Building Accessible, Inclusive Workplaces for Multiple Chemical Sensitivity (MCS)
Practical, evidence-informed guidance to help employers, HR professionals, and institutional leaders create safer environments and meet accommodation obligations
Everyone deserves a safe place to work.
Accessible Canada Act · 2019
Are You 2040 Ready?
The Accessible Canada Act requires a barrier-free Canada by 2040 — and that includes indoor air accessibility in your workplace.
Under the Accessible Canada Act (2019), federally regulated employers must identify, remove, and prevent accessibility barriers — including environmental barriers affecting people with MCS.
WHO THIS PAGE IS FOR
Designed for Professional and Instituional Settings
Employers & Business Leaders
Human Resources & Occupational Health
Legal & Compliance Advisors
Facilities & Operations Manager
Eduators & Administrators
Union Reps & Labour Relations
Indiviudals with MCS Seeking Accommodation
UNDERSTANDING MCS IN PROFESSIONAL ENVIRONMENTS
MCS in Work and Institutional Settings
Multiple Chemical Sensitivity (MCS) is a chronic condition in which exposure to certain chemicals or volatile organic compounds (VOCs) may trigger significant health reactions. In professional environments, common exposure sources may include:
Fragrances and Personal Care
Perfumes, lotions, laundry products, deodrants
Cleaning agents and disinfectants
Sprays, hand sanitzer, floor cleaners
Building materials & furnishings
Paints, carpets, furnishings, renovation off-gassing
Outdoor Sources
Landscaping chemicals, pesticides, vehicle emissions, poor indoor air quality
In Canada, over 1.13 million individuals report a diagnosis of MCS. Many experience employment-related challenges linked to environmental triggers. Structured accommodation reduces environmental barriers and supports continued participation in professional environments.
Why Scent-Free Policies Work
ASEQ-EHAQ's research with Accessibility Standards Canada tested indoor air quality across 34 Canadian offices — 17 with scent-free policies and 17 without. The results are clear.
Source: ASEQ-EHAQ / Accessibility Standards Canada IAQ Study · N = 48 spaces per group
A Collaborative Approach to Accommodation
Accommodation for MCS is a shared and structured process. Effective implementation requires coordinated participation from employers, professionals, and individuals living with MCS.
Employers are responsible for maintaining accessible professional environments and ensuring compliance with human rights obligations.
- Establish and enforce environmental policies (e.g., scent-free standards)
- Engage in good-faith dialogue with employees requesting accommodation
- Assess environmental triggers within the workplace
- Implement reasonable and proportionate adjustments
- Monitor accommodations and review effectiveness
- Ensure policy awareness and enforcement across the organization
Leadership commitment supports operational stability and inclusive workplace culture.
HR and occupational health teams coordinate accommodation processes and maintain procedural consistency.
- Receive and document accommodation requests
- Facilitate collaborative discussions between parties
- Review documentation where required
- Coordinate with facilities management
- Ensure confidentiality and fairness throughout the process
- Monitor timelines and follow-up
Legal advisors provide guidance on duty-to-accommodate obligations and procedural fairness.
- Interpret applicable human rights legislation
- Assess undue hardship considerations
- Review policy language for compliance
- Provide risk management guidance
- Support dispute resolution where necessary
Facilities and operations teams implement environmental measures that directly affect exposure risk.
- Maintain ventilation and filtration systems
- Oversee material selection and renovation planning
- Monitor indoor air quality practices
- Manage cleaning and maintenance standards using fragrance-free, lowest-emission products
- Implement outdoor environmental controls (smoke-free premises, idling reduction)
In educational and institutional settings, administrators ensure accessible learning and professional environments.
- Implement fragrance-free policies across campuses
- Coordinate environmental standards across departments
- Communicate expectations to staff, students, and visitors
- Facilitate accommodation pathways for affected individuals
Individuals requesting accommodation actively participate in the process.
- Communicate known triggers and sensitivities clearly
- Participate in collaborative discussions in good faith
- Provide relevant documentation where required
- Notify employers of changes in needs
A transparent and respectful process supports both operational stability and individual well-being.
Duty to Accommodate
Under Canadian human rights legislation, employers have a duty to accommodate individuals with disabilities, including Multiple Chemical Sensitivity, to the point of undue hardship. Accommodation must be:
Individualized
Tailored to the specific needs and circumstances of the individual
Evidence-Informed
Based on medical documentation and environmental assessment
Reasonable & Proportionate
Balancing individual needs with operational capacity
Implemented in Good Faith
With active engagement from all parties
The Canadian Human Rights Commission affirms that chemical exposures are recognized accessibility barriers. In 2025, the American Medical Association adopted policy recognizing fragrance sensitivity as a condition that can substantially limit major life activities.
Seven Domains of Effective Accommodation
Scent-Free Policies
Workplace-wide fragrance restrictions with fragrance-free, least-toxic product selection
Indoor Air Quality
Ventilation maintenance, filtration, humidity control, and environmental monitoring
Building Materials
Low-VOC selection, off-gassing mitigation, advance renovation notice
Cleaning & Maintenance
Fragrance-free products, scheduled cleaning well in advance of occupancy
Outdoor Controls
Smoke-free premises, vehicle idling reduction, responsible landscaping
Flexible Work
Remote work, adjusted schedules, temporary relocation, flexible leave
Training & Awareness
Employee education, confidential reporting, structured procedures
Making Scent-Free Policies Work
Research shows that many scent-free policies fail not because of the policy itself, but because of gaps in education, monitoring, and enforcement.
- Scientific background: Definition of VOCs, emission sources, how exposure affects health
- Clear definition of "scent-free": Not just perfume — includes all fragranced products (laundry, personal care, cleaning)
- How to choose scent-free products: Read labels, avoid "fragrance/parfum/aroma," watch for greenwashing
- Scent-free vs. unscented: "Unscented" may still contain masking agents with undisclosed chemicals
- Addressing misconceptions: Scent ≠ clean, no odour ≠ no chemical exposure, nose-blindness is real
Monitoring must be:
- Ongoing — not a one-time event
- Institutionalized within organizational processes
- Multi-modal: Environmental (IAQ spot-checks, sensors) and behavioural (reporting systems)
Reporting systems must be anonymous, accessible, simple (e.g., one-click reporting), and safe — with no retaliation for reporting.
- Clear policy communicated at time of hiring — signed agreement as part of employment contract
- Comparable to no-smoking policy enforcement — same expectations, same consequences
- Advance notice in booking confirmations, phone messages, and email reminders listing specific products to avoid
Accommodation Process: Step by Step
A consistent procedural framework supports fair and effective implementation.
Request Initiated
Individual communicates accommodation needs. Documentation may be requested.
Assessment
Workplace environment assessed for triggers: products, ventilation, materials.
Adjustments Identified
Collaborative discussion to identify proportionate, practical measures.
Implementation
Approved measures implemented. Staff informed. Facilities execute changes.
Monitor & Review
Regular evaluation ensures accommodations remain effective and responsive.
Know Your Jurisdiction
The duty to accommodate is a national principle, but the specific legislation and complaint process varies by province and territory. Use the table below to find the human rights commission or tribunal website for your jurisdiction.
| Jurisdiction | Legislation | Human Rights Body |
|---|---|---|
| 🇨🇦 Federal | Canadian Human Rights Act · Accessible Canada Act (2019) | CHRC Website → |
| British Columbia | BC Human Rights Code | BC HRT → |
| Alberta | Alberta Human Rights Act | AHRC → |
| Saskatchewan | Saskatchewan Human Rights Code | SHRC → |
| Manitoba | The Human Rights Code (Manitoba) | MHRC → |
| Ontario | Ontario Human Rights Code · AODA | OHRC → |
| Québec | Charte des droits et libertés · CNESST | CDPDJ → |
| New Brunswick | New Brunswick Human Rights Act | NBHRC → |
| Nova Scotia | Nova Scotia Human Rights Act | NSHRC → |
| Prince Edward Island | PEI Human Rights Act | PEI HRC → |
| Newfoundland & Labrador | Human Rights Act 2010 | NL HRC → |
| Nunavut | Nunavut Human Rights Act | NHRT → |
| Northwest Territories | NWT Human Rights Act | NWT HRC → |
| Yukon | Yukon Human Rights Act | YHRC → |
Tools & Resources for Implementation
Download the complete set of tools to support accommodation planning, policy development, and employee communication.