ࡱ> ` 0Wbjbj sYw  J J J $n r.r.r.P./tn r01"22025r7lz78qqqqqqq$th6wlqJ +< 5 5|+<+<q 202q???+< 2 2q?+<q??3lX  6o20 03r.<m(pq0rmDw=wPowJ o7|8? 9t9777qqg?^777r+<+<+<+<n n n $r.n n n r.n n n   Workability: People with disability in the open workplace Response to interim report of the national inquiry into employment and disability September 2005 Table of Contents  TOC \o "1-3" \h \z \u  HYPERLINK \l "_Toc116726914" 1. 鱨վ People with Disability Australia  PAGEREF _Toc116726914 \h 3  HYPERLINK \l "_Toc116726915" 2. Summary of recommendations  PAGEREF _Toc116726915 \h 4  HYPERLINK \l "_Toc116726916" 3. Introduction  PAGEREF _Toc116726916 \h 5  HYPERLINK \l "_Toc116726917" 4. PWD response  PAGEREF _Toc116726917 \h 6  HYPERLINK \l "_Toc116726918" 4.1 General principles: Compliance and special measures  PAGEREF _Toc116726918 \h 6  HYPERLINK \l "_Toc116726919" 4.2 Social and political context  PAGEREF _Toc116726919 \h 6  HYPERLINK \l "_Toc116726920" 4.3 Women with disability  PAGEREF _Toc116726920 \h 7  HYPERLINK \l "_Toc116726921" 4.4 Welfare to work and industrial relations reforms  PAGEREF _Toc116726921 \h 9  HYPERLINK \l "_Toc116726922" 4.5 Cost of disability  PAGEREF _Toc116726922 \h 10  HYPERLINK \l "_Toc116726923" 4.6 Quality of DDA compliance and disability specific decision-making by employers  PAGEREF _Toc116726923 \h 10  HYPERLINK \l "_Toc116726924" 4.7 Quality of generic human resources decision-making  PAGEREF _Toc116726924 \h 12  HYPERLINK \l "_Toc116726925" 4.8 Next steps  PAGEREF _Toc116726925 \h 14  HYPERLINK \l "_Toc116726926" 5. Conclusion  PAGEREF _Toc116726926 \h 14  1. 鱨վ People with Disability Australia People with Disability Australia Incorporated (PWD) is a national cross-disability rights and advocacy organisation. PWD represents the rights and interests of people with all types of disability. PWD is a non-profit, non-government organisation whose vision is of a socially just, accessible and inclusive community, in which the human rights, citizenship, contribution, potential and diversity of all people with disability are respected and celebrated. PWDs core membership is made up of people with disability and organisations primarily constituted by people with disability. PWD also has a large associate membership of other individuals and organisations committed to the disability rights movement. PWD is governed by a Board of Directors who are all people with disability. In addition to PWDs membership and governance structures being made up of people with disability, PWD has had significant experience as an employer of people with disability. Since our establishment in 1981, PWD has been a primary employer of people with disability. Currently our staffing establishment contains over sixty percent of staff with disability. The experience of our membership, Board and staff informs our response to the interim report. 2. Summary of recommendations PWD makes the following recommendations: Recommendation 1: That the final report of the national inquiry into employment and disability be informed by the principles of equal opportunity, anti-discrimination as well as addressing special measures. Recommendation 2: That the final report of the national inquiry into employment and disability include strategies aimed at eliminating discrimination on the ground of disability in the area of employment, particularly through compliance programs. Recommendation 3: That HREOC ensures that recommendations in the final report of the inquiry into employment and people with disability include that authorities or agencies charged with responsibility for measures to promote employment, job retention and return-to-work opportunities for people with disability must incorporate specific actions for women with disability. Recommendation 4: That HREOC ensures that recommendations in the final report of the inquiry into employment and people with disability include that authorities or agencies charged with responsibility for equal employment opportunity (EEO) and anti-discrimination laws, policies, practices and implementation directed to equality of employment opportunity for women generally must incorporate specific actions for women with disability. Recommendation 5: The final report of the national disability and employment inquiry consider the interrelationships between changes in social security, employment assistance and industrial relations laws, policies and programs, particularly as it affects the increased demand for anti-discrimination remedies and information for people with disability regarding their rights as employees and under the DDA. Recommendation 6: That the final report of the inquiry into disability and employment recommend that an employment participation allowance be paid to people with disability in recognition of the cost of disability. Recommendation 7: An appropriate authority must be charged with responsibility for developing readily implementable Disability Discrimination Act compliance program models that can be provided to small-medium sized employers free of charge, along with the services necessary to support implementation of such programs including information, support, training and face to face assistance. Recommendation 8: An appropriate authority must be charged with responsibility for developing readily implementable Disability Discrimination Act compliant human resources decision-making models for effective and procedurally fair decision-making processes in recruitment, retention, return-to-work and termination. Such models may be provided to small-medium sized employers free of charge along with the services necessary to support implementation of such models including information, support, training and face to face assistance. 3. Introduction People with Disability Australia (PWD) welcomes the interim report of the national inquiry into employment and disability produced by the Human Rights and Equal Opportunity Commission (HREOC), Workability: People with disability in the open workplace (the interim report). PWD believes the interim report provides a detailed account of the issues facing people with disability when seeking, gaining and retaining employment. In addition, it provides key information on issues for employers when hiring and retaining employees with disability. The interim report contains many important recommendations that, if implemented, will address significant barriers to the participation of people with disability in employment. PWD supports the general findings and key recommendations contained in the interim report. The PWD response to the national inquiry contains some additional comment and recommendations to strengthen the findings of the interim report. This PWD response contains both general and specific feedback on the content of the interim report. In particular, PWD wishes to draw to the attention of the inquiry matters in relation to disability discrimination compliance, women with disability, cost of disability, and quality of human resources decision making. Further information regarding this submission may be directed to: Matthew Keeley Senior Legal Officer People with Disability Australia 4. PWD response 4.1 General principles: Compliance and special measures PWD believes that two key principles must be borne in mind when considering issues raised in the national inquiry into employment and disability and when proposing solutions in the final report of the inquiry. These principles are: that discrimination against people with disability on the ground of their disability in the area of employment must, as far as possible, be eliminated, so as to promote equality of opportunity. This is consistent with the first object of the Disability Discrimination Act 1992 (DDA) and can in part be effectively implemented through better DDA compliance processes within organisations, such as those based on AS 3806, Compliance Programs; and that to facilitate fulfilment of the above principle, people with disability and employers require services, programs and facilities (special measures) over and above and more effective than those already available in the community. PWD considers that the interim report presents a comprehensive picture of the range of special measures required to better drive both the supply and demand side of the labour market for people with disability. The interim report therefore goes a long way toward addressing any concerns there may be regarding fulfilment of the second principle above. However, PWD notes with concern that the interim report fails to make concrete recommendations regarding the elimination of employment discrimination against people with disability through more effective DDA compliance programs and procedures for employers. PWD considers this a serious omission from the interim report and recommends: Recommendation 1: That the final report of the national inquiry into employment and disability be informed by the principles of equal opportunity, anti-discrimination as well as addressing special measures. Recommendation 2: That the final report of the national inquiry into employment and disability include strategies aimed at eliminating discrimination on the ground of disability in the area of employment, particularly through compliance programs. 4.2 Social and political context The social, industrial, and demographic context in which the national inquiry operates is one of increasing change. This includes increases in: expectation and demand by women for the recognition of the right to be treated on the same basis as men in the workplace; expectation and demand by people with family and caring responsibilities for greater flexibility to strike a balance between the increasingly demanding work environment and the needs of family, of maintaining quality of life, and of the people for whom they may be carers; and the ageing of the population and the prevalence of disability in the Australian community is rising. Clearly, in this context, current issues contributing to the under-employment of people with disability will not simply go away. Rather, it is likely that those issues will remain as problematic as is currently the case, and more than likely will increase in scope absent necessary action to ensure DDA compliance and the provision of all necessary special measures. Simultaneously two major developments are proposed that will radically change the nature of hiring, return to work, retaining and terminating employees with disability, amongst others: the Welfare to Work reforms announced by the Federal Government as part of the 2005-2006 Budget and the proposed industrial relations law reforms. PWD believes that one significant outcome of this swiftly changing environment in which people with disability will be seeking employment will be a substantially increased number and proportion of allegations and complaints of disability discrimination in the area of employment. In this context PWD is concerned that the interim report does not make concrete recommendations regarding the elimination of employment discrimination against people with disability through more effective DDA compliance programs, procedures and supports for individual employers. 4.3 Women with disability Notwithstanding the statistics detailed in Issues Paper 1 of the national inquiry, confirming the lowest rates of participation for women with disability, the highest rates of unemployment, and the lowest wages received by women with disability, the interim report recommendations do not address this issue directly. There are several reasons as to why women with disability have a lower labour force participation rate compared to men. These include but are not limited to: traditional divisions of household labour which constrain the opportunities of women with disability to seek employment; lack of access to mainstream and disability support services to assist in seeking and attaining work; low education participation rates and outcomes; lack of access to accessible and affordable child care; Moreover, the discussion paper Striking the balance: Women, men, work and family, (released as part of the HREOC examination of family responsibilities and paid work) focuses on the particular issues faced by women and men in balancing their various responsibilities, on the gender relations that underpin the lives of women and men and on the legal, policy and attitudinal frameworks that both facilitate and constrain choices. However, PWD is concerned that this discussion paper does not address issues as they relate to people with disability, except in instances where they are discussed as objects of care. This omission reflects a common negative perception of people with disability as unable, unfit and burdens. Such a perception contributes to the barriers people with disability face in relation to employment options, and denies the reality that people with disability are employers, employees, parents and carers. A further negative impact is that the particular circumstances of women with disability are excluded from an examination of the gender dimensions of achieving work and family balance. While women with disability face similar work and family balance issues as both men with disability and women in general, the way gender and disability intersect with each other creates particular disadvantages and issues for women with disability. It is apparent that to ensure equality of opportunity for women with disability as regards their male counterparts, let alone equality of opportunity amongst both disabled and non-disabled women, that initiatives in this area will need to be charged with additional responsibilities and duties to address issues for women with disability specifically. Much has already been recognised by the International Labour Organisation (ILO), of which Australia is a member, in ILO code of practice, Managing Disability in the Workplace (Geneva, ILO, 2002 @ 2.2.13) which states: The competent authorities should consider measures to promote employment, job retention and return-to-work opportunities for people with disabilities which incorporates specific action for women with disabilities. Further, EEO and anti-discrimination laws, policies and practices directed to women generally should also be charged with similar responsibilities and duties to incorporate specific action for women with disability. Recommendation: That HREOC ensures that recommendations in the final report of the inquiry into employment and people with disability include that authorities or agencies charged with responsibility for measures to promote employment, job retention and return-to-work opportunities for people with disability must incorporate specific actions for women with disability. Recommendation: That HREOC ensures that recommendations in the final report of the inquiry into employment and people with disability include that authorities or agencies charged with responsibility for equal employment opportunity (EEO) and anti-discrimination laws, policies, practices and implementation directed to equality of employment opportunity for women generally must incorporate specific actions for women with disability. 4.4 Welfare to work and industrial relations reforms The implementation of the Federal Governments proposed Welfare to Work reforms will witness an extremely large, new, and ongoing supply of potential employees with disability seeking to access the open labour market over and above the current level of supply of potential employees with disability. Acknowledging the substantial barriers that people with disability confront in both obtaining and retaining employment in the open labour market, including discrimination on the grounds of disability, it is reasonable to conclude that a great many of this number will continue to confront such barriers notwithstanding the recommendations of this inquiry and subsequent action. Further, a great many people will experience disability discrimination at the points of recruitment, return to work, job retention, and termination. It is reasonable therefore to foresee that these new dynamics, as an increasing number of people with disability seek to obtain work in the open labour market, will give rise to a substantial increase in allegations and complaints of discrimination on the grounds of disability in employment. At or about the same time that many more people with disability will be seeking to enter the open labour market, the proposed industrial relations reforms proposed by the Federal Government will be beginning to take effect. Under these reforms it appears unlikely that most employees with disability will be in a position to claim for unfair dismissal in the event of an unfair termination of their employment. PWD suggests that a great many people including those with disability who are denied unfair dismissal claims will seek to frame their claims relating to termination as claims of discrimination wherever discrimination may be arguable. It is certainly clear that employers who are emboldened by the new laws to terminate the employment of an employee with disability where the disability, either directly or indirectly, is perceived to be an operative part of the employers decision-making process, places him or herself is at risk of liability under State, Territory or Federal anti-discrimination legislation. These changed arrangements will place significant pressure on existing complaints mechanisms. In addition, it is reasonable to assume that many people with disability do not have information in relation to their rights as employees or rights contained within the DDA. PWD therefore recommends that: Recommendation: The final report of the national disability and employment inquiry consider the interrelationships between changes in social security, employment assistance and industrial relations laws, policies and programs, particularly as it affects the increased demand for anti-discrimination remedies and information for people with disability regarding their rights as employees and under the DDA. 4.5 Cost of disability PWD commends the synthesis of issues regarding the impact of cost of disability on seeking, gaining and retaining employment. However, we wish to point out that substantial research has been undertaken on these impacts on the lives of people with disability. While additional research may fine tune some of the findings of this research, cost of disability remains a substantial barrier to workforce participation. Therefore, PWD recommends: Recommendation: That the final report of the inquiry into disability and employment recommend that an employment participation allowance be paid to people with disability in recognition of the cost of disability. 4.6 Quality of DDA compliance and disability specific decision-making by employers The recommendations in the interim report focus on such special measures that will particularly address issues of information, cost and risk, all of which are acknowledged to be significant barriers to people with disability gaining employment on the basis of equality with others. However, PWD believes that such information and the provision of such services as will address cost and risk will still need to operate in the context of an employment relationship in which the employer is the decision-maker and has the power to choose either to comply with the law and good HR practice, or not. As decision-maker an employer can potentially operate within an environment in which there has been no proactive attempt at DDA or diversity compliance and in which decision-making processes have historically been arbitrary and lacking in procedural fairness. They may also operate in an environment in which the DDA or diversity compliance is a known entity and in which decision-making processes around recruitment, retention and termination are well informed, well reasoned, and provide procedural fairness to the individual affected by the decision. In PWDs experience the quality of decision is better in the latter environment, outcomes for actual or potential employees with disability are improved, and employers gain greater confidence that their decisions cannot be impugned for lack of due process and that their liability risks are thereby minimised. In this respect, and in our experience, large employers with designated and qualified human resource (HR) staff are at a distinct advantage to small-medium sized employers who lack such resources. The large employer operates within a context in which there is a clear focus and resources committed to the issues of compliance and risk management, and in which qualified HR personnel understand the need for a well-reasoned, fair and defensible approach to decision-making in the HR area. In our experience many if not most small-medium sized employers lack such resources, and as a consequence their DDA liability risk is proportionately greater than larger employers. These small-medium sized employers have a pressing need for DDA and HR compliance and decision-making tools and supports that cost little, and are reasonable to implement. The Interim Report at page 2 describes the need for information in the following terms: Information - people with disability and employers are concerned about the absence of easily accessible and comprehensive information that can assist in their decision making processes and support their ongoing needs. (emphasis added) PWD agrees with this description of the need for information, but believes that a corresponding need to assist employers and people with disability to model best practice decision-making processes in this area also needs to be identified. As stated by the Brotherhood of St Laurence (Submission 128) if due process is followed throughout the recruitment and employment process and workers with disabilities are treated fairly we do not believe that there is any higher risk of unfair dismissal or discrimination claims. PWD contends that employers need as much support to ensure that their decision-making processes are as effective and fair as possible, as they do to ensure that their information needs are met. It is at least in part through better practice in decision-making by employers that we may well expect better outcomes for employees with disability, compliance with legal obligations for employers, and through these outcomes the minimisation of liability risk for employers. PWD believes that small-medium employers need greater assistance than is currently provided in creating and implementing DDA compliance programs and procedures: a readily adoptable model for disability or more broadly anti-discrimination and OH&S compliance within an organisation (perhaps based on AS 3806), and for the making of effective decisions on the basis of the best available information and procedural fairness (administrative law approaches to decision making refer). In addition employers should be able to access free of charge the necessary information and advisory services to support the implementation of such models within their organisation. PWD believes that the final report of the national inquiry into disability and employment should contain recommendations directed to assisting small and medium sized employers in particular, in complying with their obligations under the DDA through: flexible compliance program models that can be provided to employers free of charge, along with the services necessary to support implementation of such programs including information, support, training and assistance; and flexible human resources decision-making models for effective, compliant, and procedurally fair decision-making processes in recruitment, retention and termination, along with the services necessary to support implementation of such models including information, support, training and assistance. In PWDs view the provision of such compliance and decision-making supports as indicated above, free of charge, would go a very long way to addressing the concerns of employers about the resource implications of implementing compliance with the DDA. As anti-discrimination laws in each State and Territory differ somewhat and it would be necessary for any compliance programs or decision-making models to comply with State or Territory anti-discrimination laws as well, PWD well considers that each Sate or Territory may require its own individualised versions of the tools and services. PWD recommends: Recommendation: An appropriate authority must be charged with responsibility for developing readily implementable Disability Discrimination Act compliance program models that can be provided to small-medium sized employers free of charge, along with the services necessary to support implementation of such programs including information, support, training and face to face assistance. 4.7 Quality of generic human resources decision-making In PWDs experience, the quality of decision-making processes by potential or actual employers is often the most significant barrier to a person with disability obtaining or retaining employment. This is particularly the case for smaller or medium-sized employers who may lack a dedicated and qualified human resources (HR) staff member. Poor decision-making processes affecting actual or potential employees with disability is unlikely to be a disability specific issue, although the particular issues identified in the interim report do make decision-making in this area even more complex. Rather, for small and medium sized businesses in particular, PWD believes that quality decision-making processes in the HR area is a generic problem, best characterised as a challenge for business in complying with best practice, or in complying with relevant laws, in all areas associated with HR practice. Put simply, there are still many workplaces where employing or retaining people with disability requires attention to good human resource practice as it does in the employment of people without disability. PWD therefore believes that approaches to the information, cost and risk issues for people with disability referred to above would be best provided in tandem with a generic set of supports to business to provide it with the low cost, easy to implement tools to assist with decision-making across all areas of HR practices, especially diversity management. After all, people with disability are women, people from CALD backgrounds, Aboriginal and Torres Strait Islanders, and older persons as well, and so would benefit directly from quality decision-making processes that target best practice in the employment of people from theses sectors of the population, as well. The corollary of this position is that information or other resources that focus on people with disability out of context from other HR issues facing business, may serve to perpetuate the view of business that all people with disability are special cases, requiring special attention or resources considerably over and above the levels required, extra work In purely economic terms, businesses that can be given cheap and easy to use tools that facilitate best practice in HR decision-making and in compliance with all laws relevant to HR practice will be able to cut through a lot of red tape and reduce business risk and resources committed to these areas. The result should be a freeing up of resources within business and employment stimulus across the board, including of people with disability. Disability specific initiatives would then operate within a broader environment of compliance, fairness and due process. In this respect therefore, we agree with that part of the submission of Australians for Diversity Employment (submission 44) that says: The fundamental strategy to increase employment opportunities for people with disabilities needs to be in convincing employers to adopt pro-active Diversity Employment policies and practices The Federal Government should allocate resources to sell this message to provide information and referral to Federal Government State Governments, local Governments, the business sector and the Not for Profit sector. The message should be that: It makes good business sense as well as making the organization a good corporate citizen to adopt Diversity employment policies and practices. This view is also reinforced by comments within the interim report: A business that is careful to match the abilities of an individual with the requirements of a job will not be at any disadvantage if that person has a disability. In other words, if the focus is on what a person can do, rather than on what he or she cannot do, then the primary factor for decision-making is whether the person is well suited to the particular job. Some submissions and research suggest that a business that focuses on good job matching will be a more efficient business, and if that is the case it makes little difference whether a person does or does not have a disability. To this end, PWD recommends: Recommendation: An appropriate authority must be charged with responsibility for developing readily implementable Disability Discrimination Act compliant human resources decision-making models for effective and procedurally fair decision-making processes in recruitment, retention, return-to-work and termination. Such models may be provided to small-medium sized employers free of charge along with the services necessary to support implementation of such models including information, support, training and face to face assistance. 4.8 Next steps PWD supports the proposed next steps for the national inquiry. In particular, PWD expresses our interest in participating in working groups recommended in the areas of: work trials risks regarding occupational health and safety, disability discrimination and industrial relations laws model for ongoing support for employers and employees model for flexible workplace. 5. Conclusion PWD welcomes the interim report of the national inquiry into employment and disability. PWD supports the key findings and recommendations contained in the report. In addition, PWD makes additional recommendations for issues and recommendations to be contained in the final report. We welcome an opportunity to further explore these issues in the future.     PAGE  PAGE 2  Our vision is of a socially just, accessible and inclusive community, in which the human rights, citizenship, contribution and potential of people with disability are respected and celebrated.  ABN 98 879 981 198 People with Disability Australia Incorporated Postal Address: PO Box 666 Strawberry Hills NSW 2012 Street Address: Ground Floor, 52 Pitt Street Redfern NSW 2016 Phone: 02 9319 6622 Toll Free: 1800 422 015 Fax: 02 9318 1372 TTY: 02 9318 2138 Toll Free TTY: 1800 422 016 Email:  HYPERLINK "mailto:pwd@pwd.org.au" pwd@pwd.org.au TIS: 13 14 50 NRS: 1800 555 677 NGO in Special Consultative Status with the Economic and Social Council of the United Nations ABN 98 879 981 198  GJҌupu]OFOh17mHnHuhh170JmHnHu$jhh170JUmHnHu h175jh175UhDhDOJQJ^J#hDhD5CJOJQJ^JaJh8iOJQJ^Jh; h8ih8ih8ih8iOJQJ^J#h8ih8i5CJOJQJ^JaJh8i5OJQJ\^Jhr85OJQJ\^Jhr8OJQJ^JhBOJQJ^J     GHIJ$a$gd8igd8igdH$h$dN^ha$gd8ih^hgd8i$a$gd8i$a$YMVH R 0  _ q BC  &dPgdDgdsR" I" 0^`0gd17" I" ! I" ! 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