On April 30, 2021 the Environmental Sensitivities Coalition of Canada emailed the following government groups of Newfoundland, informing them of their responsibilities to people with ES who react to fragrances, quats and/or volatile organic compound products. All people with ES are welcome to send this letter when requesting personal accommodations and use the personal letter template.
Email Newfoundland Accessibility at disabilitypolicy@gov.nl.ca
Email the Newfoundland Services customer service at servicenlinfo@gov.nl.ca
Email the Premier of Newfoundland at premier@gov.nl.ca
If you need to contact a specific group to ask for accommodations, you can search the Newfoundland Government website for their email address. They don’t always make them easy to find, so you can always call a group and ask for their email address.
Accessibilities accommodations letter from ESCC
Government of Newfoundland
Confederation Building, East Block
P.O. Box 8700
St. John’s, NL
A1B 4J6
Newfoundland Service Representatives,
In accordance with human rights legislation, environmental sensitivities (ES) are a recognized disability requiring accommodation both provincially and federally. The Accessible Canada Act denotes in section eight that universal design for accessibility in buildings is necessary for all disabled people to have equal access and opportunities. As people with environmental sensitivities are negatively impacted by fragrances, quaternary ammonium compounds and high levels of volatile organic compounds (VOCs) in cleaning products, hand sanitizers, and personal care products, the use of these products in government buildings is counter to accessible design as listed in the ACA, linked below. Currently, even though 32.2% of the population has self-identified as having negative health reactions to fragranced products, Newfoundland Service locations across the province do not meet the bare minimum in terms of accessibility for people with environmental sensitivities. Additionally, 1.1 million Canadians have been diagnosed with multiple chemical sensitivity, 3.8 million people have asthma, 2 million have chronic obstructive pulmonary disease, and 4.7 million people have migraines, all of whom can be affected by fragrances.
As a government service, there are several things that should already have been in place to be in accordance with accessibility law. There is currently no signage in the buildings indicating fragrance free policies, nor are there notifications for customers upon booking appointments to alert them to not wear scented products. There is insufficient ventilation and a lack of air purification systems in place to counter customer product use. Health Canada warns that indoor volatile organic compounds are a hazard—dangerous not only to sensitive customers, but a constant health risk for your employees. HVAC air purifiers rated to clear the size of the location, with carbon filtration designed to remove indoor VOCs, are necessary for accessibility.
With regards to public health policies, there are further considerations not currently being made. Customers should not be mandated to use hand sanitizers if they have a sensitivity to the product. While all Health Canada approved hand sanitizers can be problematic for people with ES, (who can have a variety of reactions to alcohol/ethanol, benzalkonium chloride and hydrogen peroxide), any additional scent, fragrance and parfum additives can compound reactions, and should be universally avoided. Ideally, unscented soaps and hand washing facilities should be made available to all people entering the building, to adhere to universal design standards. In a situation where this is not possible, hand sanitizers should be placed outside the building entrance to minimize exposure. Additionally, staff must not use hand sanitizers before touching documents for those who have specific product triggers.
Off-site and outdoor or online options must be available for people who cannot go in the building due to anaphylactic, dermatological, respiratory, neurological, emotional and vascular responses to products being used to disinfect, should non-toxic unscented soaps not be allowed by local public health mandates. A curbside service needs to be established in which the bulk of the process is handled by phone or website and then identity and documents can be verified in person outside the facility. Photographs for identifications should be able to be captured offsite based on specified parameters similar to passports. As some people have issues with print inks, digital copies should be an option for all documents. Eye tests should be available as a doctor’s note.
Accommodation for people with disabilities is a legal requirement, and as a government service, you should be held to the highest standard of adherence to this law.
Personal accommodations letter template
YOUR NAME
ADDRESS
CITY, PROVINCE
POSTAL CODE
PHONE NUMBER
Government of Newfoundland
Confederation Building, East Block
P.O. Box 8700
St. John’s, NL
A1B 4J6
DATE
Newfoundland Service Representatives,
My name is YOUR NAME HERE and I am a person with an environmental sensitivity, covered under human rights access legislation. I have attached a letter from the Environmental Sensitivities Coalition of Canada which outlines the legal obligations for public buildings regarding accommodation for persons with disabilities such as my own.
Your locations are inaccessible to me due to:
- Use of a scented and/or alcohol hand sanitizer.
- Use of scented cleaning products or quat disinfectants in the facility.
- Improper air flow and lack of air purification that includes chemical filtration.
- Lack of fragrance free policy for customers and staff and no visible signage.
- ADD OR REMOVE FROM THIS LIST
My reactions to these products include:
- ADD YOUR REACTIONS HERE
My accommodation requirements are:
- Ventilation of spaces using products that contain quats and/or volatile organic compounds.
- Air purification that includes carbon filters.
- Cleaning of areas that have been previously inundated with fragranced products to ensure they are not lingering from surface absorption in carpets and fabrics.
- Unscented soaps instead of hand sanitizers and unscented cleaning products to be used.
- ADD OR REMOVE FROM THIS LIST
If the above accommodations can not be met, I will need to have the option to submit my documents via email or online. I will need to make payments over the phone, online or via a wifi payment system outside the office. If any other information is needed from me, such as a photograph or eye exam, I will need to be able to provide it from another source.
Please contact me at XXX-XXX-XXXX to further discuss these accommodation needs.
Kind regards,
YOUR NAME