Glass Canada • April 2022 • Fenestration and Glazing Industry Alliance

Including effective accessibility requirements within various Canadian building codes has taken on an enhanced momentum in recent years. The development process features a network of organizations and committees to channel the perceived needs of various stakeholders, ensuring meaningful input from the public, the disabled, and implementers at all development stages. The Provincial/Territorial Policy Advisory Committee on Codes has ranked accessibility as second only to “alterations to existing buildings” as priorities for national model code development for the 2020-2025 code cycle. Accessibility provisions in the National Building Code include requirements for the design and construction of barrier-free access, encompassing building entrance elements that include exterior doors.

At the federal level, accessibility was substantially addressed in June 2019, with passage of the Accessible Canada Act (Bill C-81), which is analogous to the Americans with Disabilities Act in the U.S. The ACA as passed has little in terms of specific accessible construction requirements, instead establishing the regulatory environment: the organization, reporting procedures, enforcement measures and a feedback mechanism. The current focus is on improving transactional accessibility in banking, transportation and telecommunications.

The next step will be the creation of actual accessibility standards. For example, Accessibility Standards Canada and CSA are collaborating on the development of three accessibility standards.

ASC/CSA B651, “Accessible Design for the Built Environment,” is to be referenced within the NBC and various provincial codes or standards. The upcoming new edition will provide requirements involving the exterior environment, circulation (elevators, escalators and moving walkways), tactile walking surface indicators, dwelling facilities and emergency egress.

B651 currently includes fenestration-related provisions for accessible hotel-type sleeping units. These cover window sill height and operability, door closers and the maximum operating force of exterior swing doors.

ASC/CSA B652, “Accessible Homes,” will be a national standard of Canada. It is already in development with funding from the Canada Mortgage and Housing Corporation.

Meanwhile, at the provincial level, British Columbia exhibits leadership in the form of its Accessible BC Act (Bill 6). This act facilitates accessibility standards that could be in place as soon as the end of 2022. It directs the B.C. government to establish a committee, now the Provincial Accessibility Committee, to advise the provincial minister on accessibility matters and support the development of related standards.

The 2018 BC Building Code governs new construction and alterations and includes minimum requirements for accessibility. Its focus is on pathways and building access, placement of signage, illumination and accessway dimensions with no specific mention of windows. Designers are given the option of following the accessibility provisions of the B.C. building code subsection 3.8.3., or those in the CSA B651 standard. Note that input from a recent online survey of various stakeholders sought feedback to inform code change proposals. It will be published later in 2022. In 2023, feedback will be sought on actual proposed changes.

There is a widely recognized need to evaluate where gaps in accessibility standards currently exist and identify priority areas that should be addressed. The development framework briefly summarized above shows how the stage is being set to effectively fill these gaps.

While current developments have not yet focused in detail on fenestration, it is clearly on the menu. We should take advantage of the many points of input made available by both federal and provincial governmental entities to monitor developments and weigh in as warranted at the numerous available stages.

While current developments have not yet focused in detail on fenestration, it is clearly on the menu.