How have the courts interpreted the duty to accommodate in the context of human rights cases?

The applicant submitted that the substantive component of the duty to accommodate may include modifying job duties, working hours, or even the physical makeup of the workplace itself (Bechard v. Ontario Lottery and Gaming Corporation, 2012 HRTO 1761 at paragraph 25). The applicant submitted that he could have performed the duties of the cleaning position with one modification: the worker who replaced him at the end of the shift would have had to put the garbage bags into the bin. The applicant stated that from a common sense perspective, this minor modification would not have resulted in undue hardship. The applicant submitted that in any event the hospital was not in a position to demonstrate that he could not have been accommodated in the cleaning position because it failed to meet the procedural component of the duty to accommodate.