Draft CCBFC Policy Position Paper on Accessibility in Buildings

Table of Contents

March 2018 – Canadian Commission on Building and Fire Codes


This paper identifies and examines policy issues related to the access to and use of buildings by people of all ages and abilities. It comes in response to a request from the provinces and territories for input and direction in this area. The goal is to provide clarity to an increasingly fragmented policy area and a possible path forward for provinces, territories and municipalities. The Canadian Commission of Building and Fire Codes (CCBFC) recognizes that setting policy goals is fully within the power of provinces and territories, the policy positions in this paper are discussed in the context of national codes development and in the context of harmonizing common policy goals on accessibility among provinces and territories.

More specifically, this document"s purpose is to bring clarity to the continuum of features that encompass accessibility and set the direction of accessibility requirements in codes developed through the CCBFC. Considering the current definition of the NBC Objective OA Accessibility (see Appendix 3), it is the intent of the CCBFC to determine whether the current scope of the NBC is sufficient for farther reaching goals on accessibility or whether a more inclusive approach is needed.

This paper is divided into two parts.

  1. The first part provides some background, an explanation of some of the key terms and definitions, and an overview of provincial/territorial, federal and international initiatives in this area.
  2. The second part identifies some of the key policy issues and provides some analysis of those issues. For each policy issue that is identified, opportunities and challenges are discussed, and a tentative policy position is suggested for CCBFC discussion – and eventually – CCBFC approval.

As government policies are set and new information and technologies develop, it is expected that this document and the CCBFC"s position may be adjusted to reflect appropriate and relevant policy directions.

Part 1 – Background

What does accessibility mean?

Accessibility, in the general sense, implies much more than building access. The broad objective of accessibility implies the access by every citizen to all aspects of societies such as, education, work and employment, justice, health services, cultural life, recreational leisure and sports.

For the purpose of this paper, the term accessibility encompasses a range of features that improve the comfort or safety of users, including those features associated with accessible design, universal design, visitable design, adaptable design and egressibility.

All accessibility measures aim to enable independent living and full participation in all aspects of life for people of all ages with a range of physical and sensory abilities.

Both accessible design and universal design are broad measures that can be applied to various degrees and various contexts. According to the International Organization for Standardization (ISO), universal design and accessible design are often used interchangeably with the same meaning.

Adaptable design and visitable design, on the other hand, are subsets of accessible design or universal design. They are more targeted approaches to improving accessibility that focus on a specific area of a house or building, or a specific degree of accessibility.

Using the term "barrier free" as a synonym for accessibility would be limiting the discussion to mobility issues and defining it too narrowly to express all aspects of accessibility. Table 1 provides some definitions of commonly used terms (page 7).

The Social Model of Disability

The United Nations Convention on the Rights of Persons with Disabilities (Convention) is the basic international framework addressing the rights of people with disabilities. It aims to promote, protect and ensure the equal enjoyment of all human rights and fundamental freedoms by persons with disabilities.

In 2014, the Convention was signed by 161 countries of 177 Parties and ratified into national law by some 150 countries, making progress towards increasing the broad objective of accessibility as a national obligation.

Notably, Canada has obligations under the Convention, which Canada ratified in 2010 (Appendix 1). All federal, provincial and territorial governments are responsible for ongoing compliance with the Convention within their respective jurisdictions. Canadians are also pursuing change from the bottom up; this is primarily being done through the complaints process of human rights legislation.

A guidance document from the United Nations Human Rights High Commissioners office expresses the impact of the convention as follows:

"The entry into force of the Convention and its Optional Protocol in May 2008 marked the beginning of a new era in the efforts "to promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity" (art. 1). Although, persons with disabilities have always been entitled to the same rights as everyone else, it is the first time that their rights are set out comprehensively in a binding international instrument.

The development of the Convention reflects the shift that has taken place in the way disability and persons with disabilities are seen. Historically, disability has been considered to be a personal condition residing in the individual. As an individual deficit, the status of "being disabled" has been viewed as the natural cause for some people being unable to attend a regular school, get a job or participate in social life. When disability is perceived in this way, society"s responses are restricted to only one of two paths: individuals can be "fixed" through medicine or rehabilitation ("medical approach"); or they can be cared for, through charity or welfare programmes ("charity approach"). According to this old model, the lives of persons with disabilities are handed over to professionals who control such fundamental decisions as where they will go to school, what support they will receive and where they will live.

Over the past few decades, there has been an important change in the way disability is understood. The focus is no longer on what is wrong with the person. Instead, disability is recognized as the consequence of the interaction of the individual with an environment that does not accommodate that individual"s differences and limits or impedes the individual"s participation in society. This approach is referred to as the social model of disability. The Convention on the Rights of Persons with Disabilities endorses this model and takes it forward by explicitly recognizing disability as a human rights issue."

The Convention"s Article 9 then links the social model of disability with the need for accessibility of the physical environment in which we live (see Appendix 2).

Why are we talking about this?

While supplementary guidance to the NBC has been available since 1965, the NBC has had accessibility requirements in the code since 1985. All levels of government are facing pressures to advance in areas of equality and non-discrimination of people with disabilities.

The different policy goals for accessibility are starting to cause significant disharmony amongst the provinces and territories. This is largely because several provinces and territories have started to develop their own programs and policies to improve upon the status quo. Often the terminology and criteria for establishing better-than-code requirements varies by jurisdiction, making it difficult to compare one criterion to the next. This patchwork of programs and lack of consistency across Canada is causing confusion amongst industry, regulators and the general public.

Why now?

The provinces and territories are looking for a viable approach to meet their commitments to remove barriers and ensuring residents have equitable access to opportunities and services. They are looking at measures such accessible design through building codes to address their goals.

Leading up to the most recent edition of the NBC, the CCBFC and its Standing Committee on Use and Egress have done substantial work to harmonize requirements on accessibility and to catch up with public and industry"s requests to clarify these requirements. The CCBFC is aware of the need to continue this work, but has asked for a policy review of accessibility requirements to inform the approval of significant future technical work.

A pre-determined pathway towards a shared goal for accessible design might serve the provinces and territories" needs, for example, to satisfy the intent of the UN Convention. Several policy questions need to be examined, however, before a plan that sets a national direction of accessible design requirements in building codes can be developed.

Terms and Definitions

A logical first step in providing clarity to an increasingly fragmented policy area and in developing a possible path forward for the provinces, territories is coming to a consensus on its associated terms and definitions listed in Table 1 below.

The terms described in the table below are intended to provide a common understanding. The terms listed below are those developed by the ISO, the Canada Mortgage and Housing Corporation (CMHC) and the National Research Council of Canada (NRC).

Table 1: Terms and definitions




Accessible Design


Design focused on diverse users to maximize the number of potential users who can readily use a system in diverse contexts

Note 1: This aim can be achieved by (1) designing systems that are readily usable by most users without any modification, (2) making systems adaptable to different users (by providing adaptable user interfaces) and (3) having standardized interfaces to be compatible with assistive products and assistive technology.

Universal Design

The Center for Universal Design, College of Design, North Carolina State University

Universal design is the design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.

The intent of universal design is to simplify life for everyone by making products, communications, and the built environment more usable by as many people as possible at little or no extra cost. Universal design benefits people of all ages and abilities

Adaptable Design


An adaptable house is one that can easily accommodate change and a variety of family types. It is also designed to be adapted economically at a later date to accommodate someone with a disability. Features include removable cupboards in a kitchen or bathroom to create knee space for someone in a wheelchair, or a knock-out floor panel in a closet to allow installation of an elevator, or a set of stairs designed to accommodate a future stair lift. This approach is also known as FlexHousing™.

Visitable Design


A visitable house includes basic accessibility features that allow most people to visit, even if they use a wheeled mobility device. Three basic features make up a visitable home; they include a level, no-step entry (either ramped or ground level), wider doors throughout the entrance level and a minimum half bathroom (toilet and sink) on the main floor that is accessible to a user in a wheelchair.



A barrier-free building means that the building and its facilities can be approached, entered, and used by persons with physical or sensory disabilities.

EgressibilityFootnote 1


Egressibility means that, in case of an emergency, the occupants have the ability to leave a building or to reach an area of safety. It does not mean that every occupant should egress in the same manner or through the same route; rather, it intends to provide an equal level of life safety for everyone.

What is regulated in the NBC?

The first accessibility requirements were introduced into the building code in 1965 as enabling requirements (See Appendix 3). Today"s requirements – located in Section 3.8 and Subsection 9.5.2 address primarily public areas, such as areas where services are provided, and workplaces.

Between 1995 and 2005, the CCBFC performed a "bottom-up" and a "top-down" analysis that created the rationale to include accessibility as an objective in the NBC, alongside safety, health and protection of buildings.

The objective OA Accessibility is to "limit the probability that, as a result of the design or construction of the building, a person with a physical or sensory limitation will be unacceptably impeded from accessing or using the building or its facilities" (see Appendix 4). The OA objective has two sub-objectives: OA1 Barrier-Free Path of Travel and OA2 Barrier-Free Facilities.

The OA1 Barrier-Free Path of Travel objective is assigned to requirements that ensure persons with disability can access the building and circulate within it. The OA2 Barrier-Free Facilities objective is assigned to requirements that ensure persons with a disability can use the building"s facilities.

This application of the NBC OA objective is however limited and does not apply to:

  • detached houses, semi-detached houses, houses with a secondary suite, duplexes, triplexes, townhouses, row houses and boarding housesFootnote 2,
  • high-hazard industrial occupancies, and
  • temporarily occupied spaces such as automatic telephone exchanges, pump houses and substations

Even in large buildings, the NBC"s accessibility requirements have additional exemptions and do not apply to:

  • service rooms, janitor rooms, crawl spaces, attic or roof spaces,
  • above- and below-ground-level floors not served by an elevatorFootnote 3,
  • apartments and hotel rooms that have not been designated by an authority having jurisdiction to be accessible.

Section 3.8 contains design requirements for the accessible path of travel and specifies minimum dimensions for features such as ramps, clear floor space and doors. It also regulates accessible controls of all types of building systems and specifies the type and location of door hardware, grab bars, faucets and accessible plumbing features. Section 3.8 also contains minimum safety requirements such as the maximum stopping force for doors and a cane-detectable guard when a door opens into the path of travel.

Many accessibility design requirements have been updated in the NBC 2015 and certain parts of the design requirements of CSA B651, "Accessible Design for the Built Environment", are now permitted to be used as an acceptable solution to comply with Section 3.8.3. of the NBC. (See Appendix 5 for more details)


An estimated 3.8 million adult Canadians or 13.7% of the adult population reported being limited in their daily activities due to a disability in 2012. There are several types of disabilities and their prevalence decreases as follows: pain, flexibility, mobility, mental/psychological, dexterity, hearing, seeing, memory, learning, developmental and unknown (StatsCan, 2015).

The proportion of the population with some sort of disability can be expected to increase in the near future as Canada"s population continues to age. Seniors accounted for 14.8% of Canada"s population in 2011 (StatsCan, 2015), and 31% of them reported being limited in their daily activities due to a disability.

The proportion of seniors aged 65 years and over will continue to grow as the large baby-boom (1946 to 1965) cohort reaches 65. It is projected that by the year 2030, almost one in four people in Canada will be a senior citizen (StatsCan, 2014). Since prevalence of disabilities increases as people age, it can be expected that the societal benefits resulting from comprehensive accessible design will increase.

In fact, data from the 2012 Canadian Survey on Disability indicates adult Canadians with disabilities are likely at risk of encountering physical barriers in the built environment due to a lack of specialized architectural features and other accessibility features. This has the potential to impact their ability to move in and out of buildings, within buildings, and use interface items such as buttons in elevators.

In addition, a 2015 national survey canvassing disability and accessibility issues conducted by the Angus Reid Institute, in partnership with the Rick Hansen Foundation, revealed that 79% of Canadians surveyed think their community should be accessible to everyone regardless of physical disability. However, only 28% believed that their community is currently accessible.

Authority for Building Codes

The NBC is an objective-based National Model Code that is developed by the CCBFC and published by the NRC. The NBC helps promote consistency among provincial and territorial building regulations. The CCBFCFootnote 4 is responsible for developing and maintaining the content of National Model Codes.

In Canada, provincial and territorial governments have the authority to enact legislation that regulates building design and construction within their jurisdictions. Their respective legislation may include the adoption of the National Model Codes without change or with modifications to suit local needs.

One of the driving forces behind the creation of National Model Codes was regulatory disharmony amongst the provinces, territories and municipalities. In the early 20th century, building code requirements varied amongst provinces, territories and municipalities. This fragmented approach created a significant regulatory and administrative burden for stakeholders such as tradespeople, regulators and manufacturers.

Through the development of National Model Codes, there is a shared interest amongst the provinces and territories to harmonize building code requirements to the greatest extent possible. In fact, the ultimate goal of coordinating the development of codes in Canada is a greater harmonization in the design, construction and maintenance of buildings for Canadians. Harmonized codes increase productivity by reducing the regulatory burden and removing barriers to internal trade. They also simplify the administration of codes by regulators.

What is happening around us?

Provincial and international initiatives

In response to top-down (UN convention) and bottom-up (public interest) pressures, some provincial governments are creating their own accessibility legislation or related policies. The following are examples of provincial and international initiatives:

  • The Accessibility for Ontarians with Disabilities Act (2005) is a law that sets out a process for developing and enforcing accessibility standards. Implementing and enforcing these standards will help Ontario reach its goal of an accessible Ontario by 2025.
  • Accessibility 2024 is a 10-year action plan that aims to make British Columbia the most progressive province in Canada for people with disabilities by 2024.
  • The Accessibility for Manitobans Act (AMA) became law in December, 2013. Starting in 2016, the act requires Manitoba government and broader public sector organizations to prepare accessibility plans that address the identification, prevention and removal of barriers. The main goal is to prevent barriers from being created in the first place by working on long-range plans to ensure accessibility rather than relying on human rights complaints to remove barriers one at a time.
  • Quebec has plans to enhance the accessibility of the built environment for people who use motorized wheelchairs and scooters and has recently introduced requirements on accessible and adaptable dwelling units. It also plans to adopt regulations to address the accessibility of buildings built before 1976.
  • Quebec adopted the Equals in Every Respect: Because Rights Are Meant to Be Exercised policy in 2009, the aim of which is to increase the social participation of people with disabilities over a ten-year span. Furthermore, Quebec revised the law that addresses the rights of persons with a disability, Act to secure handicapped persons in the exercise of their rights with a view to achieving social, school and workplace integration, in 2004. Some aspects of this law address accessibility.
  • Nova Scotia passed its Accessibility Act, An Act Respecting Accessibility in Nova Scotia, in September 2017, and the Act is now in force. It was designed with elements of the Ontario (AODA) and Manitoba (The Accessibility for Manitobans Act) accessibility legislation.
  • The Americans with Disabilities Act (ADA) became law in 1990. Its purpose is to ensure that people with disabilities have the same rights and opportunities as everyone else.
  • The International Building Code (US ICC IBC) and the Accessible and Usable Buildings and Facilities (ANSI-A117), propose three levels of accessibility for dwelling units, from fully accessible to visitable.
  • UK Housing: optional technical standards (2015). The UK government allows local planning authorities to have the option to set additional technical requirements exceeding the minimum standards required by Building Regulations , This applies to accessibility and water, and an optional nationally described space standard. As stated on their website: Local planning authorities will need to gather evidence to determine whether there is a need for additional standards in their area, and justify setting appropriate policies in their Local Plans.

Federal initiatives

The federal government is working on several initiatives to improve the status quo. One example is the "What does an accessible Canada mean to you?" initiative undertaken by Employment and Social Development Canada to consult on planned new accessibility legislation. Another example is the "Let"s Talk Housing" initiative, which is part of the Canada"s National Housing Strategy 2017. At the federal level, these examples show that there is an appetite to seek input and possibly break new ground. The CCBFC and its stakeholders can feed into this process.

Along with signing on to the UN Convention on the Rights of Persons with Disabilities, Canada has also adopted the 2030 Agenda for Sustainable Development and its 17 Sustainable Development Goals. The 2030 Agenda focuses on five themes: People, Planet, Prosperity, Peace and Partnership. When it comes to People, the UN states that human beings should be able to "fulfill their potential in dignity and equality and in a healthy environment." Specifically, Sustainable Development Goal 11 addresses all five themes through the lens of accessibility:

Sustainable Development Goal 11

Make cities and human settlements inclusive, safe, resilient and sustainable.

By 2030, provide universal access to safe, inclusive and accessible, green and public spaces, in particular for women and children, older persons and persons with disabilities.

Other initiatives

There is growing interest from interest groups, governments and the public to improve the access of houses and buildings, particularly to Part 9 buildings that have traditionally been excluded from accessibility requirements in the NBC. The application, scope and level of these potential accessibility requirements still need to be determined. Removing the application limit from Accessibility objective and applying the requirements to – for example – dwelling units such as detached, semi-detached and townhouses could be seen as similar to an expansion of the objective itself. When a significant change like this is considered, substantial justification may be required. According to the CCBFC Policies and Procedures, any addition or change of objective requires a widely-accepted rationale (see Protocol for Modifying Objectives).

Recently, some provinces and municipalities have taken the initiative to introduce accessibility features into private buildings. For example, the City of Vancouver recently amended its building code to ban door knobs in all new construction, including private homes – a measure with a fairly low cost impact. In other areas, more extensive and higher-cost measures and guidelines have been introduced such as including visitability or adaptability features in the new construction of private buildings. For example, the Saanich Council uses both a mandatory and voluntary approach to encourage the uptake of adaptable housing. In 2003, the Council passed an amendment to the Zoning Bylaw that requires most newly-constructed apartment buildings and seniors' congregate care facilities be built to include Basic Adaptable Housing standards. Building permits issued for apartment buildings with an elevator and common corridor must comply with the regulations. Furthermore, the District of Saanich website states that those applying for rezoning, subdivision and development permit applications are also encouraged to incorporate features from the voluntary design guidelines for apartment buildings, townhouses, and single-family homes (District of Saanich, 2017).

Regardless of the policy instruments that are chosen to do the job, there is growing momentum to make Canada a more inclusive society and increase the opportunities and participation of all Canadians.

Part 2: CCBFC"s Policy Positions

This part will examine possible policy choices for the CCBFC. The desired outcome of this part is that the CCBFC can determine the extent to which the NBC will be involved in creating an accessible built environment for Canadians.

The principles of the Convention are based on the new, "social model" of disability (rather than the older, so called "medical" or "charity models" used in the 70s, when accessibility was introduced in the NBC) and seek to promote, protect and ensure the equal enjoyment of all human rights and fundamental freedoms by persons with disabilities. Article 9 (Accessibility) of the Convention aims to eliminate barriers and obstacles that could prevent people with disabilities from living and participating independently in the community. It applies to buildings, roads, transportation and other indoor and outdoor facilities including schools, housing, medical facilities and workplaces.

Canada is a signatory to the Convention, which means that all federal departments and agencies are expected to consider these principles when implementing policies, programs and services (Appendix 2).

The goal identified in the NBC objective OA Accessibility (see Part 1) is to limit the probability that, as a result of the design or construction of the building, a person with a physical or sensory limitation will be unacceptably impeded from accessing or using the building or its facilities.

What are the gaps between the NBC and the Convention?

In general terms, the NBC"s Accessibility objective appears to be aligned with the intent of the Convention. The limitation to the NBC objectives" application, however, introduces a difference between the NBC and the broader application of the Convention, which applies to the whole built environment, including housing. In contrast, the NBC objective excludes housing.

Furthermore, Division B of the NBC adds additional limits and exempts some areas from accessible design requirements. Some locations, such as crawl spaces and attics, have received full support for their exemptions but others, like storeys not served by elevators, have been questioned or modified/removed by British Columbia, Alberta, Ontario and Nova Scotia.

Does "accessibility" based on the social model of disability still fall within the minimum acceptable scope for the NBC?

The challenge for government is to ensure that the regulations and other policy instruments it uses to achieve its goals are both effective and efficient. Effective in the sense that they resolve the problem they were introduced to address and efficient in the sense that they minimize direct compliance costs borne by those subject to the regulation and indirect costs imposed on the public.

Since the inception of National Model Codes in 1941, the CCBFC and its predecessors have ensured that the code"s development process and its requirements meet their intended objectives efficiently and effectively. In 2005, the CCBFC published the first objective-based codes and explicitly defined the objective of each requirement. By definition, this means that NBC requirements (in Division B) are considered the minimum acceptable measures required to achieve the objectives (in Division A).

In this context, current NBC requirements associated with the Accessibility objective are by default considered a minimum acceptable level. "Minimum" in this context may mean that:

  • accessibility requirements only apply to buildings or building areas where they are considered most necessary (i.e. diverse set of users);
  • only a portion of occupants with disabilities are addressed and the requirements are primarily based on dimensions for people who use manual wheelchairs; or
  • buildings constructed in compliance with the NBC leave persons with disabilities with fewer choices with respect to suitable living spaces.

What is the societal expectation in terms of regulating accessibility?

One of the fundamental and most challenging questions is how an acceptable (minimum) level of accessibility should be defined in the future and evaluated by the CCBFC standing committees. And whether this level should address the needs of all building occupants or only the needs of a majority of users while other policy instruments (incentives, subsidy programs) could serve the remaining minority of users that need to further customize their living and work spaces.

The concept of only addressing the "minimum acceptable" also bears the questions whether the minimum level of accessibility is set by societal expectations or simply by a cost-benefit analysis performed by a committee. In the former case, it seems that Canada and the provinces and territories – by ratifying the Convention – have set the minimum acceptable level. In the latter case the question becomes how committees can evaluate the benefit of greater dignity.

Regulating how buildings are designed and constructed for accessibility and to which buildings the requirements apply has an impact on housing affordability. Affordability affects ownership and owner"s choices.

What should the future role of the model national codes be?

Recently, some provinces and territories have expressed a desire to take more progressive action on accessibility and are using building codes as their policy instrument of choice. For example, Ontario, British Columbia, Quebec and Alberta have developed more comprehensive accessibility requirements in their codes that meet the needs of a broader range of people with disabilities while Manitoba, Nova Scotia, New Brunswick and Newfoundland-Labrador have developed their own comprehensive accessibility requirements for selected design elements.

Other jurisdictions, such as Ontario, the United States, Australia, have recognized that minimum provisions should not be limited to accommodate a person using a typical manual wheelchair or other manual mobility devices such as walking aids, canes, crutches, braces and artificial limbs. They considered other types of wheeled mobility devices such as power wheelchairs and scooters. They are considering new anthropometric data of mobility device users to better accommodate a larger portion of the population. In Ontario, for example, the building code requirements now reflect larger dimensions to accommodate the wider range of mobility devices and larger people.

Policy Considerations: The CCBFC will provide direction to its standing committees on the development of the modular approach and in setting new acceptable minimum requirements for accessibility, adaptability, egressibility and visitability. The CCBFC will develop supporting guidance on creating transparent and clear information on the impact of possible approaches. The CCBFC should consider the latest anthropometricFootnote 5 data and the importance of accessible housing when deciding on new accessibility requirements to accommodate a diverse set of users.

Changing the notion underlying the development of the National Codes

The CCBFC recently agreed to shift model energy code requirements into a more progressive role of setting the pathway rather than following the industry. In the case of energy efficiency this is being achieved through the development of a stepped approach – that is, a series of pre-determined steps at increasingly ambitious performance levels that lead to an ultimate performance goal. This is a significant departure from the traditional role of building codes.

More progressive accessibility codes could help accommodate Canada"s aging population, likely leading to reduced health care costs as seniors are enabled to age in place. However, in the discussion about housing prices in recent months, there have also been counter arguments that governments may be overly accommodating to the boomer generation at the expense of millennials who are struggling to get established. The CCBFC may therefore wish to be seen as serving all population groups equally by building codes that take a cradle-to-grave, able-bodied to infirm approach with all the variants in between addressed.

While it would be possible for the CCBFC to make a minimum standard more progressive, setting the requirements high might create a difficulty in "backing down". Providing various levels of code options for accessibility, however, would certainly offer more flexibility to jurisdictions in accomplishing their individual policy goals.

Structure in the form of sound technical standards, tiers or modules would help governments to create good policy. It informs them of what is technically possible. Most, if not all, provinces and territories look favourably on a national framework on accessibility to preserve scarce resources and avoid a patchwork approach to accessibility across the country.

A variety of accessibility modules, ranging from the status quo to more ambitious requirements, would provide more options to owners, builders and policy makers. Of course, there would need to be a certain degree of congruence between the national status quo and the modules to ensure that design conflicts are avoided.

With the advice of the provinces and territories, the CCBFC has to decide whether it should move toward more ambitious requirements.

Policy Consideration: The CCBFC supports persons with disabilities and accepts Canada"s obligations as a State Party to the Convention and the aspirational goals of the UN convention. The CCBFC recognizes that the objectives of the NBC – to a great extent – already align with the objectives of the UN Convention. The CCBFC appreciates the difficulties and challenges in implementing further steps of these aspirational goals within the scope and context of the documents controlled by the CCBFC.

Possible Implementation Steps:

The CCBFC will work within its framework to achieve progress in the foreseeable future on making code requirements and objectives more inclusive and will continue to study the best way of achieving the aspirational goals of the UN Convention. The CCBFC will work on new approaches to maximize the potential of a consistent approach across Canada and learn from the experiences made in Canadian jurisdictions, which have already implemented more accessible building standards.

Should there be an interim or long-term policy goal for accessibility in Canada?

If more progressive codes are the answer and the national model codes development continues to include requirements for accessibility, the question becomes whether there is an overall goal that Canadians want to reach in terms of the accessibility of their physical environment.

The Convention presents a possible aspirational goal since its aim is to enable people with disabilities to live independently and participate fully in all aspects of life, which means ensuring people with disabilities have access – on an equal basis with others – to the physical environment. The Convention does not however define this access in a lot of detail.

"What we learned from Canadians"

The federal government, through Employment and Social Development Canada"s (ESDC) Office for Disability Issues, conducted a national consultation called "What does an accessible Canada mean to me?" from September 2016 to February 2017. ESDC"s goal is to create a best practice for accessibility of buildings and the built environment for federal departments and agencies. Results from the national survey were published in a report titled Creating new federal accessibility legislation: What we learned from Canadians (Employment and Social Development Canada, May, 2017). The report summarizes the results of the survey and concludes that there is emerging consensus about what the new legislation should look like and the role of the Government of Canada. Specifically, the report specifies that:

  • new federal accessibility legislation should include detailed policies for organizations on how to improve accessibility;
  • the Government of Canada should be a leader, both in practice and in supporting organizations to be successful; and
  • the Government of Canada should set ambitious goals with clear and measurable targets.

Survey participants reported that the built environment (e.g. buildings, recreational facilities, washrooms, physical surroundings) is the second highest priority area with respect to improving accessibility (second to employment). Regarding building codes and standards, survey participants shared concerns that accessibility requirements are only minimum requirements and that even these are not always being met. In particular, the report stated the following:

There was discussion on whether the Government of Canada should try to improve existing building codes or try to push builders to go beyond the minimum requirements with a program that recognizes builders who exceed them (Employment and Social Development Canada, May, 2017, pg. 18).

Input from provinces and territories

There is provincial and territorial interest to develop a long-term strategy for accessible buildings and dwelling units. A long-term strategy would provide an approach for the provinces and territories that would ultimately present a harmonized solution across Canada. This would likely be an improvement over the current disharmonious situation of "better than code" policies and programs, which can be difficult for industry, regulators and the public to navigate. Many members of Canada"s construction community have urged for more consistent requirements across the country. A single overarching ultimate goal has, however, not been identified by the provincial/territorial jurisdictions.

Beyond Canada

Many other countries are changing their accessibility requirements too. For example, the UK has implemented a design standard containing three progressive levels of accessibility for dwellings – visitable dwellings, accessible and adaptable dwellings, and wheelchair-user dwellings. The UK documents highlight the objective of the regulation to provide reasonable provision within the plot boundary for access.

What could a long-term goal look like and what needs to be considered?

Progress on accessibility may benefit from a Pan-Canadian approach that unifies the provinces and territories through a national strategy, similar to the Pan-Canadian Framework on Clean Growth and Climate Change. In particular, specific goals that align with the principles of the Convention would help set priorities and position the use of regulation amongst other policy tools.

In the absence of specific national or international goals to lean on, any potential long-term goal for Canada could mean applying the accessibility requirements to more buildings or to develop requirements that include a wider group of individuals. This might involve some or all of these four distinct targets:

  1. Enable access for more disabled persons to more locations in new buildings;
  2. Expand the scope of the OA objective and agree on accessibility levels for dwelling units;
  3. Include accessibility in the strategy for alteration on existing buildings; or
  4. Review, evaluate and adjust requirements on egressibility.

Setting an ultimate goal for accessible design and construction would require an early introduction to provide manufacturers, builders and suppliers with market opportunities and time to prepare for future code requirements, enabling a smooth transition to increased requirements.

Any future goals should comply with Canada"s Smart Regulation principles, which require that regulation is supported by evidence, reflecting the latest knowledge, and that such goals are based on clear performance targets that provide design flexibility while serving the public interest. Setting a clear goal, and making sure that the way to achieve it satisfies smart regulation principles, would help to ensure that any potential regulation is an efficient use of limited resources. It would also help standing committees to develop the respective design and construction requirements – regardless of how many steps may be necessary to reach the goal.

There is a need to make progress on accessibility within the National Codes. The CCBFC would like to work together with the provinces and territories to develop a modular approach in a timely manner. There is a risk that the provinces and territories will create their own paths to achieve their own targets if progress takes too long. This could jeopardize the ultimate goal of National Codes – namely harmonized requirements across the Canada.

Policy Consideration: The CCBFC accepts the aspirational goals identified in the convention as its long-term policy goals and will continue to move towards reaching these goals.

Possible Implementation Steps: The CCBFC is already engaged in creating requirements for the alteration of existing buildings and will continuously expand the access for and safety of disabled persons in buildings where it is demonstrated that regulation is the most effective way to do so. The CCBFC will partner with the federal, provincial and territorial governments and other organizations to quantify the associated costs and to overcome barriers in implementing accessibility.

Is the regulatory approach still effective in delivering on policy goals related to accessibility?

Regulatory approach

Regulation is often used when there is a need to take quick and effective action on a policy matter. Voluntary transformation through incentives and other non-regulatory measures is not always suitable when decisive and broad scale policy action is required.

Regulation, however, has some significant costs on society. For example, the compliance and enforcement aspect of regulation consumes considerable public resources. In a time where there are many competing demands on those resources, it is essential that the need for regulation is well justified. For this reason, regulation is generally only used when it has been determined that the market is not effectively addressing a need and that this need has a high cost on society. This is often referred to as a market failure.

While regulation can be an effective way of ensuring that market failures are addressed, it should be applied carefully to ensure an efficient use of public resources. Other policy instruments might be better suited, particularly in situations that require a more targeted approach for a specific context.

For buildings, the burden of compliance with more ambitious requirements than those in the 2015 NBC (design drawings, permits, inspections) may be considered relatively low because the current compliance process uses the same steps (for the designer) and the same infrastructure for enforcement (design review).

In the case of accessibility for housing, the case is quite different and would involve a completely new area of expertise (for builders) to design and (for building officials) to enforce the resulting construction through inspections.

Outside of building codes, there are a variety of other policy instruments that can be used to advance innovation, education and implementation of accessible design in both public buildings and dwelling units. (See Appendix 6 for more details on non-regulatory policy instruments.)

Flexibility as to where mandatory requirements apply

It is necessary to examine if other policy instruments or a combination of them can achieve the policy goal for the most difficult-to-implement accessibility measures – for example, a no-step entrance in housing or an elevator in all buildings. If regulation is determined to be the best way to achieve the policy goal, it needs to be examined if the requirements can be relaxed somewhat or if design flexibility can be provided. For example, the current NBC requirements for buildings requires only 50% of the pedestrian entrances of a building to be barrier-free and don"t require any at all in high-hazard industrial occupancies.

When it comes to accessible housing, the UK Government also provides flexibility as to where the requirements of its visitability regulations have to be applied and where not. In its 2010 Building Regulations, Section M4(1), it states: "Where it is not possible to achieve step-free access to any private entrance (as may occur on a steeply sloping plot) a stepped approach is acceptable…. "

If high-cost accessibility design requirements (i.e. elevators in all buildings or visitable housing) were to be introduced in the NBC, their application could offer similar flexibility.

Should the NBC requirements be limited to the technical rules or should it also state the application for the requirements?

The 2015 NBC Section 3.8. was re-organized to separate the application (which buildings or areas in buildings are required to be accessible) from the technical rules (how to build and design accessible buildings). Subsection 3.8.2. now contains information on where the requirements apply and Subsection 3.8.3. contains all design requirements including a new option of complying with CSA-B651, "Accessible Design for the Built Environment." These changes had very little or no cost impact over the NBC 2010 requirements.

The question whether the role of a national model code should deal with the technical rules only or whether it should also address the application has been discussed for many years among the CCBFC and the provinces/territories. If only technical rules were addressed, the NBC would effectively duplicate the CSA standard.

Policy Considerations: The CCBFC believes that there is a strong justification for regulating accessibility requirements in the National Building Code.

Possible Implementation Steps: The CCBFC will resolve with the provinces and territories whether the NBC"s role should be limited to focus on the technical rules or whether the NBC should also state the application for the requirements.

Are there other considerations regarding effective regulation?

Disability is individual

Disability affects people"s lives to different degrees and in different ways. A one-size fits all solution for accessibility is not possible because an individual"s specific disability will determine how that individual interacts with the environment. In other words, building code requirements that accommodate a person who uses a wheelchair will not necessarily benefit someone who is blind or deaf. It may even lead to conflicting requirements, for example where tactile markings for visually impaired impede the movement of those with mobility issues.

For this reason, the current notion for requirements in the building code has been to target the most cost-effective measures and apply the requirements where they would have the biggest impact on the broadest range of users. This may question how effective a regulatory solution for accessibility can be.


When addressing any policy issue, it is common practice to go after the easy wins or the "low hanging fruit" first. These are often measures that can have a broad impact at no or relatively low costs, and are relatively easy to implement. The ideal combination is when the measures have a low cost and a large beneficial impact.

Many low- or no-cost universal design features have already been included in the 2015 NBC. Recently, for example, there have been changes to accessible controls of all types of building systems and the location of door hardware or grab bars. The high-cost measures, on the other hand, need to be carefully examined; elevators, allowances for larger spaces that better reflect today"s anthropometric reality, independent means of evacuation, or implementing accessibility measures in existing buildings are all considered high-cost measures for buildings.

Regulating accessibility features in housing, such as requiring lever door handles might be acceptable because it is a cost-effective feature that benefits a broad range of users (e.g. children, the elderly, and people with disabilities). A no-step entrance for houses, on the other hand, could have a more significant cost impact and would generally preferentially benefit people who use wheeled mobility devices or have a mobility impairment. Users with other types of disabilities would not necessarily benefit from this feature. As well, a no-step entrance may have negative consequences to the building design that need to be carefully weighed. These consequences could include water ingress and changes to the construction of foundation walls.

It could be argued that Canadian society has already agreed that accessibility requirements should be regulated (when accessibility was included into the NBC). The current NBC requirements would therefore establish the cost that society is willing to pay for providing this dignity to everyone. Proposed future requirements could then be compared to that accepted value.

How to measure the benefits?

"Cost effectiveness" implies that the benefit outweighs the cost or at least matches it. While all proposed changes to the NBC are required to undergo a cost-benefit analysis before they are implemented, the cost-benefit of accessible features can be difficult to measure.

The avoided cost of future adaptation is a benefit that it is relatively easy to measure compared to other aspects (e.g. improved dignity). Studies show that adapting existing buildings to make them accessible is much more costly for individuals and the public than built-in accessibility.

Accessibility requirements should also be assessed based on a model that evaluates the benefit of improved dignity, which may be difficult to quantify. How should the benefits of providing access to buildings and housing for a larger percentile of the population be quantified – by a group of people who would otherwise not be able to access the building at all? It isn"t a question of indirect benefits such as reduced health care and institutional care costs, not even a question of increased productivity. It becomes a question of quantifying equality, unassisted living and ultimately human rights.

Measures, such as disability adjusted life years (DALY) and quality adjusted life years (QALY), which are often cited for impact assessment of public health measures may fall short here because accessibility measures are changes to the built environment and not individual medical interventions.

There are some attempts at quantifying equal access to buildings. For example, most recently, the report Projecting the Economic Impacts of Increased Accessibility in Ontario, which was written in support of the implementation of the Accessibility for Ontarians with Disabilities Act (AODA). It conducts a macro-economic analysis and compares the cost of building accessible buildings and housing to savings through decreased poverty levels among people with disabilities, reduced expenses for caregivers, and the benefit of reducing under-education and general economic exclusion of people with disabilities – all of which close the income gap and increase the GDP. A part of this increase in the GDP was attributed to the advantage that accessibility features offer the broader community (aging population, people pushing strollers, etc.).

Limitations of building codes

Every regulation has its limits. People generally don"t work, sleep and socialize in the same building and they travel between these social functions. A system is only as good as its weakest link. Any regulatory measure in the building code would need to be supported by equal measures in other areas of the built environment such as roads and public transportation in order to create true independent living for all Canadians.

One such limitation is that the current accessibility regulations affecting buildings only apply to new construction. There are thousands of inaccessible buildings that were built before building code regulations were put into place. Once an existing building undergoes an alteration, a minimum level of accessibility features could be required. In some cases it would be impossible to reach even the current level of NBC 2015 requirements.

This limitation is being discussed by the Joint Task Group on Alterations to Existing Buildings and is addressed to some degree in its draft Report on Alterations to Existing Buildings. The application and degree to which accessibility features could be required during an alteration will be determined by the technical Standing Committees in accordance with triggers and principles outlined in the draft JTG AEB report.

Industry Capacity

One criterion for choosing regulation is assessing whether the group that has to comply with the requirements is adequately trained and equipped with adequate knowledge and resources.

While the "large" buildings industry seems adequately prepared for more ambitious accessibility requirements, it needs to be recognized that the home building industry may currently not have the capacity and knowledge to achieve more ambitious goals in accessible design. More knowledge and experience with accessible technologies, related innovative building practices and regulatory experience may be required to support more progressive accessibility requirements for homes.

In the housing industry, the missing capacity could be provided through demonstration projects, incentive programs and voluntary standards not unlike those that supported the industry in learning how to build energy-efficient housing.

Depending on the extent of potential new building code requirements, the provinces and territories may need to offer more training and education before they adopt new accessibility requirements. The NRC and the CCBFC could provide this support by more effectively disseminating the information gathered during the code development process. For example, guidance on each of the accessibility modules would benefit the entire construction industry with information that is consistent with current or potential future code requirements in their respective jurisdiction.

NRC could collaborate with the provinces and territories and other industry and government stakeholders (e.g. Canadian Home Builders" Association, Office of Disability Issues (ESDC), Canada Mortgage and Housing Corporation) to build broad industry capacity on accessible construction and support the ability of industry and regulators to design, construct and enforce more accessible buildings and houses. This could also be achieved by providing "how to" guides on design and construction of accessible spaces. This kind of support will increase the likelihood that the provinces and territories will be "ready and able" to adopt new targets in accessible design. For example In Quebec, there are plans to update the current guide to reflect the changes introduced in the NBC 2015 and to include the new requirements on accessibility features for dwelling units.

Building design in conflict with accessibility

Building features can sometimes be in conflict with accessibility requirements. For example, buildings in the North are designed to stand off the ground. Heritage buildings often have stone entrance steps that go directly on to a narrow sidewalk.

For this reason, the accessibility requirements have to be administered with flexibility as to where the requirements apply and where exemptions are given. Many jurisdictions already apply such exemptions to existing buildings and in northern communities.

Policy Considerations: The CCBFC contributes to harmonization and regulations that provide better accessibility to buildings by persons with disabilities.

Possible Implementation Steps: The CCBFC will work with the provinces and territories and PTPACC to achieve this goal while recognizing that there has to be some flexibility for exemptions, such as for the North or heritage buildings. The CCBFC will continue to develop a credible impact analysis method to fairly describe the benefits for future accessibility changes. The CCBFC recognizes that accessibility and visitability are relatively new concepts for the housing industry and will work with its partners and the industry to transfer knowledge and expertise on accessibility.

Is a "modular" approach more effective at enabling harmonized accessibility requirements than a "tiered" approach?

A modular approach would see different aspects of building accessibility addressed in stand-alone sections or subsections or even in separate documents. The modules could be called up in provincial or territorial codes by adapting the application of the respective accessibility regulations when so desired.

A tiered approach would see different editions of the entire collections of acceptable solutions (such as NBC Section 3.8.). Each edition would address a different level of performance or a different extent of the requirements, such as more building types addressed, more disabilities addressed (see the four target areas on page 15).

With any approach, it is important to assess the administrative and legislative burden introduced by multiple codes or levels of performance. Since a tiered approach is already being considered for energy efficiency, any lessons learned on that subject could be applied to this subject.

The question is whether a pre-determined, tiered pathway towards improved accessibility is a suitable approach for building codes or whether a modular approach would be easier to manage for the jurisdictions.


In a regulatory environment on accessibility that is already quite fragmented it is fair to question whether a modular approach would make any progress in the move towards harmonization.

If harmonization means progressively fewer variations between provinces and territories and the National Codes, the main contribution of modules would be that they allow flexibility for each jurisdiction to adopt the technical areas (modules) they prefer and to select the timing of adoption into regulation. Any province, territory or municipality deciding to adopt the same module would then at least use the same set of solutions.

A modular approach, rather than tiers, is seen as the most appropriate approach for accessibility given the diversity of options that it covers. Whereas energy requirements are well-suited for a linear, progressive approach (one variable, one target), accessibility is better-suited for a modular approach with a menu of options (several variables, several targets).

Recognizing the fragmented situation on accessibility requirements across the country, the modular approach may reduce the competition between the provinces and territories. In contrast, a tiered approach could be seen as inviting competition to the final goal (highest tier).

The mandate of CCBFC and NRC is to harmonize national codes and provincial/territorial codes as much as possible. It will likely never be completely accomplished, but in a very fragmented technical area, modules likely offer the best chance of progress on the harmonization front for a moderate effort on the sides of CCBFC and NRC. The key challenge will be to select the modules and to structure them so that they are relevant to most if not all jurisdictions and that they address or fulfill the policy goals of most if not all jurisdictions.

Policy Considerations: The CCBFC believes that modules, rather than tiers, offer the most effective approach to enabling harmonized accessibility requirements. The CCBFC is committed to the harmonization of building code requirements across Canada and will work with the provinces and territories and PTPACC to create effective requirements that are relevant to most, if not all, jurisdictions and to assist the jurisdictions in fulfilling their respective policy goals.

Possible Implementation Steps:

In the short term, the CCBFC will develop harmonized technical modules to be included in the NBC. This will enable the provinces and territories to move forward on accessibility in a more harmonized and consistent manner. The provinces and territories can choose to opt into the modules that make the most sense for them. The CCBFC will coordinate the development of each module with other parts of the code and with the development of other modules. In the long term, the CCBFC will update and manage the maintenance of the technical modules as experience in accessible building design grows and lessons are learned.


Appendix 1 – UN Convention on the Rights of Persons with Disabilities – General Information

Canada ratified the United Nations Convention on the Rights of Persons with Disabilities (Convention) on March 11, 2010. The Convention is an international human rights treaty aimed at promoting, protecting and ensuring the equal enjoyment of all human rights and fundamental freedoms by persons with disabilities.

The Convention sets out objectives for member countries under close to 30 specific Articles, dealing with virtually every aspect of life, including education, employment, standard of living, access to health care, access to information and many others. Many of the most significant areas covered are largely within provincial/territorial jurisdiction.

Canada"s Convention obligations are implemented through a legal framework at all orders of government, including:

  • The Canadian Charter of Rights and Freedoms, which applies to the actions of all governments and guarantees all individuals a wide range of human rights and fundamental freedoms, including an explicit equality rights guarantee for persons with disabilities.
  • Federal, provincial and territorial human rights laws, which apply to the public and private sectors and prohibit discrimination on grounds such as disability, in regard to employment, the provision of goods, services and facilities customarily available to the public and accommodation.
  • Specific federal, provincial and territorial laws governing areas that impact persons with disabilities, for example, social benefits programs, disability insurance plans, accessibility, housing programs, etc.

Provincial and territorial governments are responsible for implementation of the Convention in their own jurisdictions. They also have measures in place specifically aimed at improving accessibility and providing financial and other supports to persons with disabilities in order to reduce barriers and promote their full participation in Canadian society.

The Government of Canada recognizes the need to continue efforts towards building an inclusive society for all. All federal departments and agencies are expected to include disability considerations and to ensure they are in compliance with the Convention as they renew or develop policies, programs and services.

The Government of Canada is committed to working toward ongoing compliance with the Convention over time. Canada recently (April 3 and 4, 2017) appeared before the UN Committee on the Rights of Persons with Disabilities where the Committee expressed significant interest in the planned federal accessibility legislation as well as in housing issues.

Appendix 2 – UN Convention on the Rights of Persons with Disabilities – Article 9

Article 9 – Accessibility

  1. To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas. These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:
    1. Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces;
    2. Information, communications and other services, including electronic services and emergency services.
  2. States Parties shall also take appropriate measures to
    1. Develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public;
    2. Ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities;
    3. Provide training for stakeholders on accessibility issues facing persons with disabilities;
    4. Provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms;
    5. Provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public;
    6. Promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information;
    7. Promote access for persons with disabilities to new information and communications technologies and systems, including the Internet;
    8. Promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.

Appendix 3 – History of Building Accessibility in the NBC

NBC Edition and Approach Illustrations of Accessible Floor areas

Prior to 1965

  • How: no requirement
  • Where: no requirement
"Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  No sections are shaded

NBC 1965

  • How: Supplement design standard
  • Where: optional
"Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  No sections are shaded

NBC 1970

  • How: Supplement design standard
  • Where: as dictated by AHJs
Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  All sections are line-filled in blue

NBC 1975 and 1977

  • How: Supplement design standard
  • Where: public areas on the main floor up to one elevator (exclude apartment and office buildings)
"Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  Main floor section marked 'Bar' is shaded green

NBC 1980

  • How: Supplement design standard
  • Where: public areas on the main floor up to one elevator (exclude apartment buildings)
Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  Main floor sections marked 'Bar' and 'Office' are shaded green

NBC 1985 and 1990

  • How: design standard in the NBC
  • Where: main floor and on floors served by elevators (the application within suites is vague)
Drawing of occupancies  in two floors of a building (Bar, Office, Apartment on each floor).  Main floor section marked 'Bar' is shaded green, and 'Office', and 'Apartment' are line-filled in green

NBC 1985 and 1990

  • How: design standard in the NBC
  • Where: main floor and on floors served by elevators (the application within suites is vague)
Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  On both floors, sections marked 'Bar' are shaded green, and 'Office', and 'Apartment' are line-filled in green

NBC 1995 to 2010

  • How: design standard in the NBC
  • Where: main floor and on floors served by elevators (except within hotel suites and apartments not designated by the AHJs)
Drawing of occupancies in two floors of a building (Bar, Office, Apartment on each floor).  On both floors, sections marked 'Bar' and 'Office' are shaded green, and 'Apartment' is line-filled in blue

Appendix 4 – Accessibility Objective & limitations

Division A – Part 2 Objectives Application of Objectives

(See Note A-

  1. Objective OA, Accessibility (including Objectives OA1, Barrier-Free Path of Travel, and OA2, Barrier-Free Facilities), does not apply to
    1. detached houses, semi-detached houses, houses with a secondary suite, duplexes, triplexes, townhouses, row houses and boarding houses (see Note A-, Secondary Suite),
    2. buildings of Group F, Division 1 major occupancy, and
    3. buildings that are not intended to be occupied on a daily or full-time basis, including automatic telephone exchanges, pumphouses and substations. Objectives

1) The objectives of this Code are as follows (see Note A-

An objective of this Code is to limit the probability that, as a result of the design or construction of the building, a person with a physical or sensory limitation will be unacceptably impeded from accessing or using the building or its facilities (see Sentence for application limitations).
Barrier-Free Path of Travel
An objective of this Code is to limit the probability that, as a result of the design or construction of the building, a person with a physical or sensory limitation will be unacceptably impeded from accessing the building or circulating within it (see Sentence for application limitations).
Barrier-Free Facilities
An objective of this Code is to limit the probability that, as a result of the design or construction of the building, a person with a physical or sensory limitation will be unacceptably impeded from using the building's facilities (see Sentence for application limitations).

Appendix 5 – CSA B651 and the NBC

Section of CSA-B651 referred to in the NBC

Table – Barrier-free Design Provisions

NBC Barrier-free Application (Code References)

Applicable CSA B651 Provisions

Interior accessible routes (

4.3 and 5.1

Exterior accessible routes (

8.2.1 to 8.2.5 and 8.2.7

Passenger pickup areas (


Ramps (

5.3 and 5.5

Doors and doorways (


Passenger-elevating devices (


Operating controls (


Signage (

4.5 and 9.4

Drinking fountains (


Washroom facilities ( to

6.2 and 6.3

Bathing facilities ( and


Communication ( and


Counters ( and


Spaces in seating areas (


Table of contents of CSA-B651

  • Preface
    • 1 Scope
    • 1.1 Purpose
    • 1.2 Application
    • 1.3 Dimensions
    • 1.4 Commentary and figures
    • 1.5 Annexes
    • 1.6 Terminology
    • 1.7 Large print
  • 2 Reference publications
  • 3 Definitions
  • 4 General requirements
    • 4.1 Area allowances
    • 4.2 Operating controls
    • 4.3 Floor or ground surfaces
    • 4.5 Signage
  • 5 Interior circulation
    • 5.1 Accessible routes
    • 5.2 Doors and doorways
    • 5.3 Handrails
    • 5.4 Stairs
    • 5.5 Ramps
    • 5.6 Elevating devices
    • 5.7 Emergency and security
  • 6 Interior facilities
    • 6.1 Drinking fountains
    • 6.2 Washroom facilities
    • 6.3 Universal washrooms
    • 6.4 Change benches
    • 6.5 Bathing facilities
    • 6.6 Communications
    • 6.7 Seating
  • 7 Residential accommodation — Permanent and short-term
    • 7.1 Scope
    • 7.2 Design requirements
    • 7.3 Visitable dwelling units
    • 7.4 Accessible dwelling units
  • 8 Exterior circulation, spaces, and amenities
    • 8.1 Scope
    • 8.2 Accessible routes
    • 8.3 Pedestrian crossings
    • 8.4 Intersection design
    • 8.5 Transit stops
    • 8.6 Urban furniture and equipment
    • 8.7 Landscaping elements
    • 8.8 Temporary facilities
  • 9 Vehicular access
    • 9.1 Scope
    • 9.2 Pedestrian routes
    • 9.3 Passenger pick-up areas
    • 9.4 Signage for designated parking
    • 9.5 Designated parking
    • 9.6 Ticketing dispensers or paying machines

Appendix 6 – Summary of Non-Regulatory Policy Instruments

Voluntary Incentive Programs and Demonstration Projects

Voluntary incentive programs and initiatives may serve to encourage leadership and innovation. Demonstration initiatives (pilot projects) and voluntary standards may be used to encourage next generation technology and construction practices.

Another important role of pilot demonstration projects and voluntary incentive programs is to provide the opportunity to test new designs, technologies and building practices, and learn from mistakes before they are implemented in building codes as mandatory requirements.

However, voluntary initiatives on accessibility have a history of very little up-take which could become a concern.

Financial Initiatives – Buildings

The Government of Canada"s Enabling Accessibility Fund (EAF) provides funding for projects in Canadian communities and workplaces to help improve accessibility. Since the creation of the EAF, the Government of Canada has funded over 2,300 projects, helping thousands of Canadians gain access to their communities" programs, services and workplaces. The program has an annual budget of $15 million. The federal budget in 2016 committed to providing an additional $4 million over two years, starting in 2016-17. The EAF is administered by Employment and Social Development Canada. The EAF deals with workplaces and community assets, including motor-vehicles, but not with housing.

This two-pronged approach, using codes to set the minimum acceptable requirements and financial incentives to encourage leadership and innovation to create better practice, has generally worked well. With the help of government-sponsored incentive programs, many of the innovative building products and practices used in next generation buildings have now become cost-effective and commonplace.

Financial Initiatives – Homes

As of 2016, the federal government offers a Home Accessibility Tax Credit (HATC). Canadians can claim a non-refundable tax credit for a renovation or alteration that is of an enduring nature and is integral to the eligible dwelling (including the land that forms part of the eligible dwelling).

The renovation must:

  • allow the qualifying individual to gain access to, or to be mobile or functional within, the dwelling, or
  • reduce the risk of harm to the qualifying individual within the dwelling or in gaining access to the dwelling.

Zoning requirements (bylaws)

Municipalities can use zoning requirements to mandate a certain percentage of accessible housing to be constructed in specific zones. This is sometimes required as part of a subdivision permit. Zoning bylaws can refer to codes or voluntary standards. This is currently done in BC for adaptable dwelling units in apartment buildings.

Even if zoning bylaws state the extent to which buildings and houses should be accessible and where the accessible buildings or dwelling units should be located, there is still a need for technical standards or codes to specify requirements that achieve the desired level of performance.

Research and Public Education

Organizations like the Canada Mortgage and Housing Corporation organize research and provide research material and guidelines on a variety of housing-related issues, including barrier-free design, to the public. One example includes the FlexHousing™ guidelines, a form of construction where the interior configuration can change over time to adapt to the needs of the homeowner.

Sharing such research and educating with the public using success stories and "lessons learned" can inspire owners and encourage innovative practices, as well as help persons with disabilities avoid potentially costly mistakes.

Voluntary Standards & Guidelines

There are a few international standards published by ISO that address braille signage, auditory guidance, and on guidance for standard developers as to how standards could be made more accessible.

In Canada the main standard document for accessibility is CSA B651 "Accessible Design for the Built Environment", last published by the Canadian Standards Association in 2012. For example, the Enabling Accessibility Fund (see above) requires projects to meet design standards provided in CSA B651-12.

The CSA B651 standard is referenced in Part 3 of the NBC and is offered as an acceptable compliance path instead of following Section 3.8. The standard specifies technical requirements on how to make buildings and the exterior built environment accessible and safely usable by persons with physical, sensory, or cognitive disabilities. Not all areas of the standard are referenced (see Appendix 5)

Many other standards on accessibility are available in Canada and worldwide, such as

  • ADA Standards for Accessible Design by the Department of Washington, D.C.
  • ICC A111.1 Accessible and Usable Buildings and facilities, (American National Standard)
  • AS 1428 Design for access and mobility (Australian Standard)
  • ISO 21542 Building construction -- Accessibility and usability of the built environment (International Organization for Standardization)
  • Access to and use of buildings, approved document (England and Wales Regulation )

Ranking/Certification Programs

There are ranking programs that exist for tourist locations where a locale can indicate their level of accessibility to people with disabilities – for example, wheelchair accessible, partial wheelchair access, limited wheelchair access, or no wheelchair access. The Rick Hansen Foundation is currently working on a similar initiative in British Columbia. It is expected that such ranking or certifications would drive a market advantage for the businesses and locations using it, which would create pressure on peers and competitors to offer the same level of access.


There are a few examples where organizations provide training that enhance the industry"s or the public"s capacity to address accessibility in the built environment. Accessibility Ontario provides training and consulting services to the public sector, private sector, and non-profits in Ontario to help them understand and comply with the Accessibility for Ontarians with Disabilities Act (AODA). The Rick Hansen Foundation is creating a certification program for Accessibility specialists.

A promising model is being applied by the National Association of Home Builders" (NAHB) in the United States, which offers training to builders who want to become a Certified Aging-in-Place specialist. The Canadian Home Builders' Association has recently established a Home Modification Council and is in the process of modifying for Canada the Certified Aging-in-Place courses developed NAHB.