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A person receiving a vaccine. A sleeveless arm is injected with a needle.

CNIB urges provinces to ensure vaccination distribution strategies are accessible

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As COVID-19 vaccination clinics roll out across the country, CNIB is publicly urging provincial governments and local public health units to ensure their vaccine distribution strategies are accessible to Canadians with sight loss. For example:

  • Systems and applications for booking vaccine appointments should be accessible and tested by individuals who use adaptive equipment. Online booking systems must be WCAG 2.0 compliant, at minimum, according to the law. 
  • Queues, lines, and all information presented to those being vaccinated should be as accessible as possible. 
  • Staff and medical professionals should receive training on how to accommodate the needs of people with sight loss, as required.  

CNIB has distributed the following letter to all provinces asking them to publicly outline their accessibility accommodations that will be included in their vaccine distribution strategies. CNIB will be publishing their responses on our website to ensure Canadians with sight loss can learn what to expect.

If you encounter any accessibility barriers when booking a vaccine appointment, please email advocacy@cnib.ca

Provincial Responses

Response from the Government of Alberta

March 24, 2021

Dear Mr. Rafferty:

Thank you for your March 15, 2021 email regarding the Government of Alberta’s COVID-19 vaccination plans. I appreciate you raising the issue of vaccine accessibility for Canadians with sight loss.

Work on the vaccine distribution and immunization plan for Alberta has been underway for months by Alberta Health and Alberta Health Services (AHS). Alberta’s COVID-19 Vaccine Task Force’s role is to build on and complement this work, offering further oversight and support in areas such as planning, logistics, supply change management and security. The Task Force’s objective is to provide assurance to Albertans that government can deliver the most robust vaccination plan in the province’s history.

Alberta Health and AHS have provided the information in subsequent paragraphs outlining steps that have been taken to address the accessibility of Alberta’s vaccine distribution approach to people with sight loss.  

With respect to booking vaccinations, audio communications are available on all aspects of the vaccine rollout, including booking through Health Link (telephone 811). The service is available in 240 languages. If transportation to a vaccination site is a challenge, individuals are encouraged to access available resources through local community providers via telephone 211. To assist individuals with accessing and navigating AHS vaccination sites, way finders are available onsite. AHS vaccination sites are also handicapped accessible and, if desired, a support person is permitted to accompany individuals receiving a vaccine. AHS also provides the necessary time and support at vaccination sites to accommodate full reading and/or explanation of the vaccine, potential side effects, and the consent process. AHS immunizers are all regulated healthcare professionals who have experience in, and awareness of, strategies to assist those with visual impairment.

With respect to compliance with WCAG 2.0 standards, AHS conducted accessibility testing on its online booking app resulting in an 88 per cent score, which translates to a AA rating, based on the guide: https://webaim.org/standards/wcag/WCAG2Checklist.pdf.  AHS appreciates the prompting from CNIB to ensure compliance with the WCAG 2.0 standard and has identified additional opportunities to further increase accessibility.

Pharmacies and community physicians are key partners in Alberta’s vaccine distribution rollout. With respect to the accessibility of their booking systems and vaccine strategies for Albertans with sight loss, your email will be shared with the College of Physicians and Surgeons and the Alberta College of Pharmacy for their consideration.

Again, thank you for raising these issues, and for your advocacy on behalf of Canadians with sight loss.

Sincerely,
Paul Wynnyk
Deputy Minister

Response from the Government of Prince Edward Island

April 27, 2021

Dear Mr. Rafferty:

The Prime Edward Islands vaccine rollout has a goal to enable as many Islanders as possible to be immunized against COVID-19 as quickly as possible. In order to achieve this we need to consider accessibility issues for all Islanders. Below is the list of accessible considerations and accessing and using clinics for individuals that are visually impaired.

Booking Appointments: Clients have a phone number that they can call (1-844-975-3303). Staff booking the appointment’s verbally tell them the appointment time and describe where the clinic is located. When their appointment is booked they receive a reminder message from Skip the Waiting room 7 days out and 1 day out (option available to reschedule or cancel – if this happens a staff member would call them back to rebook the appointment) that verbally explains the time and location of the appointment. 

Training: All staff will be trained on how to properly provide sighted guide assistance at the Clinics. The following video on “Introduction of Sighted Guide” from the CNIB will be included in the orientation of all staff. Step 1: Introduction to Sighted Guide - VLRC - YouTube.

Signage: Posters or signage will be created in large print, with good colour contrast and in plain language. There will be many large directional signs to show the way to the clinic. Signage fits the criteria for CNIB’s Clear Print Guidelines. Social distancing markers will be clearly indicated in large print. 

Information at the Clinic: All printed information will also be reviewed verbally at the clinic. Greeters will review Covid-19 screening questions verbally. Registration clerks will also verbally review client information. Nurses will explain vaccine contradictions and review fact sheet verbally for all clients. 

Plexiglass: Plexiglass will be used as a barrier to protect staff and clients at registration to the clinic. Plexiglass barriers will be described to individuals as they approach the registration if the individual has a visual impairment. Plexiglas will have bright coloured tape around the outside to create a contrast for those individuals who are visually impaired. 

HPEI Webpages: All Covid-19 information on the www.princeedwardisland.ca website is accessible fort hose using screen readers or other adaptive technologies.

Support Persons/ Service Pets: Support persons and service pets are welcome at the clinic if needed by an individual for support. 

Regards,

Dr. Heather Morrison
Chief Public Health Officer

Cc: Hon. Ernie Hudson, Minister of Health and Wellness

Response from Nova Scotia Health and Wellness

Good morning,

Thank you for contacting us with respect to the province’s accessibility strategies specifically for Nova Scotian’s with sight loss. In your letter you note the importance of the ease of booking appointments through to accommodations at the vaccine clinics themselves. The Province recognizes the importance of providing all Nova Scotians with accessible and equitable access to vaccines by ensuring these principles are continually considered as part of our planning process and our vaccine program was developed using these principles.

When assessing the suitability of a site for use as an immunization clinic, Nova Scotia Health used a checklist that includes dozens of accessibility considerations aimed at ensuring we are accommodating the needs of all Nova Scotians. We recognize the importance of establishing vaccine clinics that meet the accessibility requirements of all our residents which includes not only physical accessibility, but also ensuring clinic staff can provide further accommodations as needed.

With respect to booking vaccine appointments, in addition to our toll-free 1-833 appointment line, we have partnered with CANImmunize to create a centralized online booking system allowing Nova Scotians to quickly and easily book their vaccination appointment. We recognize the importance of creating accessible systems and applications including accommodation for individuals who use adaptive equipment. However, given the rapid deployment of the vaccines and associated infrastructure, the public booking system has not yet undergone WCAG 2.0 compliance review or certification. Together with CANImmunize, this review will start before the end of April and is expected to take about 2 weeks. We are committed to implementing any changes identified through this audit in a reasonable timeframe.

The province’s focus remains on attaining population immunity as quickly as possible through our age driven prioritization plan with every Nova Scotian having an opportunity to receive their first dose by the end of June. As our immunization strategy continues to unfold, we remain committed to improving the system and structures in place for individuals who require accessibility accommodations while ensuring compliance with Nova Scotia’s Accessibility Act and the Accessibility Plan (2018-2021).

Thank you,

Nova Scotia Health and Wellness Correspondence Team

Response from B.C. Ministry of Health

May 12, 2021

Dear John M. Rafferty:
 
Thank you for your correspondence of March 15, 2021, regarding the accessibility of the COVID-19 vaccination clinics in British Columbia. I am responding on behalf of the Honourable Adrian Dix, Minister of Health and Dr. Bonnie Henry, Provincial Health Officer. I apologize for the delay in communication.

The Province has a vision to make BC a truly inclusive province and is committed to accessibility for all. As part of the mass immunization clinic planning process, accessibility considerations were addressed for the following: those with visual, mobility, hearing, and intellectual impairments.

Each clinic has a small vaccination area near the admitting desk that is to support people with accessibility requirements. If a person requires assistance they should self-identify to a greeter as they enter the clinic and the clinic staff will be happy to assist and ensure the experience meets the needs.

Clinic planning and operational considerations include:

  • Staff available to assist when requested by the client
  • Access to the clinic is barrier free
  • All spaces inside the clinic are barrier free; these include check-in, registration, immunization area, waiting area, post vaccination waiting area
  • Accessible washrooms available
  • Accessible parking / ability to drop off clients close to the entrance to the clinic
  • Access to public transit and shuttles; in areas where transit is available
  • Clients are welcome to bring a support person or their guide dog with them to their appointment

All information needed regarding the vaccination will be gathered during the upfront on-line or call-in registration process. There will be no need to complete any paperwork on site.

In the coming days the mass vaccination system will be rolled out. We have ensured the on-line booking solution follows the WCAG standards. In addition to this, if further support is required, clients will be directed (within the system) to contact the provincial contact centre to help complete any booking (particularly for accessibility challenges, no connectivity, in need of language translation services, etc.). 

The Province’s COVID-19 pages on its website, where the link to the on-line booking tool, and where COVID vaccine information is found, complies with WCAG standards.

Thank you for your letter and for asking these important questions. I appreciate the opportunity to respond, and hope you find this information helpful.

Sincerely,
Thomas Guerrero

Executive Director, Patient and Client Relations
Corporate Issues and Client Relations
Ministry of Health

Response from the Government of Newfoundland and Labrador

June 10, 2021

Dear Mr. Rafferty:

Thank you for your correspondence wherein you requested that provincial vaccine distribution strategies are accessible to Canadians with sight loss. I appreciate your concern and advocacy on behalf of those with sight loss and indeed this is an important issue.

Individuals can book vaccine appointments online or through a toll-free phone number. Unfortunately, the online booking system currently in use is not fully WCAG 2.0 compliant, but this is something that the vendor’s Product and User Experience Team is working on. In the interim, individuals with sight loss are able to book their appointment through telephone. The COVID-19 vaccine website, which houses a wide breadth of information regarding COVID-19 vaccination in Newfoundland and Labrador, is WCAG 2.0 compliant.

Signage and forms used at vaccination clinics are required to meet certain accessibility standards. Examples of signage used at clinics can be found at www.gov.nl.ca/covid-19, all of which are in compliance with the provincial government’s Accessible Communications Policy. Regional health authority staff are able to avail of sensitivity training to support them in providing care to special populations; however, this training is not mandatory. 

I appreciate you raising these concerns with me and I will bring them forward to my team for appropriate action. Thank you for your correspondence. 

Sincerely,
Dr. Janice Fitzgerald, MD, MPH
Chief Medical Officer of Health

Cc: Hon. John Haggie, Minister of Health and Community Services 

Response from the Premier of Nova Scotia

November 3, 2021

Dear John Rafferty:

Thank you for your letter dated October 4th, 2021, regarding the accessibility of vaccine passport systems for blind and partially sighted individuals. We appreciate the useful suggestions for implementation strategies that would offer the necessary accommodations for Canadians with sight loss as we move forward with our proof of full vaccination protocol.

The Nova Scotia Digital Service has supported the implementation of this protocol with the rapid development and delivery of several digital services. Their philosophy includes continuous improvement in their efforts to meet user needs. This includes revisiting accessibility needs and looking for opportunities to improve products.

Their work has included providing Nova Scotians with a proof of vaccination document (in PDF form), a means of adding out-of-province doses to it, and a scanner app that businesses and organizations can use to quickly check proof of full vaccination for discretionary activities.

These digital products follow the Government of Nova Scotia design standards, which have many accessibility standards built in. These standards adhere to WCAG 2.1 AA criteria and efforts were made to comply with them whenever possible in the delivery of proof of vaccination digital products. The teams also incorporated testing with a number of assistive devices and tools.

All provinces and territories worked with the federal government to develop the Canadian standard proof of vaccination, which Nova Scotia has adopted. Where possible, efforts were made to comply with the WCAG standards: PDF Techniques for WCAG 2.0. However, it is not currently available in large print or braille. The digital products team continues to review opportunities for further improvement. Note that people can present this proof in either paper or digital formats. While the Canadian standard proof may be required for international travel, the original vaccination records that Nova Scotians received will continue to be accepted at our provincial border and within the province to access discretionary activities.

For people who do not have access to technology or require technology assistance, the province offers phone support to request proof of vaccination and receive it by email or mail. Public libraries and many community organizations are also playing an important role to help people with these challenges to access their proof.

Communications Nova Scotia has worked in lock step with the Nova Scotia Digital Service as these digital products were developed and rolled out. They are leading communications efforts to Nova Scotians about these services and other aspects of the proof of full vaccination protocol through numerous channels. While not every piece of communication material can be fully
accessible to all audiences, they offer information in many different ways in an effort to meet different audiences’ needs.

The COVID-19 site is built to WCAG 2.1 standards and is a responsive design so that content is accessible on different devices. The web content also follows web writing standards that help make the information easier to find, understand and act on. It necessarily relies on some content being presented in PDF form, such as the public health order and protocols.

On our social media platforms, more colour contrast and accessible fonts on graphics, alt-text on images and camel case for hashtags all support people with sight loss. On videos that are shared via these platforms, hard captioning supports people with hearing loss and voice overs support people with sight loss.

Our media briefings are an important communication opportunity where we’ve spoken extensively about proof of vaccination. These briefings are livestreamed, recorded and posted on the Government of Nova Scotia YouTube channel. People with sight loss can listen to these briefings and people with hearing loss can access the information via the ASL interpretation and hard captioning provided.

While the focus of your organization is people with sight loss, I would like to note that we’ve aimed to also make COVID-19 information accessible in different languages. Most materials are available in English and French. We have also partnered successfully with community organizations supporting newcomers to provide some key information which they have helped communicate in many languages. We would be pleased to partner with CNIB and other groups to do the same for people with disabilities. The Accessibility Directorate will reach out to you directly to see what opportunities there may be for such partnership.

Thank you for taking the time to share your experience and suggestions with us. 

Sincerely,

Honourable Tim Houston
M.L.A. Premier of Nova Scotia

Response from Saskatchewan Minister of Health

December 8, 2021

Dear Mr. Rafferty:

Thank you for copying me on your October 4, 2021, letter to Premier Scott Moe about the accessibility of the COVID-19 proof of vaccination. I appreciate you taking the time to share the concerns of the CNIB and apologize for the delay in response as we have been handling a very high volume of inquiries.

eHealth Saskatchewan officials indicate that MySaskHealthRecord web portal is compliant with WCAG 2.0 AA standard. For the mobile apps (SK Vax Wallet and SK Vax Verifier), a lot of different accessibility features are provided by the phone operating systems themselves and our apps are able to support and enhance these features.

Users of screen readers (text-to-speech) can navigate within the app in the logical order and eHealth officials have completed testing with VoiceOver on iOS and Talkback on Android (the default implementations of the screen readers on these systems). The nature of elements are clearly indicated to facilitate interaction (“Heading”, “button”, etc.). Elements are grouped together when that makes sense (for example, instead of getting two elements “Date of vaccination” and “2021-09-01”, the screen reader would select all the elements and pronounce “Date of vaccination is the first of September 2021”. 

Night mode supports temporary environmental constraints (at night for example, or following a user’s preference) including support for high contrast mode and for color inverted mode (while preserving the right color scheme for the QR Code). All color palettes were checked against the WCAG 2.0 AA color contrast standards.

The app supports different zoom levels (up to 600 per cent in most cases) while providing a way to scroll through content if it gets too big to display. The app also supports custom font face and font weight, this is particularly helpful for users with dyslexia. All color indicators (especially when indicating vaccination status for COVID-19) are accompanied with an icon or text.

Officials indicate that the verifier app has multiple layers to convey the information, including:

  • Visual, with color and icon;
  • Textual, with a clearly worded confirmation;
  • Auditory, with an error or success sound; and
  • Physical, with a vibration (or haptic feedback, on iOS) that is different whether the verification is pass or fail.

I hope you find this information useful. Again, thank you for writing.

Sincerely,

Paul Merriman
Minister of Health 

Cc: Premier Scott Moe
Honourable Everett Hindley, Minister of Mental Health and Addictions, Seniors and rural and Remote Health

Response from the Government of Northwest Territories

December 9, 2021

Dear Mr. Rafferty:

Thank you for your letter requesting information about how the Northwest Territories (NWT) is supporting accessibility of COVID-19 Vaccination records for the visually impaired.

In the NWT, individuals can request a copy of their Proof of Vaccine Credential (PVC) either through an online application form that can be printed or saved as a PDF to an electronic device, or in-person with direct assistance from staff.

Our Proof of Vaccine Credential (PVC) online application webpage is compliant with the Web Content Accessibility Guidelines (WCAG) and the PVC is produced as an Accessible PDF that is compatible with assistive technologies. In addition, the personal identification and health record information on the printed version of the PVC is displayed in large font. Those who may need assistance, including those who may not have access to a printer, can visit the public health unit or a Community Health Centre in any of the NWT communities and get direct support from staff to acquire their credentials.

The Government of the NWT has not yet introduced a Vaccine Passport Program that would require the use of a PVC to access certain facilities or venues. As such, we do not have an NWT PVC verifier APP. We currently have a voluntary option available to non-essential businesses or organizations that wish to exceed indoor gathering limits, with approval from the CPHO, on the condition of requiring a PVC from those in attendance.

Thank you again for your letter. We will continue to consider accessibility as a core requirement for any future decisions.

Sincerely,

Julie Green
Minister of Health and Social Services

C. Honourable Caroline Cochrane, Premier