Accessibility

Western Stevedoring Accessibility Plan
[2023-2026]

OVERVIEW

About Western Stevedoring

Western Stevedoring or Western Stevedoring Company Limited is the Terminal and Stevedoring division of Western Group Holdings Limited. We provide the people and the management responsible for handling cargo imported and exported through BC ports. We also manage terminal operations and provide various shipping and transportation based support services. Western Stevedoring plays an essential role in building relationships and ensuring that Canada’s shipping and transportation network is accessible for our employees, customers, partners and the community.  We pride ourselves in working successfully with all levels of government, port authorities, logistics partners, and First Nations. Our knowledge and leadership in the marine logistics industry are fundamental to supporting economies in the communities where we work.

Our strong support of our people and community is why we are proud to introduce our Accessibility Plan.

Accessibility-Related Requirements & Standards

As a federally regulated company in the transportation sector, Western Stevedoring is governed by the Accessible Canada Act (ACA).

The ACA is a federal law enacted by the Canadian government in 2019 to promote and ensure equal access and inclusion for persons with disabilities. The ACA applies to all federally regulated entities, including companies, organizations, and government agencies.

Per the Act, all federally regulated entities must:

  • Prepare and publish an initial Accessibility Plan
  • Establish an accessibility feedback process
  • Report annually on the progress towards the plan and address any feedback received

Our Accessibility Plan must be reviewed in its entirety and published every three years.

Provisions of the CTA Accessibility-Related Regulations

Further to the requirements in the ACA, Western Stevedoring is required to meet the applicable provisions of the CTA requirements made under subsection 170(1) of the CTA, which includes the Accessible Transportation of Persons with Disabilities Regulations (ATPDR).

This plan outlines Western Stevedoring’s current and future actions to comply with these regulations regarding:

  • Communications of information to persons with disabilities
  • Terms and conditions with respect to the transportation of persons with disabilities
  • Modifying and posting signs in and around facilities or premises used in the transportation of persons with disabilities
  • Training of personnel employed at facilities or premises used in the transportation of persons with disabilities.

    Together, the ACA, the CTA and the ATPDT represent a significant step towards creating a more inclusive and accessible society for all Canadians, including those with disabilities. By complying with these requirements, Western Stevedoring can help ensure that we are providing equal access and opportunities to all members of society.

    Plan Overview

    This Plan applies to Western Stevedoring locations in North Vancouver, Victoria and the North Island.  The Plan outlines how we will identify, remove and prevent barriers in the following priority areas:

    1. Employment
    2. The built environment
    3. Information and Communication Technologies (ICT)
    4. Communication, other that ICT
    5. The procurement of goods, services, and facilities
    6. The design and delivery of programs and services
    7. Transportation

      In the employment area, the company has set two goals that focus on promoting employment opportunities for individuals with disabilities and creating a safe, barrier-free work environment.  Key activities in this area will focus on candidate attraction and recruitment strategy, examining existing policies and developing an anti-discrimination policy, providing unconscious bias training to all managers, and conducting an audit of human resource systems and tools.

      For the built environment, Western Stevedoring aims to create a barrier-free environment that provides safe access to all employees and members of the public. The company has set two goals that include conducting a formal inventory and list of potential upgrades for all common spaces and working with the Greater Victoria Harbour Authority (GVHA) to ensure that the Victoria Cruise Terminal, Western Stevedoring’s only location accessible to the public, is a barrier-free environment.

      In the ICT area, Western Stevedoring has set two goals that focus on ensuring all employees have access to the tools and systems they need to perform their job duties and identifying existing barriers in the digital environment.

      For communication, Western Stevedoring aims to develop a communication standard that ensures accessibility and eliminates barriers. Activities will focus on establishing a best practice manual for creating communication materials and providing regular training for managers and key stakeholders.

      In procurement, Western Stevedoring aims to incorporate accessibility as a key component in the procurement of goods, services, and facilities by working with vendors that provide accessible designs and have established accessibility goals.

      Regarding transportation, Western Stevedoring has set goals to provide barrier-free access for customers and passengers, ensure the accessible design of signage, provide regular accessibility training for all employees, and include a point of contact for travelers with disabilities to inquire about accessible facilities.

      Overall, Western Stevedoring has set specific and actionable goals in each priority area to ensure accessibility and inclusivity in the workplace.

      GENERAL

      Accessibility Statement

      Western Stevedoring, and its subsidiaries, are dedicated to identifying and addressing barriers and limits to full participation that impact people with disabilities through the implementation of our Accessibility Plan.

      We will continue to consult with members of the public, our employees, and subject matter experts to ensure that new barriers are not created as we continue a path to greater accessibility.

      Accessibility Committee

      WSCL, on behalf of Western Stevedoring, will establish an accessibility working group within a broader Diversity & Inclusion Committee. Our current Accessibility Plan working group includes:

      Jessie Rai
      Director, Human Resources
      Western Stevedoring

      Kim Stegeman
      Vice President, People & Sustainability
      Western Group

      Nelia Willis
      Sustainability Program Manager
      Western Group

      Donna Edwards
      Human Resources Coordinator
      Western Stevedoring

      Roger Dias
      Director, Information Technology
      Western Stevedoring

      Feedback

      Western Stevedoring is committed to providing an open and transparent feedback process. For more information, to provide feedback, or to request alternative formats of this Plan, please Jessie Rai, Director, Human Resources at Western Stevedoring through one of the following methods: 

      Alternative Formats

      Western Stevedoring’s Accessibility Plan is available in the following formats:

      • Print
      • Large Print
      • Electronic
      • Audio

      A Braille copy of Western Stevedoring’s Accessibility Plan may be requested:

      PRIORITY AREAS

      Area 1: Employment

      Our Accessibility Goal

      Western Stevedoring values diversity, equity and inclusion (DEI) in the workplace and strives to create a welcoming and accessible environment for all employees.

      Current Level of Accessibility

      Western Stevedoring has taken a proactive approach to diversity and inclusion for all underrepresented groups including individuals with disabilities. In 2021-2022, we performed a diversity, equity and inclusion audit to identify areas of improvement and have since:

      • Established a DEI Committee dedicated to establishing best practices and promoting DEI at Western Stevedoring and its subsidiaries.
      • Published a DEI policy and job ad statement.
      • Engaged a proactive recruitment strategy to attract underrepresented groups through engagement with immigration services, refugee services, Wounded Warriors Canada, and various First Nations communities.
      • Rolled out DEI fundamentals training through the Blue Ocean Brain Platform in 2023.

      Actions

      Goal 1: Western Stevedoring will implement additional candidate attraction and recruitment strategies that promote employment opportunities and growth for individuals with disabilities by:

      • Reviewing policies to ensure that accessibility is fully incorporated into an Anti-Discrimination policy and have it clearly articulated on all job ads and associated job activities by December 2023.
      • Including a statement that encourages applicants to request accommodations during the application process by December 2023.
      • Expanding our candidate outreach program to include accessible job boards geared towards underrepresented groups, including people with disabilities, by December 2023.
      • Creating an annual internship program through British Columbia’s Work-Able Internship program and applying in March 2024.
      • Establishing at least three community partnerships, such as associations and post-secondary institutions to further promote employment opportunities within the disability community by 2026.

      Goal 2: Provide a safe, welcoming, and barrier-free environment for employees with disabilities by:

      • Providing allyship and unconscious bias training to all managers through the Blue Ocean Brain Platform and other means (as deemed appropriate) starting in 2023.
      • Collecting feedback from employees on DEI, including accessibility, starting in 2023.
      • Establishing a policy to provide employees with disabilities accommodations for training and development opportunities to ensure equal access to career advancement by December 2023.
      • Assess the effectiveness and impact of past manager training related to accessibility and inclusion training programs starting in 2024.
      • Conducting an audit of employee-facing human resources systems and tools to identify barriers and develop a barrier removal plan by 2026.

      Goal 3: Launch a comprehensive employee communication campaign starting in 2023 to inform them of new accessibility policies and services available to them. Communications will include awareness of disability definitions and common barriers to accessibility.

      Area 2: Built Environment

      Our Accessibility Goal

      Western Stevedoring wants to ensure that all our facilities are barrier-free for our employees, customers, and members of the public. We need to understand the safety and security of our facilities and the jobs performed on-site to prioritize accessibility upgrades.

      Current Level of Accessibility

      The majority of Western Stevedoring’s facilities are accessible only by employees, vendors and other authorized personnel; members of the public are not permitted to enter without prior approval and knowledge of safety and security procedures. We provide accommodation for employees wherever possible per the safety standard of each job performed. As many of the services performed by Western Stevedoring are conducted by trained professionals in labour-intensive roles with bona fide occupational requirements, we recognize that accessibility has not always been a priority in the design of our Built Environment and common spaces.

      The Victoria Cruise Terminal is our one facility open to the public. Western Stevedoring operates the terminal on behalf of the Greater Victoria Harbour Authority (GVHA) and works with cruise carriers in the transportation of passengers from the cruise ship through the terminal. In 2022, several service enhancements and upgrades were identified at this facility, many of which are underway.

      Actions

      Goal 1: Create a physical environment that is free from barriers and provides safe access to all employees by: 

      • Completing the addition of an accessible ramp to the North Vancouver office building by June 2023.
      • Implementing training for all new employees during onboarding on the proper use of accessibility features throughout the facilities by December 2023.
      • Allocating and communicating a designated quiet space at all work locations for employees by December 2023.
      • Conducting a formal inventory and list of upgrades for all common spaces by June 2024, including but not limited to, lunchrooms, washrooms, shower facilities, common areas, access points, and parking spaces that will need to be upgraded with accessibility features.
      • Establishing a priority list, budget and approvals for all accessibility upgrades by June 2025.

      Goal 2: Provide a barrier-free environment for members of the public travelling through the Victoria Cruise Terminal by:

      • Establishing designated service animal relief areas outside the terminal, inside the terminal on the path of travel, and in restricted access areas beyond security checkpoints by December 2023.
      • Conducting a formal inventory and list of upgrades for all areas accessed by the public, including but not limited to washrooms, access points, and parking spaces that will need to be upgraded with accessibility features by June 2024.
      • Establishing a priority list and budget for all accessibility upgrades by June 2025.
      • Obtaining approval and establishing a timeline for the implementation of all accessibility upgrades by June 2026.

      Area 3: Information and Communication Technologies (ICT)

      Our Accessibility Goal

      At Western Stevedoring, our goal is to ensure that all digital platforms and content are accessible to everyone, regardless of abilities. First and foremost, we are dedicated to establishing best practices and identifying existing barriers in our digital environment. We will continue to monitor and improve our online accessibility by implementing accessible design practices, providing alternative formats, and offering assistive technologies.

      Current Level of Accessibility

      Western Stevedoring adheres to Web Content Accessibility Guide (WCAG) 2 standards for all public-facing ICT communications. We rely on service providers such as Microsoft and ADP to provide accessibility features to our employees and, wherever possible, we have provided accessibility tools to accommodate employee access to ICT.

      Actions

      Goal 1: Ensure that all employees have access to the tools and systems they need to perform their job duties by:

      • Consulting with professionals with lived experience of disability to develop a formal process for employees to request adaptive technology for interpretation and accessibility by January 1, 2024.
      • Establishing an understanding of employees’ need for adaptive technologies, then creating a budget for securing and implementing adaptive technologies requested by employees starting in 2024.
        • Identifying government programs that offer employers subsidies to provide adaptive technologies starting in 2024.
      • Amending guidelines for fonts and colour schemes for all digitally published and broadcast communication materials by December 2024 and implementing the guidelines starting in 2025.

        Goal 2: Further understand the barriers that exist in our ICT infrastructure and ensure plans are in place to remove barriers where possible and upgrade our standards to WCAG 2.2 by:

        • Creating an internal ICT Accessibility Assessment tool by December 2023.
        • Conducting an Accessibility Assessment of all ICT systems by December 2024.
        • Establishing actionable goals to address any barriers identified during the assessment by December 2025.

        Area 4: Communication, other than ICT

        Our Accessibility Goal

        Communication is crucial for the day-to-day interactions between our employees and our customers. At Western Stevedoring, our goal is to ensure that all communication standards meet or exceed accessibility standards, allowing individuals with disabilities to access and communicate within our organization.

        Current Level of Accessibility

        Western Stevedoring has been intentional in our communication to ensure that our communications are understood by the intended audience; however, accessibility has not been a priority in our communication strategies.

        Actions

        Goal 1: Develop and incorporate a communication standard designed to eliminate barriers and ensure accessibility from the outset by: 

        • Establishing a best practice manual that incorporates accessible design principles and communication standards (e.g., plain language) for creating documents, presentations, memos, etc. for all published and broadcast communication materials by December 2024.
        • Providing regular training for key stakeholders on effective communication strategies for accessible communication starting in 2024.
        • Collecting feedback from employees and the public regarding our overall communication strategy and the level of accessibility starting in 2026. 

        Goal 2: Ensure that all employees have access to training opportunities and career advancement by:

        • Establishing a process for employees to request accommodations in advance of training sessions to ensure that training platforms and materials are accessible by December 2023.

        Area 5: Procurement of Goods, Services and Facilities

        Our Accessibility Goal

        At Western Stevedoring, we aim to promote and support accessibility for all Canadians by holding ourselves and our vendors accountable for establishing accessible practices. We will work with vendors owned and operated by people with disabilities, that provide goods and services with accessible design, and/or have established accessibility goals to remove barriers for employees, customers, and the public.

        Current Level of Accessibility

        Accessibility has not been a priority in the procurement of goods, services and facilities at Western Stevedoring.

        Actions

        Goal 1: Incorporate accessibility as a key component in the procurement of goods, services and facilities by:

        • Including accessibility consideration in the development of a Responsible Procurement policy by December 2026.
        • Establishing a formal process to re-evaluate agreements with existing vendors to address barriers that exist in the procurement process and delivery of those goods, services and facilities by December 2026.

        Area 6: Design and Delivery of Programs and Services

        Our Accessibility Goal

        Western Stevedoring offers a wide variety of programs and services to our customers including ship operations, terminal operations, cruise ship services, and cargo tracking. Our goal is to provide customers with barrier-free access to our services through the design and delivery of those services.

        Current Level of Accessibility

        Western Stevedoring has some accessibility services available to customers including washrooms and parking but acknowledges that many of our services will need to be made more accessible.

        Actions

        Goal 1: Ensure customers and passengers travelling through the Victoria Cruise Terminal are aware of and have access to information about the services and facilities available to them by:

        1. Publishing the following information on our website and in multiple formats by December 2024:
          • hours of operation
          • location of the designated parking area
          • location of designated drop-off and pick-up areas
          • passenger assistance information, including telephone numbers for accessibility information
          • wheelchair or electric cart services
          • location of designated relief areas for service animals
          • accessible inter-terminal transportation
          • accessible ground transportation
          • complaint resolution services
          • escort passes; and
          • any other relevant information.
        2. Conducting an audit of the Victoria Cruise Terminal to assess opportunities to implement accessibility safety measures, such as tactile and high contrast markers on walkways, by 2026.

        Goal 2: Provide a barrier-free experience for our customers and passengers travelling through the Victoria Cruise Terminal by:

        • Providing regular accessibility training informed by subject matter experts for public-facing employees starting in 2024.
        • Establishing a point of contact (e.g., an existing customer service desk) at the Victoria Cruise Terminal where travellers can inquire about accessible facilities, request assistance, and/or submit recommendations for improvements to accessibility by 2026.

        Area 7: Transportation

        Our Accessibility Goal

        Western Stevedoring operates under the jurisdiction of Transport Canada and is subject to the accessibility requirements outlined in the Canada Transportation Act and the Accessible Transportation of Persons with Disabilities Regulations. Our Cruise Terminal operations in Victoria, on behalf of the Greater Victoria Harbour Authority (GVHA), facilitate the transportation of members of the public arriving on cruise ships. Our goal is to provide facilities that limit barriers and support people with disabilities arriving at Victoria responsibility to provide training to our personnel, signage, communication, and policies that support the mobility of individuals with disabilities.

        Current Level of Accessibility

        Western Stevedoring, following a Canadian Transportation Authority (CTA) inspection in 2023, has begun the process of upgrading the facilities open to the public with accessibility features, including but not limited to updating signage, providing on-site wheelchair services, reviewing transportation options, and adding animal relief areas.

        Area 7.1: Signage

        Goal 1: Provide cruise passengers with barrier-free access to the Victoria Terminal by:

        • Establishing priorities, timelines, budget and securing approvals from GVHA and Western in 2023 for accessibility enhancements (e.g., incorporating Braille on washroom signage).
        • Implementing signage accessibility enhancement priorities throughout the Victoria Terminal by June 2026.

        Area 7.2: Personnel Training

        Goal 1: Ensure the passengers with disabilities have access to the services and support to travel through the Victoria Terminal by:

        • Providing training informed by subject matter experts to all staff who may interact with people with disabilities from the public starting in 2024. The training will include best practices for communicating with travellers, what services to offer people with disabilities, how to provide physical assistance, and how to handle mobility aids and other special equipment including service animals.
          • Establishing a timeline for when new employees will receive training and a regular schedule for refresher courses.
          • Keeping employees and management accountable for maintaining records of when employees have been trained.

          Area 7.3: Terms and Conditions

          Terms and Conditions are a priority area outlined in the Transportation Canada Act. Western Stevedoring is dedicated to ensuring barrier-free access to the Victoria Cruise Terminal for all passengers but is not responsible for establishing tariffs, rates, fares or charges concerning the transportation of people with disabilities.

          Where we work with GVHA, carriers, and other entities of WSCL, Western Stevedoring will facilitate, promote, and encourage high standards of accessibility and the removal of barriers.

          CONSULTATIONS

          Summary

          Understanding the lived experience of people with disabilities is a key factor in the development of our Accessibility Plan. The Government of Canada’s Accessibility Strategy starts with the guiding principle, “Nothing without us”; these Plans and Strategies cannot meaningfully progress accessibility without input and guidance from people with disabilities. Western Stevedoring worked with British Columbia Centre for Ability (BC CFA) in the review and development of our Accessibility Plan.

          Consultation Process

          We provided the BC CFA with a draft of our Plan for their review. We followed this with a live session to discuss the impact and significance of our goals towards creating an accessible workplace and experience for our employees, customers and the public.

          The session was hosted in person at #15 Mountain Hwy, North Vancouver on May 4, 2023, and we inquired about any accommodations that could be made to support the full engagement and participation of the BC CFA consulting team in advance of the meeting.

          During the consultation session, each priority area of the Plan was discussed and was accompanied by a PowerPoint presentation visible to all participants.

          Results

          During the consultation session, each of Western Stevedoring’s goals and corresponding commitments were reviewed in detail to gather feedback from the BC CFA. Overall, the BC CFA provided feedback that our Plan is well-written using concise and plain language. The BC CFA identified that the Plan follows a logical sequence of actions, and our commitments are realistically achievable in the specified time frames.

          The BC CFA also identified several areas for improvement where our commitments would benefit from being more specific to help us achieve our goal. This feedback was incorporated into our Plan by:

          • Integrating opportunities for audits to provide enhanced baseline data and enable strategic implementation of training.
          • Broadening the scope of our commitments to include opportunities to engage subject matter experts, such as professionals with lived experiences of disabilities, to progress towards our accessibility goals.
          • Enhancing the level of detail within our commitments to help us achieve our goal by including accessibility-specific language (e.g., from “job boards” to “accessible job boards”).

          Further Consultations

          To truly exemplify the notion of “Nothing Without Us”, Western Stevedoring aims to conduct a more robust consultation process. Our goal is to work with additional organizations, collect testimonials and feedback from our employees and customers, and survey the public (where applicable) for future updates and republications of our Accessibility Plan.

          CONCLUSION

          Western Stevedoring is committed to this Accessibility Plan and its ongoing efforts and improvements in identifying, removing, and preventing barriers to accessibility in various priority areas. By implementing these measures, Western Stevedoring aims to create a barrier-free work environment that provides equal access to all employees and customers, regardless of their abilities. This will benefit the company’s employees and customers and contribute to a more inclusive and diverse society.

          DEI is important to our work, well-being and growth. It is our commitment to Canadians to continue working towards equity for all. Western Stevedoring recognizes that the work does not end with accessibility. We are dedicated to creating a safe and fair work environment for all groups, including Indigenous, racialized, and 2SLGBTQ+ people.