometimes be a daunting prospect. If you haven’t worked with blind people before, it can be very easy to over-estimate risks or make assumptions about what blind people can or can’t do.

People who risk assess the workplaces and activities of blind and partially sighted people, looking for advice, often approach RNIB. While we are aware that mistakes can be made, we also know that risks can be managed successfully and we want to share good practice.

This guidance has been produced to highlight some of the things that we’re often asked about, share examples of successful risk management and suggest sources of help.

We are also aware that risk assessment, or health and safety in general, has been used as an excuse not to employ blind and partially sighted people (Hurstfield et al, 2003). We hope that the guidance we have put together will help to overcome unnecessary barriers.

Most importantly, we hope that this guidance helps you to reach informed decisions and, in so doing, ensures that blind and partially sighted people can continue to work effectively and safely.

2. Blind and partially sighted people at work

In the middle of the last century, blind people were encouraged to work in specific occupations. These included jobs as switchboard operators, masseurs, piano tuners and even basket weavers.

Things have changed quite considerably and blind and partially sighted people now succeed in a range of jobs across different sectors. “This IS Working 2” (RNIB, 2009), gave examples of ten people working as: a company director, senior physiotherapist, sales and marketing manager, shop owner, policy officer, development and funding officer, teacher, administrative assistant, and outreach worker. A copy of this document, which includes testimonials from employers, can be fond here:

Blind people do succeed at work. When safety management works well, we know that all employees, including blind and partially sighted people, can work safely.

3. The process of risk assessment

Employers are required by law to manage health and safety in the workplace. Each organisation will have their own ways of doing this and the roles of individual risk assessors can be different.

This document does not deal with the mechanics of undertaking and recording risk assessments. The principles are the same for everyone, but guidance is already available on dealing with “disability” in relation to safety management. See, for example, ‘Health and Safety for Disabled People and Their Employers (Health and Safety Executive and DRC).

IOSH, the Chartered body for health and safety professionals, offers advice on their website about the responsibilities that the Equality Act imposes on those who manage safety.

They specifically suggest that:

• the Equality Act has an effect on the way you
• manage safety.
• while you may be able to use health and safety issues related to disability as a reason not to employ someone – or to refuse a service to someone – you can only do so if certain conditions are met.
• if the safety of a task may be affected by someone’s disability, then a risk assessment should be carried out for everyone, not just for disabled employees.
• if you don’t document the steps you’ve taken to consult disabled workers or customers, and to make reasonable adjustments, your organisation could be involved in an expensive tribunal case.

This factsheet will focus on how risk assessment can affect blind and partially sighted people at work.

4. Key points for risk assessment

In general, the following points will help to shape your risk assessments:

4.1 Risk assessments should address a task and everyone

Whilst the legislation requires employers to identify groups that might be at risk of harm, telling someone that “you must be risk assessed” sends out a negative message. In a way, it suggests that the individual is the issue, when this is clearly not the case. It sounds much more positive to tell someone that activities are being assessed.

4.2 The individuals involved must be consulted

The Health and Safety Executive’s “Five Steps to Risk Assessment” recommends that: ‘In all cases, you should make sure that you involve your staff or their representatives in the process. They will have useful information about how the work is done that will make your assessment of the risk more thorough and effective.’

Your blind or partially sighted employee is usually the best person to describe how their sight loss affects them and you should be able to tap in to that knowledge. Risk assessments carried out without the involvement of blind and partially sighted employees are significantly more likely to be inaccurate.

4.3 “Adjustments” must be considered as part of the process

Employers have a responsibility to make “reasonable adjustments” to working practices and physical features. This is likely to include the provision of auxiliary aids. While this might be beyond your area of responsibility as a risk assessor, you must be prepared to take proposed changes into account.

4.4 It is important that you do not make assumptions about
the level of someone’s functional vision

Most blind people have some useful vision. Some people will be able to see fine detail, while some may have very good peripheral vision. Even people with the same eye condition can have widely different levels of useful sight.

Employers often ask for medical guidance to help understand what people can or can’t see. However, this is often presented in medical terms and is usually lacking an occupational focus.

Asking the individual to describe their sight is often the best way to gather information to assess risk. Professionals who work with blind and partially sighted people at work can be another source of information. Making assumptions about what people can and can’t see will produce flawed risk assessments.

5. Common issues

Employers often contact RNIB to ask for advice about specific worries they have about the safety of a blind or partially sighted colleague. Things we have been asked about include:

5.1 Guide Dogs at work

Guide dogs are one example of an aid to mobility. However, it has been estimated that as few as one or two per cent of blind or partially sighted people use guide dogs to get around. It is therefore important that you don’t assume that people either use guide dogs, or choose to bring them to work.

Having said that, if an employee brings a guide dog to work, proper planning is required to ensure that things run smoothly.

We have been asked about accommodating guide dogs at work and, in most cases, working practices can be adopted to ensure a safe and comfortable working environment.

Some of the common questions revolve around:

Toileting – a suitable area must be identified for the guide dog. While in some places there are very obvious locations for this, some companies (particularly in town centres) find this difficult.

Moving around building – the extent to which a blind person uses a guide dog once at their workstation will vary, depending on the person’s other mobility skills and knowledge of the environment. It is important that the guide dog user is aware of his or her responsibilities. Working rules should be established. These could include where the dog goes when not “on harness” or how often breaks are required.

Induction/emergency procedures – it may be necessary to review your evacuation plans. There may already be a structure in place (such as personal emergency evacuation plans) to facilitate this within your organisation. Standard instructions, such as those issued during induction should be available in the correct format for the employee to read.

Colleagues – the extent to which colleagues interact with guide dog users is likely to vary. There are both positive and negatives to this. For example, colleagues can distract a working dog, or alternatively can assist with “walking” the dog. Colleagues may need to be told of their responsibilities. For example, they may need to know when it might be appropriate to play with or to walk the dog, or to know when the dog is working.

Allergy/Fear of dogs/cultural influences – Some thought may need to be given to where guide dogs are based while people are working to allay concerns.

If in any doubt about any aspect of working with Guide Dogs, representatives from the Guide Dogs for the Blind Association will want to help you with this.

5.2 Mobility and travel

When considering potential risks involved in travelling, it is important to bear in mind that most blind or partially sighted people will travel easily with no problems. Some may need support.

Blind and partially sighted people have varying levels of sight and particular eye conditions affect sight in different ways. We can’t assume that people with the same eye condition are affected in the same way, as people with the same eye condition often see the world in entirely different ways. Familiarity with the area and environmental factors, such as lighting, are other things that can affect someone’s mobility.

Additionally, people adjust to sight loss in different ways. It is safe to say that the mobility skills of blind and partially sighted people vary considerably. Some people travel independently, while others use mobility aids or support from others to travel.

It probably goes without saying that an individual should be consulted when considering potential risks with travel. It is also good practice to ensure that any concerns about mobility are kept in perspective – issues should not be allowed to be blown out of proportion.

If an individual is looking for mobility support for specific parts of their travel, two agencies might be able to help.

In each local authority area, there are mobility specialists, sometimes known as rehabilitation workers, who can teach people how to use mobility aids and help them learn to navigate routes. They either work for the local authority social work team, or the organisation that holds the register of blind and partially sighted people.

The Access to Work programme supports people at work and individuals can apply for financial assistance to travel to and from work and within work. The Access to Work programme can only cover the additional costs of travelling to meet disability-related and it is not intended to replace the standard costs involved in business use.

5.3 Lighting

Both the quality and quantity of lighting has a significant impact on all working environments. For some people, it can help to create a comfortable workplace. For others, lighting can pose a barrier to effective working.

Guidance on lighting levels tends to be either general, aimed at a technical audience, or individual, based on one person’s experience. For example, Building Site (1995), suggests that light levels are crucial. It suggests that lux levels (a measure of luminance) for blind and partially sighted people should be 25 per cent to 50 per cent above the “general” level.

The difficulty with such generalised recommendations is that individual blind and partially sighted people have very different needs. Increasing the general “background” lighting levels might not necessarily make a working environment safer or more comfortable.

For some people, increasing background light would be helpful. But it might be more effective to introduce additional light sources, rather than make the existing fittings brighter. This is particularly true if units can be switched on and off to allow more control over lux levels.

Other people find it difficult to work with high levels of lighting and prefer a darker working environment.

As well as the amount of light, the source of light is also an important factor. Many people find that natural light is best. This can mean that making the best of light from windows is preferable to using electric lighting. Similarly, some people find that light fittings emulating natural light (daylight bulbs) are very effective.

The key to resolving lighting issues is to talk to the people involved and call in specialists where necessary. Sometimes simple changes can make a huge difference to a working environment. At other times, more work is required to strike a balance between the needs of one individual among a group of other employees.

5.4 Trip hazards

Research suggests that blind and partially sighted people are more likely to trip than sighted people (Legood et al, 2009). Yet, when we introduce controls to reduce risk, it is very important to keep a sense of perspective. Introducing “no-go” areas, such as stairs or in specific areas you perceive as dangerous, can be discriminatory. It is very unlikely that the only way to manage potential trip hazards is to exclude people from certain areas, as other alternative steps can be taken to reduce risk. Most blind and partially sighted people can navigate around buildings and other workplaces. If you feel strongly that there are parts of a workplace that are not safe, you should seek advice.

5.5 Lone working

Working alone is an integral part of many jobs. Whether this involves visiting customers at home, working from other premises, travelling either locally or more widely or working at home.

Lone working is an area that often raises concerns for employers. But while there may be occasions when a blind or partially sighted person is exposed to risk, these risks are often no greater than a sighted colleague would face.

It is very easy to make assumptions about potential dangers and introduce unnecessary risk controls. And yet, very many blind or partially sighted people work successfully and safely on their own, sometimes in challenging environments.

Considering risks

It is important to consider how an individual is affected by sight loss. Some people travel independently and confidently. Others look for support, particularly in unfamiliar environments.

Some employers have found it helpful to consider the extent of an individual’s sight loss. Having an understanding of what a person can or cannot see can make it easier to discuss risks. Medical “evidence” is not likely to help with this. A diagnosis does not usually describe the extent of functional vision. Most of the time, your blind or partially sighted employee is the best person to describe this to you.

Minimising risk

Your starting point for managing risks should be the systems you already have in place for your lone workers. Your local working practices must be robust and comprehensive, so that the work of all of your lone-working employees is covered. Your blind or partially sighted employee is no different in this respect.

5.6 Evacuating the building

Most blind and partially sighted people will understand the need for plans to deal with unexpected evacuations, for example, in the case of fire. Employers generally deal with evacuation routes, procedures and assembly points during an employee’s induction period.

It is important to ensure that written evacuation procedures are available in different formats during induction. For example, having a Word version of the procedures available will allow most users of access technology to read them.

Some blind or partially sighted people would welcome the chance to familiarise themselves with the main routes and practise leaving the building by emergency exits. This could be arranged with their line manager when starting work.

If a blind or partially sighted person is finding it difficult to learn routes and needs some support, it may be appropriate to allocate a “buddy” to assist with evacuation until routes are learned.

Further information can be found in the publication “Fire Safety Risk Assessment: Means of Escape for Disabled People”, Department of Communities and Local Government, 2007.

5.7 Stairs

While risk assessing the use of stairs, your starting point should be to assume that blind and partially sighted people are subject to the same risks as any other employee. Therefore, any steps you might take to reduce risk apply to all employees.

If you believe that there are risks to stair users, you may want to consider the following extracts form Building Sight:

“Lighting on stairs should be sufficient to highlight any obstructions on the flight of the stairs, but should highlight the treads as opposed to the risers to emphasise each step. It is very important that ceiling-mounted luminaires do not become a glare source – they should be well shielded. Alternatively, large-area, low-brightness sources can be mounted on a side or facing wall.”

“The stair covering should not have a pattern that can cause confusion between tread and riser or between one tread and another.”

It is worth pointing out that making physical changes of this type may be the responsibility of your landlord, but this does not mean that you shouldn’t raise the issues with them.

5.8 Safe use of computer systems

Employers are required to “analyse workstations, and assess and reduce risks. Employers need to look at the whole workstation including equipment, furniture, and the work environment; the job being done; and any special needs of individual staff. The regulations apply where staff habitually use display screen equipment as a significant part of their normal work.” (HSE, 2006).

It is entirely likely, then, that the needs of blind and partially sighted people will be highlighted as part of a general risk assessment of display screen equipment.

In addition to this, employees will often highlight difficulties in using computer systems related to their sight. Unless the individual has a good idea of their requirements, it is usually a good idea to seek specialist advice. RNIB or Action for Blind People offices will be able to recommend ways to make it easier to change the way screens look, or alternative ways of accessing screen content.

5.9 Machinery

Employers often have legitimate concerns about blind or partially sighted people operating power tools, hand tools or other machinery such as grass cutting or gardening power tools.

There will be times when you will need to eliminate risk by specifying tools that should not be used at work.

However, it is very important to discuss with an individual exactly how their sight restricts them and how real the risks are. Bear in mind that some new employees may underplay any difficulties as they may have had negative experiences with past employers.

Another factor to take into account is the environment in which people will be working. If you can control the immediate work area, machinery can be made safe to use. For example, in a factory, machines can be fitted with guards and walkways restricted to improve the safety of the work environment. If you are in doubt, ask for advice.

5.10 Caring for others

Many blind and partially sighted people work in jobs where they provide social care services. This can include working in nurseries, care homes and delivering community services.

As you would expect, the generic risk assessments carried out to cover the working routines of care workers are often sufficient to ensure a safe working environment for blind and partially sighted people.

However, employers sometimes have concerns about certain aspects of working that could be perceived as dangerous. These could include, for example:

Reading facial expressions to predict behaviour:

This is a contentious issue. The vast majority of blind or partially sighted people will be able to read facial expressions, but some will find it difficult or impossible. Logically, this could suggest that a blind person may be at higher risk of sudden changes in behaviour.

However, there is a considerable body of research that shows how people are able to perceive mood or feelings from verbal communication only. So the extent of the risk involved is not at all clear.

Reducing risk in this situation calls for a balanced judgement based on an understanding of an individual’s sight and the requirements of the job.

Missing visual cues, such as evidence of substance misuse or
concealed weapons:

Potential hazards of this kind could be addressed by adopting working practices that apply to all employees. This could include ensuring that thorough background information is obtained with referrals. Additionally, initial assessments of the individual customers should cover the likelihood of issues arising. There may be situations where it is safer for people to work in pairs.

Reading correspondence while visiting customers:

In some jobs, workers may be required to read forms or letters when visiting people in their homes or other settings. Generally, this can be overcome by using access technology, such as portable video magnifiers or scanners.

Perceived difficulties dealing with children:

Nurseries, after school clubs and similar establishments that provide childcare services have well-developed risk management systems in place. If a blind or partially sighted person starts work, the working practices in place are often robust enough to ensure safe working.

Occasionally, parents have concerns about blind or partially sighted people caring for their children. Concerns could include tripping, not seeing children putting things in their mouths, escorting children in the local area or identifying parents when children are collected.

In your role as a risk assessor, you should discuss concerns with the individual to establish whether any of these concerns are genuine and if so how they could be minimised. For example, another worker could check the identity of parents collecting children.

It is really important that the concerns of parents are not confused with actual risk.

6. References

‘Building Sight: A handbook of building and interior design solutions to include the needs of visually impaired people’, P Barker, J Barrick and R Wilson, London HMSO in Association with RNIB, 1995

‘Fire Safety Risk Assessment: Means of Escape for Disabled People’, Department of Communities and Local Government, 2007

‘Five Steps to Risk Assessment’, Health and Safety Executive

‘Health and Safety for Disabled People and Their Employers’, HSE and DRC

J Hurstfield et al, ‘The extent of use of health and safety as a false excuse for not employing sick or disabled persons’, research report 167, HRC/DRC, 2003

JMU Access Partnership, Fact Sheet 24 – Lighting

Legood R, Scuffham PA and Cryer C, “Are we blind to injuries in the visually impaired? A review of the literature”, June 2009

RNIB and Thomas Pocklington Trust, ‘Make the most of your sight, Improve the lighting in your home”, RNIB and Thomas Pocklington Trust, 2009

‘This is Working 2’, RNIB, October 2009

‘Working with VDUs’, HSE leaflet INDG36(rev3), revised 12/06

7. Sources of help and further information

7.1 RNIB and Action for Blind People

Employment services for employers

We can help you retain a current employee who is losing their sight, and we can help you to take on someone who is visually impaired.

Advances in technology mean that visually impaired people can now overcome many of the barriers to work that they faced in the past, and government schemes like Access to Work mean that many of the costs can be met.

We provide a number of services that can be directly commissioned by employers. These include:

• Work-based assessments – a visit to a workplace, by one of our specialists, to evaluate the potential for equipment, software, and adjustments that would better allow an employee to fulfil their role.
• 1 to 1 access technology training. Our technology specialists can visit your workplace and provide training tailored to suit your employee’s needs.
• Visual and disability awareness training.

For further information about any of these services, please contact us via our website or directly via our employment services mailbox:

Web site:


Employment factsheets

We currently produce the following factsheets for employers and employment professionals:

• Access to Work
• RNIB work-based assessment services
• Blind and partially sighted people at work – Guidance and good practice for Risk Assessors
• Testing the compatibility of access software and IT applications
• Guidelines on meeting the needs of visually impaired delegates on training courses

In addition to this you may like to check out our ‘This IS Working’ documents, which showcase blind and partially sighted people working in a range of occupations, and include testimonials from employers, as well as our ‘Vocational rehabilitation’ document, which sets out the business case for retaining newly disabled staff.

All of these factsheets and documents can be found in the employment professionals section of our website which also contains the latest research in the field, as well as information on IT and accessibility, the Equality Act, success stories, and more.

We also produce a number of factsheets aimed at blind and partially sighted people, on a range of employment related issues. These can be found at

RNIB Helpline

The RNIB Helpline can refer you to an employment specialist for further advice and guidance. RNIB Helpline can also help you by providing information and advice on a range of topics, such as eye health, the latest products, leisure opportunities, benefits advice and emotional support.

Call the Helpline team on 0303 123 9999 or email

7.2 Access to Work

Access to Work is a scheme run by Jobcentre Plus. The scheme provides advice, grant funding, and practical support to disabled people and employers to help overcome work related obstacles resulting from a disability. Read our Access to Work factsheet, or visit the Access to Work pages at to learn more about qualifying for the scheme. Further details are also available at

7.3 Guide Dogs

The best place to find out information relating to guide dogs. Visit:

7.4 The Health and Safety Executive

HSE is responsible for enforcing health and safety at workplaces. Visit:

7.5 Equality and Human Rights Commission

The Equality and Human Rights commission have a statutory remit to promote and monitor human rights; and to protect, enforce and promote equality across the nine “protected” grounds – age, disability, gender, race, religion and belief, pregnancy and maternity, marriage and civil partnership, sexual orientation and gender reassignment. The website includes a section on employment.

Factsheet updated: April 2013


Recognize Deafblindness as a single disability: Open Your Eyes and Ears

Recognize Deafblindness as a single disability: Open Your Eyes and Ears



Deafblindness is a unique disability, which requires a unique approach to support and a unique system to deliver that support.

At the Twelfth World Conference in Portugal (1999), Deafblind International (DBI), agreed to pass a resolution to appeal to governments around the world to use the following definition:  “Deafblindness is a combination of visual impairment and hearing impairment.”  Recognition for a common definition should be included in legislation and acknowledge the particular needs of individuals who are deafblind.

DeafBlind Ontario Services calls for official recognition of deafblindness as a distinct disability with equal rights and opportunities for individuals living with deafblindness in Canada. The organization advocates for: provision of appropriate lifelong supports of Intervenor Services; collection of data on the incidence of the distinct disability of deafblindness; recognition of the profession of Intervenor Services (starting with inclusion in the National Occupational Codes classification system); and, accessible environments to ensure that individuals with deafblindness lead a quality life and have every opportunity to fulfill their potential and enjoy independence.

Understanding Deafblindness

Deafblindness is a distinct disability.  It is defined as a combined loss of hearing and vision to such an extent that neither the hearing nor vision can be used as a means of accessing information to participate and be included in the community.

Individuals who are living with deafblindness do not belong to a homogenous group. Each person will experience their own specific degree of vision and hearing loss that will affect their individual access to information, communication and mobility. The two main types of deafblindness are acquired deafblindness and congenital deafblindness.

Acquired deafblindness is a description applied to people who experience both vision and hearing loss later in life.  Losses may occur at separate times or may occur simultaneously.  They may also be progressive.


Congenital deafblindness is a description applied to people who are born with both hearing and visual loss or who became deafblind before developing symbolic language.

In addition, persons who are deafblind may live with other co-occurring disabilities, such as a physical and/or cognitive disability. This can further create barriers for the individual in accessing supports and services, as well as restrict their access to full participation in their communities.

The condition of deafblindness is not well recognised or distinguished from other disabilities. Although the term ‘deafblindness’ leaves little room for misunderstanding, many people are unaware of the causes of deafblindness, the variation of impairment that may be experienced and the impact of deafblindness on everyday life. ‘Deafblindness’ does not refer only to profound blindness and deafness; it refers to any degree of dual-sensory impairment.

With an increased number of seniors losing their sight and hearing or experiencing “dual sensory loss,” this changing demographic will require training from service providers to help them adapt to the realities of their changing world.

Disabilities and Deafblindness in the Canadian Legal Landscape:

The legal framework in Canada provides a standard to support people who are living with disabilities to ensure they have full and equal access to areas such as employment, education, health and justice.

As Canadians, we value the right to an inclusive and diverse society. The Canadian Human Rights Act extends the laws of Canada within the Federal sphere to uphold the principle that “all individuals should have an opportunity equal with other individuals to make for themselves the lives that they are able and wish to have and to have their needs accommodated…without being hindered in or prevented from doing so by discriminatory practices based on…disability.”

This principle continues to be at the forefront of the Canadian political system. Human rights legislation across all provinces and territories in Canada has similar visions, rights and obligations.



United Nations Convention on the Rights of Persons with Disabilities

Canada and 159 other member states signed, and 168 members’ states ratified the convention at the United Nations. Canada ratified this treaty in March 2010. The treaty aims to eradicate discrimination against persons with disabilities in all areas of life including employment, education, health services, transportation and access to justice.

The OP-CRPD is one of the communications mechanisms of the UN treaty bodies.  The Optional Protocol (OP-CRPD) to the Convention on the Rights of Persons with Disabilities (CRPD) allows for individual complaints to be submitted to the CRPD Committee by individuals and groups of individuals, or by a third party  on behalf of individuals and groups of individuals, alleging that their rights have been violated under the CRPD.


Despite the efforts by the Canadian government to identify disability issues as a priority, a National Disabilities Act does not currently exist and this issue has been a matter of public debate to a greater or lesser degree for three decades.

The Government of Canada has committed to adopting a strong federal accessibility law to remove and prevent barriers people with disabilities face.

The new accessibility law will cover areas that are under the jurisdiction of the federal government. This includes: railways, airlines, banks, postal services, radio, television, telephone and internet providers, Employment Insurance (EI), immigration, Aboriginal lands and rights, the military and criminal law.

This new law will not address areas that are under the jurisdiction of the provinces. This includes: health care, education, municipal transportation, guardianship and property rights.

DeafBlind Ontario Services is participating and facilitating consultation and engaging disability stakeholders in Canada to contribute to the development of federal accessibility legislation.


Accessibility for Ontarians with Disabilities Act, 2005

Passed unanimously in the Ontario Legislature, this Act commits the Government of Ontario to create, implement, and enforce standards of accessibility with respect to goods, services, facilities, accommodation, employment, buildings, structures and premises for the 15%(2005) of Ontarians living with disabilities. A similar Act exists in Manitoba (2013). The Nova Scotia legislature introduced an Act Respecting Accessibility (currently at Second Reading as of November 3, 2016), making it the third province in Canada to introduce an accessibility act.


Ontario Human Rights Code


Ontario’s Human Rights Code explicitly states that everyone has the right to be free from discrimination. The Ontario Human Rights Commission’s Policy on Ableism and Discrimination based on Disability outlines details and gives practical measures for workplaces, public transit, health and education services, restaurants, shops, and housing to provide Ontarians with disabilities equal treatment and barrier-free access. The Code prohibits discrimination based on someone’s disability in all aspects of the employment relationship. Discrimination in employment may occur when a person experiences negative treatment or impact because of their disability. Discrimination does not have to be intentional. A person’s disability needs to be only one factor in the treatment they receive for discrimination to have taken place. The Code provides that organizations (e.g. employers, service providers, and vocational associations, including unions) have a duty to accommodate disability, and other grounds, short of undue hardship, based on cost, health and safety.


Ministry of Community and Social Services Act, Ontario


The Ministry of Community and Social Services (MCSS) Intervenor Services Program was established in 1981 under Section 12 of the Ministry of Community Social Services Act which defines the mandate and scope of MCSS activity. The ministry funds non-profit organizations to provide Intervenor Services to individuals who are deafblind. These services enable people to communicate and participate in a variety of settings, such as medical, mental health, social services, employment, educational, legal, and government services.

In Ontario, 20 organizations receive funding to provide Intervenor Services, including: the Canadian Hearing Society, the Canadian National Institute for the Blind, the Canadian Deafblind Association – Ontario, DeafBlind Ontario Services and the Canadian Helen Keller Center.

Deafblindness – a Unique Disability in Canadian Context

Deafblind Awareness Month

On December 21, 2000, the Legislative Assembly of Ontario, proclaimed June as Deaf-blind Awareness Month.

On June 26, 2015, the Canadian Senate passed a motion to recognize June as National Deafblind Awareness Month across the country. The intent of this motion was to help “to promote public awareness of deaf-blind issues and to recognize the contribution of Canadians who are deaf-blind.” It additionally would “recognize the strength, courage and dedication that deaf-blind people show every day in living their lives and facing their daily challenges.” June is also the birth month of Helen Keller, an internationally recognized person who lived with deafblindness.

In keeping with Article 31 on Statistics and Data Collection of the United Nations Convention on Rights of Persons with Disabilities (UN-CRPD), Employment and Social Development Canada launched the New Disability Data Strategy. They gathered disability data to achieve greater consistency in disability identification by type, and to improve coverage of the full range of disability types, especially mental/psychological, learning and memory disabilities. Sensory disabilities – seeing and hearing is collected along with other co-occurring disabilities.  It is recommended that standardised data be collected relating to rights for individuals who are deafblind,  along with opportunities and services available in each province  to help assess and compare differences and developments.


Access to Communication Support and Training

Because of the unique nature of deafblindness, communication is a significant and essential issue for a person who may require support to learn and develop communication.  For an individual who is deafblind, communication support and development needs to be a specific focus of service provision. Every person who is deafblind has the capacity for communication.  A lack of training in communication methods can greatly restrict individuals who are deafblind from opportunities for a full and active life. Even if training is available, it does not mean that individuals have the opportunity to communicate more widely, since this may depend on the availability of adequate Intervener Services.

Assistive Devices

Assistive Devices refers to any item, piece of equipment or product system that is used to increase, maintain and improve functional capabilities of individuals with disabilities. This can range from simple equipment or assistive devices (such as magnifiers) to integrated systems such as environmental controls (computerised systems for home automation tasks such as answering phone calls, answering door, turning lights off, smoke alarms).

Access to Healthcare

General practitioners are positioned to be a central point of access for healthcare and are usually the gateway to further medical support for persons who are deafblind. However, if the condition of deafblindness is not widely understood, it is unlikely that healthcare professionals will connect the wide-reaching effects associated to the complex conditions that cause deafblindness. Evidence from a 2013 Usher Syndrome survey carried out by Sense in England indicates that people who are deafblind often have to explain their condition to their family physician, as well as the progression of the condition and the types of issues they face in everyday life. Additional time and energy is required of the individual who is deafblind and misunderstandings can develop, especially if they see a different doctor each visit.

Access to Services

Canadians living with deafblindness have inconsistent access to supports and services across the country, whereby each province or territory has a varying degree of funding available to provide services for persons who are deafblind. A 2016 review of the services and supports available to individuals who are deafblind in Canada found that inconsistent and limited pockets of funding were available in Ontario, Alberta, part of British Columbia, Nova Scotia and New Brunswick. To further complicate the situation, most of the funding is limited to a specific number of hours per week or focussed on supporting individuals in specific tasks, such as employment supports.

A limited number of resources to support essential daily communication supports for this vulnerable population in a recognized G8 country is unacceptable. It also serves to defy the spirit of existing legislation and regulations that protect the rights of all Canadians. The Canadian Charter of Rights and Freedoms guarantees that regardless of race, national or ethnic origin, colour, religion, sex, age, or mental or physical disability, “every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination.”


These limits on access to supports and services for individuals living with deafblindness also contradict the CRPD’s “overarching principle promoted by the United Nations Convention on the Rights of Persons with Disabilities…that services be provided in the community, not in segregated settings,” and that “person-centred services are pref­erable, so that individuals are involved in decisions about the support they receive and have maximum control over their lives.


“Exclusion of individuals from the opportunities, freedoms, networks, events and resources of the society in which they live has a negative impact on that society and its economic prosperity” Individuals who are deafblind deserve the basic right to have access to a barrier free society which includes opportunities to communicate and interact within their communities on an equal level to opportunities enjoyed by their peers.




We have a commitment to uphold the UN Convention on Rights of Persons with Disabilities and promote, protect and ensure the full and equal enjoyment of all human rights and their fundamental freedoms for individuals with deafblindness.  Canada needs to recognize that the value and effectiveness of an accessible environment by trained, experienced professionals will achieve the most successful outcomes for individuals who are deafblind.


Official legal recognition of deafblindness as a unique and single disability is imperative; it is essential that individuals who are deafblind have their needs and experiences recognised and considered in disability legislation and policy.


A Common Framework and standardised census questions for the Canadian Disability Survey must be established to collect standardised data on the number of individuals with vision and hearing loss; so that the extent of deafblindness is understood and captured.  It is important that deafblindness is most common amongst older people is recognized and that a focus on early detection and support be provided to help prevent more serious health issues in this population.

All individuals with deafblindness must be offered the same opportunities regardless of where in the country and in which municipality they live. They must have access to competent and adequate support to ensure that they do not experience discrimination and have their rights respected on an equal level to that of their peers.

All individuals who are deafblind must be offered equal opportunities to realize their full potential regardless of age, residual vision and hearing, geographic location and any additional impairment.

Individuals who are deafblind are doubly challenged for physical accessibility as they cannot rely on visual or auditory cues for information.    They must be supported with specialized services to acquire knowledge and information, express requests and make choices.






Intervenor Services

Intervenor services provide the person who is deafblind with accurate information in an appropriate manner to enable them to make choices, plan future actions, communicate successfully, navigate their environment and achieve as much independence as possible. Intervenor services are responsive to the changing needs of the person who is deafblind.



“An intervenor…facilitates the interaction of the person who is deafblind with other people and the environment. The intervenor provides information about the environment and what is happening (using receptive language), assists the individual who is deafblind to communicate (using expressive language), provides or develops concepts where necessary, confirms actions, assists with life skills and most importantly, assists the individual to achieve as much independence as possible within their situation. The intervenor takes direction from the individual who is deafblind.”


Langue des signes québécoise (LSQ)/Quebec Sign Language

LSQ is a visual language with its own grammar and syntax, distinct from French, used by Deaf people primarily in Quebec and other French Canadian communities. sign language used in Canada and most LSQ users are located in Quebec.  LSQ is a combination of American Sign Language and French Sign Language.


Large Print

This helps people who have low vision. Large print materials should be prepared with a font (print) size that is 16 to 20 points or larger.


Methods of Communication

  • Adapted American Sign Language (AASL)
  • American Sign Language (ASL)
  • Braille
  • Fingerspelling
  • Gestures
  • Langue des Signes Québéquoise (LSQ)
  • Large print notes
  • Oral
  • Other, as determined by the individual who is deafblind
  • Print on Palm
  • Signing Exact English (SEE)
  • Tangible Symbols, including object cues and picture cues
  • Two-hand Manual








blindness, Deaf-blind, Disability, Independence, Independent Mobility, Low Vision, Victoria BC

Accessibility Working Group Survey, City of Victoria

Greetings from the City of Victoria,

The Accessibility Working Group (AWG), a City Council working group, was brought together to consider the needs of persons with a diverse range of disabilities including, but not limited to, physical, sensory, developmental, learning and mental health challenges. The AWG aims to recommend solutions which best meet the “wants” of all without compromising the “needs” of any.

If you are a person with a disability, and live in or visit the City of Victoria, you are invited to complete the following survey:

Accessibility Working Group Survey, City of Victoria.

The aim of the survey is to determine the accessibility barriers persons with disabilities face when travelling, shopping, working, living, and playing in Victoria. The AWG recognizes that accessibility challenges do not stop at municipal boundaries, but for the purposes of this survey, the AWG would like to hear about your experiences within the City of Victoria.

If you are unable to complete the survey yourself, you may have someone assist you. If you are assisting an individual with a disability to complete this survey, please indicate the answers of the person you are assisting.

Privacy Information and Considerations:
Please do not provide your name and address or any other personal information that identifies yourself or other individuals. Personal information that is submitted will be treated as though the City has received your consent to disclose it to the Mayor and Council, appropriate staff and the public. If you require further information about this survey, please contact

Information about the Accessibility Working Group can be found on the City website here.

Brad Dellebuur
Manager, Transportation
Engineering and Public Works
City of Victoria
1 Centennial Square, Victoria BC V8W 1P6

T 250.361.0325 F 250.361.0311