106 | Zimbabwe Rule of Law Journal In Europe, the European Council Directive aiming to provide a general framework for equal treatment in employment and occupation calls for the reasonable accommodation for PWDs in these terms: “In order to guarantee compliance with the principle of equal treatment in relation to persons with disabilities, reasonable accommodation shall be provided. This means that employers shall take appropriate measures, where needed in a particular case, to enable a person with a disability to have access to, participate in, or advance in employment, or to undergo training, unless such measures would impose a disproportionate burden on the employer. This burden shall not be disproportionate when it is sufficiently remedied by measures existing within the framework of the disability policy of the Member State concerned.”49 The requirement of reasonable accommodation is also part of the South African law under the Promotion of Equality and Prevention of Unfair Discrimination Act,50 which directs all persons and entities to reasonably accommodate PWDs. In addition, the South African Employment Equity Act 55 of 1998 defines ‘reasonable accommodation’ to be “any modification or adjustment to a job or to the working environment that will enable a person from a designated group to have access or to participate or advance in employment”.51 In addition, the recently adopted White Paper on Disability Rights52 also relies on reasonable accommodation to secure the dignity of PWDs. Accordingly, in removing barriers to ensure access and participation for PWDs, amongst others, the White Paper’s Strategy includes the need to focus on reasonable accommodation measures,53 which include adjustments to: • Make the physical environment accessible; • Provide persons with disabilities with access to information and communication; • Redress stress factors in the environment; • Accommodate specific sensory requirements such as those relating to light, noise and spatial stimuli; 49 Council Directive 2000/78/EC, art 5. 50 Act 4 of 2000. 51 Employment Equity Act section 1. 52 The White Paper on The Rights of Persons with Disabilities adopted on 9 December 2015, Government Gazette, No 39792 of 9 March 2016. 53 Ibid, para 6.1.1.6.