Housing Accessibility Regulation
In Canada
Prepared for:
Canadian Home Builders’ Association
By:
Rowena Moyes
June, 2011
Table of Contents
Executive Summary ........................................................................................................................ 3
Accessibility Requirements for Housing in Canada ....................................................................... 1
Introduction ................................................................................................................................. 1
Background ................................................................................................................................. 1
Codes are only one part of the answer ........................................................................................ 3
Provincial status in brief ............................................................................................................. 4
Requirements in the National Building Code, 2010 ....................................................................... 6
Recognized Goal ......................................................................................................................... 6
Requirements in Part Nine .......................................................................................................... 6
Requirements in Part Three – Section 3.8 .................................................................................. 7
Design Assumption ................................................................................................................. 7
Occupancies affected by Section 3.8 ...................................................................................... 7
Requirement for Washroom Doors ......................................................................................... 8
Requirement for Barrier-Free Path of Travel.......................................................................... 8
Requirements and exemptions affecting accessing the building and travelling to the units .. 9
Requirements and exemptions affecting designated units themselves ................................. 13
Comparison with Provincial Requirements for Residential Suites: .............................................. 17
BRITISH COLUMBIA ......................................................................................................... 17
ALBERTA ............................................................................................................................ 20
SASKATCHEWAN ............................................................................................................. 24
MANITOBA ......................................................................................................................... 26
ONTARIO............................................................................................................................. 30
QUEBEC............................................................................................................................... 33
NEW BRUNSWICK ............................................................................................................ 34
NOVA SCOTIA.................................................................................................................... 35
PRINCE EDWARD ISLAND .............................................................................................. 40
NEWFOUNDLAND............................................................................................................. 41
Executive Summary
1. Building codes currently do not require barrier-free/accessibility for all residential units.
 The national model building code (NBC) has been amended over the years to
include requirements for a barrier-free path of travel and access to
services/facilities; this has concentrated primarily on “public” areas, services and
workplaces.
 Private residences have generally been exempted from the requirements,
including all single-detached, semi-detached, duplex, triplex, row and town
houses up to three storeys in building height.
 At least one entrance and public areas of apartment buildings on floors served by
an elevator have generally been required to be accessible, while the units
themselves were not.
 The NBC includes requirements for at least one washroom doorway in suites of
residential occupancy to allow passage of a manual wheelchair.
 The NBC contains requirements for residential units which apply where units
have been designated by an authority having jurisdiction to be barrier-free units.
 Several provinces already require that a percentage of units in apartment buildings
be constructed as barrier-free or accessible units, and have included specific
requirements in their codes or interpretations for the units themselves.
i. In some cases, this only applies to government-funded units. For example,
in Alberta a percentage of all government-funded housing units must be
barrier-free (details provided in a Standata interpretation document);
projects funded under Manitoba’s Affordable Housing Initiative must also
provide accessible units.
ii. In others, it applies as well to privately funded units. In Ontario 10% of all
apartment units must meet accessibility requirements in the province’s
building code; in Nova Scotia one in 20 of all multi-family units must
meet Nova Scotia code accessibility requirements; in Saskatchewan, it is 5
%; and in Newfoundland all apartment buildings with more than 15 units
must provide barrier-free access to all floors and meet provincial
accessibility standards.
 Several more provinces are in process of introducing similar “number or
percentage of apartment units” requirements or widening the scope of current
programs aimed at government-funded units only so they include privately funded
units as well (Quebec, Manitoba, Alberta, New Brunswick).
 British Columbia has passed a code section for “adaptable” units in multi-unit
buildings, and given municipalities the right to require these standards by passing
a bylaw.
2. A few municipalities have begun to pursue accessibility requirements beyond the
requirements of provincial codes. (These are sometimes referred to as adaptability,
visitability, aging-in-place or universal design policies.)



In a number of provinces municipalities are not prohibited by provincial law from
imposing requirements beyond the building code, although scope differs
substantially (BC, SK, MB, QC, NB, PE, NF1).
Even where they do not have power to require more than the code, municipalities
can use their power over rezoning and subdivision approval to negotiate
“voluntary” agreements on design elements for accessibility.
Municipalities can use zoning to encourage accessible housing – creating zones
where projects that meet certain accessibility requirements may be allowed to
build more storeys, smaller units, fewer parking spaces, etc.
3. Discussions are under way or anticipated in some provinces to encompass additional
residential units and housing types.
 Manitoba and Nova Scotia code representatives say they expect to be discussing
some form of accessibility requirements that would apply to more units, including
those small low rise housing types currently exempted from barrier-free
requirements, within the next two years.
 Alberta building code branch staff is currently reviewing code change requests
which may result in proposed Alberta-specific changes later this year or in 2012;
if not, they expect a form of adaptability or visitability to be discussed for the next
round of changes.
 In 2010, the Ontario Ministry of Community and Social Services’ advisory
Accessible Built Environment standard development committee proposed wideranging changes to requirements affecting the built environment from roads and
transit to buildings. The provincial government has deferred these from the 20102011 round of code change discussions, but identified accessibility as an area for
future research.
4. Renovations could be affected.
 The impact on renovation projects appears mixed. It depends on the wording of
the provincial code and how the province designates units required to be
accessible/adaptable/barrier-free. In general, major rebuilding and additions
would probably be captured in current requirements. In provinces with specific
accommodation in their codes for renovation, impacts could be muted.
5. More study is required.
 For example, as mentioned above, the Ontario provincial government has deferred
consideration of wide ranging additional code requirements for accessibility in
this round of code changes, in order to research them further. The Ministries of
Municipal Affairs and Housing and Community and Social Services have said
that they want to make sure that any requirements that become law are clear,
consistent, enforceable and build on current accessibility requirements.
1
However, in Newfoundland, designation of and requirements for barrier-free apartments is handled
differently. It is not imposed through a building code, but by the province under a separate provincial statute.
Accessibility Requirements for Housing in Canada
Introduction
This paper contains a survey of current/proposed requirements and policy directions in the
national and provincial building codes, with regard to scope and requirements for accessibility in
residential buildings.
It focuses primarily on current or
proposed moves to include in-suite
requirements for “adaptability” or
“visitability” in apartments in private
market multi-unit buildings.
Definition of “Small Housing”
The National Building Code specifically exempts
detached houses, semi-detached houses, houses with
a secondary suite, duplexes, triplexes, townhouses,
row houses and boarding houses from requirements
in its barrier-free design sections. This exemption is
also found in provincial building codes.
While the precise definition varies,
visitability involves wheelchair
This paper uses the term “small housing” to refer to
access from the exterior to the main
these housing types.
living spaces and to a washroom in
every new dwelling unit.
Adaptability can include design for
future adaptation, such as how to provide access from the street and/or to expand a washroom to
accommodate a wheel-in shower.
The paper also identifies a growing interest in requiring more residential units to be visitable or
adaptable, including the small housing types currently exempt.
Background
It is important to realize that up until the 1960s and 70s, it was taken for granted that disabled
persons would generally be housed in some form of institution. Perhaps ‘warehoused’ is a more
accurate term. Perceptions of disabilities and disabled persons’ rights and role in society and the
workforce have changed significantly since then. This has been aided by some significant
medical and technological advances in mobility devices, communications, etc.
1. Design guidelines in the 1960s
In the 1960s, a number of bodies were working on ways to increase accessibility for people in
wheelchairs or other restrictions on their strength/mobility to buildings and spaces open to the
public. In 1965, for example, the National Research Council published a Supplement to the
National Building Code titled Building Standards for the Handicapped. It contained guidelines
(not model regulations) for incorporating provisions for the physically handicapped into the
design and construction of “buildings used by the public”, including facility planning, site
development, and building equipment, plus specifications for such things as toilets, utilities,
ramps, stairs, parking and storage.
1
2. National Building Code section published in 1985
Requirements from the Supplement relating specifically to buildings were incorporated into the
1985 edition of the National Building Code (NBC) as model regulations. As well as a new
section 3.7 on Barrier-Free Design2, Part Three of the 1985 NBC was also amended to provide
protection for the disabled in the event of an emergency.
The new requirements affected only Part Three buildings. Generally speaking, that meant
buildings used for assembly, and institutional occupancies, as well as buildings larger than 600
sq m in building area or three storeys in building height used for residential, business, retail, and
medium- or low-hazard industrial occupancies.
While apartment buildings were required to provide accessible entrances, corridors, etc.,
individual residential suites were exempted from many of the requirements, except where a
province or territory specified that certain units must be accessible. Houses, including detached,
semi-detached, duplexes, triplexes, town houses, row houses and boarding houses, were – and
still are – specifically exempted.
There were no equivalent accessibility requirements in Part Nine for buildings up to 600 sq m in
area and three storeys in height.
3. Provincial/Territorial building codes began in the 1980s
Provinces and territories (and some municipalities) have jurisdiction over building regulation in
Canada. However, for a long time, provinces and territories allowed municipalities to create their
own building requirements. The country’s National Building Code (NBC)3 was intended as a
model for the appropriate jurisdictions to use when they were introducing or upgrading their
building requirements.
Even with a national model code, leaving regulation to municipalities resulted in a chaotic
situation. So, the first provinces introduced their own province-wide building code acts and
regulations in the 1980s. Today, most provinces and territories have done so. Some adopt the
NBC without amendment, while others make changes and/or additions. All provinces and
territories have signed on to the principle of harmonization to the greatest extent possible.
In addition to enacting provisions for barrier-free access, many provinces have specified that a
certain percentage of multi-family units must be accessible. (See below for more details.)
2
Now renumbered as section 3.8.
Preparation of the NBC is overseen by an independent body, Canadian Commission on Building and Fire
Codes, with advice from the Provincial/Territorial Policy Advisory Committee on Codes, and staffed by the
National Research Council.
3
2
Codes are only one part of the answer
It is also important to note that building code requirements are only one element of a series of
tools being used to address accessibility for the disabled. Others include:
Legislation:
 anti-discrimination clauses in Canada’s national Charter of Rights and Freedoms
which took effect in 1982 (disability was added to the Charter late in the drafting
process)
 anti-discrimination clauses in provincial/territorial human rights legislation
 the Accessibility for Ontarians with Disabilities Act (2005) and its associated current
and proposed standards
International Convention:
 Canada’s signing of the United Nations Convention on the Rights of Persons with
Disabilities (March 2007) and recent ratification of same (March 2010).4
Government’s own building programs:
 construction and renovation programs by federal, provincial and municipal
governments and agencies to make their buildings, public spaces and services
accessible
Incentives and government funding program conditions:
 subsidies and incentives from federal, provincial or municipal governments for
accessible buildings and/or units
 Canada Mortgage and Housing Corporation (CMHC) mortgage insurance for multiunit housing, which requires a percentage of units to be accessible
4
Article 9 of that convention deals with accessibility, stating:
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:
a) Buildings, roads, transportation and other indoor and outdoor facilities, including schools,
housing, medical facilities and workplaces;
b) Information, communications and other services, including electronic services and emergency
services.
2. States Parties shall also take appropriate measures:
a) To develop, promulgate and monitor the implementation of minimum standards and guidelines
for the accessibility of facilities and services open or provided to the public;
b) To 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; ... (plus 6
more subsections not specifically related to buildings)
3
Research and information:
 research into products, design, etc. by the National Research Council and others
 participation in development of voluntary standards such as the Canadian Standards
Association’s B651-04 Accessible Design for the Built Environment
Demonstration projects:
 development and demonstration of various housing options such as Flex-Housing by
CMHC and others
Private market initiatives and experience:
 experience from builders’ and developers’ projects mostly designed for specific
individuals or niche markets and housing sectors such as seniors’ buildings and
retirement communities
Approval powers:
 requirement of specific design features by municipalities through rezoning
process/development agreements
This list is not exhaustive. These other tools have their own scope and goals, and their own
strengths and weaknesses. Full discussion of them is beyond the scope of this paper.
Provincial status in brief
British Columbia
British Columbia’s code was amended in 2009 to set out requirements which local governments
must use if they decide to pass a bylaw requiring adaptable apartment units. A number have done
so, usually by specifying a percentage of units, whether government funded or not. The province
has no plans at this time for further accessibility-related changes to the code.
Alberta
Currently Alberta uses NBC accessibility requirements, but expands 3.8.1.1(3) to require a
specified number (generally equivalent to 10 and 20%) of units in new government-funded
residential projects to be ‘adaptable’. Specific requirements for adaptable units are contained in a
STANDATA. Alberta Municipal Affairs staff have received requests from the public for
increased accessibility, such as visitability, to be included in proposals for Alberta-specific code
changes for the Alberta Building Code, 2012. The Building Technical Council has reviewed the
recommendations and the province is expected to release its document on proposed Albertaspecific code changes for public comment late this year or in 2012.
Saskatchewan
The Saskatchewan building code requires 5% of units in new rental buildings to be barrier-free.
Requirements cover accessible washrooms, space in bedrooms and kitchens, finishes in kitchens,
and barrier-free balconies. No changes are expected at this time.
4
Manitoba
Manitoba published changes to its building code, including new requirements for
accessibility/universal design for Part Three multi-unit residential buildings, in March 2011.
Most come into effect as of January 1, 2012. The province is also working on Made-in-Manitoba
Accessibility Legislation, similar to that introduced in Ontario. That is expected to produce wideranging standards and regulations for removing various types of barriers experienced by seniors
and people with disabilities.
Ontario
The current Code requires 10% of units in new multi-unit buildings to have an internal barrierfree path of travel, which triggers other requirements for doors sizes and washrooms. Under the
Accessibility for Ontarians with Disabilities Act, 2005 (AODA), the Ministry of Community and
Social Services has been coordinating efforts to produce wide ranging plans and standards to
achieve an “accessible Ontario” by 2025. In 2010, an Advisory group proposed standards under
AODA for the built environment, including many on- and off-site elements affecting multi-unit
residential. Ministries of Community and Social Services (disabilities directorate) and Municipal
Affairs and Housing (building code) are doing further analysis of the proposals, and research to
make sure that any future requirements they may adopt are clear, consistent, enforceable and
build on current accessibility requirements. Requirements for small housing may be considered
later.
Quebec
Proposals for adaptability in multi-unit buildings are expected to be submitted to the Advisory
Council of the Regie du batiment du Quebec in August 2011 for approval to proceed. If granted,
proposed code changes are expected to be released for public comment in late 2011 or 2012.
New Brunswick
Officials with the Department of Public Safety have engaged stakeholder groups through an
advisory committee. The mandate of this committee is to make recommendations for enhancing
the barrier-free requirements in Section 3.8 of the National Building Code.
Nova Scotia
Nova Scotia has fairly extensive requirements for 5% accessible units in all multi-family
buildings. The expectation is that they will be discussing visitability for all housing types within
two years.
Prince Edward Island
There is no province-wide building code in PEI. Three municipalities have adopted the NBC:
Summerside and Stratford have added a requirement that one in every 12 units in new apartment
buildings be barrier free as defined in Section 3.8 of the NBC; Charlottetown has similar
proposals before Council.
Newfoundland
A Buildings Accessibility Act requires at least one accessible unit in all apartment-type buildings
and barrier-free access to all floors in those with more than 15 units. Regulations are similar to
the NBC but in a somewhat different format and with changes. They were last amended in 2006
and staff do not expect significant imminent changes.
5
Requirements in the National Building Code, 2010
At this point, the NBC requirements in Section 3.8 represent the base for requirements across the
country.
Recognized Goal
Accessibility is one of the four Objectives which were defined for the NBC when it moved to an
objective-based format in 20055. Today, the NBC sets out what that means in two sub-objectives,
as follows:
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 (OA1
Barrier-Free Path of Travel
 using the building’s facilities
(OA2 Barrier-Free Facilities)
2.1.1.2 Application of Objectives
5) Objective OA, Accessibility (and its
sub-objectives), does not apply to
a) detached houses, semi-detached
houses, houses with a secondary
suite, duplexes, triplexes,
townhouses, row houses and
boarding houses,
b) buildings of Group F, Division 1
major occupancy*, and
c) buildings that are not intended to be
occupied on a daily or full-time
basis, including automatic telephone
exchanges, pumphouses and
substations.
As noted in the box above, there is a clear
exemption from the accessibility objective for
single family housing and small multiples.
*
(high hazard industrial)
Requirements in Part Nine
Part Nine of the NBC applies to smaller buildings (up to 600 m2 in building area or three storeys
in building height6) used for residential, business and personal services, mercantile or mediumand low-hazard industrial occupancies. The main requirements for accessibility in Part Nine
buildings are found in Section 9.5.2 Barrier-Free Design. This section contains only three
subsections:
5
The others are Safety, Health, and Fire and Structural Protection of Buildings
6
Buildings divided by a firewall may be considered separate buildings in determining the 600 m2 area.
Residential buildings divided by a 1 hr. fire separation extending through all storeys and service spaces may also be
considered separate buildings, as long as each separated portion is no more than three storeys. Part A, 1.3.3.4
6
9.5.2(1) says every building except those exempted by 3.8.1.1 (which includes the
exemption for single family housing and small multiples as described in the box above)
or amended by 9.5.2(3) shall be designed in accordance with Section 3.8.
9.5.2(2) says that every floor area above or below the first storey which is required to
have a barrier-free path of travel and is not sprinklered throughout must provide the
fire protection found in 3.3.1.7. This includes one of a firefighter elevator, fire-separated
zones, balconies providing temporary refuge for persons with disabilities (for residential
occupancies), an exterior exit at ground level or a ramp leading to ground level.
9.5.2(3) provides a specific exemption, saying small apartment buildings that don’t
have elevators only need to provide a barrier-free path of travel on the entrance
storey, and even that is not required if there is more than 600 mm difference in floor
elevation between the entrance level and every dwelling unit.
Another important requirement is found in 9.5.5.3, which says that where one or more
washrooms (containing a bathtub, shower or water closet) is served by a hallway at least 860 mm
wide7, the doorway to at least one must be wide enough to accommodate a 760 mm door and
provide access to each of those fixtures. This is outside the barrier-free section, and appears to
apply to all housing.
Requirements in Part Three – Section 3.8
Design Assumption
For Section 3.8 Barrier-Free Design, where most of the requirements for accessibility are
found, Appendix A adds a statement about the level of physical/mobility disability addressed.
“Design Assumption: This Section contains minimum provisions to accommodate a
person using a typical manual wheelchair or other manual mobility assistance devices
such as walking aids, including canes, crutches, braces and artificial limbs.”
Occupancies affected by Section 3.8
Except as exempted from the overall Accessibility Objective (see 3.8.1.1., below) or amended by
Part 9.5.2 (as described above), some or all of the requirements in Section 3.8 apply to all
buildings used for assembly, care, treatment, and detention occupancies, and larger residential,
business and personal services, mercantile or medium- and low-hazard industrial occupancies.
Section 3.8 Exemption for houses (and other):
As with the overriding Objective, Section 3.8 includes this exemption for single family housing
and small multiples:
7
Narrower hallways (minimum 710 mm) are permitted for hallways only serving bedrooms and bathrooms,
but there must be a second exit at the end of the hall or from each bedroom. In that case, washroom doors are only
required to be 610 mm wide.
7
3.8.1.1 The requirements of this Section apply to all buildings except
a) detached houses, semi-detached houses, houses with a secondary suite8,
duplexes, triplexes, townhouses, row houses and boarding houses ...
Requirement for Washroom Doors
Since the 1985 edition, sentence 3.8.3.3(2) of the NBC has required the door to at least one
washroom within a suite of residential occupancy to which Part Three applies to be wide enough
to provide access for a manual wheelchair. This is defined as a clear width of 800 mm when the
doors are in the open position. It is roughly parallel to the requirement in Part Nine, above,
although as it is within section 3.8 on Barrier-Free Design, the exemption in 3.8.1.1. (above)
means it doesn’t apply to larger detached houses, etc.
Requirement for Barrier-Free Path of Travel
Most of the specific requirements for accessibility are triggered by being part of, or within an
area requiring, a barrier-free path of travel. It can be helpful to think of this as at least one route
through all floor areas normally accessible to the public, allowing persons with physical and
sensory disabilities to access the building, circulate within it or use its facilities. This affects
entrances, lobbies, service areas, work places, elevators, corridors, public washrooms, access to
parking, etc.
3.8.2.1 Exemptions from wheelchair accessibility
The NBC contains a number of exemptions where a barrier-free path of travel for people
in wheelchairs is not required.9 These exemptions include spaces which are not normally
public, such as service rooms, elevator machine rooms, janitor’s rooms, service spaces,
crawl spaces, attic or roof spaces, high hazard industrial occupancies, and:
a) Exemptions affecting floors and floor levels
A barrier-free path of travel for people in wheelchairs is not required (for a number of
spaces, including):
3.8.2.1(2)g to floor levels not served by a passenger elevator, a platform-equipped
passenger-elevating device, an escalator, or an inclined moving walk
3.8.2.1(2)l within those parts of a floor area that are not at the same level as the entry
level, provided amenities and uses provided on any raised or sunken level
are accessible on the entry level by means of a barrier-free path of travel
b) General exemption for all residential units not designated accessible
8
The exemption for secondary suites was added in the 2010 Code, as part of a package of code changes to
allow these uses.
9
Requirements intended to help those with non-wheelchair disabilities, affecting vision, hearing, etc, would
still apply.
8
A barrier-free path of travel for people in wheelchairs also is not required:
3.8.2.1(2)k within a suite of residential occupancy that has not been designated by an
authority having jurisdiction10 to be accessible for use by persons with
physical disabilities (emphasis added)
The effect of these is that multi-family projects with elevators must meet requirements for an
accessible path from the sidewalk to at least one main accessible entrance, through the vestibule
and lobby, including ramps, doors, public washrooms, etc., to all other floors served by an
elevator including those with recreation facilities, laundry, accessible parking, etc., and along
corridors to the residential units. The units themselves are not required to meet accessibility
requirements in 3.8 unless they have been designated.
Multi-family projects without elevators only need to provide access into and through the
entrance floor. If they come within the scope of Part Nine, they do not have to make the entrance
floor accessible if all dwelling unit entrances are at least 600 mm above or below the entrance
level. Again, the units themselves are not required to meet accessibility requirements in 3.8
unless they have been designated.
Requirements and exemptions affecting accessing the building and
travelling to the units
Element
Entrances
Barrier-free
path of travel
10
Requirements
Not less than 50% of the pedestrian
entrances must be barrier free and lead
from the outdoors at sidewalk level or by
a ramp from a sidewalk
Doors must comply with requirements in
3.8.3.3
Generally, must be not less than 920 mm
wide, except that the minimum clear
width permitted for open doorways is
“not less than 800 mm”
Exterior walks must
 be not less than 1 100 mm wide
 have a slip resistant, continuous and
even surface
 have a level area next to an entrance
doorway conforming to 3.8.4(1)(c)
NBC reference
3.8.1.2
3.8.3.3
3.8.1.3.(1)
exception in 3.8.3.3
3.8.2.3
a province/territory or a municipality which has been given jurisdiction
9
Element
Requirements
NBC reference
If a barrier-free path of travel is more
than 30 m long, it must contain passing
areas 1 500 mm wide by 1 500 mm long
at intervals no more than 30 m
Walking surfaces must:
 not have any openings that a ball
more than 13 mm in diameter could
go through
 only have elongated openings that
are approximately perpendicular to
the direction of travel
 be stable, firm and slip resistant
 be bevelled at a maximum slope of 1
in 2 at changes in level not more than
13 mm and
 have sloped floors or ramps at
changes in level more than 13 mm
A barrier-free path of travel may include
ramps, elevators or similar
If an escalator or inclined moving walk
provides access from the entrance level
to another floor, there must also be an
interior barrier-free access (ramp,
elevator, passenger lift), with appropriate
signage
10
Element
Fire protection
Ramps in
barrier-free
path of travel –
Requirements
every storey above or below the first
storey that is not sprinklered throughout
and has a barrier-free path of travel must
have one of the following:
a) a firefighter elevator
b) fire separations dividing the floor area
into at least two zones so that persons
with disabilities can be accommodated
in each one, and can travel to the other
safely
c) (residential) have balconies
conforming to Sentence (5), except on
the storey containing the required
barrier-free entrance
d) have an exterior exit at ground level,
or
e) have a ramp leading to ground level
NBC reference
3.3.1.7.(1)
Sentence 5 calls for balconies to have
direct barrier-free access, space 1.5 m
minimum in depth, and a minimum of
1.5 m2 for each non-ambulatory
occupant
Floors or walks in a barrier-free path of
travel having a slope steeper than 1 in 20
shall be designed as ramps
 clear width of not less than 870 mm
 slope of not more than 1 in 12
 level area of not less than 1 500 mm
by 1 500 mm at the top and bottom
and at intermediate levels of a ramp
leading to a door, so that on the latch
side the level area extends not less
than
a) 600 mm beyond the edge of the
door opening if the door swings
towards the approach side
b) 300 mm if the door swings away
from the approach side
 level area not less than 1 200 mm
long and at least the same width as
the ramp, at intervals not more than 9
m along its length, and where there is
an abrupt change of direction
3.3.1.7.(5)
11
3.8.4.(3)
3.8.4.(1)(a)
3.8.4.(1)(b)
3.8.4.(1)(c)
3.8.4.(1)(d)
Element
Requirements

Parking
Public
washrooms
Doorways and
Doors located
in a barrier-free
path of travel
(active leaf
only)
handrails and guards meeting 3.4.6.5
and 3.4.6.6
barrier-free path of travel from exterior
parking (if provided) to barrier-free
entrance, and/or (if served by an
elevator) from at least one level of
indoor parking to all parts of the
building required to be accessible
(also specific requirements for exterior
passenger loading zone)
Only applies to residential projects if
there is a public washroom (e.g., in pool
or gym areas)
minimum clear width in the open
position is 800 mm
threshold no more than 13 mm higher
than the finished floor, and bevelled
(except at the entrance to a dwelling
unit) door closer works with force of
a) 38 N for exterior door
b) 22 N for interior door
and has a closing period of not less than
3 seconds
unless equipped with a power door
operator, there must be a clear space on
the latch side the same height as the
doorway and extending
a) 600 mm beyond the edge of the
door opening if the door swings
towards the approach side
b) 300 mm if the door swings away
from the approach side
a vestibule located in a barrier free path
of travel shall ... provide a distance
between doors in series of not less than 1
200 mm plus the width of any door that
swings into the space of travel
12
NBC reference
3.8.4.(1)(e)
3.8.2.2
See 3.7.2 and 3.8.2.3
3.8.2.2.(1)
3.8.3.3.(4)
3.8.3.(7)
3.8.3.(9)
3.8.3.(10)
3.8.3.3.(11)
Element
Elevators, etc.
Controls in a
barrier-free
path of travel
Requirements
level floor area on each side of a door in
a barrier-free path of travel that is
 as wide as the door plus the
clearance on the latch side in
3.8.3.3.(10)
 dimension perpendicular to the door
of not less than the barrier-free path
or travel (but need not be more than
1 500 mm)
A passenger elevating device in 3.8.2.1
shall conform to CAN/CSA-B355, “Lifts
for Persons with Physical Disabilities”
3.8.1.5 applies, except that controls for
an elevator must be accessible to a
person in a wheelchair – i.e., 400 – 1200
mm above the floor
NBC reference
3.8.3.3.(13)
3.8.3.5
3.8.1.5
Requirements and exemptions affecting designated units themselves
Even where residential units are designated as accessible, the NBC provides some exemptions
from other requirements. For example:
3.8.2.1.(2)(j) (A barrier-free path of travel for people in wheelchairs is not required ...)
within floor levels of a suite of residential occupancy that are not at the
same level as the entry level to the suite
3.8.2.3.(2)
A washroom need not (meet the barrier-free requirements in 3.8.3.8 to
3.8.3.12) provided:
a) it is located within a suite of residential occupancy ...
(If such a bathroom contains a bathtub, however, it will have to meet the
space requirements for universal bathrooms in 3.8.3.12)
The following chart lists some of the key requirements for residential suites which have been
designated to be accessible for persons with disabilities.
13
Element
Doors to
dwelling units
(located in a
barrier-free
path of travel)
Barrier-free
path of travel:
Ramps in
barrier-free
path of travel
Washrooms
Requirements
minimum clear width in the open
position of 800 mm
NBC reference
3.8.2.2.(1)
threshold no more than 13 mm higher
than the finished floor, and bevelled
unless equipped with a power door
operator, there must be a clear space on
the latch side the same height as the
doorway and extending
c) 600 mm beyond the edge of the
door opening if the door swings
towards the approach side
d) 300 mm if the door swings away
from the approach side
vestibule located in a barrier free path of
travel shall ... provide a distance
between doors in series of not less than 1
200 mm plus the width of any door that
swings into the space of travel
rectangular level floor area on each side
of a door in a barrier-free path of travel
that is
 as wide as the door plus the
clearance on the latch side in
3.8.3.3(10)
 dimension perpendicular to the door
of not less than the barrier-free path
or travel (but need not be more than
1 500 mm)
Generally, must be not less than 920 mm
wide, except that the minimum clear
width permitted for open doorways is
“not less than 800 mm”
A barrier-free path of travel may include
ramps, elevators or similar
See requirements in 3.8.4
3.8.3.3.(4)
Not required to meet 3.8.3.8 to 3.8.3.12
if within a suite of residential occupancy
3.8.2.3.(2)
See 3.7.2
14
3.8.3.3.(10)
3.8.3.3.(11)
3.8.3.3.(13)
3.8.1.3.(1)
exception in 3.8.3.3
Element
Accessible
shower,
lavatory and
water closet
Bathtubs
Universal
Toilet Rooms
Grab bars
Requirements
Doorways in a path of travel to at least
one bathroom within a suite of
residential occupancy shall have a clear
width of at least 800 mm when the doors
are open
Including requirements for dimensions,
clearances, grab bars. (Would apply to
“accessible apartment suites” unless
alternate standards are specified)
Where a bathtub is provided in a suite of
residential occupancy required to be
barrier-free, it shall be located in a room
meeting 3.8.3.12.(1) space requirements
(see sections of Universal Toilet Rooms,
below) and conform to 3.7.2.9 and be
equipped with a hand-held shower head
conforming to 3.8.3.13.(1)(h)
must ...
c) have one lavatory conforming to
Article 3.8.3.11.,
d) have one water closet conforming to
the requirements of Article 3.8.3.9. that
has a clearance to the walls of
i) not less than 285 mm and not
more than 305 mm on one side,
and
ii) not less than 875 mm on the
other side,
e) have grab bars conforming to Clause
3.8.3.8.(1)(d),
f) have no internal dimension between
the walls that is less than 1 700 mm,
...
h) be designed to permit a wheelchair to
back in alongside the water closet in the
space referred to in Subclause (d)(ii),
and
i) be designed to permit a wheelchair to
turn in an open space not less than 1 500
mm in diameter
Grab bars that are installed shall resist
a load not less than 1.3 kN applied
vertically or horizontally
15
NBC reference
3.8.3.3.(2)
3.8.3.13
3.8.3.17.(1)
3.8.3.12.(1)
3.7.2.8
Element
Counters
Elevators, etc.
Controls in a
barrier-free
path of travel
Requirements
only regulated for counters where the
public is served, work areas, etc.
A passenger elevating device in 3.8.2.1
shall conform to CAN/CSA-B355, “Lifts
for Persons with Physical Disabilities”
controls for operation of building
services or safety devices must be
mounted 400 – 1200 mm above the floor
(except elevator controls must meet
3.5.2.1.(3) )
16
NBC reference
3.8.3.14
3.8.3.5
3.8.1.5
Comparison with Provincial Requirements for Residential Suites:
NOTE: The lists here are not exhaustive, and other requirements may apply, especially to common areas.
BRITISH COLUMBIA
In Brief:
British Columbia’s code was amended in 2009 to set out requirements which local governments must use if they decide to pass
a bylaw requiring adaptable apartment units. A number have done so, usually by specifying a percentage of units, whether
government funded or not. The province has no plans at this time for further accessibility-related changes to the code.
Current Code Requirements
BC adopts the NBC with province-specific amendments. For accessibility, the government has added a new consolidated subsection
3.8.5 to its code, dealing with Adaptable Dwelling Units, effective December 31, 2009. It applies to single storey units in new multiunit residential buildings. The requirements are not mandatory for all of these units. However, local governments can add a
requirement for adaptable housing to their bylaws, with a reference to this section. Because municipalities in BC (except Vancouver)
may not require standards in excess of the building code without provincial approval, this section establishes a ceiling for mandatory
requirements for adaptable dwellings. On the other hand, municipalities can negotiate conditions on projects requiring subdivision,
rezoning, or similar planning approvals.
Subsection 3.8.5 of the BCBC requires:
Element
Building
Access:
Corridors and
passageways
Requirement
Corridors and passageways providing access to adaptable dwelling unit
entrances and common facilities must be
 not less than 1 200 mm in width and
 provide a clear areas of 1 500 mm x 1 500 mm adjacent to the
elevator entrance and at intervals not exceeding 10 m where it is
more than 10 m from the elevator to the end of the corridor
17
Matches NBC?
3.8.1.3.(1) barrier-free path of travel, only
requires 920 mm in width
matches 3.8.1.3.(4) for clear area, but NBC
allows 30 m intervals in a BFPT
Element
Doorways
Adaptable
dwelling unit
doorways
(within unit)
Clear space
Adaptable
dwelling unit
bathrooms
Grab bar
support
Adaptable
dwelling unit
kitchens
Outlets,
switches and
controls
Requirement
Doorways in the accessible path of travel throughout the building (but
not within the suite) must have a clear opening width not less than 850
mm
doorways providing access to common living areas and at least one
bathroom and one bedroom shall have a clear opening width of not less
than 800 mm
Floor space on both sides of the bathroom and bedroom doors above
shall conform to 3.3.1.13.(10)(b)
The accessible bathroom shall be designed to be adaptable for use by
persons in wheelchairs by providing:
 not less than 1 800 mm from the front edge of the toilet to the facing
wall
 not less than 510 mm from the front face of the bathtub or shower to
the centre line of the toilet
 a clear floor area in front of the lavatory not less than 760 mm wide
by 1 220 mm deep, centred on the lavatory
Walls adjacent to the toilet and bathtub or shower shall accommodate
the future installation of conforming grab bars, able to resist a vertical or
horizontal load of not less than 1.3 kN
Shall be designed so that the range and sink are adjacent or can have
continuous counter between them


Outlets (electrical, telephone, cable and data) intended for use by the
occupants shall be located between 455 and 1 200 mm above the
floor
Switches and controls intended for occupant use shall be located
between 900 mm and 1 200 mm above the floor
18
Matches NBC?
NBC 3.8.3.3 equivalent is 800 mm
matches 3.8.3.3.(1) size requirements for
doorways in a BFPT, which would apply
to designated accessible units
This is a different approach than found in
the NBC
No requirement for future grab bars, but
3.7.2.8 has the same requirement for load
resistance where they are installed
No equivalent requirement
Separate requirements for outlets and
controls
The new subsection 3.8.5 was prompted by municipal action and interest, and allows those local governments that wish to require
adaptable apartment units to do so on a consistent basis, without imposing the requirements in other areas where they aren’t wanted.
Several municipalities have introduced requirements, and others have proposals under consideration.
North Vancouver has had Adaptable Housing Guidelines in place since 1998, for example. In 2003, it expanded that to three levels of
adaptability. The basic level is essentially what was added to the BCBC.
Pitt Meadows is one of the newest municipalities to join the fray. It adopted a new adaptable housing policy and bylaw amendment in
February, 2011. The regulations require all apartments in new multi-unit rental and condominium buildings with a common corridor
and an elevator to be constructed as adaptable units. For those projects that do not require a rezoning, the bylaw would call up the
Adaptable Dwelling Unit section of the BCBC. For those which require rezoning approval, the municipality would require some
additional features as part of the approval, plus registering a restrictive covenant on title to ensure the adaptability of the units.
Additional features for the rezoning process include:
 indicating on plan how a dwelling can be retrofitted for barrier free access to front door, parking space and onsite amenities
 providing adaptable parking spaces – a minimum of two adaptable space for buildings with 0-25 required space; 10 for
those with 151-200, and 20 for those with 401-450 – and these spaces must be 3.7 m wide, although adjacent adaptable
spaces may share a 1.2 m access space (amended in May 2011); plus manoeuvering space for doorway if there is a stepless
entrance in the garage – the space may overlap stall design
 maximum 13 mm thresholds for access doors throughout the unit
 at least one window in the common area with a sill height not more than 750 mm above floor level
 at least one full accessible bathroom and full accessible bedroom, located on the same level
Future Directions:
A spokesperson for BC says that there are no current plans for additional requirements for accessibility or visitability. Aging in place
initiatives are cross-jurisdictional. So far, they are mostly involved with increased densification around urban cores, and transit.
19
ALBERTA
In Brief:
Currently Alberta uses NBC accessibility requirements, but expands 3.8.1.1(3) to require a specified number (generally
equivalent to 10 and 20%) of units in new government-funded residential projects to be ‘adaptable’. Specific requirements for
adaptable units are contained in a STANDATA. Alberta Municipal Affairs staff have received requests from the public for
increased accessibility, such as visitability, to be included in proposals for Alberta-specific code changes for the Alberta
Building Code, 2012. The Building Technical Council has reviewed the recommendations and the province is expected to
release its document on proposed Alberta-specific code changes for public comment late this year or in 2012.
Current Code Requirements
Alberta adopts the NBC, but also introduces Alberta-specific code changes. In Section 3.8, the Alberta government sets out
requirements for the number of adaptable units required in new government-funded projects. If a residential project is funded in whole
or in part by the Government of Alberta, adaptable dwelling units which could be made to meet barrier-free design principles must be
provided. (Requirement is: 2 or more units in a 10-25-unit project, 5 or more in a 26-50 unit project, 10 or more in 51-100, 15 or more
in 101-200, and 20 or more in a 200+-unit-project. This is not limited to specific housing types.) Interpretation details are given in a
STANDATA11 (see below).
The Province also added an Appendix note to 3.8.1.1 (3), which calls for flexibility:
“Providing adaptable dwelling units which could be made to meet barrier-free design principles needs further clarification. In
designing dwelling units, it is difficult to anticipate the specific needs of individuals, If a dwelling unit is inhabited by an ablebodied person as well as a person confined to a wheelchair, the height at which the kitchen counters are to be installed
becomes an issue. Flexibility must allow the height of different work stations to be raised or lowered. Adaptable means that the
dwelling unit can be adjusted to suit all occupants’ needs. For this to happen, each occupant’s limitations must be understood.
As a general rule, the pathway from the street to the entrance of the dwelling unit must be well marked and free of curbs or
steps. A person in a wheelchair must be able to turn into and turn around in any room. Work stations for persons in
11
STANDATA are prepared by Alberta’s Safety Services and the Safety Codes Council. This one is a Building Code Interpretation, which applies across
the province.
20
wheelchairs must be capable of being lowered to the person’s height with allowance for their feet beneath. For persons who are
blind or deaf, a common electric circuit must interconnect all rooms and be able to be connected to the fire alarm, intrusion
alarm, intercom or phone system.”
The requirement for adaptable housing is further defined in the Building Code Interpretation STANDATA 06-BCI-01012. It identifies
required features as:
Element
Turning
space
Doorways
Thresholds
Accessible
shower
Accessible
lavatory
12
Requirement
Open space not less than 1 500 mm in diameter for turning in entryways,
kitchens, washrooms and (if applicable) laundry areas
Minimum 800 mm clear width when in the open position for every
doorway into rooms within the dwelling unit
Matches NBC?
No matching provisions
As doorways in designated path of travel,
this would be called up for designated
accessible units.
No more than 13 mm in height and bevelled, for doorways above
ditto
At least one washroom in the adaptable dwelling unit must have a
Matches 3.8.3.13(1)(a) to (d) and (g),
which would be called up for designated
barrier-free shower:
accessible units, but omits requirements for
 not less than 1 500 mm wide and 900 mm deep
 clear space in front not less than 900 mm deep and the same width as a seat, grab bars, hand-held shower head
and recessed soap holders
the shower
 slip resistant floor surface
 bevelled 13 mm threshold
 (temp mix/control) valve operable with closed fist
matches 3.8.3.4 (a) to (d) but does not call
 distance between centreline and side wall is not less than 460 mm
up requirements for soap and towel
 rim height not more than 865 mm above floor
 clearance beneath is not less than 760 mm wide, 735 mm high at the dispensers
front edge, 685 mm high 205 mm back from the front edge, and 230
mm high from 280 mm to 430 mm back from the front edge
available online at http://www.municipalaffairs.gov.ab.ca/documents/ss/STANDATA/building/bci/06BCI010.pdf
21
Element
Accessible
water closet
(toilet)
Requirement
Matches NBC?
 seat not less than 400 mm and not more than 460 mm above the floor matches 3.8.3.9.(1) (a) to (d), plus
3.8.3.12(1)(c)
 easily accessible or automatic flushing controls
 have a seat lid or other back support
 not have a spring-actuated seat
 have clearance to the walls of not less than 285 mm and not more
than 305 mm on one side and not less than 875 mm on the other
Room for
The accessible washroom must be designed to permit a wheelchair to
wheelchair
back in alongside the water closet in the minimum 875 mm space
required above
Accessible
Must have at least one section not less than 760 mm long centred over a matches 3.8.3.14(1), but the NBC only
kitchen
knee space as defined below
applies this to counters at which the public
counter - size
is served
ditto - height Top surface no more than 865 mm above the finished floor level
clarification of 3.8.3.14(2), but the NBC
only applies this to counters at which the
public is served
ditto – knee
Not less than 760 mm wide, 685 mm high and 485 mm deep
3.8.3.14(3) for barrier-free counters as
space
above, intended to be used as a work space
ditto –
Must be provided with a means of adjusting their height so that the
no such requirement
intended for
counter surface is not less than 710 mm above the finished floor level,
installation of and not more than the height of the adjacent counter
a kitchen
sink or range
Kitchen sink The sink referred to above shall be provided with a clearance of not less no such requirement for sinks in kitchens
than 760 mm wide, 735 mm high at the front edge, 685 mm high at 205
(but it matches the requirement in
mm back from the front edge, and 230 mm high from 280 mm to 430
3.8.3.11(1)(c)(iv) for bathroom sinks)
mm back from the front edge
22
In addition to the above elements which are seen as mandatory to comply with Alberta’s 3.8.1.1(3), the STANDATA identifies the
following as items to be taken into consideration:






Lighting equipped to provide an average 50 lx at floor or tread level in all living spaces of the dwelling unit
Door frames and base boards contrasting in colour and texture from the surface to which they are applied
Windowsills located not more than 865 mm above the floor level, with easy-to-use opening devices
Controls for building services or safety devices (electrical switches, outlets, thermostats and intercom switches) accessible
to a person in a wheelchair, operable with one hand and mounted between 400 mm and 1 200 mm above the floor
Sink and lavatory faucets that operate automatically or have lever-type handles that do not close under spring action
Bathrooms designed to allow installation of appropriate grab bars
Of note: in May 2011, the Alberta Legislature debated and agreed to a private member’s motion put before it by government MLA Cal
Dallas. Rather than calling for new code requirements, that motion stated: “Be it resolved that the Legislative Assembly urge the
Government to utilize incentives to encourage visitability standards in all newly constructed single-family homes, including one zerostep entrance, wider doorways (minimum 32 inch clear door opening), and a main floor half bathroom.”
Future Directions
Several groups, municipalities, etc. submitted accessibility-related requests for Alberta-specific changes to the building code for the
2012 code cycle. An Alberta spokesperson reports that the Province’s Barrier-Free Council has been concentrating on stadium seating,
hotel suites/rooms and measures to increase accessibility for all new residential units, with or without government funding. Visitability
(zero-step entrance, larger foyer, and at least one basically accessible bathroom on the main floor) has been one of the Council’s main
interests.
A number of the public code change requests called for inclusion of the Adaptable Dwelling Unit STANDATA into Division B of the
code. Additional requests include higher design standards for parking, and such things as requiring structural support for grab bars,
and for ceiling lifts in the bathrooms and bedrooms of adaptable units, clear turning space in front of closets, minimum 850 mm clear
opening width for doorways in a barrier-free path of travel (including to bathrooms within adaptable suites), areas of refuge in
sprinklered (as well as unsprinklered) floor areas, extra manoeuvring space at corners in smaller public corridors, etc.
23
Proposals have been put before the Building Technical Council, and a number will be included in the public review, probably later this
year. That includes requirements in the Adaptable Dwelling Unit STANDATA, applied to multi-unit buildings. Some other
recommendations will be referred to the CCBFC for discussion as potential changes to the NBC. Final decisions on Alberta’s 2012
code contents are expected next year. The provincial Design Guide also will be updated after the Code has been published, to reflect
any changes in the regulations or new considerations on accessibility.
As in other areas of the country, several municipalities are also taking steps on accessibility. Edmonton, for example, is considering
zoning bylaw amendments which could allow smaller unit sizes and lower parking requirements for seniors’ congregate housing, or a
separate land use class for seniors’ projects. Criteria may include universal design/accessibility, smaller/convertible dwelling units,
accessory convenience stores and/or health services and provision of indoor community amenity space including a common dining
area. Other initiatives are outlined in Edmonton’s “Making Our Houses Lifelong Homes: Accessible Housing for Seniors” report. That
document reports on an October 2009 Mayor’s Roundtable on accessible housing/universal design for seniors. Recommendations
included a mix of incentives for builders and consumers and legislation or zoning practices mandating features for new home
construction.
SASKATCHEWAN
In Brief:
The Saskatchewan building code requires 5% of units in new rental buildings to be barrier-free. Requirements cover
accessible washrooms, space in bedrooms and kitchens, finishes in kitchens, and barrier-free balconies. No changes are
expected at this time.
Current Code Requirements:
Saskatchewan adopts the NBC with some amendments13. Since 1998, they have amended the code to say at least one unit or 5% of the
units, whichever is higher, in new rental apartment buildings must be barrier-free. Condominium apartment buildings are specifically
exempted from this requirement. Key requirements for these units include:
13
available online at http://www.qp.gov.sk.ca/documents/English/Regulations/Regulations/U1-2R5.pdf
24
Element
Accessible
washrooms
Kitchens
Sleeping
areas
Balconies
Requirement

minimum 1 500 x 1 500 mm clear floor space










toilet and sink meeting requirements in 3.8.3
lever faucet handles
grab bars
accessible shower
minimum 1 500 mm clear space/turning circle
lever faucet handles
insulated/protected pipes 1 200 mm or less above floor
no sharp edges or rough corners
designed so that the range and sink are adjacent or can have
continuous counter between them
minimum 1 500 mm clear turning circle on one side of the bed

barrier-free, meeting size requirements in 3.3.1.7.(5)
Matches NBC?
equivalent to 3.8.3.8.(1)(a) or
3.8.3.17.(1)(i)
same
3.8.3.8.(1)(d)
3.8.3.13
no equivalent requirement
No equivalent requirement for bedrooms
3.3.1.7.(5)
Future Directions:
A representative of building standards staff was not aware of any proposals at this time to increase requirements or extend them to Part
Nine residential, either in this form or as adaptability, visitability, etc.
25
MANITOBA
In Brief:
Manitoba published changes to its building code, including new requirements for accessibility/universal design for Part Three
buildings, in March 2011. Most come into effect as of January 1, 2012. The province is also working on Made-in-Manitoba
Accessibility Legislation, similar to that introduced in Ontario. That is expected to produce wide-ranging standards and
regulations for removing various types of barriers experienced by seniors and people with disabilities.
Made-in-Manitoba Accessibility Legislation
In November, 2010, Manitoba released a “Discussion Paper for Made in Manitoba Accessibility Legislation”. The main goal is to
prevent and remove barriers to accessibility for seniors and people with disabilities, rather than relying on individuals pursuing the
complaints process of human rights legislation to create change. The province points to legislation introduced in the United States,
Australia and Ontario. “While these laws take different forms,” its discussion paper says, they contain common elements, including
“clear, specific and achievable goals”, “accessibility standards for both the public and the private sectors”, and “regular review of the
progress made”.
Current Code Requirements:
At the moment, Manitoba is using the NBC 2005 requirements for accessibility14. However, the government published its Manitobaregulation adopting the 2010 NBC and Manitoba-specific changes on March 31, 2011. That document has included a number of
recommendations from the Barrier-Free subcommittee which has been examining code requirements in Section 3.8 and some other
areas that affect accessibility. New requirements move towards more “universal design”, and the scope of several articles has been
widened. The new requirements will take effect as of January 1, 2012.
Key elements include:
14
regulation adopting the NBC 2005 with amendments is available online at http://web2.gov.mb.ca/laws/regs/pdf/b093-127.06.pdf
26
Element
Scope
Accessible
entrances
Requirement



Barrier-free
path of travel





Doors




3.8.1.1 (1) keeps the exemption for small housing
pedestrian entrances in buildings covered under 3.8.1.1 (1) are
required to be barrier-free and lead to the outdoors at sidewalk level
or by a ramp to the sidewalk
where this isn’t practical for alterations to an existing building, at
least one pedestrian entrance must be barrier-free
required from all barrier-free entrances required as above
“throughout the building and to all of the building exits”
removes the NBC exemption for “floor levels not served by a
passenger elevator (and similar elevating devices)”, but adds one for
“interior paths of travel that are not a means of egress”
adds an exemption so that unsprinklered floor areas which conform
to 3.3.1.7 (1) (a) through (c) (i.e., floor areas which provide a
firefighter elevator, are fire separated into at least two zones, or
(residential only) provide “area of refuge” balconies) do not have to
provide a barrier-free path of travel to all exits
minimum width of 1 100 mm
requirements for detectable warning surfaces where elevation
changes more than 225 mm (full width; colour, texture, resiliency
and sound; etc.)
clear width of every public pedestrian doorway shall be not less than
850 mm in the open position
same width required for the door to at least one full bathroom in a
suite of residential occupancy (except small housing)
power door operator required on a door at every entrance to a
residential occupancy (except individual dwelling units)
vestibule must provide a distance between doors in series of 1 500
mm plus the width of any door that swings into the space
27
Matches NBC?
yes
3.8.1.2 requires 50% of entrances
different approach
3.8.1.3 requires 920 mm
no equivalent
- applies to doorways in a barrier-free path
of travel, and specifies 800 mm
- applies to doors in a path of travel to that
bathroom, and specifies 800 mm
- no equivalent requirement
1 200 mm
Element
Ramps
Requirement






Exterior
walkways


Universal
toilet rooms

Other




maximum slope of ramp used for pedestrian traffic is 1:12 in all
occupancies
3.8.3.4 (1) applies to ‘ramps’
clear width of not less than 900 mm between handrails or inside of
guard
level areas 1 500 mm x 1 500 mm at intervals not more than 9 m
level areas 1 800 mm long x 1 500 mm at changes in direction
greater than 90o
colour and texture contrast to mark leading edge of landing and
beginning and end of ramp (also for stair nosings, treads and risers)
not less than 1 200 mm in clear width
not less than 1 500 mm if immediately adjacent to and at the same
level as moving vehicles
if a storey of a building is not serviced by an elevator or inclined
moving walk, it shall be equipped with a universal toilet room or
barrier-free washroom
minimum 1 700 x 1 700 mm turning space
more specific requirements for signage, prohibition on curved stairs
in an exit, larger dimensions for exterior passenger loading zones,
and uses the term “mobility device” rather than “wheelchair” in most
instances
installation of assistive listening systems in large classrooms or
theatres
installation of visual signals as part of fire-alarm systems
28
Matches NBC?
- various – most 1:10
- 3.8.3.4 (1) applies to ramps in a barrierfree path of travel
- 870 mm
- 1 200 mm long x width of ramp
- same as above
- colour or texture
- 1 000 mm
- no equivalent requirement
new
1 500 x 1 500 mm
Guidelines on Visitability for government-funded projects
In addition, approximately 20% of units built in Manitoba under the Affordable Housing Initiative (AHI) contain visitable design
features. As outlined in provincial guidelines, these include a minimum of:
 one level, no-step entrance - minimum 36 inches (914 mm) wide - on an accessible route
 wider doorways - minimum of 32 inches (813 mm) clear passage throughout
 a wheelchair accessible bathroom on the main floor (can include the space under the sink in calculating the normal 1 500 turning
radius)
The guideline also says that other desirable features would include:
 Reinforced bathroom walls (for the installation of grab bars, if desired)
 Levered door handles and single-lever kitchen and bathroom faucets
 Raised electrical outlets - 18 inches (45.7 centimetres) from the door
 Lowered climate controls
 Lowered light switches - 48 inches (121.9 centimetres) from the door
A Manitoba Housing representative says that visitability is required as a condition of funding for these Affordable Housing Initiative
projects. For infill projects, they don’t require the normal 1 500 mm turning radius in the bathroom, but the visitor must be able to
wheel in and wheel out.
Future Directions:
As above, changes affecting multi-unit buildings were released in April. Staff expects the Subcommittee will start discussing
recommendations for Part Nine buildings, including the small housing types currently exempted by the building code, within the next
couple of years.
29
ONTARIO
In Brief: The current Code requires 10% of units in new multi-unit buildings to have an internal barrier-free path of travel,
which triggers other requirements for doors sizes and washrooms. Under the Accessibility for Ontarians with Disabilities Act,
2005 (AODA), the Ministry of Community and Social Services has been coordinating efforts to produce wide ranging plans
and standards to achieve an “accessible Ontario” by 2025. In 2010, an Advisory group proposed standards under AODA for
the built environment, including many on- and off-site elements affecting multi-unit residential. The Ministries of Community
and Social Services (disabilities directorate) and Municipal Affairs and Housing (building code) are doing further analysis of
the proposals, and research to make sure that any future requirements they may adopt are clear, consistent, enforceable and
build on current accessibility requirements. Requirements for small housing may be considered later.
Current Code Requirements:
Ontario’s Building Code15 specifies that at least 10 per cent of the units in all new apartment buildings must have a barrier-free path of
travel from the suite entrance door to at least one bedroom at the same level, and at least one bathroom with not less than 4.5 m2 in
area. Several requirements differ from those in the NBC.
Element
General
Requirement




barrier-free path of travel from sidewalk to (but not into) all suites,
with a minimum width of 1 100 mm
barrier-free path of travel into 10% of suites, and along path to (but
not into) one bedroom and one bathroom in each of those suites
doorways in a barrier-free path of travel with a clear width of not
less than 850 mm in the open position
an accessible balcony if required in accordance with 3.3.1.7.(1) to
(3) of Ontario’s code
15
available online at http://www.search.e-laws.gov.on.ca/en/isysquery/4c518dc0-84d9-4ab8-bfbbeb7fdba655ed/2/doc/?search=browseStatutes&context=#hit1
30
Matches NBC?
Width for interior corridors is minimum
920 mm
silent
800 mm
different approach
Element
Bathrooms
within the
10% of suites
required to
meet
accessibility
Controls (for
vision
impaired)
Ramp
dimensions
Grab bar
‘readiness’
Requirement



2
minimum 4.5 m floor area in designated suites
minimum door width of 760 mm where the corridor is at least 1 060
mm wide
minimum door width of 810 mm where the corridor is less than 1
060 mm wide
Matches NBC?
different approach to space requirement

extra requirements may apply in common areas for location of vision No equivalent requirements
panels in barrier-free-path of travel and marking for glass doorways



minimum width between handrails: 900 mm (NBC is 870)
level area at top and bottom of ramps: 1 600 x 1 600 (NBC is 1 500)
level area at intervals not more than 9 m and where there are abrupt
changes in direction: 1 670 mm
all dwelling unit washroom walls framed with wood or sheet steel
framing must provide reinforcement for future installation of grab
bars

3.8.3.4
No equivalent requirement
Accessibility for Ontarians with Disabilities Act (AODA)
Passed in 2005, AODA sets a goal of reaching an “accessible Ontario” by 2025. It requires accessibility plans and standards to be
created in five key areas: accessible customer relations, accessible transportation, accessible information and communications,
employee accessibility, and accessible built environment. As proposed standards for each area were produced by the relevant Standard
Development Committee they were submitted to the Minister of Community and Social Services (MCSS) for decision on further
action. The customer service regulation has been in force since January 2008, and an integrated regulation addressing transportation,
information and communications and employment is expected to be enacted in 2011.
31
Final broad-ranging proposals from the Accessible Built Environment Standards Development Committee, issued in 2010, are still
under review. They include recommendations for a large number of things not dealt with in the Building Code, as well as building
requirements for many types of occupancies. This discussion only deals with the recommendations for residential buildings.
The report specifically excludes retrofit projects and the small housing types currently exempted from accessibility requirements in the
Code. For multi-unit buildings, it proposes requirements for common access and circulation, interior accessible routes, exterior spaces,
plumbing elements and facilities and building performance and maintenance. Some of the proposals are consistent with current code
requirements, some are beyond its scope (e.g., those related to maintenance), and there are a number of increases.
In particular, Section 13 of the report called for all individual dwelling units in multi-unit buildings to be “visitable”, and all units
larger than 46.5 m2, and 50% of smaller units, to be “adaptable”. A Committee Comment in that Section says that it “represents a
broad-based framework that requires more detailed work to develop the concepts of visitability and adaptability”.
As proposed in the report, “visitability” would include having a zero step entry and at least one living space and a washroom on the
visitable level. Corridors on that level were proposed be at least 920 mm wide and have no level changes requiring steps. Except for
those serving a closet or pantry, doors would need a clear opening of 900 mm. Washrooms were proposed to have a clear floor area at
least 920 mm wide by 1 200 mm long. A two-piece washroom would be acceptable. Alarms should have an auditory and a visual
mode, and an electrical rough-in for a power door would be required beside the main entry door.
The definition of “Adaptability” would include that, where possible, the unit should be designed so that rooms can be enlarged
through removal of non-structural interior walls. For washrooms, this should allow later expansion to accommodate a mobility device
and zero-threshold roll-in shower. The report also called for washrooms to provide blocking for future installation of grab bars
(already required in the Code in Ontario). An adaptable unit should also “consider the provision of a level ceiling to allow for the
future installation of a patient lift track”.
Future Directions:
The proposed Accessible Built Environment Standard is under review by staff at the Building and Development Branch of the
Ministry of Municipal Affairs and Housing (MMAH), which is responsible for development of Ontario’s Building Code, and at the
Accessibility Directorate of Ontario in the MCSS. While information posted by MMAH in the fall of 2010 with the first round of
32
proposed Building Code amendments suggested accessibility would be dealt with in the 2011 round, when those proposals were
released in February accessibility was identified as an area for further study instead.
MMAH and MCSS have said that the government wants to make sure that any requirements that become law are clear, consistent,
enforceable and build on current accessibility requirements. As such, they are working together to complete a thorough analysis of the
proposed Accessible Built Environment standard. In addition, the committee that developed the final proposed standard recommended
that government conduct further research in some key areas. Once research and analysis of the standard is complete, the government
will make decisions on what will become law and when, and those requirements proposed for integration into the Ontario Building
Code will be included in the code consultation process. Requirements for small housing may be considered later.
QUEBEC
In brief:
Proposals for adaptability in multi-unit buildings are expected to be submitted to the Advisory Council of the Regie du
batiment du Quebec in August 2011 for approval to proceed. If granted, proposed code changes are expected to be released for
public comment in late 2011 or 2012.
Current Code Requirements:
Quebec uses the NBC with minor changes. It has adopted a version of Section 3.816 which requires 10% of suites in hotels and motels
to meet accessibility requirements.
Future Directions:
An Accessibility Group has been working on proposals for new requirements which would affect multi-unit residential buildings. The
Regie du batiment du Quebec initially set a target for staff to submit proposed code changes for accessibility to its Advisory Council
in March 2011, but that has been put off until August. Preparation has been delayed by work involved with energy efficiency
16
available online at http://www2.publicationsduquebec.gouv.qc.ca/dynamicSearch/telecharge.php?type=3&file=/B_1_1/B1_1R0_01_01_A.HTM, see
sentences (59) to (77).
33
regulations. If that group gives approval to proceed, the proposed changes would be published for public comment in late 2011 or
2012.
The approach may require 100% of units on floors served by an elevator to be adaptable in residential buildings required to provide
barrier-free entrances and path of travel. Where there is no elevator (but a barrier-free path of travel is required), 100% of the units on
the ground floor may be required to be ‘adaptable’. Specific requirements would probably include zero-step entrance, a bit wider
doorways and corridors, ability to renovate a bathroom to accommodate a wheelchair, space in kitchens and bedrooms, window
height, some elements of wardrobes, and balconies, but not full accessibility.
The NBC exemption for small housing (single detached to boarding houses) would remain. Proposals for requiring
accessibility/visitability in small housing types currently exempt from accessibility requirements are not anticipated in the near future.
NEW BRUNSWICK
In Brief:
Officials with the Department of Public Safety have engaged stakeholder groups through an advisory committee. The mandate
of this committee is to make recommendations for enhancing the barrier-free requirements in Section 3.8 of the National
Building Code.
Current Code Requirements:
New Brunswick, which regulates building in unincorporated areas of the province through planning commissions, adopted the 2005
NBC in 2009. Municipalities, which regulate building through bylaws passed under the Community Planning Act, also adopt the NBC
but can add to it.
Requirements for accessibility in larger municipalities appear to follow the 2005 NBC without amendment.17
17
Communications from building officials in Fredericton and the City of Saint John.
34
Future Directions:
The New Brunswick Building Code Act received Royal Assent in 2009 and is scheduled to be proclaimed by 2012 adopting the 2010
NBC by reference (work is well under way on the supporting regulations). Municipalities will still be able to pass by-laws with
technical requirements that go beyond those in the referenced NBC.
Any provincial proposals for enhancing the barrier-free requirements in section 3.8 of the NBC would proceed as a proposed
regulation, with the normal public comment period.
NOVA SCOTIA
In Brief:
Nova Scotia has fairly extensive requirements for 5% accessible units in all multi-family buildings. The expectation is that they
will be discussing visitability for all housing types within two years.
Current Code Requirements:
The Nova Scotia building code is based on the NBC with some modifications and additions to suit the province. Most requirements
for accessibility are essentially the same as those in the NBC.
The biggest change is that Nova Scotia has added a new sentence 3.8.1.1.(6) requiring all multiple family buildings to provide one
barrier free unit in every 20 units. This applies across the board, whether the units are publicly funded or not. The exemption for
houses, semi-detached, duplexes, triplexes, townhouses, row houses, boarding houses and rooming houses is retained. Specific
requirements for Suites of Residential Occupancy Required to be Barrier-Free are found in the added subsection 3.8.3.18. (Details are
in the chart below.) The province has also added requirements for designated barrier-free parking stalls.
35
Houses, including semi-detached, duplexes, triplexes, townhouses, row houses, boarding houses, and rooming houses, are exempt
from all accessible provisions so these would not apply. The building code also sets out two Alternate Compliance Methods for
application of accessibility requirements to renovation/alteration of existing buildings:
 a barrier-free washroom need not be provided in an existing building with a building area of less than 120 m2
 where an existing building has a building area of less than 120 m2 and the slope from the entrance level floor to the street
or public way is greater than 1 in 10 and no alternate access for a street or public way is possible, the owner may use a stair
with a maximum rise of 150 mm and minimum run of 280 mm and tactile landings with contrasting colour nosings and an
unobstructed width of 1 m
Section 3.8 requirements in Nova Scotia18 apply when there are more than three residential suites. For those buildings, one in
20 residential suites must conform to the following:
Element
General
18
Requirement
Matches NBC?
Where a suite of residential occupancy is required to provide barrier-free yes
access, it shall be served by:
 entrances in accordance with 3.8.1.2
 barrier-free path of travel to, into, and throughout each required suite
in accordance with 3.8.1.3
 an accessible balcony if required in accordance with NBC 3.3.1.7.(c)
 barrier-free controls (as outlined below)
available online at
36
Element
Washrooms
Requirement







Kitchens


2
minimum 3.7 m floor area, with no dimension less than 1 700 mm
(when the door swings out) and 4.0 m2 floor area, with no dimension
less than 1 800 mm (when the door swings in)
toilet and sink meeting requirements in 3.8.3.
lever faucet handles
grab bars
where a shower is provided, it must meet 3.8.3.13 (1)(a) to (i)
where a tub is provided, it must meet 3.8.3.13 (3)(a) to (d)
a ground-fault-interrupter (GFI) razor outlet located not more than 1
200 mm above the floor level
minimum 1 200 mm clearance between counters and all opposing
base cabinets, counter tops, appliances or walls, except in a U shaped
kitchen the minimum distance shall be 1 500 mm
minimum clear floor space of 750 mm x 1 200 mm at each major
appliance
37
Matches NBC?
different approach to space requirement
rest match, except
NBC has no requirement for a GFI razor
outlet
no equivalent requirements for kitchens
Element
Kitchens
(contd)
Requirement





a minimum of one work surface:
o 750 mm wide x 600 mm deep and 810 mm to 860 mm above the
floor
o at least one electrical receptacle at the front or side of the work
surface
o a clear floor area 750 mm wide x 1 200 mm (which may extend
480 mm under the work surface)
o knee space at least 750 mm wide, 480 mm deep and 680 mm
high
base cabinets shall have a minimum toe space 150 mm deep and 230
mm high
sinks shall:
o be mounted with the rim between 810 to 860 mm above the floor
o have a knee space at least 750 mm wide, 250 mm deep and a toe
space 750 mm wide and 250 mm deep and 230 mm high
o have the same size of clear floor area as for counters
o have faucets with lever handles
o insulated hot water and drain pipes where they abut required
clear space
upper cabinets shall have a minimum of one shelf not more than 1
200 mm above the floor
storage cabinets’ doors and drawers shall
o have a handle that is easily graspable
o be mounted at the top of base cabinets and the bottom of upper
cabinets
38
Matches NBC?
no equivalent requirements for kitchens
Element
Controls
Sleeping
areas
Requirement
controls for the operation of building services or safety devices,
including all electrical switches, thermostats, intercom switches, and
kitchen controls shall be:
 accessible to a person in a wheelchair
 operable with one hand
 mounted not more than 1 200 mm above the floor
electrical receptacles shall be located between 400 and 550 mm above
the floor, except for bathroom GFI razor outlet per 3.8.3.18.(3)(f) and
kitchen counter outlet per 3.8.3.18.(4)(c)(v)
 minimum floor area of 12.25 m2
 one horizontal dimension not less than 3.35 m
 at least one closet with
o minimum clear opening of 900 mm
o clothes hanger rods located at a height of 1 200 mm
o at least one shelf at a height of 1 370 mm
Matches NBC?
3.8.1.5
No equivalent requirement for bedrooms
Future Directions:
Building Code staff say they expect to be discussing visitability for all residential units, including the small housing forms currently
exempt from the accessibility objective, within two years. Any proposals will proceed through normal processes, including public
comment periods.
39
PRINCE EDWARD ISLAND
In Brief:
There is no province-wide building code in PEI. Three municipalities have adopted the NBC: Summerside and Stratford have
added a requirement that one in every 12 units in new apartment buildings be barrier free as defined in Section 3.8 of the
NBC; Charlottetown has similar proposals before Council.
Current Code Requirements:
Requirements differ across the province. Outside of Charlottetown, Summerside and (very recently) Stratford, Prince Edward Island
uses the United States-based National Fire Protection Association’s NFPA 101 - Life Safety Code, which concentrates on number of
exits, means of egress, fire alarms and fire protection of building elements. By regulation, the province also requires new construction
in those geographic areas to meet the Barrier-Free Design section of the 1990 NBC, and to produce a Quality Control Plan showing
how compliance will be achieved. Enforcement for projects in affected municipal areas is carried out by the municipal building
official; the province provides those services in rural areas.
Charlottetown and Summerside adopt the NBC. Summerside has just updated to the 2010 NBC effective May 16, 2011, and amended
it to also require one unit in every 12 units in new apartment construction to be barrier-free. Charlottetown did the same in June (one
unit in 12 for smaller buildings; one in 18 for those 36 units and up). The requirements for these barrier-free units include minimum
dimensions and facilities for sleeping areas, bathrooms and kitchens. The City of Stratford has also this spring adopted a bylaw to
adopt the NBC 2010 rather than NFPA 101 and introduce the same requirement for one in every 12 apartment units to be barrier-free.
Future Directions:
The Province has recently appointed a person to oversee a project to adopt the NBC province-wide.
40
NEWFOUNDLAND
In Brief:
A Buildings Accessibility Act requires at least one accessible unit in all apartment-type buildings and barrier-free access to all
floors in those with more than 15 units. Regulations are similar to the NBC but in a somewhat different format and with some
changes. They were last amended in 2006 and staff do not expect significant imminent changes.
Current Code Requirements:
Newfoundland and Labrador does not regulate accessibility through a building code, but through a separate Buildings Accessibility
Act passed in 1996 and its regulations19, which apply across the province. Under that regime, all apartment buildings with more than
15 units constructed or renovated/altered since December 1981 must make “all floors to which the public and occupants have lawful
access” accessible to persons with disabilities from an accessible entrance, and provide at least one accessible residential unit. If the
cost of the reconstruction is less than 50% of the replacement cost of the building, it will be exempt from these accessibility
requirements as an “existing building”.
Also, smaller apartment buildings with 5 to 14 units must provide at least one residential unit in which all rooms are on the same level
or which are connected by a ramp, but access throughout the remaining suites is not required. Where buildings are divided into
separate sections by firewalls, each portion is considered a separate building.
Some of the key elements include:
Element
Barrier-free
path of travel
Requirement


19
Matches NBC?
at least one accessible entrance opening at sidewalk level of to a
ramp leading to a sidewalk
public corridors: minimum width of 1 100 x 1 100 mm
available online at http://assembly.nl.ca/Legislation/sr/Regulations/rc961140.htm
41
Element
Barrier-free
path of travel
(cont’d)
Barrier-free
path of travel
Doors into
and within
dwelling unit
Other
Requirement
Matches NBC?

turning area of 1 500 x 1 500 mm at end of any corridor exceeding 3
000 mm in length
 interior corridors: minimum width of 920 mm, no openings that will
pass a sphere more than 13 mm in diameter, may include ramps
 areas of refuge or an accessible balcony in accordance with NBC
3.3.1.7.(c)
 ramp width: minimum of 870 mm between handrails
 level area at top and bottom: 1 500 mm x 1 500 mm and at
intermediate levels; extending 600 mm beyond the latch side of the
door (except 300 mm beyond if door opens away from the ramp)
 turning areas of 1 200 x the same width as the ramp at intervals of
not more than 9 m
 entrance door: minimum clear width when open of 800 mm
 door to at least one bathroom in the accessible unit: minimum 760
mm
Similar requirements to NBC in many areas
Same
smaller
Future Directions:
The regulations were amended in 2006, and provincial staff do not anticipate any changes to these standards at the moment. Some
proposals may arise from municipalities.
42