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45consideration in analyzing a BFOR. In Meiorin, the Court stated at para. 66: “It may often beuseful as a practical matter to consider separately, first, the procedure, if any, which was adoptedto assess the issue of accommodation and, second, the substantive content of either a moreaccommodating standard which was offered or alternatively the employer’s reasons for notoffering any such standard.” (See also Oak Bay Marina Ltd.v. British Columbia (Human RightsTribunal) (No. 2), 2004 BCHRT 225, at paras. 84-86).[154] In Lane v. ADGA Group Consultant Inc., 2007 HRTO 34, at para. 150, (decision upheld bythe Ontario Superior Court of Justice, Divisional Court, at [2008] O.J. No. 3076, 91 O.R.(3d) 649)the Ontario Human Rights Tribunal held that:2010 CHRT 23 (CanLII)…[T]he failure to meet the procedural dimensions of the duty to accommodate is aform of discrimination. It denies the affected person the benefit of what the lawrequires: a recognition of the obligation not to discriminate and to act in such away as to ensure that discrimination does not take place.[155] In Meiorin, the Supreme Court identified the following question as being relevant inanalyzing the procedural part of the accommodation process followed by the employer:i. Has the employer investigated alternative approaches that do nothave a discriminatory effect, such as individual testing against amore individually sensitive standard?ii. If alternative standards were investigated and found to be capable offulfilling the employer's purpose, why were they not implemented?iii. Is it necessary to have all employees meet the single standard for theemployer to accomplish its legitimate purpose or could standardsreflective of group or individual differences and capabilities beestablished?iv. Is there a way to do the job that is less discriminatory while stillaccomplishing the employer's legitimate purpose?v. Is the standard properly designed to ensure that the desiredqualification is met without placing an undue burden on those towhom the standard applies?