Accessible Transportation for Persons with Disabilities Regulations Training Content Guide

1. Purpose of this guide

The Accessible Transportation for Persons with Disabilities Regulations (ATPDR) Training Content Guide and checklist are intended to assist large Transportation Service Providers (TSPs) with designing training programs that align with the requirements set out in Part 1 of the ATPDR.

The Content Guide offers practical guidance on how to develop training that meets the regulatory objectives, and compliments the information set out in the Personnel Training for the Assistance of Travellers with Disabilities: A Guide. The ATPDR require that personnel receive training that equips them with adequate knowledge and skills to perform their duties. Where TSP personnel have an adequate level of knowledge and skill to perform their duties, they will gain greater experience and have more confidence when providing services and assistance to persons with disabilities, making for a better experience for all.

This guide highlights key considerations for ensuring that training addresses:

• The requirements of the ATPDR; and
• The TSP’s own internal policies and procedures with respect to persons with disabilities.

It is important to note that this guide does not cover all requirements of the ATPDR. TSPs should refer directly to the regulations to ensure full compliance with all applicable requirements.

This document is provided for general information purposes only and does not constitute legal advice. In the event of any discrepancy between this guidance and the ATPDR, the regulatory text takes precedence.

Nothing in this guide or in the ATPDR should be interpreted as:

• Limiting the duty to accommodate under the Canadian Human Rights Act or any other Act of Parliament; or
• Requiring any action that would compromise security, public health, or public safety.

To further assist TSPs in meeting their ATPDR training requirements, and as a compliment to the detailed information set out in this guide, the Canadian Transportation Agency has prepared a checklist which can be found in Annex A.

2. Context for use

A successful accessible travel experience is a shared responsibility between persons with disabilities and TSPs.

Persons with disabilities must communicate their accessibility-related services or accommodations to the TSP, and to provide advance notice when required. The Canadian Transportation Agency (the Agency) has developed a suite of traveller-focused resources that offer guidance on available services and tips for accessible travel planning.

For TSPs, the training requirements set out in the ATPDR serve as the foundation for understanding and implementing more than 200 regulatory provisions. Once a person with a disability communicates their abilities and accessibility requirements, the TSP is responsible for engaging in a meaningful dialogue to identify the appropriate services and ensure these are delivered in a manner that complies with the regulations.

The ATPDR requirements, including the training requirements, represent the minimum requirements that those subject to the ATPDR must meet. TSPs are encouraged to exceed the requirements of the ATPDR wherever possible.

TSPs carry a proactive duty to provide equal access to their services for persons with disabilities. This duty remains in effect unless accommodating the individual would result in undue hardship. As emphasized by the Supreme Court of Canada in Council of Canadians with Disabilities v. VIA Rail Canada Inc., 2007 SCC 15, paragraph 122:

“[u]ndue hardship implies that there may necessarily be some hardship in accommodating someone’s disability, but unless that hardship imposes an undue or unreasonable burden, it yields to the need to accommodate. The bar for undue hardship is appropriately high in recognition of the fact that these are fundamental human rights.”

Achieving a fully accessible transportation system is one that requires commitment, communication, and collaboration between persons with disabilities and transportation service providers. The Canadian Transportation Agency recognizes the importance of this joint effort and is committed to supporting it by providing clear, practical guidance to help all parties meet their obligations and uphold the rights of persons with disabilities.

3. Members of personnel required to be trained (Subsection 16(1))

Subsection 16(1) of the ATPDR identifies the members of personnel who must receive training. Please see section 2 of Personnel Training for the Assistance of Travellers with Disabilities: A Guide for a list of examples of personnel who must receive training.

Please see subsection 1(1) of the ATPDR for the definition of personnel.

There are a variety of roles and responsibilities in the provision of transportation services that impact access by persons with disabilities. For this reason, there can be no one-size-fits-all approach to training. Although there will be some common elements, training must be tailored to ensure that personnel receive training appropriate to their jobs. For example, a reservations agent needs different training than someone who assembles and disassembles mobility aids. Regardless of their roles, all personnel need to understand some key accessibility principles.

4. Requirements of the ATPDR (subsection 16(1))

Subsection 16(1) also sets out that members of personnel “receive training that provides an adequate level of knowledge and skills” to carry out their functions with respect to the requirements of the ATPDR, in addition to a TSP’s policies and procedures with respect to persons with disabilities.

The intent of the ATPDR is to ensure consistency with respect to accessibility across the federal transportation network. For this to be achieved, there must be adequate knowledge of the ATPDR requirements by all applicable TSP personnel.

5. The principles (Paragraph 16(2)(a))

Underpinning the training requirements in the ATPDR are principles that form the foundation of personnel training. All personnel who are required to be trained must receive “an adequate level of knowledge” in respect of the principles set out in subparagraphs 16(2)(a)(i) to (iv) of the ATPDR.

It is recommended that the training includes the explanation of the principles, as well as examples of how they can be implemented both effectively and ineffectively.

The following provides suggested language on how to explain the principles as well as examples which TSPs might find helpful.

Principle 1

“All persons must be treated with dignity regardless of their disabilities.”

In terms of human rights, dignity speaks to the right of a person to be valued and respected as a person, regardless of their abilities or choices.

Examples of where Principle 1 has and has not been followed:

Scenario: Helen is a person who is blind, and who uses a wheelchair. When travelling, Helen requests wheelchair service and baggage assistance between check-in and the gate. After completing security screening, Helen asked the TSP member of personnel providing wheelchair service to stop at the restroom on the way to the gate.

• Principle followed: The member of personnel advised Helen that they could stop briefly for Helen to use the restroom while the personnel member waited outside, but that they would need to hurry to ensure that Helen arrived in time for priority boarding. Following the brief stop, Helen made it to the gate with time to spare before priority boarding was called.
• Principle not followed: Helen was informed by the member of personnel that they needed to return to their post as soon as possible, and they could not take the time for Helen’s rest stop. The member of personnel advised Helen that she must choose between receiving her requested services for the remainder of the distance to the gate, and her need to use the restroom prior to boarding. As a result, Helen was left in the accessible washroom with the wheelchair, her carry-on baggage and no sighted guide to assist her to navigate to the gate, or someone to push the wheelchair. Finding the gate without any support was a difficult, painful and demeaning experience for Helen. When Helen arrived at the gate, she was informed that the carrier had been paging her and she was late. As a result, Helen would not receive priority boarding as she had requested.

Considerations to be taken into account when addressing Principle 1 in training materials, including:

• The principle of dignity must be met through more than good manners and customer service. It is through the attitude (verbal and nonverbal) while services are being provided and throughout the travel journey, allowing the person to navigate, independently or with the requested support, the mandatory tasks that need to happen during the travel journey (e.g., curb to check-in, check-in process, check-in to boarding area, etc.).
• If there is a sense that most persons in a given situation would be hurt, uncomfortable or embarrassed, then the principle of dignity has not been met.
• Personnel are expected to ensure that a person with a disability who has requested assistance to the gate is never left in an unfamiliar environment without confirming if the person is safely oriented, understands their surroundings, and has clear next steps, including how to access further assistance, if needed.

Principle 2

“All persons must have the same opportunity to make for themselves the lives that they are able and wish to have regardless of their disabilities or of how their disabilities interact with their personal and social characteristics.”

This principle sets out the intersectionality lens required for an inclusive society. Inclusivity means ensuring equitable access, even when the elements necessary to achieve equity are different for different people.

Examples of where Principle 2 has and has not been followed:

Scenario: Parker is a person who is Deaf and communicates primarily using American Sign Language (ASL). Parker also uses a power wheelchair and has a service dog trained to assist with mobility and object retrieval.

• Principle followed: When booking travel online, Parker was able to confirm that they would be travelling with a power mobility aid and their service dog, and would require additional space for the service dog. Parker also confirmed that the carrier already had all information relating to their mobility aid and service dog on file, and that assistance with boarding and disembarking would be required. All requested services were identified on Parker’s itinerary, which Parker requested to receive by email.

  On the day of travel, Parker had the confirmation email handy to reference, but it was not necessary because all requested services were provided without any questions or delays.

• Principle not followed: When booking travel online, Parker was unable to select all services that they wanted to request and had to search for contact information for the carrier in order to seek assistance to book their travel and request all required services. Parker was able to contact the carrier using a video relay service, ensuring that Parker could communicate using his first language, ASL. However the reservation agent seemed unfamiliar with how to communicate through an interpreter and Parker felt like the call was rushed. When Parker received their itinerary, it was missing the information confirming that Parker was travelling with a service dog, and that extra space was required, resulting in Parker having to contact the carrier again.

  On the day of travel, Parker arrived at the airport to check-in and was advised that Parker’s passenger record did not indicate that there was a service dog accompanying them, and that the service dog required extra space. Carrier staff further advised that the flight was full, and that there were no extra seats that could be assigned to provide sufficient space for both Parker and their service dog. Because of this, Parker was rebooked on a flight the next day. This resulted in Parker missing a presentation for work early the next morning, even though Parker had made all efforts to ensure that the carrier was aware of all requested and required services more than 48 hours in advance of Parker’s flight.

Considerations to be taken into account when addressing Principle 2 in training materials, including:

• To ensure equitable access when persons with disabilities request services set out in the ATPDR, those services must be provided in accordance with the ATPDR requirements.
• Furthermore, the ATPDR sometimes requires TSPs to make “reasonable efforts”. Reasonable effort denotes a prudent and moderate measure of sustained diligence necessary to achieve compliance with the regulatory requirement. Alternatively put, it describes the effort that a reasonable person, committed to achieving compliance, would have undertaken. This could potentially result in a change of policy, operations, procedures or an investment.

Principle 3

“All persons must have barrier-free access to full and equal participation in society, regardless of their disabilities.”

Barrier-free objectives should be at the forefront of planning in all aspects of the transportation system. Accessibility needs to be thought about when:

• facilities are planned, built, and renovated;
• equipment is designed, bought, and retrofitted;
• policies and procedures are written, implemented and revised.

The most successful outcomes for all will come from the inclusion of, and meaningful consultation with, persons with disabilities in relation to all three of these elements (facilities, equipment, and policies and procedures).

Where there is a piece of equipment that is crucial to a person’s ability to access the federal transportation network, it is especially important to actively engage and seek feedback from persons with disabilities who will be using that equipment to identify and remove any potential barriers that may exist.

Examples of where Principle 3 has and has not been followed, such as:

• Principle followed: Eli is a person who is hard of hearing and who uses a T-coil equipped hearing aid to assist. Due to the background noise that exists at most terminals, even with the use of his hearing aid, Eli doesn’t enjoy travelling because communicating is difficult and very frustrating in crowded places with lots of background noise.

  Upon his arrival at the train station, Eli made his way to the check-in counter and discovered that the station had installed hearing loops since he last travelled. With the hearing loop and the technology in his T-coil hearing aid, Eli could clearly hear all information and instructions that the check-in agent was saying without any issue, greatly increasing Eli's confidence to travel independently.

• Principle not followed: Remy is a person with a mobility impairment who uses a walker and who cannot climb stairs. After checking-in, Remy made their way to the elevator to proceed to the boarding gate, only to discover that the elevator was out of service.

  Without clear instructions about an alternate path of travel, Remy tried to locate personnel to explain how to reach the gate. Twice Remy was directed to the stairs, and the third time they were told someone would look into the alternate path but that person never returned.

  As a result of this delay, Remy missed the scheduled boarding time and was not able to travel as planned.

Considerations to be taken into account when addressing Principle 3 in training materials, including:

• Barrier-free needs to be a primary objective when personnel are trained, retrained and when their performance is evaluated.

• Persons with disabilities must have equal access to all information and services that everyone else has access to, at no extra fare or charge to the person. This includes: accessing information online, booking reservations, and receiving information in a format that is accessible.

  Where this mindset is incorporated at the outset, and potential barriers relating to physical, technological or attitudinal barriers are identified and removed as early as possible, fewer services or accommodations may be required as all persons would have equal access.

Principle 4

“All persons must have meaningful options and be free to make their own choices, with support if they desire, regardless of their disabilities.”

“Meaningful options” are options that do not just address a potential barrier, but also reflect a person’s dignity, safety and comfort. Meaningful options may vary from person to person because everyone is different and has different abilities.

Examples of where Principle 4 has and has not been followed, such as:

• Principle followed: Micah is a person who is paraplegic and uses a power wheelchair. Micah is an avid traveller and knows what does and does not work for him when travelling.

  Micah requires transfer assistance to board an aircraft and always requests the carrier to use a lift to assist with this.

  On the day of travel, after making his way to the gate, Micah was approached by personnel to confirm his preferences for his transfer. Personnel asked Micah if he would be comfortable with a manual transfer, as staff were ready and available to do so. However, when Micah confirmed that he prefers to use a lift, personnel stated that they understood and they located the lift to use for the transfer. Micah was transferred to his seat without issue and he was on his way to enjoying his trip.

• Principle not followed: Grace is a person with reduced mobility and balance. Grace finds it challenging to walk long distances, or to climb into a golf-cart to receive assistance in proceeding through the terminal. With this in mind, Grace always makes arrangements for wheelchair service to navigate through the airport.

  On the day of travel, Grace checked in and confirmed her requested services. However, the check-in agent advised her that there was a shortage of wheelchairs and Grace’s request had been changed to cart service. Grace informed the check-in agent that she would not be comfortable or feel safe using the golf cart transportation, and that this service did not take into consideration her abilities which the carrier was made aware of at the time of reservation. The check-in agent advised that Grace’s only options were to walk through the airport or to climb into the cart, neither of which were good options for Grace.

  Grace chose to wait for a wheelchair, as she had requested this service well in advance of travel, but by the time the wheelchair service was provided and she made it through security, Grace was late to the gate and missed her flight.

Considerations to be taken into account when addressing Principle 4 in training materials, including:

• Prior to providing any type of requested services to assist a person with a disability, the first step is for personnel to ask how best they may assist the person, and respect the choice or request made by the person, up to the point of undue hardship.
• Personnel are expected to ensure a continuity of services and communication throughout the travel journey. This includes periodically checking on individuals who are not independently mobile after assisting them to the gate, or making sure another staff member will do so, and communicating these arrangements to the individual.

6. Training for personnel (Subsection 16(2))

6.1 Barriers that may hinder equal access (Paragraph 16(2)(b))

The training has to provide “an adequate level of knowledge” with respect to the “different types of barriers that may hinder equal access to transportation services for persons with disabilities”.

Topics to be covered in the training include:

• Communication and technological barriers: including inaccessible websites and mobile applications, not providing information in accessible formats, not speaking in clear, simple and concise language, unclear announcements, inaccessible self-serve kiosks, and signage not being easy to locate and use, including Braille and tactile signage;
• Physical or architectural barriers: including stairs, doors that are not automated, long distances to travel without rest points, the height of various amenities or features (e.g., counters, signs), lighting, lack of adult change tables; and,
• Attitudinal barriers: this can include personnel making assumptions about a person’s abilities instead of asking them. This can result in a loss of dignity for the person and failing to meet one or more of the four main principles noted above.

6.2 Types of assistance that may be needed and the duties of the TSP in relation to those needs (Paragraph 16(2)(c))

Types of assistance that must be provided to persons with disabilities (Paragraph 2(c)(i))

The training has to provide “an adequate level of knowledge” with respect to the “types of assistance that may be needed by persons with disabilities”, and “the duties of the transportation service provider in relation to those needs”. Training needs may vary depending on the roles and responsibilities of the personnel.

The types of assistance which may be needed by persons with disabilities, include:

• Assistance with making reservations (sections 54 and 55 of the ATPDR, and where services are requested, section 58):
  • where a person identifies the nature of their disability when making a reservation, the TSP must engage in a dialogue with the person to identify their needs in relation to their disability, and the services offered by the carrier in relation to those needs;
  • where a person identifies the nature of their disability when making a reservation, the carrier must inform the person of the passenger seats and cabins that are available in the class of service that the person has requested and that best meet the accessibility needs of that person and take into account the person’s opinion with respect to which seats or cabins would best meet the accessibility needs of that person;
  • if a carrier is required by Part 2 of the ATPDR to provide a service to a person with a disability, the carrier must indicate, without delay, the services that the carrier will provide in the record of a person’s travel reservation and include a written confirmation of the services in the itinerary that is issued to the person; if a service is confirmed only after the itinerary is issued, the carrier must, without delay, provide a written confirmation of the service.
• Assistance with making reservations specific to bus carriers (ss. 54(2) of the ATPDR)
  • where a person identifies the nature of their disability when making a reservation, the TSP must:
    • provide information about any stops and transfer points; and
    • advise the person in advance if the route does not have a regularly scheduled stop that has a washroom that accommodates a person using a mobility aid and any support person, and offer the person their choice of alternative rest stops on the route.
• Assistance at the terminal (s. 216 and s. 35 of the ATPDR), including:
  • from the curbside zone to the check-in counter;
  • with checking in;
  • proceeding through security screening to the boarding area, including guiding, wheelchair and/or baggage assistance;
  • priority boarding;
  • boarding, including transferring to and from a mobility aid;
  • disembarking and proceeding through border clearance, as applicable;
  • retrieving checked baggage; and,
  • proceeding to the general public area or the designated curbside pickup location.
• Assistance onboard, including (s. 35 of the ATPDR):
  • Storing and retrieving carry-on luggage;
  • providing a description of the layout of the aircraft/rail car/ferry/bus;
  • opening packages, identifying food items and their location, and cutting large food portions.
• Services related to the transportation of mobility aids, including (sections 40 to 43 of the ATPDR):
  • carrying mobility aids as priority baggage when they cannot be stored in the cabin;
  • permitting a person to retain their mobility aid until it becomes necessary to store it;
  • remove any cargo and other baggage from storage if necessary in order to make room for the storage of a mobility aid;
  • making every reasonable effort to permit a person who uses a walker or a manual folding wheelchair to store it on board an aircraft or bus; and
  • disassembling, packaging, unpackaging and reassembling mobility aids, and returning the mobility aid to the person on arrival at the destination without delay.
• Services related to the provision of an additional seat, such as (sections 50 to 52 of the ATPDR, and s. 31, as applicable):
  • persons travelling with a support person;
  • persons travelling with a service dog; and,
  • persons who require more than one passenger seat due to the nature of their disability.
• Services specific to bus carriers (s. 36 of the ATPDR), such as:
  • assisting the person with boarding and disembarking;
  • assisting the person to proceed to the stop, including by guiding the person and by assisting with the person’s wheelchair;
  • stopping the bus, at least every two and a half hours, at a rest stop with such a washroom or at a rest stop chosen by the person if the bus is not equipped with a washroom that accommodates a person using a mobility aid and any support person;
  • allowing the person an adequate amount of time to use washrooms at rest stops, taking into account the additional time that is required for the person to board and disembark from the bus; and,
  • permitting the person to board or disembark at a stop of their choice if the member of personnel who is operating the bus considers it safe to do so and, if not, informing the person of the location of the closest safe stop.

Assistive devices and methods of communication (Paragraph 16(2)(c)(ii))

The training has to provide “an adequate level of knowledge” with respect to the “assistive devices commonly used by persons with disabilities”, which TSPs are required to permit a person to bring on board per s. 49 of the ATPDR, including, but not limited to:

• mobility-related assistive devices, such as: a cane, crutches, or slide board.
• communication-related assistive devices, such as: a hearing aid or augmentative and alternative communication devices.
• an orthotic positioning device
• a portable oxygen concentrator
• portable dialysis machine

The training also has to provide “an adequate level of knowledge” with respect to the “methods of communication that may be used by, or may facilitate communication with, persons with disabilities”, per paragraph 16(2)(c)(ii), including, but not limited to:

• Augmentative and alternative communication (AAC) devices assist persons with limited verbal skills or persons who are nonverbal to communicate with others. There are many different kinds of AAC, including no-tech (e.g., thumbs-up hand sign), low-tech (e.g., pointing to photos, pictures, or written words) and high-tech (e.g., using an app on a tablet to communicate).
• Sign language: In Canada, there are two predominant visual languages: American Sign Language (ASL) and langue des signes québécoise (LSQ).
• Lip or speech reading
• Assistive listening systems or assistive listening devices, which can include the use of a microphone to capture sound which is transmitted wirelessly, including through an induction loop (also known as a “hearing loop”) to a person who uses a wireless receiver to hear the sound.
• Clear, concise and plain language: means that writing is clear, sentences are short, and grammar is simple. It avoids technical words, jargon, acronyms and complex sentence structures when possible, such that the text is easily understandable.

The training does not need to list all possible devices in order to be considered “adequate” but it is recommended that training address how personnel are expected to approach situations where they do not recognize or know what a device is, and what it is used for, in order to ensure compliance with s. 49 of the ATPDR.

For more information and best practices for interacting with persons with disabilities, please refer to Best Practices for Interacting with Persons with Disabilities: A Guide.

6.3 Communication with persons with disabilities and how to interact with them (Paragraph 16(2)(d))

The training has to provide “an adequate level of knowledge” in respect of “communication with persons with disabilities in accordance with s. 6 and how to interact with them in a manner that respects their autonomy and dignity”.

To ensure the adequacy of the training, a training program should address communication and interactions with persons with disabilities and take into account:

• The nature of the person’s disability, for example if the person:
  • is blind or partially sighted and/or uses assistive device(s) to assist with navigation or to obtain visual information;
  • is Deaf, deafened or hard of hearing, and/or uses assistive devices to communicate or obtain audible information;
  • has a communication-related disability and uses an assistive device to communicate, such as an augmentative and alternative communication device.
• Whether the person uses an assistive device to assist them to hear, see or communicate, such as:
  • Braille displays and notetakers, screen readers, and electronic or handheld magnifiers;
  • Smart phones or smart glasses, in combination with apps, such as Aira;
  • Video Relay Services (VRS) and Real-Time Text (RTT);
  • Assistive listening systems (ALSs) generally refers to system-wide technology that is useful in public settings, such as airports or terminals. Some examples of ALS are:
    • Hearing loops;
    • FM or DM systems;
  • Assistive listening devices (ALDs) are tools that have been designed to amplify sound for people with hearing loss in specific settings, both for at home and in public places. Some examples of ALDs are:
    • Amplified and captioned telephones;
    • Apps and smart watches, including caption apps which can provide text translation for speech;
    • Alerting devices;
  • Haptic gloves and communication devices, as well as augmentative and alternative communication devices as discussed above under paragraph 16(2)(c)(ii).
• Other methods of communication that may facilitate communication with persons, such as an augmentative or alternative communication system, sign language or clear, concise and plain language.
• In addition, in order to ensure the adequacy of the training, a training program should also explain: what these devices do, how they are used, and how to identify them.
• To ensure the adequacy of the training, a training program should reflect steps that personnel may take when communicating with a person with a disability, such as:
  • Best practices for persons who are Deaf, deafened or hard of hearing:
    • Get the person’s attention before you speak. A gentle tap on the shoulder is appropriate if the person is near you.
    • Ask the person what their preferred method of communication is and whether it would be helpful to communicate using a pen and paper or a computer, tablet or smartphone.
    • Maintain eye contact with the person. Don’t look down or sideways.
    • Rephrase what you have communicated or offer to explain things in writing if you think it is needed to clarify your message.
    • Body language helps to project the meaning of what you are saying; use facial expressions and gestures when appropriate.
  • Best practices for persons who are deaf-blind:
    • Identify yourself by stating your name and who you work for, and let them know you’re there (for example, gently touching their arm or shoulder).
    • Ask how they prefer to communicate.
    • Speak directly to the person, not to an interpreter or support person.
    • Don’t assume what the person can or cannot do, and always ask before helping. Some people who are deaf-blind have residual vision and/or hearing. Accept “no” if help is not wanted.
    • Avoid multitasking. Giving your full attention makes communication smoother and more respectful.
    • End interactions clearly, letting the person know when you’re leaving.
  • Best practices for persons who have a communication disability:
    • Give the person time to speak without interrupting them, and resist the temptation to finish their sentences for them.
    • Watch and listen as the person may use body language, speech, or a communication device.
    • If the person is having difficulty expressing their needs, summarize what you have understood and ask for confirmation of your understanding. In this way, the person can then just complete their thought rather than having to repeat everything.
    • Where possible, communicate away from noisy areas, including those where others are speaking.
    • Avoid speaking loudly, this does not help.
    • Consider using pen and paper or a computer, tablet or cell phone to communicate if you are having difficulty understanding the person, but first ask the person if this is acceptable.
    • If the above strategies do not help, ask questions that require only short answers or a nod of the head. Try to offer a choice of answers to your questions to obtain a “yes” or “no”. The “yes” and “no” can be expressed by pointing at these two words on a piece of paper or by pointing a thumb up or down. Personnel should first ask the person if this is acceptable.
  • Best practices for persons who have an intellectual, cognitive or learning disability:
    • Offer assistance or extra time to complete forms, understand written instructions, or make a decision; wait for the person to accept an offer of assistance – don’t “over-assist” or be patronizing. “Over-assisting” means giving someone more help than they asked for or need, while “patronizing” means treating someone as if they’re less capable than they really are. Neither term reflects the Principles of Accessibility.
    • Be prepared to rephrase or provide an explanation more than once.
    • Be flexible and supportive and take the time needed to understand the person and make sure the person understands you. If you are not sure what the person said, ask for clarification.
    • Speak slowly – give information in clear, short sentences.
    • Break instructions into small parts. Ask the person if they would like key information in writing.
    • Consider moving to a quiet or private location, especially if you’re in a public area with many distractions.

For more examples of best practices, please refer to Best Practices for Interacting with Persons with Disabilities: A Guide.

6.4 The role of a support person (Paragraph 16(2)(e))

The training has to provide “an adequate level of knowledge” in respect of “the role of a support person”.

To ensure the adequacy of the training, a training program should address subsection 50(1) of the ATPDR, which requires a carrier to:

• accept a support person for transport on the request of a person with a disability, if, because of the nature of their disability, the person needs assistance after departure and before arrival with any of the following:
  • Assistance with eating meals, taking medication, using the washroom
  • Assistance with transferring to and from a passenger seat
  • Assistance with orientation or communication, or
  • Physical assistance in the event of an emergency, including in the case of an evacuation or decompression.

  Persons do not require assistance with all of these elements in order to be eligible for a support person.

• ensure support person(s) are seated in an adjacent seat to the person with a disability that they are travelling with.
• ensure a fare for a support person is not imposed for domestic flights.

6.5 The role and needs of a service dog (Paragraph 16(2)(f))

The training has to provide “an adequate level of knowledge” in respect of “the role and needs of a service dog”.

To ensure the adequacy of the training, a training program should address:

• (ss. 51(1)) A carrier must, on the request of a person with a disability who needs to travel with a service dog, accept the service dog for transport and permit the animal to accompany the person on board, subject to ss. 51(2):
  • a carrier may require a person with a disability who requests to travel with a service dog, the “handler”, to control the dog with a leash, tether or harness during travel;
  • to provide, at the time of reservation with the carrier, a declaration attesting that the service dog has been individually trained by an organization or person specializing in service dog training to perform a task to assist the person with a disability with a need related to their disability; and,
  • to provide, before departure, an identification card or other document that is issued by an organization or person specializing in service dog training that identifies the person with a disability and attests that the service dog has been individually trained by the organization or person to perform a task to assist the person with a disability with a need related to their disability.
• The various types of service dogs, and the tasks those service dogs perform to assist persons with disabilities. Some examples include:
  • Guide dogs (assist a person who is blind or has reduced vision by guiding them around obstacles);
  • Hearing dogs (alert persons who have reduced hearing to the presence of people or sounds, such as an alarm or telephone);
  • Seizure alert dogs (recognize specific changes that happen before a seizure and alerting a person);
  • Post traumatic stress service dogs (provide assistance by grounding a person or providing a barrier against other people crowding too close to the person);
  • Autism service dogs (provide assistance by mitigating specific functional challenges related to autism, reducing sensory overload and supporting daily functioning).
  • Diabetic alert dogs (alert persons when their blood sugar has spiked too high or dropped too low, allowing the person to take action before the problem turns into a medical emergency).
• Provide appropriate seating and sufficient space for any size of service dog, including additional seating adjacent to the passenger seat if required. The ATPDR does not set out a size limitation for service dogs.
• Dos and don’ts of service dogs (e.g., do not pet, feed, talk to or distract a service dog; every reasonable effort must be made, up to the point of undue hardship, to ensure that service dogs are not separated from their person/handler, etc.).
• Personnel must be aware of the locations of service dog relief areas in a terminal, including both within and outside of secured areas.
• Personnel should seek guidance from the person with a disability travelling with a service dog, or handler, if an interaction with a service dog is required at any time for the purposes of security screening.

In addition to the required information about service dogs, it is recommended that training programs also include information about emotional support dogs (ESDs).

The Agency issued Decision No 105-AT-C-A-2023, which clarified the conditions under which it would not cause undue hardship for TSPs to accept ESDs for carriage in the passenger cabin. This information could be helpful for some personnel, such as: reservation agents, or check-in agents.

It is recommended that this training include:

• What an ESD is, and how ESDs differ from service dogs.
• TSP’s policy with respect to the acceptance and carriage of ESD’s, including the following conditions, as applicable:
  1. The person with a disability must provide proof from a physician or medical health professional who is licensed and in good standing with their governing body, that they are treating the person for a mental health disability, and that the person requires an ESD to accommodate that disability;
  2. The person with a disability must provide a veterinary certificate that:
     • Identifies the specific ESD by name and breed;
     • Identifies the person with a disability who relies on that dog as an ESD;
     • Attests that the ESD is healthy enough to travel; free from contagious diseases, ticks and fleas; and current on its vaccinations; and
     • States whether the veterinarian has any knowledge of inappropriate behaviour exhibited by the ESD, including aggressive behaviour, excessive whining or barking, or causing injury to others.

     If the timing for the veterinary certification has not otherwise been prescribed in the jurisdiction of the country, province, state or territory where the person travels to or from, the certificate must be dated within two months prior to the date of initial travel set out in the itinerary.

  3. The person with a disability must provide the above documentation to the carrier at least 96 hours in advance of travel. If a request is made less than 96 hours in advance, the air carrier should make every reasonable effort to transport the person with a disability and their ESD. However, the Agency strongly encourages all persons with disabilities to provide sufficient advance notice and to provide adequate supporting documentation for themselves and their ESD when they make their request to minimize the risk that they will not receive adequate accommodation.
  4. The ESD must fit comfortably in an appropriate animal carrier that must fit and be kept at the seat – or in the case of air travel, under the seat in front – of the person with a disability for the duration of the trip. The animal carrier must meet the carrier’s conditions and restrictions for carriage of animal carriers in the cabin, and the ESD must remain in the carrier for the duration of its time in the passenger cabin.
  5. The person with a disability must demonstrate to the carrier that their ESD meets all travel, entry or exit requirements of the country, province, state or territory they travel to or from, which includes providing all required documentation as applicable.
  6. A person with a disability travelling with their ESD in compliance with these conditions must not be charged for this accommodation.

It is noted that a carrier may refuse transportation to any person with a disability and their ESD if the ESD poses a threat to the health or safety of others by exhibiting aggressive or other inappropriate behaviour, or if the user removes it from its animal carrier during travel. For more information, please refer to Decision No. 105-AT-C-A-2023, or the ATPDR’s Service Dog Guide.

7. Training for personnel that may be required to provide physical assistance (Section 17)

The training has to provide “an adequate level of knowledge and skills” with respect to the provision of physical assistance to a person with a disability.

7.1 Seek information (Subsection 17(a))

The training has to provide “an adequate level of knowledge and skills” on how to “seek information from the person with a disability with respect to their preferred method of assistance and any other measures they may require to ensure their safety and their comfort” (paragraph 17(a) of the ATPDR).

To ensure the adequacy of the training, a training program should provide examples on how to seek information, such as:

• After identifying who you are and which TSP you work for, ask the person if they have any preferences or considerations for personnel to be aware of. This can include transfer preferences, identifying any personal considerations that personnel should be aware of, advising which arm is preferred for requested guiding assistance, or if there is a request for baggage assistance in addition to wheelchair service. This reflects the principles set out in the ATPDR and noted above. Everyone is unique and the person with a disability will know their own abilities and preferences better than anyone else.

7.2 Manoeuvring mobility aids (Subsection 17(b))

The training has to provide “an adequate level of knowledge and skills” on how to “manoeuvre mobility aids through doors and on irregular and multi-level surfaces, steps, curbs and elevators” (paragraph 17(b) of the ATPDR). The training program for personnel who manoeuvre mobility aids and provide assistance for persons with disabilities must include:

• how to manoeuvre over thresholds and multi-level surfaces as smoothly as possible;
• how to manoeuvre through doors, in/out of elevators, and up/down ramps while ensuring a person’s safety.

To ensure the adequacy of the training, the following considerations and approaches should also be reflected in a training program:

• While there may be a written or video component to this training requirement, it is considered to be a best practice to have a practical/hands-on or in-person training component for how to manoeuvre mobility aids, in order for personnel to gain sufficient experience and confidence prior to providing assistance to persons with disabilities.
• Relevant accessible paths of travel for applicable terminals to avoid stairs; ensure that there are contingency plans in place if an elevator is not working.
• Baggage assistance – not all persons who use a mobility aid are able to transport their carry-on bag on their lap while receiving wheelchair assistance. In situations where the person has indicated that they cannot transport their carry-on baggage on their lap, it is considered best practice to have alternatives available. These alternatives may include a wheelchair with a built-in luggage rack or additional personnel to assist with carry-on baggage.
• Policies and/or protocols that are in place to ensure the safety of persons with disabilities who are not independently mobile during an emergency situation.
• Finally, it is considered best practice that the above-noted training be completed with a real person, prior to providing assistance to passengers, in order to gain experience, confidence and understanding of the maneuvers.

7.3 Transfer assistance (Subsection 17(c))

The training has to provide “an adequate level of knowledge and skills” on how to “transfer the person with a disability between their own mobility aid and a mobility aid provided by the transportation service provider and between a mobility aid and the person’s passenger seat, including performing appropriate lifting techniques involved in various types of transfers of the person with maximum consideration for their dignity, privacy, safety and comfort” (paragraph 17(c) of the ATPDR).

To ensure the adequacy of the training, a training program for personnel who provide transfers to and from mobility aids should include:

• various types of transfers, and where equipment is used to assist with transfers, programs must include training on transfers with the equipment AND without.
  • Equipment could be as complex as Eagle Lifting devices or as simple as slide boards.

To ensure the adequacy of the training, the training program should also:

• Identify and highlight sensitivities that personnel need to be aware of and take into consideration, such as: dignity, privacy, safety and comfort.
  • Transfers can be physically uncomfortable for some persons as a result of their disabilities. Communication with the person is key to ensuring that all possible precautions and care are taken.
• Reflect a clear pre-boarding process, and a clear disembarkation process.
• Identify alternative options, or what is not an alternative option. For example, in the worst-case scenario where an Eagle Lift or an aisle or boarding chair was requested in advance but is not available, ensure personnel understand what alternative steps to take (such as requesting to borrow one from other personnel or another TSP).
• Reflect the need for a descriptive and on-going dialogue to inform the person of each step that is coming, so that the person is aware of what to expect throughout the transfer.
• Include a practical/hands-on or in-person training component for transfer techniques so that personnel can gain experience, confidence and understanding of the different techniques prior to providing assistance to persons with disabilities outside of training, in addition to a written or video component.
• Include transfer experience with a real person, prior to providing assistance to passengers, in order to gain sufficient experience, confidence and understanding of the transfer techniques.
• Identify how personnel are expected to handle situations where they are uncertain of the steps that need to be taken in order to perform a transfer safely.
  • Additional assistance or instruction needs to be sought immediately. This can include personnel who are immediately assisting, or, if necessary, additional assistance can be sought from managers and/or personnel with more experience, even if they are working elsewhere in the terminal or station.

Recommendation for TSPs: The regulations require personnel (including third-party contractors) to be retrained at least once every three years. However, if personnel receive refresher training more frequently, such as annually, they would gain greater experience and confidence. More frequent retraining may also prevent incidents which have a direct impact on the physical and mental health of persons with disabilities.

7.4 Guiding and orienting assistance (Subsection 17(d))

The training has to provide “an adequate level of knowledge and skills” on how to “guide and orient a person with a disability whose impairment affects their mobility” (paragraph 17(d) of the ATPDR).

To ensure the adequacy of the training, the following considerations and approaches should be reflected in a training program:

• First ask the person how TSP personnel can best assist them. The person with a disability will know their own abilities and preferences better than anyone else.
  • Some persons will prefer to take an elbow, place a hand on a shoulder or on the top of an arm when receiving guiding assistance, and may prefer one side or the other.
  • Some persons who use guide dogs, may prefer to instruct their guide dog to “follow” and will ask the member of personnel to take the lead.
• The training for this requirement should stress the need for communication between personnel and the person being assisted. Directional communication needs to be clear and specific, but not overly detailed to the point that it is confusing or difficult to follow. (e.g., Pause at obstacles, such as stairs, and let the person know they are there; give a warning before changing directions or stopping suddenly. Do not point and say “over there” when describing a location.
• There should be a descriptive, on-going dialogue to inform the person of their surroundings, possible obstacles, directional changes or other travellers around them.
• While there may be a written and/or video component to this training requirement, it is considered best practice to have a practical/hands-on or in-person training component for how to provide guiding and orientation service, in order for personnel to gain sufficient experience and confidence prior to providing assistance to persons with disabilities.

7.5 Assistance with balance, agility or coordination (Subsection 17(e))

The training has to provide “an adequate level of knowledge and skills” on how to “assist a person who has limitations in balance, agility or coordination that affect their mobility” (paragraph 17(e) of the ATPDR).

To ensure the adequacy of the training, the following considerations and approaches should be reflected in a training program:

• First ask the person how TSP personnel can best assist them. The person with a disability will know their own abilities and preferences better than anyone else.
• They may prefer that personnel assist with their baggage, leaving their hands free to use a walker, cane or crutches, or they may prefer to have an arm to assist with balance and stability while walking.
• If there is a distance to be covered between check-in and the point of boarding, the person may prefer wheelchair assistance – but the choice of options is for the person with a disability to make.

8. Contents of training for personnel that may be required to handle mobility aids (Section 18)

The training has to provide “an adequate level of knowledge and skills” with respect to the handling of mobility aids.

To ensure the adequacy of the training, a training program for personnel to handle mobility aids should reflect:

• “the different types of mobility aids”, and the unique properties and considerations of each that are relevant to personnel, such as:
  • different types of manual wheelchairs, including collapsible or folding wheelchairs;
  • different types of electric wheelchairs;
  • different types of electric scooters;
  • battery types and battery handling for electric wheelchairs or scooters, and any considerations related to each type;
    • Personnel need to be aware of what types of batteries are and are not accepted for carriage in both the cabin and as priority checked-baggage;
  • walkers, canes, crutches or other aids specially designed to assist a person with a disability with a need related to mobility.
• “the requirements and appropriate methods for transporting and storing mobility aids, including the disassembling, packaging, unpackaging and reassembling of mobility aids”. To ensure the adequacy of training for personnel who handle mobility aids, the training program should include the following best practices, considerations and elements:
  • How to reduce the size and weight of the mobility aid, and how to disassemble and reassemble without causing damage to the aid.
  • Identify what pieces can be removed to better assist with safe transport (e.g., the headrest for some electric wheelchairs could break during transport, and the function of this feature is critical for many users).
  • The steps or process to be followed to ensure all pieces of a mobility aid that must be disassembled remain together for transport. (e.g., specialized cushions or inserts necessary to adapt an aid for a specific person’s needs must arrive undamaged with the aid.) Where possible, persons with disabilities are permitted to retain such specialized equipment in the cabin.
  • The steps or process to be followed for packaging a mobility aid for safe transport, including protecting fragile parts such as the joystick or steering control, which are crucial for safe operation.
  • Securement techniques, where possible. Please see Safe Securement and Containment of Mobility Aids in the Cargo Compartment (Phase 2) on the Canadian Transportation Agency’s website for more information. For example, it is expected that a mobility aid be transported right side up, and securement points, such as specified brackets or sturdy points on the frame, are identified and used for a 4-point tie-down. In addition, it is recommended that a mobility aid not be tilted for loading into the cargo hold, or transported on its side. Identify what mobility aids do not need to be disassembled for safe travel (i.e., some manual collapsible wheelchairs do not need to be disassembled for travel).
  • Personnel consult with persons with disabilities regarding any considerations specific to their device, prior to disassembly and packaging.

    • Note: ss. 41(2) of the ATPDR sets out that a carrier may require a person who is travelling with a mobility aid to: (a) provide the carrier with written instructions for the disassembly and reassembly of the mobility aid; and, (b) check in or arrive at the boarding area before the scheduled time for check-in or boarding.

      It is recommended that this be reflected in a training program for personnel who handle mobility aids, as well as for personnel who assist with making reservations. Persons with disabilities need to be informed that a TSP may require this information.

• Identify the steps or process to be taken to ensure that the mobility aid is returned to its owner upon arrival without delay, in the same condition that the person last saw it (fully reassembled, with all parts intact and functioning). This element of training may also include information such as:
  • Identification of reference point(s) and/or best practices to assist personnel. Some examples include: the manual for the mobility aid, a book or collection of various manuals that personnel have access to, a standard powered mobility aid information form that passengers complete, a tag attached to the mobility aid with necessary information that can be used by personnel throughout a person’s travel journey, and/or pictures of the aid prior to disassembling to facilitate reassembly.
• Provide a practical/hands-on or in-person training component for how to disassemble, package, unpackage and reassemble a mobility aid, in addition to the written and/or video component, so that personnel may gain sufficient experience and confidence prior to providing this service to persons with disabilities.

9. Contents of training for personnel that may be required to use or assist with special equipment (Section 19)

The training has to provide “an adequate level of knowledge and skills” on the use of special equipment.

To ensure the adequacy of the training, examples of special equipment that TSP personnel may use in providing assistance to persons with disabilities should be included in the training program, such as:

• “a telecommunication device for persons who are deaf or who have any other hearing impairment” (e.g., TTY machine, hearing loop);
• “a lift, ramp and any other level-changing device” (e.g., a lift to access a mode of transportation, such as a train, a lift to assist with transfers to/from a mobility aid);
• “an on-board electrical power supply”;
• “a device for the connection of on-board auxiliary respirator systems”;
• “an on-board entertainment system or a personal electronic device that is accessible to persons with disabilities”; and,
• “an automated self-service kiosk that is accessible to persons with disabilities.”

For the above noted special equipment, the following topics should be reflected in training programs to ensure the adequacy of the training, as applicable:

• How to appropriately and carefully use each piece of equipment;
• Considerations to be aware of (e.g., ensure that the training addresses that lifts have a maximum weight capacity, and that ramps used for boarding are often mobile and have safety requirements for safe operation, such as brakes or a locking mechanism)
• In addition to a written and/or video component to these training requirements, provide a practical/hands-on or in-person training so that personnel may gain experience and confidence prior to providing this service directly to persons with disabilities.

10. General notes and considerations

• Not all personnel need to receive the same type of training. The training must be suitable to their functions. For example, in most cases personnel who are responsible for assisting with reservations will not need to receive training on how to disassemble, package, unpackage and reassemble a mobility aid. However they are responsible for being knowledgeable about the ATPDR requirements relating to the carriage of mobility aids, in addition to the TSP’s related policies.
• Ss. 20(2) of the ATPDR requires that until a member of personnel has completed training that is suitable to the requirements of their functions, TSPs must ensure that they carry out their functions under the direct supervision of a person who has completed that training.
  • “Direct supervision” means that a person who has completed the training is close enough to observe the task(s) being performed, and if needed, can intervene, direct and correct the activity in real time.
• Personnel training that involves directly providing a service or assistance to a passenger with a disability must not occur outside of training, without direct supervision.
• While not a requirement of the ATPDR, it is recommended that TSPs include an evaluation portion for each training program, to test the knowledge gained through training and ensure it is adequate for the requirements of the ATPDR.
• Ss. 23(2) of the ATPDR requires that TSPs consult with persons with disabilities in the development of each training program and the principal teaching methods. It is expected that TSPs are able to explain specifically what was consulted on, who was consulted, what feedback was received and how that feedback was taken into consideration when each training program was finalized.

11. Best Practices

• While the ATPDR does not include it as a requirement as part of a TSP’s training obligations, accessibility awareness training where personnel are provided with an opportunity to have a better understanding of different disabilities and the potential barriers related to those disabilities is encouraged as a best practice. Awareness training includes persons with disabilities in the training session(s) and gives context to the ATPDR requirements with lived experience from persons who are best placed to share such information.
• S. 21 of the ATPDR requires that TSPs ensure that members of personnel receive refresher training at least once every three years. In situations where personnel do not have the opportunity to use the skills received through training often enough, it is recommended as a best practice that training be provided more frequently, such as annually, to ensure that personnel are able to perform all skills suitable to the requirements of their functions safely and appropriately.
• As a best practice, it is recommended that training programs include information about how personnel should manage situations where service delivery does not go to plan, or when conflict arises. This would assist personnel with navigating challenging situations when providing services to persons with disabilities. Topics could include alternative options or problem-solving techniques when requested equipment is unavailable, communicating effectively and respectfully when a service request cannot be met, and de-escalation techniques.
• For more information on different types of disabilities, potential barriers that may impact persons with disabilities, and best practices for interacting with persons with disabilities, please see Best Practices for Interacting with Persons with Disabilities: A Guide.

Annex A: Checklist

The following checklist is intended to assist Transportation Service Providers (TSPs) with designing training programs that align with the requirements set out in Part 1 of the ATDPR.

This document is provided for general information purposes only and does not constitute legal advice. In the event of any discrepancy between this guidance and the ATPDR, the regulatory text takes precedence.

Members of personnel required to be trained (Subsection 16(1))

• Subsection 16(1) of the ATPDR identifies the members of personnel who must receive training. Please see section 2 of Personnel Training for the Assistance of Travellers with Disabilities: A Guide, for a list of examples of personnel who must receive training.
• TSP training programs should clearly identify what members of personnel must receive what type of training. Please refer to section 3 of this guide for more information.

Requirements of the ATPDR (Subsection 16(1))

• Subsection 16(1) requires that members of personnel receive training that provides an adequate level of knowledge and skills with respect to the requirements of the ATPDR to carry out their functions, in addition to a TSP’s policies and procedures with respect to persons with disabilities.
  • Please refer to section 4 of this guide for more information.

The principles (Paragraph 16(2)(a))

• TSP training programs must include an adequate level of knowledge in respect of the Principles of Accessibility set out in paragraph 16(2)(a) of the ATPDR.
• Please refer to section 5 of this guide for more information about the principles, and recommendations on how they can be incorporated into a TSP’s training program.

Barriers that may hinder equal access (Paragraph 16(2)(b))

• TSP training programs must provide an adequate level of knowledge with respect to the types of barriers that may hinder equal access to transportation services for persons with disabilities.
• Please refer to section 6.1 of this guide for more information about barriers.

Types of assistance and TSP duties (Paragraph 16(2)(c))

• TSP training programs must provide an adequate level of knowledge with respect to the types of assistance that may be needed by persons with disabilities, and the duties of the TSP in relation to those needs.
• TSP training programs must also provide an adequate level of knowledge with respect to the types of assistive devices that are commonly used by persons with disabilities, and the methods of communication that may be used.
• Please refer to section 6.2 of this guide for more information about the types of assistance and a TSP’s responsibilities.

Communication with persons with disabilities and how to interact with them (Paragraph 16(2)(d))

• TSP training programs must provide an adequate level of knowledge in respect of communication with persons with disabilities in accordance with section 6 of the ATPDR, and how to interact with persons in a manner that respects their autonomy and dignity.
• Please refer to section 6.3 of this guide for more information about communicating with persons with disabilities.

The role of a support person (Paragraph 16(2)(e))

• TSP training programs must provide an adequate level of knowledge in respect of the role of a support person.
• Please refer to section 6.4 of this guide for more information about support persons.

The role and needs of a service dog (Paragraph 16(2)(f))

• TSP training programs must provide an adequate level of knowledge in respect of the role and needs of a service dog.
• Please refer to section 6.5 of this guide for more information about service dogs.

Training for personnel that may be required to provide physical assistance (Section 17)

Seek information (Subsection 17(a))

• TSP training programs must provide an adequate level of knowledge and skills on how to seek information from a person with a disability with respect to their preferred method of assistance, and any other measures that they may require to ensure their safety and comfort.
• Please refer to section 7.1 of this guide for more information on seeking information.

Manoeuvring mobility aids (Subsection 17(b))

• TSP training programs must provide an adequate level of knowledge and skills on how to manoeuvre mobility aids through doors and on irregular and multi-level surfaces, steps, curbs and elevators.
• Please refer to section 7.2 of this guide for more information on manoeuvring mobility aids.

Transfer assistance (Subsection 17(c))

• TSP training programs must provide an adequate level of knowledge and skills on how to transfer a person with a disability between their own mobility aid and a mobility aid provided by the TSP, and between a mobility aid and the person’s passenger seat.
• This includes performing appropriate lifting techniques involved in various types of transfers of the person with maximum consideration for their dignity, privacy, safety and comfort.
• Please refer to section 7.3 of this guide for more information about transfer assistance.

Guiding and orienting assistance (Subsection 17(d))

• TSP training programs must provide an adequate level of knowledge and skills on how to guide and orient a person with a disability whose impairment affects their mobility.
• Please refer to section 7.4 of this guide for more information about guiding and orienting assistance.

Assistance with balance, agility or coordination (Subsection 17(e))

• TSP training programs must provide an adequate level of knowledge and skills on how to assist a person who has limitations in balance, agility or coordination that affect their mobility.
• Please refer to section 7.5 of this guide for more information about assistance with balance, agility or coordination.

Contents of training for personnel that may be required to handle mobility aids (Section 18)

• TSP training programs must provide an adequate level of knowledge and skills with respect to the handling of mobility aids.
• This knowledge and skills must include the different types of mobility aids, and the requirements and appropriate methods for transporting and storing mobility aids, including the disassembling, packaging, unpackaging and reassembling of mobility aids.
• Please refer to section 8 of this guide for more information about the handling of mobility aids.

Contents of training for personnel that may be required to use or assist with special equipment (Section 19)

• TPS training programs must provide an adequate level of knowledge and skills on the use of special equipment, or how to assist a person with disability in using special equipment.
• Please refer to section 9 of this guide for more information about training contents for special equipment.

Other training obligations

TSP training, including TSP policies and procedures, as appropriate, must also meet the following requirements of the ATPDR:

• Initial training (Subsection 20(1))
• Supervision of untrained personnel (Subsection 20(2))
• Refresher training (Section 21)
• Duty to inform personnel (Section 22)
• Preparation of training programs (Subsection 23(1))
• Consultation (Subsection 23(2))
• Information about training program (Subsection 23(3))