ࡱ> wztuv_ zbjbjzz 7B\B\&&&8 \O&!Lr!"!!!"" "ήЮЮЮЮЮЮ$1r#""##!!4 &&&#!!ή&#ή&&  f!pΆTZ#Fb0OdY$HYffY##&#####b%N###O####Y#########&> d:  Blind Citizens Australia Inquiry into improving the employment participation of people with disability in Australia October 2015 Contact: Rikki Chaplin National Advocacy And Policy Officer Blind Citizens Australia Ross House Level 3, 247251 Flinders Lane MELBOURNE VIC 3000 Phone: 03 9654 1400 Email: Rikki.chaplin HYPERLINK "mailto:jessica.zammit@bca.org.au" @bca.org.au This submission is available in large print, audio, Braille and in electronic formats for access by people who are blind or vision impaired. 鱨վ Blind Citizens Australia: Who we are and why we say what we say Blind Citizens Australia is a unique organisation that is solely made up of and represents people who are blind or vision impaired. All of our Board of Directors and our committees are required by our Constitution to be people who are blind or vision impaired. Many of our staff are also vision impaired. We have over 3000 members around Australia who are all people who experience blindness. This is why we are best placed to comment on the necessary changes that are needed to improve employment opportunities and career pathways for people who are blind or vision impaired. In addition to our role as the national peak consumer body, Blind Citizens Australia provides information, support and assistance to people who are blind or vision impaired to successfully advocate for their needs. We are driven by our mission to achieve equity and equality by our empowerment, by promoting positive community attitudes and by striving for high quality and accessible services which meet our needs. Background Blind Citizens Australia welcomes the opportunity to provide comment to the Willing To Work inquiry. Our expertise lies in sharing the issues and barriers currently experienced by members who are blind or vision impaired and advocating for reform which will best meet their complex interests. In December 2012, Blind Citizens Australia launched an Employment Policy suite, a series of five policies and six factsheets targeted to recruiters, employers, disability employment service (DES) providers, all levels of government and to the Federal Government. The fifth policy in the suite focuses on how Australia can meet its national and international obligations as they relate to increasing employment opportunities for people with disability, particularly people who are blind or vision impaired. Our factsheets focus on challenging assumptions and breaking down common myths about what people who are blind or vision impaired can do, provide guidance on legal blindness and how people who are blind access information and provide useful links for recruiters, employers and DES to access more detailed information. The development of the Blind Citizens Australia employment policy suite was extensively informed from the experiences of our membership, with a sub working group formed of people who are blind or vision impaired as people currently in the workforce, people who have been long term unemployed, job seekers and recent retirees. In the development of these documents, Blind Citizens Australia also consulted extensively with external stakeholders including the 鱨վ, Disability Employment Australia, blindness specific DES providers Royal Society for the Blind and Vision Australia, the Australian Blindness Forum, Australian Human Resource institute, Jobs Australia and the Australian Public Service Commission. The full employment policy suite has been included with this submission in the attached Appendices [ HYPERLINK "https://wordpress.bca.org.au/employment/" https://wordpress.bca.org.au/employment/]. We strongly encourage the Department to read the full suite as the suite provides significant guidance on the areas of reform that are warranted to significantly address the unemployment and under-employment of people who are blind or vision impaired. How Australia can meet its national and international obligations In order to meet our national and international obligations, Australia needs to invest in a new approach to address this long standing inequity. Blind Citizens Australia refers the Inquiry to our policy document How the Australian government can meet its national and international obligations which outlines a number of significant areas for reform. In summary these include: Supporting people with disability to explore flexible employment options, including financial incentives (such as the National Enterprise Incentive Scheme) and support to start their own businesses. The implementation of the National Disability Insurance Scheme could be a good opportunity for some individuals with disability to form viable business practices where transferable skills can be shared. Providing practical support to small and medium sized businesses to ensure that strategies are tailored to the needs of specific workplaces and to enable career advancement Increasing employer wage subsidies to help people who are blind or vision impaired to get a foot in the door More targeted promotion of DES and how DES can support a business to employ a person with disability Ensuring that legislation backs up the talk about improving employment opportunities for people with disability, including the development of compulsory Disability Standards for Employment Continued reform of DES requirements to ensure that DES are working to maximise outcomes for jobseekers rather than working to generate profit. Individuals should be placed in a job that best meets their skill set and interests, rather than the first job that is available. Refer to Appendix A for our policy document How the Australian Government can meet its national and international obligations. What are the practical and workable approaches to make a real improvement to employment outcomes and workplace equality for people with disability? How would they work? The employment of people with disability needs to be demonstrated to employers as a venture which is profitable both in terms of time invested and money not just as the right thing to do or to give a person with disability a fair go. This requires a significant shift in how the employment of people with disability is marketed to businesses across Australia and is contingent on a number of elements in addition to the reforms outlined in our employment policy suite. For example: We need to be seeing positive images of people who are blind or vision impaired and people with disability working in a variety of roles including as a storeman to an office professional to a farm hand to a financial advisor. We need to breakdown the perception of people with disability as one homogenous group with limited skills and to showcase that the vast majority of people with disability are highly competent individuals who can step into a role. This messaging needs to be targeted to the wider public (ie. television and social media) and provocative so that it is spoken about in the lunch rooms of companies and is at the front of mind of recruitment staff and company directors. Most importantly, the cost benefit to a business needs to be showcased as part of a marketing campaign. Removing or lessening the costs of recruiting and retraining new staff, paying lower workcover premiums long term and retaining corporate or job specific knowledge is an investment, particularly when considering that an individual with disability may only require some minor adjustments to complete the role. 2.. Showcasing the best of the best and how they are doing it Showcasing the best of the best some of the top 200 companies who are hiring a proportionate percentage of people with disability can show other companies that it is possible and it is profitable, both financially and in the value add to the company through the addition of a persons rich life skills. Business leaders who have seen the commercial benefit for their business could be some of the strongest allies to the employment of people with disability. This could include talking about the benefits that this has had for their company but also talking about how their company made the transition and how it can be sustained. Importantly, organisations that are showcased need to be able to show the different roles that people with disability hold within the organisation. Showcase organisations are organisations where there are people with disability in senior leadership positions, people with disability in mid level roles and people with disability in entry level positions. Showcase organisations are also organisations which have employees with a range of disabilities, not just disabilities that can most easily be accommodated. People who are blind or vision impaired can be software developers, lawyers, office professionals, administration assistants and more. This should be reflected in the diversity of the workforce. 3. Federal, State and Territory governments to lead by example Blind Citizens Australia refers the Inquiry to our policy document titled Government as an Employer: What can all sectors of the government do to improve the employment of people who are blind or vision impaired?. This document outlines a number of strategies which can set government as a benchmark employer. Leading by example requires the following: Improving workplace accessibility which extends beyond simply improving the physical environment. This includes accessible procurement. Blind Citizens Australia refers the Inquiry to the recent report released by the Australian Communications Consumer Action Network titled  HYPERLINK "https://accan.org.au/index.php?option=com_content&view=article&id=495:government-ict-purchasing-what-differences-do-accessibility-criteria-make-for-people-with-disabilities&catid=98:access-for-all&Itemid=234" Government ICT purchasing: What differences do accessibility criteria make for people with disabilities which was also informed by the experiences of people who are blind or vision impaired. Blind Citizens Australia recommends Government to meet its national and international obligations), that the compatibility of new computer systems with software and technology used by employees with disability should be resolved by the development of whole of government requirements which embed accessibility. These requirements could be modelled on Section 508 of the US Rehabilitation Act. This section requires that electronic and information technology used by US Federal agencies is accessible to people with disability. Improving recruitment and retention, including at senior levels Targeting underperforming departments with low levels of employment of people with disability Ensuring that work experience programs are open and flexible to people of different ages and experience Developing tailored career advancement programs and implementing processes to enable current employees with disability to make their way up the career ladder. We are aware of many instances where people who are blind or vision impaired have been bypassed for career advancement because of the trouble it would take to relocate an employee to another work section or to apply for new modifications, if required. Requiring contracts with external recruitment agencies to clearly include the active recruitment of people with disability Investigating short internships for high school and post high school students to provide practical work experience which can lend itself to future employment opportunities Ensuring that interview panels include a person with disability, where possible, similar to the requirement to have balanced gender representation on recruitment panels. This not only serves as best practice to ensure that a panel has a range of experience, but also helps to build the capacity of recruitment staff to see beyond a persons disability and to have a better understanding of the job skills that people who are blind or vision impaired have. As one member put it: I am certain that many very qualified people who are blind or vision impaired lose out during the interview process not because of anything they lack, but because of a limited understanding of interview panel members as to how people who are blind or vision impaired use access solutions to undertake a particular job. 4. Building the capacity of people with disability as viable employees Increasing employment opportunities and positions to people with disability should in turn lead to an increased demand for highly skilled qualified individuals. It is therefore important that reforms in this space are not viewed purely as a one sided approach. While there are many skilled people with disability who are ready to jump or rejump into the workforce, there are also many people with disability who need to learn the social mores of a workplace and the skills needed to make a productive contribution. Building capacity of people with disability, particularly for people who have been long term unemployed is part of the equation of increasing the employability of people with disability. For people who are blind or vision impaired, this can include mentoring of jobseekers who are blind or vision impaired by people who are blind or vision impaired who have reached, or are successfully realising, their employment goals. Capacity building can help people who are blind or vision impaired to develop the necessary skills to move up through the ranks and in turn, be in a position to influence recruitment decisions and create opportunities to hire people with disability and people who are blind or vision impaired. Capacity building also requires access to peer support networks and programs which links successful people with disability with jobseekers with similar disabilities to learn transferable employable skills and the best way to approach disability specific challenges which can arise in a work setting. Disability disclosure and disability employment reporting Blind Citizens Australia is supportive of the proposal to establish baseline data for disability employment as well as transparent methods of collection across the board. Blind Citizens Australia also supports reporting by companies on the level of disability employment within their company. Blind Citizens Australia recommends that the development of any benchmark also include a requirement to provide disability specific data, particularly on the numbers of people who are blind and people who have disclosed a vision impairment. While increased reporting would provide a benchmark to measure improvement in the employment of people with disability, it is imperative that the option to disclose the presence of a disability remains at the sole discretion of the individual. This is particularly crucial for people who may not outwardly appear to have a disability, such as people with some vision impairments or people with a psychosocial disability who may not want to disclose. The privacy issues surrounding disclosure should be resolved by giving primacy to an individuals right to dignity and privacy under the UN Convention on the Rights of Persons with Disabilities and the view that the disclosure of disability is only relevant to matters which relate to the inherent requirements of the job at hand. It is therefore important that the concept of inherent requirements should be interpreted expansively so as not to exclude people with disabilities. What are the main barriers faced by people with disability in employment? 1. Acquiring The Necessary Skills. Access to work experience A job seeker with well rounded skills and previous work experience has become the benchmark for many positions, including entry level positions. While students without disability may gain preliminary work experience through retail or hospitality experience during their teenage and post high school years, many students who are blind or vision impaired do not gain this experience. Unfortunately, Attitudinal barriers by employers can come into play, thereby preventing opportunities to develop such skills from arising for many people who are blind or vision impaired. Getting paid work experience is pretty hard & volunteer work experience doesnt have the same value in the application process regardless of how hard you work in a volunteer role. I was recently interviewed by (disability service provider) for a position, and although the feedback I received from them was very positive, I didnt get the job simply because the person who did get it had worked in areas I had never had the opportunity of working in. I think the limited opportunities we have to gain on-the-job experience that would allow us to either get a job in the first place, or to be able to progress up the career ladder is placing us at greater and greater disadvantage. Employers are pretty much ruthless these days in choosing candidates with the most experience and the candidate who will fit their agendas most closely. People dont just walk into jobs anymore and get given a go. Those days seem to be gone, and for us, I think they need to return. In addition, career advisors in high school and post secondary institutions can arbitrarily restrict work experience opportunities for students based on their perception of the careers people who are blind or vision impaired can pursue. Blind Citizens Australia is aware of a number of students who are blind who have been discouraged from pursuing careers in certain fields because blind people cant do that job or have been encouraged to choose specific careers because this is what other people who are blind do. Work placements are often negotiated with the assistance of a career advisor, therefore it is vital that perceptions of blindness are not used to impose limitations on students who are blind or vision impaired in considering what might be suitable work placement options. Likewise, work experience is also critical for people who are blind or vision impaired who have been out of the workforce for some time. Absence from the workforce can be due to limited opportunity to be re-employed, lack of consistent employment opportunities or permanent work, or a lack of training in the use of critical assistive technologies for completing tasks associated with a persons area of knowledge and/or expertise. Acquiring the skills for employment today requires a heavy focus on the development of technology skills in most areas of employment, and possibly, input from professionals such as occupational therapists to assist in the development of strategies for performing skills associated with certain chosen career paths. This does not mean that people who are blind or vision impaired do not have knowledge specific to their chosen career. Rather, skill development can be simply about developing strategies for completing specific tasks, the neuances and importance of which a person is already aware. For younger people finishing high school or attending university as students who are blind or vision impaired, the development of assistive technology skills is an almost inevitable part of their education. However, for a person who loses their sight later in life and still wishes to work, these skills need to be developed from scratch, and ready access to assistive technology in a persons everyday environment needs to be facilitated so that the use of this technology becomes second nature. Recommendation 1 A: Career advisors should be educated about the impacts of making subjective judgements regarding the type of career a person who is blind or vision impaired, (or who has any type of disability), is able to pursue. People who are blind or vision impaired have been successfully employed in every kind of occupation, from music teacher, to mechanic to surgeon. Most occupations can demonstrate a precedent where a person who is blind or vision impaired has undertaken all associated tasks successfully. Recommendation 1 B: The eligibility criteria of the Employment Assistance Fund (EAF) needs to be addressed to ensure that people who are blind or vision impaired can access the aids and equipment they need as a job seeker or volunteer to enable greater job readiness. If a person who is blind or vision impaired does not have the equipment they need and the skills to use the equipment and to demonstrate their aptitude, it can make it much more difficult to compete for roles. Recommendation 1 C: Where the EAF can not be accessed, or in the event that it is dismantled due to the advent of the NDIS, assistive technology needs to be made available through the NDIS for people seeking employment, and for people who are employed and who lose their sight. This will make it easier for people who are blind or vision impaired to complete training in the use of such technology, and use that technology on an everyday basis to cement that training. 2. Discrimination and Attitudinal Barriers. People who are blind or vision impaired experience one of the highest rates of unemployment even amongst people with disability. Recent research undertaken by Vision Australia, a blindness service provider, indicated that 58% of respondents to the research were unemployed not by their own choice, as compared to 14% of the wider Australian population at the time the research was undertaken. People who are blind or vision impaired who are seeking a job are therefore four times more likely to be unemployed compared to the general population. Underemployment also continues to be a significant issue for people who are blind or vision impaired, with one third of participants in the same research study wanting to work more hours. Looking more broadly at community attitudes, research has indicated that acquiring blindness is feared to the same extent as developing cancer a fear that can place people who are blind or vision impaired in a position of pity as well as compromise perceptions of what a person who is blind can do successfully and independently. This has a flow on effect to the perception of the capacity of people who are blind or vision impaired in the world of work. There are a number of barriers which our members have shared which have contributed to their inability to find long term, well paid and meaningful employment. These are as follows: Pre-conceived ideas about what people who are blind or vision impaired can and cant do Pre-conceived ideas about the capacity of people who are blind or vision impaired is a major stumbling block for many of our members. Perceptions about increased occupational health and safety risks, how other staff members will cope and communicate with a person who is blind and a lack of knowledge of the practicalities of how a person who is blind or vision impaired will conduct the role remain significant hurdles to gain employment. I was told that unfortunately I wouldnt be offered the job with the call centre. The lady told me that as the hours worked would be after hours, it would be difficult for me as a person with low vision. Also I had to negotiate stairs and she expressed that I wouldnt be able to do that because of my low vision and that I could fall. Despite telling her that I could use stairs (and that people who are blind or vision impaired can use stairs safely) and that I would wait for my taxi under the building light - which other people would do too I was told sorry, but no. Effort and perceived cost of hiring a person with disability The perceived cost of hiring a person who is blind or vision impaired particularly the cost of adaptive equipment can act as a barrier even where an individual is able to communicate how they conduct work related tasks. One of the main barriers to employment is the general ignorance around blindness and low vision in how we function as people and how we function as employees. A lot of employers seem to think that employing us will require too much change and be too big an imposition on other employees without even talking to us about how we would carry out the role. For some jobs Ive interviewed for someone with less experience than me has gotten the job over me as they didnt have a disability so the employer didnt need to rethink their workplace practices like using taxis & carpooling rather than using the work car. Some organisations are looking for someone that they can mould into their own image rather than someone who has already developed a sense of who they are & their working style. Recommendation 2: A solid marketing campaign which outlines the facts If employers do not understand how people who are blind or vision impaired see a computer screen or are uncertain about their workcover obligations as they relate to a person with an existing disability, they may take the easy way out. The facts greater longevity in a role, lower safety and insurance costs and better ratings on attendance, sick leave and recruitment and the supports, such as the Employment Assistance Fund, that are available to support employment of people with disability are still largely unknown by small and medium sized businesses. A targeted and sustained marketing campaign is necessary to dispel the perception of what people with disability can do and to showcase people with disability who are currently working in a range of professions. The Other Film Festivals marketing campaign is a fantastic example which showcases the person first and places emphasis on their attributes as everyday people. The persons disability is then shown as a second, almost after thought. This is effective in teaching the community to put the person before the label. 3. Issues Faced When Applying For A Job. Position descriptions which indirectly discriminate A requirement which is increasingly appearing in position descriptions is the requirement for a drivers licence even for roles where extensive travel would not be ordinarily required to conduct the role. This requirement, simply through its inclusion in a position description as a mandatory or essential criterion, automatically eliminates people who are legally blind (a person with 10% or less vision or a visual acuity of 10 degrees) and all people with a significant vision impairment who are unable to drive. This also excludes many people with disability who are unable to drive and people who choose not to have a drivers licence who have the competitive skills to conduct the role advertised. Recommendation 3 A: that mandatory removal of the requirement to hold a drivers license be imposed, with the exception of occupations where a license is key to the role. Examples of such an exception would be truck driving, operating heavy vehicles or driving taxis or private hire vehicles. Recommendation 3 B: Where a job requires travel, alternative methods of travel, such as car pooling, reimbursement for taxi use and utilisation of public transport should be regarded by all employers as acceptable alternatives to possessing a drivers licence. Inaccessible recruitment processes Jobs advertised on websites which do not comply with W3C accessibility, online application systems which are inaccessible or hard to navigate using screen enlargement or screen reading software (which reads information presented on a computer screen audibly) and documents which are only available in PDF formats are all information barriers which can limit, or prohibit, access by job seekers who are blind or vision impaired. Some interview processes can also be inaccessible to applicants who are blind or vision impaired, such as in-house assessments which are not compatible with adaptive technology. Recommendation 4: all recruitment processes should follow accessibility guidelines in all areas to ensure that every stage of a process does not discriminate against people who are blind or vision impaired, or more broadly, people with any type of disability. Such a requirement would be underpinned by article 9 of the United Nations Convention on the Rights of People with Disabilities, (UNCRPD). The knowledge of DES staff to promote the capacity of people who are blind or vision impaired It is commonly expressed to Blind Citizens Australia that many DES providers are not currently meeting the needs of jobseekers who are blind or vision impaired and often have little understanding of how to best support a person who is blind or vision impaired to seek, gain and keep employment. If a DES does not understand how a person who is blind or vision impaired can complete work related tasks, they will not be the best advocate nor support resource to assist a person who is blind or vision impaired into a meaningful role which meets a persons full access needs. Blind Citizens Australia has created a policy directed to DES providers titled Hello Disability Employment Service (DES) providers to improve knowledge by DES of how to work and support a person who is blind or vision impaired and provides extensive recommendations. Recommendation 5: In regional areas, the closest service provider with specialist knowledge of a specific disability should be funded to provide disability employment services to people who would prefer to access a DES with specialist knowledge of their particular disability. This should occur regardless of whether specialist providers are funded in general to provide service for a certain region or not. While arrangements for DES funding may change with the introduction of the NDIS, consistent input from an experienced service provider in the area of blindness and vision impairment is crucial if people who are blind or vision impaired are going to gain employment as individuals, and to be better represented in the workforce collectively. 4. Difficulty Keeping A Job. Accessibility of the worksite and processes Accessibility is more than a ramp. Accessibility barriers for people who are blind or vision impaired include databases and programs which are inaccessible with screen reading software inaccessible procurement such as phone systems, photocopiers and systems that are used in an office environment inaccessible procedures and information poor access considerations such as signage, lighting or glare and Inflexibility to modify some components of a role, particularly where a role has some visual based tasks. Minor modifications to a process and/or trading of tasks between team members are simple adjustments which can increase efficiency, accessibility and in some instances, streamline processes. The impact of procurement policies which do not consider accessibility can be demonstrated as follows: As an example, a major government department continues to utilise a database that is known (including through the lodgement of a Disability Discrimination complaint) to be incompatible and inaccessible to employees and external staff who are blind or vision impaired using screen reading software. Most importantly, the inaccessibility of this database was identified during the testing phase prior to introduction (when script modifications could have been made) but was implemented regardless with no modifications. Inaccessible systems which compromise access for people who are blind or vision impaired are also evident in other parts of government including local council, where one of our members notes: I have been working at local council for five years and some of the programs I need are completely inaccessible with screen reading software. I have raised this repeatedly to my manager and have progressed this within Council. I have spoken about it, written about it and emailed about it. I am continually told that IT are looking into it but it only seems to progress after I chase it up. If I dont chase it up, nothing happens. It is no more accessible now than it was five years ago. We have a disability advisory committee and we work on improving disability access in the community but I am treated like my needs are irrelevant. Recommendation 6 A: All equipment and software purchased by government departments must meet relevant accessibility standards and be trialled by accredited accessibility consultants to ensure that the standards are met before purchase. Recommendation 6 B: In cases where costs of purchasing accessible equipment or software by private companies are prohibitive, all avenues for funding must be explored and documented. Alternatively, every opportunity to explore task trading and role modification must be explored and documented, with a view towards achieving a successful outcome for all parties. People losing their sight while employed Age related vision loss is now one of the leading causes of vision impairment. Many people who are blind or vision impaired who have lost their sight later in life have noted that the decision to leave the workforce prematurely was made: Out of concern that an employer would not, or could not meet their needs; Because the person was unaware that adjustments could be made to their role and were unaware of where to turn to for support; Due to a fear to disclose; Based on self determination that they would not be able to do the role that they used to do. Many of our older members have noted that they would have stayed in employment had they not lost a significant level of sight. These experiences are consistent with research conducted with people who have acquired a significant hearing impairment later in life.  Labour force activities, barriers and enablers for people with a hearing impairment: the workforce barriers and incentives study, Professor Luke B Connelly, Report No.13, Australian Centre for Economic Research on Health (September 2012) As noted in our employment policy suite: It makes more sense to modify a role to retain a good worker than to replace them with someone who may not have the same skills, knowledge and experience and who will need to be trained from scratch. Losing your sight is one of the most difficult transitions and challenges a person can experience. A common experience among our members is difficulty holding on to employment during this very distressing time. Losing a job at the same time as losing your sight can trap people into poverty and social and financial exclusion that statistics and experience show is very hard to escape again. Recommendation 7 A: Education campaigns in all workplaces which seek to eliminate the stigma associated with acquiring a disability should be implemented. At present, many people fear disclosing their disability to an employer for fear of being made redundant. Recommendation 7 B: A culture needs to be created whereby a review of a persons role should be able to occur when they disclose a disability such as worsening vision for example, in a non-threatening and positive manner. The review of the role should be with a view to maintaining a persons employment, either with the same organisation, or through collaboration with another company or organisation where a position may be able to be created. The review should focus on the capabilities of a person which continue to be of value and which could be applied to another role, or to an entirely new role yet to be created. Recommendation 7 C: Opportunity should be created for a person to develop new skills and abilities while remaining employed. Inherent Role Requirements The phrase inherent requirements of the role, is often used by employers to maintain direction and purpose for a job description. However, having inherent requirements can lead to a restrictive rigidity which can result in discrimination against people with disabilities. For a person who has lost their sight in later life for example, the notion of inherent requirements of a role fails to take into account the skills and knowledge a person has built up often over many years. Rather than exploring what transferable skills a person has, and what skills he or she may possess which could be brought into use in an altered role, the term inherent requirements denies the opportunity for a person to demonstrate their worth to an employer, and the chance for all parties to thoroughly evaluate the situation with the idea of the persons ability to positively contribute at the centre of all considerations. Similarly, for people who are blind or vision impaired attempting to enter the workforce, the notion of inherent requirements can prohibit them from applying for roles, as they may not have had the opportunity to acquire the experience demanded even for entry level roles. Another real possibility at present is that due to inaccessible technology, people who are blind or vision impaired may not be able to perform some specific tasks associated with a rigid role simply because the method of completing those tasks is not accessible. Procurement policies which mandate the purchase of equipment and software which is accessible would go a long way towards solving this problem and should be adopted. However, the practice of trading tasks among staff is a healthy practice nonetheless, and should occur so that people with disabilities do not feel that their chances of being successful in obtaining employment are significantly reduced even before they apply for a job. Recommendation 8: A looser application of inherent requirements is recommended, as greater role flexibility would allow the opportunity for colleagues to trade tasks and cross roles, creating opportunities for all staff members to gain experience. This is now a common practice in therapeutic teams, which often now adopt what is referred to as trans-disciplinary practice, where team members learn from each other and teach each other. This is opposed to multi-disciplinary practice, where people stick rigidly within their respective roles. Closing Comments Blind Citizens Australia welcomes the commitment of the Australian government to explore how the employment of people with disability can be improved and to develop meaningful opportunities for the employment of people who are blind or vision impaired across the public and private sector. Blind Citizens Australia believes that a multifaceted approach is needed to address the current barriers to employment experienced by people who are blind or vision impaired which targets recruiters, employers, disability employment service providers and government as a whole. This includes a tailored marketing campaign to increase awareness of the capacity of people with disability; showcasing businesses that have achieved successful outcomes through the move to a more diverse workforce; targeted approaches for government, including specific measures to address accessibility barriers and capacity building of job seekers to create a competitive workforce. Appendices: Blind Citizens Australia Employment Policy Suite [see:  HYPERLINK "https://wordpress.bca.org.au/employment/" https://wordpress.bca.org.au/employment/]  Research and Measures Team Vision Australia (2012), "Employment Research Survey Report 2012" International and Stakeholder Relations Department, Vision Australia.  Refer to 1.  Eye Research Australia (2004) Clear Insight - The Economic Impact and Cost of Vision Loss in Australia, accessed via  HYPERLINK "http://www.cera.org.au/uploads/CERA_clearinsight_overview.pdf" http://www.cera.org.au/uploads/CERA_clearinsight_overview.pdf     PAGE  PAGE 15 wxzк~kUk@+@U(hhQ[CJOJQJ^JaJmH sH (hU^hQ[CJOJQJ^JaJmH sH +hU^hQ[5CJOJQJ^JaJmH sH %hVf;5CJOJQJ^JaJmH sH %h.F5CJOJQJ^JaJmH sH %h.F5CJ(OJQJ^JaJ(mH sH +hU^hQ[5CJ(OJQJ^JaJ(mH sH +hU^hQ[5CJ OJQJ^JaJ mH sH 4jhU^hQ[5CJ OJQJU^JaJ mH sH (hU^hQ[CJ OJQJ^JaJ mH sH x   2  Z [ v  7 gd[gdQ[9 F G u v w   ǵـiXG2(hU^hQ[CJOJQJ^JaJmH sH h+hQ[OJQJ^JmH sH hU^hIOJQJ^JmH sH ,hU^hQ[0JCJOJQJ^JaJmH sH 7j&hU^hQ[CJOJQJU^JaJmH sH 1jhU^hQ[CJOJQJU^JaJmH sH "hNCJOJQJ^JaJmH sH "h.FCJOJQJ^JaJmH sH (hU^hQ[CJOJQJ^JaJmH sH "hVf;CJOJQJ^JaJmH sH  Y Z [ 7 F r u  ? 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