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Letter to Travel Agencies and Airlines Operating in Canada regarding Accessible Transportation Information

In its continued efforts to support travel professionals in providing quality service to travellers with disabilities, the Canadian Transportation Agency issued this letter to travel agencies and airlines throughout Canada. It outlines a number of steps which travel agents and air carriers should undertake to ensure that the most accessible service possible is provided to travellers.

June 30, 2003

Under the Canada Transportation Act (CTA), the Canadian Transportation Agency (Agency) is responsible for ensuring that undue obstacles to the mobility of persons with disabilities are removed from the federal transportation network. The Agency does this in two ways: on a case-by-case basis by adjudicating individual complaints, and on a systemic basis by developing regulations, codes of practice and standards concerning the level of accessibility in modes of transport under federal jurisdiction such as air, rail and marine.

Upon receipt of an application and pursuant to section 172 of the CTA, the Agency may inquire into matters to determine whether there is an undue obstacle to the mobility of persons with disabilities when they travel. Should the Agency find that an undue obstacle exists, the Agency may require the taking of appropriate corrective measures or direct that compensation be paid for any expenses incurred by a person with a disability arising directly from the undue obstacle or both.

The Agency recognizes the importance of travel agents to the accessibility of the federal transportation network as the intermediaries between passengers with disabilities and transportation service providers. While proper understanding of the needs of persons with disabilities and effective communication of this information by travel agents to transportation service providers contribute to the successful travel of persons with disabilities within the federal transportation network, incomplete or erroneous information exchanged between travel agents and transportation service providers can result in significant travel problems for persons with disabilities. These problems can escalate when a third party, such as a consolidator, becomes involved.

In the summer of 2000, the Agency conducted the Air Travel Accessibility Survey, which indicated that 66% of travellers with disabilities book their flights through a travel agent and that, in 19% of the reservations made, the relay of information on disability-related requirements between the booking agent and the check-in counter left much to be desired. As a result, in July 2001, the Agency distributed to travel agencies and major airlines operating in Canada the Reservation Check-List - Air Travel to help travel agents and air carriers meet the needs of persons with disabilities using air travel services (copy attached). While the Check-List has been found to be a useful tool by the travel agent industry and by air carriers, the Agency continues to receive numerous complaints involving miscommunication of information in respect of:

• disability-related service requests not properly recorded by the travel agent at the time of the reservation;

• information not accurately communicated by the travel agent to the air carrier; and

• disability-related service requests not accurately reflected by the air carrier in a passenger's reservation file.

In the context of complaints filed with the Agency, it would appear that the lines of communication frequently break down between travel agents and air carriers with respect to the following services:

• Wheelchair assistance
  Service request codes for wheelchair assistance range from persons with disabilities who require assistance for distances to/from the aircraft or for ascending/descending steps to passengers who are completely immobile and must be transported up/down steps and to/from the cabin seat using an onboard wheelchair. With this in mind, it is important that travel agents discuss with their customers the exact nature of the assistance they require and ensure that this information is accurately conveyed to carrier personnel. Assumptions about the needs of persons with disabilities should never be made. Travel agents and carriers should also be knowledgeable of the disability-related service codes utilized in a passenger's reservation file to ensure that the proper code has been entered on the file.

• Advance seating requests
  The Air Transportation Regulations (ATRs) recognize the importance of accessible seating to persons with disabilities. In many complaints before the Agency it has been noted that information provided by travel agents to carrier personnel regarding a passenger's seating needs had not been sufficient to enable the carrier to assign a seat which best met the specific needs of the passenger. While an aisle seat with space to stretch a leg into the aisle may accommodate a particular passenger's disability, in some cases bulkhead seating or a seat with a liftable armrest may be required. Likewise, a hearing impaired passenger may wish to sit away from the engines to make it easier to hear the flight attendant's safety demonstration and announcements, while a passenger who cannot walk long distances or has to make frequent use of the washroom may request a seat close to such facilities. It is important that travel agents obtain a clear understanding of the travel-related needs of persons with disabilities and the accessibility features which they require through open and clear communication and ensure that proper identification of their seating needs is provided to carrier personnel.

• Meet and Assist service
  While "Meet and Assist" service consists of carrier personnel providing limited assistance with boarding, during connections and at final destinations, in many cases it would not necessarily accommodate the needs of adults with intellectual disabilities who require assistance throughout their air travel from the time of check-in up to and including meeting their designated contact at the final destination. It is important that travel agents communicate the limited nature of the "Meet and Assist" service to the person with the intellectual disability or to the person making the reservation on his/her behalf. Furthermore, services such as the unaccompanied passenger service, sometimes referred to by carriers as "Unaccompanied Minor Service" (see below) may more appropriately meet the passenger's needs and travel agents should provide detailed information on this service.

• Unaccompanied passenger service
  Unaccompanied passenger service ensures that a passenger is escorted at all times during his/her air travel. This service is available at no extra cost to minors and to adults with intellectual disabilities upon medical clearance (see "Meda Desk" below). Because intellectual disabilities are not necessarily visible, carrier personnel are often unaware of a passenger's specific needs. This problem is exacerbated in situations where the person's disability and travel-related needs have not been entered on his/her reservation file. It is important that travel agents ensure that the reservation file of an adult passenger requiring this service accurately reflects their disability and the service which he/she requires.

• Meda Desk
  Medical clearance by the carrier's medical department may be required for passengers in certain circumstances. Travel agents should be aware that, in these cases, passengers are subject to prior clearance for air travel and that medical information in respect of the passenger's physical and/or mental health through a licensed physician familiar with the passenger must be provided to the air carrier. Travel agents should be familiar with the circumstances requiring medical clearance, ensure that the passenger provides the required information to the carrier and follow up with the carrier as to whether clearance has been obtained.

In general, there are a number of steps which travel agents and air carriers should undertake to ensure that the most accessible service possible is provided to all travellers:

• Travel agents should be aware of carriers' policies and procedures with respect to the carriage of passengers with disabilities and ensure that this information is conveyed accurately to passengers with disabilities so that they can make informed decisions about their travel options.

• Travel agents should obtain a clear understanding of the travel-related needs of passengers with disabilities and reflect these in the Reservation Check-List - Air Travel to use as a tool to accurately communicate these needs to the carrier.

• Simple procedures for relaying information between travel agents and carriers should be encouraged so that the carrier is made aware of the passenger's needs related to his/her disability to enable it to apply its policies and procedures in a manner that will ensure, as far as possible, that the person's needs are met during travel.

• If the carrier is unclear as to the passenger's needs related to his/her disability, it should request further information to enable it to make informed decisions as to the services that should be provided.

• Travel agents should confirm a passenger's disability-related service requests with the carrier, request confirmation of the measures the carrier intends to take to ensure, as far as possible, that the person's needs are met during travel and provide a copy of the confirmation to the passenger so that he/she can be certain of the services that will be provided.

The Agency is responsible for developing and administering accessibility regulations governing the federal transportation network. Part VII of the ATRs sets out the terms and conditions of carriage of persons with disabilities. Your particular attention is drawn to subsection 147(1) which sets out the disability-related services which a carrier shall provide. Copies of all Agency publications, including the Reservation Check-List, and of transportation-related statutes and regulations may be found on our website at www.cta-otc.gc.ca.

In view of the number of complaints involving the miscommunication of information regarding the travel-related needs of persons with disabilities at the travel agent and the air carrier levels, I strongly encourage travel agents and air carriers to implement the steps set out above in order to ensure access to the transportation network by persons with disabilities and prevent, as far as possible, situations which result in complaints being filed with the Agency.

Should you have any questions regarding this matter, you may contact Rosemary Baldwin, A/Manager, Complaints and Investigations, Accessible Transportation Directorate, by phone at (819) 953-9151, toll free 1-888-222-2592, TTY 1-800-669-5575, or by e-mail at rosemary.baldwin@cta-otc.gc.ca

Sincerely,

Marian L. Robson
Chairman

c.c.

Members of the Agency's Accessibility Advisory Committee Michael Pepper Travel Industry Council of Ontario André Derome Office de la protection du consommateur Québec, Québec Tom Aquiline Registrar of Travel Services Consumer Services Ministry of the Attorney General of British Columbia Association of Canadian Travel Agencies