On April 11th, 2021 the coalition sent the following letter as an official request for proper accommodations for people with environmental sensitivities to Service Ontario. It is available to use for all people with environmental sensitivities in Ontario to attach to their requests for safe access to their local branch.
Please see correspondence updates below the letter and template.
Email Service Ontario at CEO@ServiceOntario.ca.
Email Ontario Accessibility at accessibility@ontario.ca.
Email the Premier at premier@ontario.ca.
If you need to find a specific government office email address you can search on the Ontario government website. They don’t always make it easy to find them, so you can call the office and ask for their email.
In addition, the Coalition has created a personal accommodation letter template so that you can fill out your specific requirements and reactions and submit it with your request. You can download the letter in Word or Pages formats.
Accessibility accommodation letter from ESCC
Service Ontario
Treasury Board Secretariat
315 Front Street West, 7th floor
Toronto, Ontario
M7A 0B8
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, Service Ontario 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 are 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 accommodation letter template
YOUR NAME
ADDRESS
CITY, PROVINCE
POSTAL CODE
PHONE NUMBER
Service Ontario
Treasury Board Secretariat
315 Front Street West, 7th floor
Toronto, Ontario
M7A 0B8
DATE
Service Ontario 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
Correspondence Updates
On April 30th, 2021, the ESCC replied to Service Ontario Customer Service:
We are glad that you are moving towards using scent-free products in the service centres. As indicated in the letter attached, simply choosing scent-free products is not sufficient however as that is just one substance that affects people with environmental sensitivities to chemical substances. We have created a full accommodations information package here: https://environmentalsensitivities.org/2021/04/12/fragrance-quat-and-voc-sensitivity-information-and-accommodation-guide/
Without ensuring that the products do not also contain VOCs and quats, this will not be meeting the accommodation request. What is the timeline for your change of products? We would have happy to assist in selecting products that would be safer for people with ES.
While we understand that management of scents on clients is difficult, signage must created, employees must adhere to the policy, the policy needs to be clearly stated on the website and people must be told when they make their appointments. This process is used at many other businesses and hospitals. It is not an undue burden as set out by law. Proper ventilation and air purification were also listed. These not only make the air safer for people with ES, should clients have scented products, they increase safety for everyone for Covid-19 transmission risks. Please advise as to the availability of hand washing with unscented soaps over the use of hand sanitizers. We hope you all are well and we look forward to working with you on this important access issue that affects approximately 30% of the population.
On April 27th, 2021, Service Ontario Customer Service sent us this reply:
Dear Erin Caton:
Thank you for your letter on behalf of the members of the Environmental Sensitivities Coalition of Canada and for sharing your concerns about the accessibility of ServiceOntario locations.
ServiceOntario recognizes that accessibility is crucial in making sure that persons with disabilities have full access to every aspect of life and we are committed to preventing, identifying and removing barriers for our customers.
While ServiceOntario cannot guarantee a scent-free environment, we recognize the difficulties many face due to these sensitivities. When our customers require assistance, our centres will help in any way they can.
We have introduced an ‘active offer of assistance’ protocol that requires staff to offer assistance to customers who are experiencing barriers to our services, whether or not assistance is requested, or whether the customer is accompanied by a support person.
We are reviewing our website and our ‘active offer’ process to help ensure that customers with accessibility requirements are accommodated.
We are also working to ensure that products placed in ServiceOntario centres are scent-free.
Once again, thank you for writing, and for your commitment to keeping your members safe. Please accept our best wishes for health and safety during these uncertain times.
Sincerely,
Customer Experience Office