Code changes for functionality and accessibility

April 17, 2018

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By Dominic Esposito, P.Eng.
People with disabilities encounter accessibility challenges on a daily basis. Often there are unintended barriers because of how the features are designed and constructed. However, knowledge on accessibility-related issues is growing rapidly to better serve Canadians with various disabilities.

The National Building Code of Canada’s (NBC’s) 2015 edition was amended with low- and no-cost impact requirements, enhancing the usability and functionality of the built environment for all occupants without creating additional financial burdens for owners. (This article is based on Codes Canada seminars provided by the National Research Council Canada [NRC] introducing the changes to National Building Code of Canada [NBC] 2015 as well as a policy paper on accessibility in buildings developed for the Canadian Commission on Building and Fire Codes [CCBFC] by NRC staff. For additional information, visit[2].)

Many of the changes to NBC 2015 appear to be minimal but their impacts are significant when it comes to an occupant’s ability to independently move through a building.

Leading to changes
Codes Canada publications (formerly known as the National Model Construction Codes)—including NBC—are model documents only. (Visit NRC’s Codes Canada website at[3].) They must be adopted by an authority having jurisdiction (AHJ) to come into effect as the Constitution gives the 10 provinces and three territories jurisdiction over construction. In several cases, Codes Canada publications are amended and/or supplemented to suit regional needs, and then published as provincial/territorial codes.

In January 2012, a task group (TG) on accessibility was established with a mandate to review current code requirements for interior access routes, doors, entrances, ramps, stairs, universal washrooms, washrooms, bathtubs, showers, and drinking fountains. The group analyzed and assessed more than 400 items and came up with the several observations, including:

The TG recognized the costs associated with enhancing building accessibility is an important criterion in deciding the feasibility of making any changes to NBC. Therefore, it categorized all potential technical changes related to accessibility as no-, low-, medium-, or high-cost.

National Building Code of Canada (NBC) 2015 changes to device controls, such as light switches and fire alarm manual stations, make them more useable by all people.
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Changes to NBC
In order to address the gap in accessibility requirements, a set of changes with no or low cost were introduced. The accessibility requirements in NBC are located in Section 3.8., “Accessibility,” of Division B. They have now been reorganized. Previously, design requirements were sometimes contained alongside application requirements. NBC has been clarified by the reorganization so one Subsection is now dedicated to application (i.e. Subsection 3.8.2.) while another one—Subsection 3.8.3—contains solely design requirements.

Another enhancement is NBC users now have the option to use the Canadian Standards Association (CSA) B651, Accessible Design for the Built Environment, as design requirements in lieu of those contained in NBC. As an internationally well-respected Canadian standard, CSA offers a highly credible source for accessibility requirements. This alternative eliminates compliance difficulties for designers, owners, and officials as some buildings in Canada are required to comply with both NBC and CSA B651. However, the option to use CSA B651 is limited to specific applications. Work is ongoing to harmonize NBC provisions with those in the CSA standard, and it is anticipated NBC will reference CSA B651 for design requirements and keep application requirements within the Code.

Changes were made to NBC 2015 so there are now explicit requirements for drinking fountains.
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Doors are often a barrier for people with disabilities because they can be heavy and awkward to open. Sometimes, they are not necessarily obvious to people with limited vision. For example, doors with large portions of glazing may be difficult to identify for people with limited vision. Additionally, NBC did not specifically address features for the use of sliding doors. This has been rectified as the accessibility requirements for doors and doorways now also apply to sliding doors.

Another challenge for some building users was power door operators. Previous editions of NBC did not mandate location of activation devices for power-assisted doors and minimal safety requirements for these doors. A person would sometimes have to manoeuvre around an open door to enter the building. Additionally, a person with limited vision could collide with a door that was automatically opened. NBC now provides guidance on where a power-door activator has to be located. Other minimal safety requirements are also specified, including:

The type of door hardware can also create significant barriers to individuals with disabilities. Round door knobs, for example, are difficult to use for people who are unable to grasp or employ a twisting motion. Previous requirements on opening devices for doors in an accessible path of travel as well as other doors intended for public use did not include all the criteria that would make them operable by people with dexterity limitations. NBC 2015 now requires all door hardware be usable by all people (e.g. lever-type door handles) and door-opening devices are to be installed at a specific height.

An accessible path of travel is important to a person with a disability when negotiating through a building and using ramps to overcome changes in levels.

Prior to the 2015 edition, NBC was silent on many essential criteria for ramp design. There are now minimum requirements for ramps including acceptable types of surfaces. For example, thick carpets with soft underpads are not permitted as wheelchair users need significant strength to navigate this surface. Edge protection requirements have also been added. The changes appear minor but enhance a ramp’s usability and safety for everyone.

Wheel-in shower requirements have been updated to enhance their accessibility.
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Common design requirements
Individuals with disabilities are often hindered by the inability to reach and use controls like light switches, thermostats, and fire alarm manual stations effectively. Prior to NBC 2015, common control criteria were stated in many provisions and differed in wording with no apparent reason. Further, there was no requirement prohibiting the installation of a control in a confined location such as in a corner inaccessible to a person in a wheelchair. Changes were introduced in NBC to group common criteria on controls (i.e. operable by a closed fist and with a limited force). NBC clarified these requirements also apply to faucets and door hardware. This ensures different types of controls are graspable and usable by the majority of people. The use of automatic controls (e.g. automatic faucets) is now also explicitly permitted by NBC as these types of controls were deemed to provide acceptable performance.

Grab bars
Prior to NBC 2015, a number of criteria for grab bars were not clearly stated and difficult to find. It now provides additional guidance to Code users and sets clear dimensional requirements for grab bars. The clarifications appear to be minor, but their application provides an enhanced level of safety and use.

Drinking fountains
Using a public drinking fountain for a person in a wheelchair could be very challenging as, in many cases, the fountain itself is too high, or when it is at an adequate height, the water flow is unreachable.

Previously, drinking fountain design criteria were vague and NBC was silent on several features resulting in challenges when it came to enforcing the requirements. Changes such as ensuring a clear floor and knee space, spout and water flow height, and others were introduced in NBC 2015.

Water closet stalls
People with disabilities, particularly wheelchair users, often ask two questions when considering accessibility:

The requirements for accessible washrooms were lacking many key elements that could greatly improve their use by people with various disabilities. NBC now requires:

In the eyes of builders, these are minor changes, but they are significant for people who use wheelchairs and scooters.

A person with dexterity limitations may not be able to employ knob-type hardware. Lever-type hardware is easier to use by more people.
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Universal washrooms
Universal washrooms accommodating people with disabilities and families are available in public buildings.

In NBC 2015, the NBC Article on universal washrooms has been updated to clarify criteria for locking devices and toilet paper dispensers, making them more easily usable by people with disabilities. The section also harmonizes requirements like grab bar placement and toilet paper dispenser with those applicable for other accessible washrooms.

Safe access to showers and bathtubs for people with disabilities is essential. In both spaces, NBC 2015 provides more clarity to improve their accessibility, functionality, and safety for users.

In spaces where a wheel-in shower is provided, NBC has been updated to enhance its accessibility. First, a requirement for more grab bars, which provides stability when using a shower seat or when walking in and out of the shower. Second, a longer hose for hand-held shower heads making them more reachable and usable. Third, shower doors or curtains cannot obstruct the controls or transfer space, and, finally, an allowance for a maximum vertical threshold of 6 mm (1⁄4 in.) is permitted.

The broad objective of accessibility implies the access by every citizen to all aspects of societies.

Code development process
The changes to NBC 2015 were achieved through a transparent consensus-based process, which included input and feedback from stakeholders and the general public.

Established by the National Research Council Canada (NRC), the Canadian Commission on Building and Fire Codes (CCBFC) develops and maintains NBC. Committee members are selected from across Canada for their individual interests and expertise. Membership on committees is also balanced across Canada’s different regions and general interest categories.

CCBFC receives policy advice from the Provincial/Territorial Policy Advisory Committee on Codes (PTPACC). This committee is made up of representatives from the provincial and territorial ministries responsible for building, plumbing, energy efficiency, and fire safety regulations. CCBFC oversees the work of several committees and TGs, and formally approves all model code documents and technical revisions prior to publication by NRC.

Accessibility requirements in NBC fall under the mandate of the Standing Committee on Use and Egress (SC-UE).

Code change requests
The NBC development process partly relies on Code Change Requests (CCRs) from users. These CCRs can be submitted online by anyone and will be evaluated by the relevant committees.

CCRs should demonstrate there is a problem with existing requirements, there is an omission, or a change is needed. Requests should be clearly stated and address generic or widespread technical issues. Each request should answer the following questions:

The submissions of CCRs help the committees to understand the gaps in accessibility requirements.

What can one do?
NBC is constantly being re-evaluated, analyzed, and updated. The process involves input from stakeholders, committee members, and the general public. To continue with enhancement and improvement of NBC, interested persons are encouraged to:

Moving forward
The need to advance accessibility requirements in NBC is currently being reviewed by CCBFC to make sure provincial/territorial as well as federal policy goals for an accessible built environment are addressed by the requirements in NBC.

The SC-UE is currently evaluating a variety of topics, including:

The committee looking at accessibility changes is analyzing a variety of topics including the locations where tactile warning surface indicators (TWSIs) are to be provided.

History of the accessibility requirements in NBC
The history of accessibility requirements in NBC provides an interesting view of how they have progressed throughout the years and the gaps that still remain.

Initially, there were no requirements for accessibility in NBC. In 1965, NBC introduced an enabling document (Supplement No. 7, Building Standards for the Handicapped) that was optional to implement. The document focused on requirements that could render a building more usable for people using wheelchairs. For NBC 1970, the implementation of accessibility requirements was at the discretion of AHJ. From NBC 1970 to NBC 1985, specific accessibility requirements were added and more locations in a building were expected to be accessible. In 1985, requirements for the “protection for floor areas with barrier-free access” were introduced. From NBC 1985 to NBC 2015, requirements were continually updated and more locations in a building were expected to be accessible.

The current edition of NBC has an objective related to accessibility (OA objective). However, its application is limited. For example, the OA objective does not apply to detached houses and temporarily-occupied buildings. Even in larger buildings, there are exemptions for NBC’s accessibility requirements. For example, the accessibility requirements do not apply to above- and below-ground-level floors not served by an elevator as well as within apartments and hotel rooms not designated accessible by an AHJ.

Future work
The updates to the accessibility requirements in NBC 2015 have helped to address some of the gaps when it comes to the usability of a building by all persons. However, to assess how the accessibility requirements are expected to progress, it is useful to review what accessibility means and what is being done around us.

What does accessibility mean?
The OA objective in NBC is to limit the probability of—as a result of the building’s design or construction—a person with a physical or sensory limitation will be unacceptably impeded from accessing or using the building or its facilities.

However, 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.

People with disabilities encounter accessibility challenges on a daily basis.

The term “accessibility” encompasses a wide range of features improving the comfort or safety of users, including those associated with accessible, universal, and visitable designs (i.e. a house with basic accessibility features allowing most people to visit the space, even if they use a wheeled mobility device), adaptable design (i.e. an easily-adaptable space), and egressibility (i.e. in case of an emergency, occupants have the ability to leave a building or to reach an area of safety).

All accessibility measures aim to enable independent living and full participation in all aspects of life for people of all ages with diverse physical and sensory abilities. Both accessible and universal designs—often used interchangeably—are broad measures applicable to various degrees and contexts.

Adaptable and visitable designs, on the other hand, are subsets of accessible or universal design. These designs focus on a specific area of a house or building, or a particular 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.

Social model of disability
The United Nations Convention on the Rights of Persons with Disabilities (CRPD) 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.

CRPD demonstrates a paradigm shift in how disability and persons with disabilities are seen. Traditionally, disability was considered a condition residing within a person and the models used were based on “fixing” them through medicine or rehabilitation (i.e. the medical approach) or caring for them through charity or welfare programs (i.e. the charity approach). In the old approaches, professionals control decisions for people with a disability. However, there is now a movement towards a social model of disability whereby disability is a result of the interaction of a person with an environment that does not accommodate the person to participate in society. (Refer to the Convention on the Rights of Persons with Disabilities Training Guide No. 19 guidance document for additional information.)

As of 2017, CRPD was signed by 160 countries/regional integration organizations, and ratifications/accessions were made by 175 countries/regional integration organizations, making progress toward increasing the broad objective of accessibility as a national obligation. (For more on the United Nations Convention on the Rights of Persons with Disabilities, refer to[11].)

Canada has obligations under the CRPD, which it ratified in 2010. Within their respective jurisdictions, all federal, provincial, and territorial governments are responsible for reaching the goals identified within CRPD. Canadians are also pursuing change from the bottom up, which is primarily being done through the complaints process of human rights legislation.

There is a movement toward a social model of disability whereby disability is a result of the interaction of a person with an environment that does not accommodate the person to participate in society.

Why are we talking about this?
The NBC accessibility requirements progressed little between 1985 and 2015. Meanwhile, the provinces and territories are pressured to advance in areas of equality and non-discrimination of people with disabilities.

The different goals for accessibility are starting to cause significant disharmony amongst the provinces and territories as some have started to develop their own programs and policies to improve the status quo. Often the terminology and criteria for establishing better-than-code requirements varies by jurisdiction, making it difficult for designers 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?
CCBFC and the provinces and territories are looking for a viable approach to meet their commitments to removing barriers and ensuring residents have equitable access to opportunities and services. They are looking at measures such as accessible design through building codes to address their goals. Leading up to the most recent edition of NBC, substantial work has been done to harmonize requirements on accessibility and to catch up with public and industry requests to clarify these requirements. There is a need to continue this work, but a policy review of accessibility requirements is currently being undertaken by CCBFC to inform significant future technical work.

A pre-determined pathway toward a shared goal for accessible design might serve the provinces and territories’ needs, for example, to satisfy the intent of the UN Convention.

The accessibility requirements of NBC 2015 have been updated with several low- and no-cost updates. This is an important step in addressing the gap in accessibility requirements. Although improvements have been made, all persons will not be able to move independently through a building. However, there is a movement towards a social model of accessibility where more people are accommodated, but implementation is a challenge. In the future, it is expected accessibility requirements will progress. The short-term work includes determination of key policy issues and development of an approach to further enhance the usability and functionality of buildings for all persons.

Dominic Esposito, P.Eng., is a technical advisor with the National Research Council Canada (NRC) where he provides support to the Canadian Commission on Building and Fire Codes (CCBFC) and its related committees, which are responsible for the development of Codes Canada publications. He can be contacted via e-mail at[13].

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