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ONTARIO GOVERNMENT CONSULTATION PAPER ON THE ONTARIO
BUILDING CODE'S DISABILITY ACCESS PROVISIONS
SUMMARY BY THE ODA COMMITTEE
The following is the nine pages of text of the Ontario Government's
Consultation Paper on the Ontario Building Code's Disability Access provisions.
The Government has extended the deadline for sending in written submissions to
March 1, 2002.
You will see that a number of the themes that the Ontarians with Disabilities
Act Committee has advocated for years are echoed to some extent in this paper,
including the need to remove and prevent barriers facing persons with
disabilities in Ontario.
Submissions may be sent to the Ministry of Municipal Affairs and Housing at the
addresses listed at the end of this material.
MINISTRY OF MUNICIPAL AFFAIRS AND HOUSING A CONSULTATION ON
BARRIER-FREE ACCESS REQUIREMENTS IN THE ONTARIO BUILDING CODE
6 December, 2001
Ministry of Municipal Affairs and Housing
The Government of Ontario is committed to increasing accessibility,
independence and opportunity for persons with disabilities.
Over the next two months, the Ministry of Municipal Affairs and Housing will be
conducting a public consultation to hear your views on priorities for changes
to the disabled access requirements of the Ontario Building Code.
Ontarians with disabilities, communities, builders, designers and businesses
need to work together to develop creative approaches to remove existing
barriers and ensure no new ones are created.
I look forward to receiving your ideas on priorities for changes to the
disabled access requirements of the Ontario Building Code. I know that together
we can foster greater accessibility, independence and opportunity for persons
Chris Hodgson Minister of Municipal Affairs and Housing
1.0 Purpose of Consultation
This paper was developed by the Ontario Ministry of Municipal Affairs and
Housing to receive comments from the public on disabled access priorities in
the Ontario Building Code. Your participation in the consultation is very
important to the success of this initiative.
As part of a larger commitment to improving the opportunities for people with
disabilities, the government of Ontario is undertaking a series of initiatives
this fall to further the removal and prevention of barriers for people with
Although progress has been made in improving access, individuals with
disabilities are becoming more integrated in our society, and continue to face
obstacles. Some of these can be prevented, and others can be removed.
The purpose of this consultation is to:
provide a means for the involvement of members of the public and Building Code
users in helping to shape the evolution of disabled access requirements of the
Ontario Building Code; learn your views on the existing requirements; and
identify key priorities for change.
The government of Ontario is committed to hearing your views about how we can
remove physical barriers for Ontarians across the province. The government also
commits that no existing disabled access requirements in the Building Code will
Scope and Format for Submissions
Over the years, the development and evolution of the Building Code has depended
on the involvement and support of input from stakeholders. These stakeholders
include designers, builders, building owners and users, enforcement officials
and consumers. This participation has ranged from serving on the committees
responsible for reviewing the code, suggesting changes, and commenting on the
changes suggested by others. Your involvement in this consultation is equally
important and your input will help guide future decisions on possible
amendments, which address the needs of people with disabilities in new
This discussion paper poses a number of important questions to help guide you
in preparing a response to the consultation. You are, of course, welcome to
provide your response using whatever approach you find most effective in
communicating your views on priorities for change. Any additional background
information or documentation on suggestions would help in the evaluation of
priorities. Public submissions will be accepted until January 25th, 2002.
As part of the process for identifying priority areas related to barrier-free
design, the Ministry of Municipal Affairs and Housing will create a technical
advisory group that will examine the submissions and make recommendations on
specific suggestions for changes to the Code.
Following consideration by the government, it is expected that proposals for
changes to the Code will be included in the development and review process for
the upcoming edition of the new, objective-based Ontario Building Code, which
is expected to be released for full public consultation in 2002.
Recommendations will also be forwarded to other provinces, territories, and the
Canadian Commission on Building and Fire Codes (CCBFC) for review.
Recommendations that are not suitable for Code changes will be considered for
inclusion in a future Ministry of Municipal Affairs and Housing publication of
best practices for barrier-free design. Because the Ontario Building Code is
the minimum standard for accessibility in the province, the publication will
outline suggestions that go beyond Building Code requirements through examples
of innovative design.
2.0 People with Disabilities in Ontario
Barrier-free access is not only an issue for specific stakeholder groups or for
the aging segment of society. Although old age is a time when disabilities are
more evident, many Ontarians experience hearing, mobility, vision, speaking,
mental or other disabilities at various times of their lives. Data from the
1991 federal Health and Activity Limitations Survey (HALS) estimated that 16%
or 1.6 million of Ontario's population have some form of disability.
The most common disabilities in Ontario adults were related to mobility (64%)
and agility (58%). Rates of other physical disabilities include seeing/vision
(16%), hearing (30%), and speaking (8%). Learning disabilities and mental
health conditions accounted for approximately 33% of the adult population with
Age and Disabilities
The HALS data showed that disability rates increased with age, from 7% of
children in Ontario under the age of 14, to approximately 44% of those aged
over 65. Naturally, as the population of Ontario continues to age and grow, the
number and proportion of people with disabilities is projected to increase. It
is projected that the percentage of people with some form of disability will
increase from 1.6 million (16%) in 1991, to 2.3 million or 17.6% of the
population in 2010. Over the long term, population projections show a further
increase to an estimated 2.7 million Ontarians, or 20% of the total population,
living with disabilities in 2020. The following table displays the variety of
types of disabilities that Ontarians live with according to age bracket:
3.0 Background on the Ontario Building Code
The Ontario Building Code was created in 1975. Ontario uses the model National
Building Code as the basis for the Ontario Building Code, and has also modified
or supplemented the model code to address unique provincial objectives
including issues raised by Ontario code users.
The Ontario Building Code has evolved over the years to address changes in
construction practices and to respond to public expectations, such as
barrier-free access. It has also evolved since 1975 to address issues such as
renovation, improved requirements for accessibility, energy efficiency, water
conservation and septic systems. As well, other provincial construction
requirements have been consolidated into the Ontario Building Code over the
The Ontario Building Code does not cover exterior construction standards such
as streets, landscaping or traffic standards. These standards are generally
within the jurisdiction of municipalities and are addressed through other
regulatory requirements or policy decisions.
It is important to remember that the Building Code only addresses minimum
requirements for new construction and is only one of the elements within a
large industry that ultimately determines the construction and design features
The Future of the Ontario Building Code
In its current form, the Ontario Building Code is generally prescriptive in
nature, meaning that it contains requirements on what users have to do to meet
The Canadian Commission on Building and Fire Codes (CCBFC), the body
responsible for the model National Building Code (NBC), has been working with
provinces and territories in recent years toward replacing the current model
codes with objective-based codes. This would change building codes from
dictating how construction must be undertaken, to codes that emphasize
objectives and facilitate the use of alternatives to achieve these objectives.
It is expected that the existing prescriptive codes will continue to be
available as an option for compliance under the new Code format.
Between October 2000 and January 2001, MMAH and the Ministry of the Solicitor
General conducted Ontario's portion of the national consultation on
objective-based codes. This consultation was the first use of a new, more
coordinated, federal-provincial process for code development. The public
responses were generally supportive of the proposed direction and expressed
broad support for objective-based codes and confirmed "accessibility" as a core
objective of the Ontario Building Code.
The Ontario Building Code has undergone careful analysis, including each of the
provisions of the existing code upon which has been built a profile of what the
objectives of the code currently are. It is expected that by identifying for
code users what they have to achieve in addition to the prescriptive
requirements, designers will be more likely to utilize innovation in designs
and materials and create safer, more accessible buildings throughout Ontario.
4.0 Background on Disabled Access Requirements in Ontario Buildings
The Ontario Building Code has played a leading role in making buildings more
accessible for the citizens of Ontario. Requirements for barrier-free access
have been included, and improved, in every subsequent edition of the Ontario
Building Code since 1975.
The Ontario Building Code contains detailed requirements for barrier-free
design in section 3.8. The code applies to all new construction and renovation
with the exception of houses and hazardous facilities. (Click here for details)
The Ontario Building Code is not a retrofit standard, and how it applies in a
renovation depends on the circumstances of the specific project. For example,
the minimum hallway widths in a barrier-free path of travel may be impossible
to achieve in an historic building undergoing renovation. As a result,
barrier-free improvements in existing buildings are largely accomplished where
significant construction takes place.
The 1997 edition of the Ontario Building Code included many new accessibility
requirements including, but not limited to, the following:
Increased the number of building entrances required to be barrier-free. Prior
to 1997, the OBC only required one entrance to be barrier-free. The 1997 change
requires up to half of a building's entrances in larger buildings to be
Required improvements to interior and exterior walking surfaces in barrier-free
paths of travel to prohibit the use of elements that would make walking or
wheeling difficult for the mobility-impaired.
Addressed the needs of the visually impaired by requiring warning strips, and
prohibiting escalator or stair designs that are dangerous to the
Required all building controls in barrier-free paths of travel to be operable
using one hand. Lighting and heating control heights are not to be more than
1.2 metres above the floor.
Increased circumstances where automatic openers for doors are required. Prior
to 1997, only exterior doors required an opener. Doors on both ends of a
vestibule must now be automatic.
5.0 What should be Ontario's priorities for change?
Strategies to make buildings more accessible can include barrier-removal
techniques that address, but are not limited to: mobility, vision, and hearing
The following sample questions are provided to assist you in forming your
Question: What is the most important improvement that could be made to the
barrier-free design requirements in the Ontario Building Code? What are the
reasons that make this the top priority for you?
Question: Are the requirements of the barrier-free regulations in the Ontario
Building Code adequately communicated? How should the language be changed to
Question: Are there any issues not covered by the Ontario Building Code that
should be considered?
Question: What Code changes can be made to improve safety for people with
Question: Are there accessibility requirements in other jurisdictions' Building
Codes that could make it easier for people with disabilities in Ontario? How
could these approaches be applied in Ontario?
6.0 How to Submit a Response
Your response to this paper is requested by: January 25 th , 2002
Responses related to the Ontario Building Code should be sent to the Ontario
Ministry of Municipal Affairs and Housing at the address below. Comments
received will be shared with the CCBFC and other provincial and territorial
You may send your submission by surface mail to:
Public Consultation on Accessibility Development and Buildings Branch Ministry
of Municipal Affairs and Housing 777 Bay Street, 2nd Floor Toronto, Ontario M5G
You may fax your submission to: Public Consultation on Accessibility (416)
You may email your submission to: email@example.com
For more information, or to get an electronic version of the response paper,
visit the consultation website: www.barrierfree.mah.gov.on.ca
or call Ontario's Ministry of Municipal Affairs and Housing at:
TTY: (416) 326-0148 Toll Free: 1-888-335-6611
The Province thanks you for carefully considering how changes to the Ontario
Building Code can play an important part in accommodating the needs of people
with disabilities in Ontario.