Improving accessible built environment standards — 2023 initial recommendations report

Letter from the chair

The Honourable Raymond Cho
Minister for Seniors and Accessibility
777 Bay Street
5th Floor, Toronto, Ontario
M7A 1S5

Dear Minister,

The Design of Public Spaces Standards Development Committee has finished the first phase of our work in reviewing the built environment standards in regulation under both the Accessibility for Ontarians with Disabilities Act, 2005 (AODA) and the 2015 barrier-free accessibility requirements in the Ontario Building Code.

I am pleased to submit on behalf of the committee our review of the accessible built environment standards in the Accessibility for Ontarians with Disabilities Act and the Ontario Building Code initial recommendations report.

Our committee is keen to have this report posted online in order to garner as many people's comments and feedback on our recommendations as possible. We believe in the power and voice of people with disabilities and want to ensure that their opinions are considered in the development of our final recommendations.

The committee has endeavored to be considerate of the full spectrum of abilities in the development of these initial recommendations. We know that people with disabilities have a lot more to offer our society than they are typically afforded, and among the main barriers to their inclusion are those in both the outdoor and indoor built environments.

With this in mind, we have conducted a thorough review of the existing built environment standards and know that this report has the potential to promote the change necessary to meet the government’s mandate of creating a more accessible Ontario.

Thank you for the privilege of allowing me to chair this committee. It has been among the most important milestones of my career, and I look forward to continuing this work towards improving the accessibility of our province.

Sincerely,
Julie Sawchuk
Chair of the Design of Public Spaces Standards Development Committee

Background

The Accessibility for Ontarians with Disabilities Act, 2005 (AODA) aims to achieve an accessible Ontario through the development, implementation and enforcement of accessibility standards that apply to the public, private and not-for-profit sectors.

The first accessibility standard for the built environment were proposed by the Accessible Built Environment Standards Development Committee with the submission of their final report in 2010. The result of this work led government to develop the design of public spaces standards under the AODA and the 2015 barrier-free accessibility requirements of the Ontario Building Code.

The design of public spaces standards was adopted in 2012 and establishes minimum accessibility standards primarily for outdoor public spaces including, but not limited to, public sidewalks, parking facilities, public outdoor play spaces as well as some indoor elements like service counters and waiting areas. These requirements were established on a go-forward basis such that all new construction or redevelopment of the applicable areas set out in the standards are required to comply.

Ontario’s Building Code has included design requirements for barrier-free accessibility since its inception in 1975. Accessibility requirements in the Building Code have changed over time, with improvements in each new edition of the Building Code and some of the most substantial coming into effect in 2015. The 2015 barrier-free accessibility amendments included requirements for 15% of suites in apartment buildings to include certain barrier-free design features, increased requirements for power door operators, requirements for an elevator or other barrier-free access between storeys in most buildings, enhanced requirements for visual fire alarms, enhanced dimensions for doorways and a barrier-free path of travel, updated requirements for barrier-free washrooms and universal washrooms, and other accessibility elements. These requirements apply to all new construction or major renovation as defined by the Building Code.

In December 2021, the Minister for Seniors and Accessibility established the Design of Public Spaces Standards Development Committee (committee) to undertake an evidence-based and focused review of the province’s accessible built environment standards in regulation under both the AODA and the 2015 barrier-free accessibility requirements in the Ontario Building Code.

Specifically, the committee was tasked by the Minister for Seniors and Accessibility to:

1. Re-examine the long-range objectives of the standard.
2. If required, revise the measures, policies, practices, and requirements to be implemented on or before January 1, 2025, and the timeframe for their implementation.
3. Develop another proposed standard containing modifications or additions that the committee deems advisable for public comment.
4. Make such changes it considers advisable to the proposed accessibility standard based on comments received and make recommendations to the minister.

Over a 10-month period, the committee held a series of 12 two-day meetings, where members actively shared their own lived experiences and drew upon their professional expertise. These contributions were instrumental in enriching the collaborative decision-making process. Throughout their work, the committee consistently applied a multifaceted lens that encompassed equity, diversity, inclusion and intersectionality.

The committee was provided with foundational documents and extensive research pertaining to accessibility in the built environment. They also benefited from informative presentations delivered by subject matter experts representing key entities, including the Ministry for Seniors and Accessibility, the Ministry of Municipal Affairs and Housing, as well as the City of Ottawa, DesignABLE Environments and the Accessibility for Ontarians with Disabilities Act Alliance.

Current state of accessibility in Ontario

The current regulatory and legislative framework in place to enforce accessibility in Ontario has not evolved fast enough to keep up with the growing needs of persons with disabilities across the province. Accessible built environment regulations and standards need to consider and address the broad spectrum of disability. In order to effect change that will ensure accessibility for all, regulations and standards should be backed by clear, defensible research and hard data.

We have high hopes for the collective work being carried out across federal and provincial levels to find alignment across accessibility standards. This work is pivotal to ensure that standardization of accessibility regulation is prioritized not just in Ontario, but across the country. Leveraging the work carried out by other groups in this space, including Accessibility Standards Canada and CSA Group's “B651, Accessible design for the built environment,” we hope that persons with disabilities may benefit from the great work already established.

Recommendations presented by this committee are informed by validated data from academic research, national standards for accessibility and principles of universal design for the built environment. This initial report represents our committee’s first step towards identifying the barriers that continue to exist in the built environment and proposing recommendations to remove them.

Long-term objective

Committee discussion

Under the Accessibility for Ontarians with Disabilities Act, the committee is required to determine the “long-term accessibility objectives for the industry, sector of the economy or class of persons or organizations in relation to which the committee has responsibilities.”

Considering the scope of the review, the committee recognized the importance of the long-term objectives being reflective of both the design of public spaces standards as well as the Ontario Building Code.

Recommendation

Recommendation 1: long-term objectives of the design of public spaces standards

The committee recommends adoption of the following as the long-term accessibility objectives:

• the long-term objective of the design of public spaces standards is to enhance the quality of life for everyone in the community, including persons with disabilities, by removing and preventing barriers to accessibility to create safe, convenient and inclusive spaces that promote social engagement, physical activity and mental well-being
• this objective will be accomplished by providing obligated organizations with the specifications, guidelines and financial and informational resources needed to design, construct or renovate spaces not governed by the Ontario Building Code in such a way as to create access for everyone

Overarching barriers in the built environment

Introduction

The barriers identified below highlight recommendations that are jointly applicable to the design of public spaces standards and the Ontario Building Code.

Committee discussion

The committee identified that some recommendations were required to bridge gaps between the two sets of regulations and promote a more cohesive approach to accessibility in public spaces.

The committee discussed making education a requirement for all professionals involved in the design, construction and management of a property (for example, municipal planners and building officials, architects, landscape architects, sign fabricators, graphic designers, engineers, contractors, tradespeople, building project contractors, accessibility consultants) to improve their understanding of how to implement accessibility measures effectively. Ongoing education is necessary to stay up to date with current accessibility requirements and ensure they can provide accurate accessibility guidance.

Finally, there was much discussion about providing tools to help obligated organizations and building accessibility professionals understand their obligations, to prevent and remove barriers to accessibility.

Recommendations

Recommendation 2: align definitions of major/extensive renovations

Intended outcome: To improve understanding and awareness of requirements for major/extensive renovations by aligning their definitions across the Ontario Building Code and the design of public spaces standards.

The committee recommends:

• require government to review and coordinate the definitions for major/extensive renovations so they are aligned and ensure the greatest level of accessibility when organizations plan renovations
• the government shall undertake a jurisdictional scan to identify best practices for defining major/extensive renovations

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 3: municipal site plan accessibility strategy

Intended outcome: To improve the application of accessibility best practices in the site plan approval process.

The committee recommends:

• require municipalities to add the requirement for a comprehensive accessibility report to accompany site plan approval submissions
• the government shall develop the framework for the report to clarify what needs to be included, and to help promote consistency from one municipality to the next
• professionals responsible for creating the accessibility report within the site plan approval submission shall be encouraged to seek the advice of accessibility specialists if they do not have the necessary experience
• the government shall require that municipal staff reviewing site plan submissions to be educated about the design of public spaces standards requirements and how they apply to the site review process, and the government shall certify these educational materials and providers of this training

Implementation timeline: Within one year of regulation being adopted.

Recommendation 4: site plan reviews by Accessibility Advisory Committees

Intended outcome: To ensure municipalities are supported to meet the requirement related to site plan reviews by Accessibility Advisory Committees, and Accessibility Advisory Committee members are supported to conduct meaningful accessibility reviews of site plans.

The committee recommends:

• the government shall require municipalities to develop a well-defined process for site plan reviews by their Accessibility Advisory Committee, where these exist
  • this shall include training, and the development of materials to assist the Accessibility Advisory Committee in their reviews
• the process shall be evaluated and updated as required as part of a municipality’s multi-year accessibility plan (every five years)
• the government shall ensure municipalities and Accessibility Advisory Committees can be supported to meet this requirement in a timely manner (that is, 30 days), while also upholding Bill 23, More Homes Built Faster Act, 2022 and Bill 109, More Homes for Everyone Act, 2022
• the government shall develop guidance to support municipal Accessibility Advisory Committees in reviewing site plans, including training and the development of materials

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 5: mandatory accessibility training for officials/inspectors

Intended outcome: To ensure officials are always up to date with accessibility best practices to help create spaces that are more accessible for everyone.

The committee recommends:

• the province shall require relevant training for officials/inspectors on the accessibility requirements in both the Ontario Building Code and the design of public spaces standards in Integrated Accessibility Standards Regulation and require supplementary training when they are amended

Implementation timeline: Within one year of regulation being adopted.

Recommendation 6: authoritative guidance materials for officials/inspectors

Intended outcome: To ensure that municipal building officials are more knowledgeable about all aspects of accessibility both inside and outside the building.

The committee recommends:

• the province shall work with professional organizations to fund and develop authoritative guidance and educational materials to help officials/inspectors better understand and apply the accessibility requirements in both the Ontario Building Code and the design of public spaces standards in the Integrated Accessibility Standards Regulation

Implementation timeline: Within one year of regulation being adopted.

Recommendation 7: authoritative guidance for Ontario Building Code and design of public spaces enforcement

Intended outcome: To provide guidance to obligated organizations of their requirements to the Ontario Building Code and the design of public spaces standards.

The committee recommends:

• require the province to develop educational/authoritative guidance materials to help municipalities with enforcement of the Ontario Building Code and the design of public spaces standards
• these guidance materials shall be promoted and widely shared

Implementation timeline: Within one year of regulation being adopted.

Recommendation 8: maximum length and rise of ramps

Intended outcome: To set a maximum vertical rise and length of slope for the application of ramps in both the design of public spaces and Ontario Building Code.

The committee recommends:

• the maximum vertical rise of a ramp shall be 2.5 m
• the maximum slope of ramps shall be 1:20, except where space constraints exist, then the maximum shall be 1:15
• where changes in level are greater than 2.5 m, an elevator shall be installed as a means of barrier-free access

Implementation Timeline: Immediately upon adoption of regulation.

Recommendation 9: multiple switchbacks and widths of ramps

Intended outcome: To increase the width of long ramps with multiple switchbacks to allow two-way traffic under the Ontario Building Code and the design of public spaces standards.

The committee recommends:

• where a ramp services a public building and the total length of the ramps is more than 22.5 m long or vertical height is more than 1.5 m, the landings need enough width (for example, 1800 mm minimum) to accommodate two-way traffic

Implementation Timeline: Immediately upon adoption of regulation.

Recommendation 10: bilingual signage

Intended outcome: To ensure signage meets the needs of Franco-Ontarians with disabilities.

The committee recommends:

• the government shall consult with Franco-Ontarian persons with disabilities to ensure the French Language Services Act, R.S.O. 1990, is meeting the needs of Franco-Ontarians with disabilities, such as:
  • ensuring signage serves the purpose of navigation, direction or amenities (washrooms) through inclusion of bilingual text in English and French, where text is present
• French braille code signage is provided by obligated organizations when English braille is provided
• government shall also require compliance by public sector organizations, municipalities and large organizations not currently obligated under the Francophonie Act, 2019

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 11: adoption of Unified English Braille (UEB) and Code Braille Français Uniformisé (CBFU)

Intended outcome: To provide a consistent braille reading experience for all braille readers in Canada.

The committee recommends:

• the province shall amend the Ontario Building Code and the design of public spaces standards to require signage to use Unified English Braille (UEB) and Code Braille Français Uniformisé (CBFU)
• the government of Ontario shall work with its federal counterparts, Accessibility Standards Canada and CSA Group, to ensure the harmonized use of Unified English Braille (UEB) and Code Braille Français Uniformisé (CBFU) across the country

Implementation timeline: Immediately upon adoption of regulation.

Design of public spaces standards definition and application

Introduction

This section aims to provide clarity and guidance to organizations on how to interpret and apply the requirements specified in the standard. Including definitions helps to ensure that obligated organizations have a common understanding of the terms used within the regulation. This common understanding is crucial for consistent and effective implementation of the standards.

Committee discussion

The committee identified a lack of alignment in the terminologies used between the accessibility legislation and other existing regulations, such as the Ontario Building Code. Differences between the design of public spaces standards and the Ontario Building Code, such as in the definitions of major/extensive renovations, have the potential to cause confusion, non-compliance and reduced accessibility in buildings and outdoor spaces.

The committee recognizes that new accessibility standards are also being created by Accessibility Standards Canada. The group strongly believes that harmonization across all levels of government is essential moving forward. Harmonization can lessen confusion and aid in the seamless integration of accessibility requirements across different laws, guidelines and standards.

Recommendations

Recommendation 12: definitions

Intended outcome: To align terminology between accessibility legislation, including the Ontario Building Code and the design of public spaces standards.

The committee recommends:

• the government shall research existing definitions from standards from other provinces, municipalities and organizations (for example, National Building Code, the Ontario Building Code, municipal Facility Accessibility Design Standards, Accessibility Standards Canada and CSA Group) and adopt the best practices for terms and definitions for the Ontario design of public spaces standards
• in addition, a review and update of terms and definitions shall be considered on a yearly basis
• particular focus shall be placed on clarifying/harmonizing terminology related to alterations, including basic renovation, extensive renovation, retrofit and redevelopment

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 13: expand definitions section

Intended outcome: To ensure the design of public spaces standards includes all definitions of all relevant technical terms used in the regulation.

The committee recommends:

• the government shall develop a comprehensive list of terms relevant to the design of public spaces standards and provide this list as a glossary for the standard. The glossary shall include, but is not limited to, the list of terms below. The following are not defined in the design of public spaces standards:
  • boardwalk
  • comparative maintenance
  • construct
  • curb
  • firm and stable
  • fixed queuing guide
  • handrail
  • landing
  • landscaping
  • locator tone
  • passing area
  • pedestrian control signal
  • ramp
  • renovation
  • service counter
  • sidewalk
  • tactile arrow
  • trail head
  • tactile walking surface indicator
  • viewing area
  • waiting area
  • walk indicator tone/audible walk indicator

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 14: definition of redevelopment

Intended outcome: To better clarify the meaning of “redevelopment” and ensure changes to existing infrastructure cannot reduce the performance and accessibility of current infrastructure.

The committee recommends:

• the regulation and government shall better define “redevelopment” under the design of public spaces standards
• government shall remove the term “redevelopment” and replace it with “material alteration” which shall be defined as “any planned changes to public spaces, not including maintenance activities, environmental mitigation or environmental restoration”
• material alteration to existing infrastructure shall increase the performance and accessibility of current infrastructure
• government shall define material alteration with percentages under each requirement of the design of public spaces standards
• material alteration of a space must include the application of current accessibility standards under the Integrated Accessibility Standards Regulation or the Ontario Building Code
• the design of public spaces standards shall include definitive direction around material alteration for all elements of the standards (that is, material alteration of a path of travel, material alteration of an intersection, triggering accessible pedestrian signals requirement, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 15: amended definitions for trails and sidewalks

Intended outcome: To ensure clarification of definitions under the design of public spaces standards for municipalities to know what regulations need to be applied and where.

The committee recommends:

• clarify sidewalk and exterior walkway in the list of definitions
• for both Integrated Accessibility Standards Regulation and the Ontario Building Code, reserve “sidewalk” to mean a municipal sidewalk that is located adjacent to a roadway and use “exterior path of travel” to mean all other walkways within a site’s lot lines
• add definitions for recreational trails and multi-use trails:
  • most multi-use trails are used for both recreational and commuting purposes and shall be considered as an exterior path of travel (that is, multi-use trails on former rail lines or those used in lieu of a sidewalk adjacent to a road)
  • recreational trails are not subject to maximum 5% slope requirement. The obligation is to only consult on slope, whereas exterior paths of travel must have a maximum slope of 5%
  • the term “recreational trails” is to be used for those intended for recreational and leisure purposes only
• government must define multi-use trails (refer to Ontario Traffic Manual — 18) and outline specific requirements to maximize accessibility as aligned with exterior paths of travel and recommendation 27: “Wider exterior paths of travel”

Implementation timeline: Within one year of regulation being adopted.

Recommendation 16: consultation

Intended outcome: To set out specific guidelines as to how the consultation process will be conducted.

The committee recommends:

• create new guidelines on consultation for all areas of the design of public spaces standards. These guidelines shall provide details on:
  • who is responsible for conducting consultations
  • best practice for number and diversity of end-users consulted via percentage of impacted community
  • targeted outreach to include diverse perspectives. These may include community representatives
  • who to engage in consultations and how to make the process accessible and inclusive (for example, sign language interpretation or French language translation, Communication Access Realtime Translation (CART)
  • how the consultation will take place (that is, virtual, in person, survey, etc.)
  • how feedback will be collected, privacy maintained
  • what timelines are required when the consultation must happen
  • what specific feedback is needed for each section of the design of public spaces standards
  • what is to be done with the information gathered in the consultation
  • what duty the consulting agency has to incorporate the feedback into the design of public spaces standards element
  • how records of proceedings shall be maintained and be made available along with the status of consultations
• compensation shall be provided for persons with disabilities who participate in the consultation process
  • ensure that any compensation received does not impede the amount or process by which individuals receive ODSP or other financial support

Implementation timeline: Immediately upon adoption of regulation.

Recreational trails and beach access routes

Recommendations under the design of public spaces standards in the AODA.

Introduction

Accessible recreational trails and beach access routes provide an inclusive experience that allows people of all abilities to enjoy natural spaces in Ontario’s communities. The design of public spaces standards lays out accessibility requirements for both recreational trails and beach access routes. The standards include technical requirements such as minimum width, slope, signage, as well as other non-technical requirements such as the need for consultation with persons with disabilities on the accessibility features of recreational trails.

The committee’s goal is to ensure that these routes become more accessible so that everyone can enjoy the benefits of outdoor recreation and beach access.

Committee discussion

The committee worked to identify existing issues based on their expertise, policy and inter-jurisdictional research, stakeholder/partner feedback and compliance information. The members also considered different solutions and tactics to increase accessibility such as recommending non-regulatory approaches including outreach, awareness initiatives and education programs.

Some issues identified by the committee included clarifying the definitions of wilderness trails, recreational trails and exterior path of travel, clarifying the organization responsible for consultations and trail development, and amending the technical requirements for the ramps and slopes of recreational trails and beach access routes.

Recommendations

Recommendation 17: definition of rest area

Intended outcome: To define “rest area” in the design of public spaces standards.

The committee recommends:

• revise definition of “rest area” to mean:
  • in respect to recreational trails and exterior paths of travel, a dedicated area that is level and intended for public use to allow persons to safely stop or sit on accessible benches and other apparatus, while not impeding the use of the trails and exterior paths by other users
• rest areas for recreational trails and beach access trails are to include:
  • level landing pad with clear floor space must encompass both persons with disabilities who use mobility aids (for example wheelchairs, scooters, walkers, service animals, etc.) and people with non-apparent disabilities
  • use signage to give persons with disabilities priority to use the rest area
  • seating must include armrests and backrests to help persons with disabilities who have difficulty sitting and rising, include enough clear space within a rest area to accommodate people who use mobility aids and also allow for non-disruptive flow of pedestrian traffic
  • fixed seating to the ground so that it is safe to use
  • a selection of seating clear of obstructions for easy transferring for people using mobility aids who may wish to transfer to the seating
  • government to review existing research and best practice for spacing of rest areas along recreational trails and beach access routes to maximize the usability of the paths for people with reduced stamina, and also at viewing areas, waiting areas and other points of interest
  • edge protection may also be necessary if the rest area is near a slope or a drop off, such as along water
  • service animal relief area that doesn’t impede the path of travel
  • room underneath benches for service animals to stretch

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 18: distances between rest areas

Intended outcome: To ensure persons with disabilities and older adults have consistent access to rest areas that meet their needs.

The committee recommends:

• government shall create requirements for accessible rest areas and these requirements shall include:
  • in addition to consulting on the placement of rest areas, obligated organizations shall include information in their multi-year accessibility plan on how feedback informs the placement of such rest areas
  • the need for accessible benches in shaded rest areas wherever possible
  • based on consultation, rest areas shall include a mix of benches that have an open-end for transferring, and benches with a third arm (to allow a person to use both arms when moving from sitting to standing)
  • rest areas must be placed on a hard surface and include backrests, arm rests (unless providing a space for transferring) and a space beside and below a bench for service animals or mobility devices
  • rest area must not impede the path of travel or trail
  • rest areas must provide space for persons using a mobility device to move safely from the path of travel or trail
  • rest areas shall be provided every 30 m along a path of travel including multi-use trail, sidewalk, recreational trail or beach access route, unless not feasible
  • government shall develop a list of exceptions where organizations are not obligated to include a rest area every 30 m
  • government to research best practices for the installation of tactile surface changes for rest areas to alert persons who are blind or low vision of the transition between the path of travel and the rest area
  • rest areas must include a space next to the bench, if one is provided, for someone using a mobility device

Implementation timeline: Immediately upon adoption of regulation. This shall include exemption for plans or contracts established prior to implementation of the new standards.

Recommendation 19: definition of firm and stable

Intended outcome: To clarify and define “firm and stable” in the design of public spaces standards to ensure that surface materials of recreational trails and beach access routes are accessible and safe, and allow users to expend less energy while enjoying their use.

The committee recommends:

• government to add additional specificity to existing requirements within the regulation for “firm and stable,” including a definition
• government to add regulatory performance requirements, similar to the guidance outlined in the Integrated Accessibility Standards Regulation policy guidelines
• government to add prescriptive requirements that are enforceable, measurable and discernable within the regulation
• government to consult with potential end users and experts to determine functional/performance requirements

Implementation timeline: Within two years of regulation being adopted.

Recommendation 20: passing areas along trails and access routes

Intended outcome: To better define where and when a passing area should be included.

The committee recommends:

• create a guideline for best practices for the installation of passing areas appropriate to the type of multi-use trail, recreational trail or beach access route aimed at providing space for passing as appropriate

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 21: trails and route widths

Intended outcome: To create prescriptive requirements for accessible trails wide enough for safe two-way use by a diverse group of users.

The committee recommends:

• government to prescribe minimum width for all recreational trails
• government to require multi-use trails providing divided bi-directional paths of travel to be double width (3600 mm)
• government to require rest/passing areas where minimum width requirements cannot be met
• anthropometric data needs to be updated to ensure the trail meets the needs of a diverse group of users
• government shall examine varying widths of recreational trails and beach access routes to identify if a universal width is desired or a range of widths

Implementation timeline: Immediately upon adoption of regulation.

Outdoor public use eating areas

Recommendations under the design of public spaces standards in the AODA.

Introduction

It is essential for public eating areas to be accessible to ensure inclusivity, equal opportunity and dignity for all individuals. By providing accessible entrances, pathways, seating and facilities, public eating areas foster a sense of belonging and community for everyone.

Committee discussion

The committee agreed the current requirements for public use eating areas lack sufficient measures to guarantee accessible and inclusive gatherings. Amendments such as extending the outdoor public eating area requirement to small organizations can help ensure that all individuals are accommodated, and barriers are minimized for a more inclusive dining experience in public spaces.

Recommendations

Recommendation 22: general requirement public use eating areas

Intended outcome: To provide persons with disabilities a more inclusive experience in outdoor eating areas where groups tend to gather.

The committee recommends:

• government shall review and amend the general requirements of outdoor public use eating areas (s. 80.17), according to best practices, universal design principles, and minimum standards that exceed the current requirements from similar jurisdictions, to meet the needs of people with a variety of disabilities.
• the committee further recommends:
  • all tables shall be accessible at public use eating areas
  • organizations shall be required to remove impediments caused by structural supports that prevent easy access and use by people with a variety of disabilities
  • table benches shall have a minimum clearance under the table of at least 800 mm wide by 430 mm deep by 685 mm high
  • public use eating areas shall include a variety of accessible tables and seating to accommodate persons with a variety of disabilities
  • a minimum 2000 mm clear space shall be required around all public use eating areas
  • the area around and under the table and all accessible seating spaces shall be level, firm and stable to allow for access by a person with a mobility device
  • gradient around public eating areas shall be no steeper than 2% — cross slope and running slope
  • where a traditional picnic table is used, tabletop extensions shall be provided on one end of the table to allow for access for persons using a mobility device
  • similar to trail requirements, signage shall be required at access points for public use eating areas indicating number and location of accessible tables, and this information shall also be provided in multiple accessible formats (for example, website, QR code)
  • larger obligated organizations shall be required to consult (public, municipal Accessibility Advisory Committee, etc.,) on new or redeveloped public use eating areas
  • accessible tables must remain in an accessible or designated area that allows for flexibility with regards to placement of tables
  • obligated organizations must monitor to ensure that accessibility is maintained (for example, when tables are moved to an inaccessible area)
  • the province shall develop authoritative guidance materials to help obligated organizations meet the standards and the needs of their users
  • accessible pathways must be provided to public use eating areas
  • amenities, such as the garbage/recycling area, must be adjacent or along the accessible path of travel to ensure that a person with a disability can access them independently

Implementation timeline: Within two years of regulation being adopted.

Recommendation 23: extending requirements of public use eating areas to small organizations

Intended outcome: Ensure that all outdoor public eating spaces are accessible.

The committee recommends:

• government shall review and amend the application requirements of outdoor public use eating areas (s. 80.16) to include small organizations as defined in the Integrated Accessibility Standards Regulation (O. Reg. 191/11) (that is, an organization with at least one but fewer than 50 employees in Ontario)

Implementation timeline: Within five years of regulation being adopted.

Outdoor play spaces

Recommendations under the design of public spaces standards in the AODA.

Introduction

The outdoor play spaces section applies to an area that has play equipment such as swings or includes features that are designed to provide multi-sensory play opportunities such as logs, rocks, sand or water. The requirements in this section are intended to ensure that new or redeveloped outdoor play spaces are accessible to children and caregivers of all abilities.

Current standards require that outdoor play spaces incorporate accessibility features such as sensory and active components to aid children and caregivers with various disabilities. These spaces must also ensure that the ground surface is firm, stable and clear to prevent any injuries for children and caregivers using the play space.

They also require obligated organizations and the Government of Ontario to consult with the public and persons with disabilities when constructing new or redeveloping existing play spaces. Municipalities must also consult with their designated Accessibility Advisory Committees, if they have one established, for any new outdoor play spaces or changes to existing play spaces in their jurisdiction.

Committee discussion

The committee found that the current requirements for these spaces do not adequately ensure a fully accessible experience for all users. They discussed which organizations are obligated to follow the requirements and the potential to extend these requirements to private and not-for-profit organizations’ play spaces. The members also spoke about playground equipment, slopes and railings and what would be most useful for mobility aids users such as ensuring there is edge protection on playground equipment. Tactile indicators, visual and auditory play components, along with surface changes so persons with visual impairment are aware of when they are nearing play equipment were also discussed.

Maintenance activities were also discussed with the intent of ensuring safety as well as how consultation practices could improve to ensure that play spaces are safe and accessible for all. In addition, the application of these requirements to splash pads were also examined.

Recommendations

Recommendation 24: authoritative guidance for outdoor play spaces

Intended outcome: To provide authoritative guidance to developers in creating accessible outdoor play spaces.

The committee recommends:

• government shall develop in collaboration with accessibility stakeholders and obligated organizations a comprehensive authoritative guidance resource that considers the minimum requirements in regulation in addition to best practices and universal design principles to assist obligated organizations in creating accessible outdoor play spaces
• the development of this resource shall include a thorough scan of current guidelines, best practice documents and all relevant research, and consultation with accessibility professionals, Accessibility Advisory Committees and members of the public

Implementation timeline: Within three years of regulation being adopted.

Recommendation 25: improving accessibility design requirements for outdoor play spaces

Intended outcome: To provide prescriptive requirements for outdoor play spaces to improve overall accessibility and safety.

The committee recommends:

• outdoor play spaces, which includes play space equipment, ground surfaces and paths leading to such equipment, shall use materials that prevent barriers and enable interactive participation for the broad spectrum of children and caregivers of a variety of abilities
• obligated organizations shall ensure that their multi-year accessibility plans include the following:
  • procedures for preventative and emergency maintenance of the accessible elements in outdoor play spaces which includes play space equipment and paths leading to such equipment
  • procedures for dealing with temporary disruptions when accessible outdoor play spaces are not in working order. Notice of the disruption must include the reason for the disruption, its anticipated duration and a description of alternative facilities or services, if any, that are available
• maintenance of outdoor play spaces and the accessible path of travel leading to such equipment shall be prioritized
• outdoor play spaces shall include nearby seating on an accessible path of travel
• outdoor play spaces shall include a variety of sensory play components
• outdoor play spaces shall include consistent tactile features and surface elements (for example, tactile attention indicators on stairs or unprotected edges) on surfaces of play spaces and visual contrast elements to indicate steps, slopes and/or changing surfaces
• delineation of play space needs to be made so that people can travel safely around the play space
• outdoor play spaces, including the space around play space equipment, shall provide direct access with no step or level change, beyond requirements for drainage
• outdoor play spaces shall have firm, stable, level paths of travel leading from sidewalks and/or parking lots to the entire play space
• similar to trail requirements, outdoor play spaces shall require signage at access points and provide this information in multiple accessible formats (for example, website, QR code)
• outdoor play spaces must be designed to prevent injury, where appropriate
• where provided, amenities such as drinking fountains or waste facilities must be adjacent to or along the accessible path of travel to ensure that a person with a disability can use them independently
• in addition, government shall review and amend the accessibility in design requirements of outdoor play spaces (s. 80.20), according to best practices, universal design principles and standards that exceed the current requirements from similar jurisdictions, and shall consult with accessibility professionals, Accessibility Advisory Committees and members of the public to ensure new requirements meet the needs of people with a variety of disabilities

Implementation timeline: Within two years of regulation being adopted.

Recommendation 26: dog off-leash areas

Intended outcome: To provide dog off-leash areas that accommodate both persons with disabilities and the free movement of non-working dogs.

The committee recommends:

• the government must develop standards for dog off-leash areas, including but not limited to accessible parking, designated accessible path of travel, entrance (gate), interior space that is suitable for persons with mobility devices (firm and stable surface), rest areas, accessible signage and accessible waste receptacles

Implementation timeline: Immediately upon adoption into regulation.

Exterior paths of travel

Recommendations under the design of public spaces standards in the AODA.

Introduction

Ensuring the accessibility of external paths, such as sidewalks, is of paramount importance to create an inclusive and barrier-free environment for all individuals.

Sidewalks are essential elements of public infrastructure, serving as crucial pathways for pedestrians, including those with mobility challenges and disabilities. By making sidewalks accessible, we enable all people, including those who use wheelchairs, walkers or have difficulty walking to navigate freely and safely, promoting their independence and participation in community life.

Moreover, accessible sidewalks benefit parents with strollers, older adults and anyone with temporary or permanent mobility limitations, ensuring equal access to public spaces, amenities and services, and fostering a more inclusive and equitable society.

Committee discussions

The committee discussed how the current standards for external paths may lead to inconsistent accessibility experiences across municipalities. The standards do not address portable ramps, bike usage on paths or lighting requirements.

Updating the standards for tactile walking surface indicators, stairs and considering rest areas during path consultations would reflect current best practices. Temporary obstructions and the placement of permanent infrastructure further hinder accessibility on exterior paths, and insufficient requirements for passing areas and bridges may limit mobility device access.

Addressing these shortcomings in the standards would greatly enhance accessibility and ensure a barrier-free experience for all individuals.

Recommendations

Recommendation 27: expand requirements to small organizations

Intended outcome: To require all requirements for exterior paths of travel to be met by obligated small organizations.

The committee recommends:

• all small organizations shall meet the requirements outlined in the exterior path of travel section under the design of public spaces standards
• these requirements shall be applied retroactively to small organizations that were previously exempt

Implementation timeline: Within five years of regulation being adopted.

Recommendation 28: wider exterior paths of travel

Intended outcome: To eliminate the possibility of a narrow sidewalk that restricts accessibility and enable two-way travel and/or two mobility device users to pass one another.

The committee recommends:

• all new and redeveloped exterior paths must have a minimum clear width of 1,800 mm or 1,500 mm where site/physical constraints exist (for example, restricted space, heritage/environmental concerns)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 29: consideration of bridges as paths of travel

Intended outcome: To ensure that bridge redevelopment incorporates a minimum level of accessibility features.

The committee recommends:

• the government shall develop authoritative guidance related to the installation of accessibility features on bridges
• this guidance shall consider exceptions related to load constraints and measures that may be implemented to ensure safe and accessible paths of travel for all persons, which may include, but is not limited to, guards, tactile walking surface indicators, etc.

Implementation timeline: Within two years of regulation being adopted.

Recommendation 30: requirement to build sidewalks on existing streets or as part of redevelopment

Intended outcome: To require municipalities to provide sidewalks for all thoroughfares.

The committee recommends:

• when redeveloping and/or widening thoroughfares where there is no exterior path of travel, municipalities shall install accessible exterior paths of travel on both sides of the thoroughfare
• government shall develop a list of exceptions where municipalities are allowed to have only one accessible exterior path of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 31: pathways to accessible areas

Intended outcome: To require the design and construction of connections between accessible spaces to have a continuous, firm and solid surface with no interruptions.

The committee recommends:

• the design of public spaces standards shall be amended to require the design and construction of connections between accessible spaces (for example, playground, parking, sidewalk) that have a continuous, firm and solid surface with no barriers to access

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 32: temporary obstructions to exterior paths of travel

Intended outcome: To prevent temporary obstructions from blocking accessible paths of travel and requiring indication to signal an accessible path of travel during temporary disruptions.

The committee recommends:

• where an organization creates a temporary obstruction along an exterior path of travel (for example, construction, sidewalk patio, etc.), that organization shall ensure accessibility is maintained by creating an accessible path of travel around the obstruction that is clearly indicated and signed
• organizations shall indicate the temporary disruptions electronically through their websites
• where the organization is a municipality and the obstruction is long term, municipal Accessibility Advisory Committees shall be consulted along with persons with disabilities on temporary disruptions
• consideration shall be made for installation of portable ramps and accessible washrooms during temporary disruptions

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 33: infrastructure objects may reduce accessibility

Intended outcome: To avoid barriers in a public path of travel and prioritize pedestrian accessibility.

The committee recommends:

• a minimum width of 1.5 m of travel must be maintained along exterior paths of travel where permanent or temporary infrastructure (for example, street furniture, garbage cans, poles, etc.) is placed

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 34: wider allowances for gates and entryways

Intended outcome: To require curbs, gates and entryways to allow passage by persons using a mobility device and be navigable by persons with visual disabilities.

The committee recommends:

• the entrance to the exterior path of travel must provide a clear opening of 920 mm to 1000 mm, whether the entrance includes a gate, bollard or other entrance design
• if bollards are installed, the bollards shall have colour contrast to assist persons with vision disabilities
• include visuals in the standards to depict these requirements

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 35: technical requirements for portable ramps

Intended outcome: To ensure accessibility while managing safety for others on exterior paths.

The committee recommends:

• if impractical to install a permanent ramp or other means of access, the province shall promote the use of temporary, portable ramps for businesses that have step barriers
• this includes educating municipalities on the development of by-laws that include considerations for temporary ramps
• province shall create a best practice document to address specifications, procurement and placement, etc. of portable ramps
• the province shall develop customer service measures to ensure persons with disabilities know how to request and access portable ramps (that is, signage, website, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 36: visual and tactile identification of bike paths

Intended outcome: To provide clearly marked biking infrastructure that is accessible to persons who are blind, visually impaired and the elderly.

The committee recommends:

• install tactile walking surface indicators where all pedestrian and bike lane infrastructure intersect to ensure that people are alerted of non-pedestrian traffic (for example, vehicle or bicycle):
  • to be retroactively installed when new bike paths are installed along vehicular intersections and crossings
• government shall conduct research on best practices and collaborate with Ministry of Transportation to ensure consistency and safety remain a top priority in the design of bike lanes (for example, bike lanes that are adjacent and level with pedestrian paths of travel, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 37: accessible pedestrian signals

Intended outcome: To ensure that persons with disabilities can safely navigate the use of accessible pedestrian signals and cross safely at pedestrian crossings.

The committee recommends:

• require that accessible pedestrian signals be installed at the back of the exterior path of travel, away from the road:
  • accessible pedestrian signals shall be placed away from parallel traffic and in a location that doesn’t impede with a clear path of travel
  • poles shall be placed at the back edge of the accessible path of travel in a way that maintains a person’s safe, accurate and convenient crossing alignment
• the province shall consult on the language in this requirement with orientation and mobility specialists prior to its enactment, to ensure clarity
• the province shall provide example images. An image shall be included showing a 1.8 m sidewalk, against a building, as a constrained example
• the province shall create a guideline to ensure consistency across Ontario jurisdictions

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 38: lighting requirements

Intended outcome: To ensure a safe and properly illuminated path of travel.

The committee recommends:

• government shall develop requirements for lighting of exterior paths of travel based on best practice of other jurisdictions and standards:
  • these requirements shall consider number and distance between lighting fixtures as well as brightness and colour of light
• government shall develop a set of guidelines on lighting requirements for a range of outdoor paths of travel and according to specific conditions (for example, change of elevation, direction, arrival to key amenities such as picnic areas, that meets the Ontario Building Code)

Implementation timeline: Within a year of regulation being adopted, precedent from other jurisdictions.

Recommendation 39: signage requirements

Intended outcome: To ensure adequate signage is provided along exterior paths of travel, with information on accessibility features.

The committee recommends:

• where signage may assist in accessing amenities along exterior paths of travel, such signage shall:
  • provide an overview of amenities and paths of travel available, including availability of accessible washrooms
  • provide braille, QR codes, photoluminescence, etc., printed in large font formats, have identifiable colour contrast, and provide blade sign options
• obligated organizations shall ensure that information provided in their signage be extended electronically to their websites/apps

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 40: tactile walking surface indicators

Intended outcome: To ensure consistency in the design, installation and usability of tactile walking surface indicators in public spaces.

The committee recommends:

• where a curb cut is required under the design of public spaces standards or the Ontario Building Code, tactile walking surface indicators shall conform to ISO 23599, “Assistive Products for Blind and Vision-Impaired Persons — Tactile Walking Surface Indicators”
• the design of public spaces standards requirements shall have better alignment with Canadian technical and design requirements for applications of tactile walking surface indicators along the pedestrian path of travel and shall be integrated under the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 41: amend standards for stairs and ramps

Intended outcome: To improve safety on stairs and ramps for all users along exterior paths of travel.

The committee recommends:

• update design of public spaces standards for stairs and ramps to include all current best practices found in Accessibility Standards Canada and CSA Group’s CSA/ASC B651, Accessible design for the built environment, such as:

• colour contrast and slip resistance material must wrap around nosing of all stairs (top and riser face edges)
  • stair nosings must be flush or slope at an angle greater than 60 degrees to avoid creating a tripping hazard
  • handrails must have contrast to mounting surfaces
  • horizontal handrail extensions at top and bottom must extend and terminate with a return to post, wall or floor
  • railings must be continuous through flights of stairs, landings and at changes of direction
  • ramps must have colour contrast and slip resistant bands that extend the full width of the ramp at the start and end of each run
  • ramps with two or more consecutive slopes must be of the same slope ratio
  • ramps and stairs must be well lit when located in an area that is expected to be lit and in a manner that reduces shadows or pools of light
  • ramps must be provided in a convenient location along a main route to an entrance
  • directional signage to the ramp must be provided if the ramp location is not obvious
  • all steps and ramps must have adequate drainage
  • stairs and ramps must have adequate overhead clearance

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 42: requirement for rest areas

Intended outcome: To require the development of rest areas to involve consultation with persons with disabilities.

The committee recommends:

• consultation requirements for rest areas under the design of public spaces standards (s. 80.29) shall involve persons with disabilities and consultations shall consider the following:
  • types of rest area provided (for example, accessible benches, etc.)
  • number of rest areas provided
  • amenities provided
• where consultations lead to the installation of rest areas, these rest areas shall:
  • be located on a level and firm surface
  • include multiple types of rest areas (for example, benches) with a variety of arm rest supports to accommodate people with a variety of disabilities
  • include level and firm surface next to rest area (for example, benches) to allow for service animals and mobility devices
  • not impede the accessible exterior path of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 43: outdoor washrooms

Intended outcome: To require public washrooms to include an accessible stall and be connected by accessible paths of travel.

The committee recommends:

• the government shall require accessible options to be provided when washrooms are made available for public use
• multi-stall washrooms shall have at least one accessible water closet (with all required accessibility features)
• where portable toilets are provided (in any design of public spaces standards regulated facilities), at least one shall be the larger, accessible size
• where handwashing facilities are provided, they shall be required to be accessible to a person who is in a seated position and not foot activated
• washrooms shall be connected to all other facilities by an accessible path of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 44: outdoor changerooms

Intended outcome: To require that all outdoor public spaces where changerooms are available include an accessible option.

The committee recommends:

• the government shall require accessible options to be provided in changerooms available for public use
• multi-stall changerooms shall have at least one accessible size stall with a bench and appropriate grab bar placement
• all changerooms shall be connected to facilities by an accessible path of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 45: mobility device charging stations

Intended outcome: To make mobility device charging stations available and accessible to all users.

The committee recommends:

• government do research (for example, interjurisdictional scan and consultation with municipalities and persons with disabilities) into developing standards for providing accessible charging stations for mobility devices along exterior paths of travel and interior areas

Implementation timeline: Immediately upon receipt of the Standards Development Committee’s final recommendations report.

Accessible parking

Recommendations under the design of public spaces standards in the AODA.

Introduction

Accessible parking requirements provide minimum standards for the installation of parking spaces accessible to persons with disabilities and who may require greater space for embarking and disembarking from vehicles in a safe manner. Included in the standards are requirements for both on-street and off-street parking.

Currently, off-street parking facilities must accommodate the needs of persons with disabilities with the installation of two types of parking spaces with different measurements (type A and B). There are also requirements for signage of accessible parking spaces as well as consultation requirements when designated public sector organizations install new or redevelop existing on-street parking spaces.

Committee discussion

The committee discussed the requirements of accessible parking spaces such as accessible paths to these spaces, protection of accessible on-street parking spaces, and what designates inclusive parking for persons with disabilities and older adults. The members also focused on clarifying type A and B parking spaces, how self-serve kiosks in parking facilities may be made more accessible, the materials used for parking lots, and the accessibility of electric vehicle charging stations.

We brought up barriers that occur from improper use of accessible parking spaces as well as discussed how to increase the minimum number of accessible parking spaces in the standards and how to ensure that persons with disabilities from smaller rural municipalities have the same level of access to these types of parking spaces. The committee also explored through discussions creating a comprehensive communication plan for accessible parking in Ontario in addition to a resource guide to facilitate compliance.

Recommendations

Recommendation 46: accessibility of parking pay stations

Intended outcome: To require the placement and design of pay stations in parking lots to be accessible.

The committee recommends:

• the placement and design of automated kiosks in parking facilities shall be accessible. The committee recommends that accessible automated kiosks shall:
  • be placed such that kiosks provide barrier-free travel to accessible parking spots
  • be placed at a maximum of 20 m from an area designated for accessible parking
  • parking facilities shall include multiple automated kiosks based on size of parking facility
  • provide self-serve kiosks that are accessible to people of all abilities
  • signage be provided indicating location of automated kiosks and that this signage includes the information needed to use payment apps

Implementation timeline: Within three years of regulation being adopted.

Recommendation 47: authoritative guidance on accessible parking

Intended outcome: To provide obligated organizations guidance on accessible parking requirements to ensure understanding and compliance.

The committee recommends:

• government shall develop in collaboration with accessibility stakeholders for obligated organizations a comprehensive authoritative guidance resource
• the resource shall advise on the requirements of regulation in addition to best practices, universal design principles and all other related research to assist obligated organizations in creating accessible parking facilities
• the development of this resource shall include a thorough scan of current guidelines and best practice, and consultation with accessibility professionals, Accessibility Advisory Committees and members of the public

Implementation timeline: Within two years of regulation being adopted.

Recommendation 48: changing parking requirements to type A spaces only

Intended outcome: To ensure that no person is ever in an accessible parking space they cannot manoeuvre around.

The committee recommends:

• amend the parking regulations such that all accessible parking spaces meet requirements for type A spaces

Implementation timeline: Within one year of regulation being adopted.

Recommendation 49: clarify application of standards for off-street parking

Intended outcome: To promote application of provincial accessible parking requirements and prevent confusion for developers in the building of accessible parking facilities.

The committee recommends:

• amendment be made to the application of off-street parking (s. 80.32) and that the accessible parking requirements be applicable to both facilities intended for “public” and “private” use
• where there may be confusion as to the application of the accessible parking requirements under the design of public spaces standards, that government create a schedule and include this schedule in the standards outlining all exceptions to the requirements

Implementation timeline: Within five years of regulation being adopted.

Recommendation 50: parking lot path of travel

Intended outcome: To ensure there are universal accessible paths of travel from parking space to intended destinations (that is, main entrance or adjacent amenities).

The committee recommends:

• accessible parking must be located on a flat surface with a maximum cross slope that does not exceed 2%
• parking must be connected to an accessible path of travel (for example, delineated path, sidewalk) with a maximum running slope of 1-in-20 (that is, 5%) and a cross slope that does not exceed 2%
• where infrastructural needs (for example, drainage) require greater slopes, these will be located to minimize their impacts and ensure the greatest level of accessible parking and path of travel

Implementation timeline: Within one year of regulation being adopted.

Recommendation 51: requirements for on-street parking

Intended outcome: To add technical guidance or standards in order to ensure that accessible on-street parking meets the needs of drivers and passengers.

The committee recommends:

• the province shall investigate best practices to develop standards for on-street parking and sidewalk/road access that could complement the existing consultation requirement
  • for example, accessible routes shall not require persons who have disabilities to cross a driveway aisle or to interfere with vehicular routes
• consideration shall be given to providing access to both passengers and drivers who have disabilities by providing access aisles at each side of the parking stalls that require parallel parking, where space exists
• municipalities shall be required to designate accessible parking spaces, upon request, where practical (for example, in front of a residence where no driveways are present)
• municipalities shall be required to have plans in place to ensure and protect existing on-street parking for persons with disabilities (this could be considered in the multi-year accessibility plan)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 52: increased parking requirements

Intended outcome: To ensure an appropriate amount of accessible parking spaces to meet the needs of drivers and passengers with disabilities.

The committee recommends:

• the province shall reconsider the percentage of accessible spaces, based on more current demographic data
• the standards for accessible parking spaces shall be consistent (for example, 4%) and not decrease in percentage based on the number of parking lot spaces, as it currently does
• The placement of spaces for persons with disabilities shall be prioritized over other users (for example, new parents, electric vehicle charging)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 53: enhanced parking requirements for specific sectors

Intended outcome: To ensure an appropriate amount of accessible parking spaces to meet the needs of drivers and passengers accessing essential service sectors and obligated organizations.

The committee recommends:

• the province shall require these sectors to meet a higher percentage of accessible parking spaces, based on evidence such as updated user/demographic data of accessible parking pass users
• as this requirement would be based on the type of services being provided, the province shall develop a list of these categories for inclusion in the standards (for example, medical facilities, recreational facilities, seniors’ residences, cultural centres, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 54: maintenance requirements for accessible parking

Intended outcome: To ensure accessible parking spaces are always available and accessible.

The committee recommends:

• organizations must prevent obstructions to parking spaces and pathways leading to these spaces at all times
• obligated organizations shall ensure that their multi-year accessibility plans include procedures for preventative and emergency maintenance in parking lots, including paths to parking lots
• repainting lines shall be considered redevelopment for the purposes of triggering accessible parking lot requirements when there are no other resulting infrastructure costs (for example, curb cuts, path of travel)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 55: firm and stable materials for parking lots

Intended outcome: To ensure the materials used for parking lots do not negatively impact accessibility and spaces and access aisles are clearly marked.

The committee recommends:

• ensure accessible parking spaces have a surface with appropriate materials and meets AODA standards. Surfaces shall be firm and stable
• consider use of additional visual cues such as posts or landscaping to replace the role of a painted access aisle if surfaces cannot be painted (for example, gravel parking surface)

Implementation timeline: Within one year of regulation being adopted.

Recommendation 56: parking ratios across multiple parking sites

Intended outcome: To ensure parking spaces are located along safe and accessible paths of travel that lead to the connected facility or location.

The committee recommends:

• the total number of accessible parking spaces shall be determined based on the combined number of accessible spaces required for all of the separate parking facilities and shall be located near all accessible entrances
• the location of the accessible parking spots shall be safe and allow barrier-free access in and out of the parking lot
• in multilevel parking lots, accessible spaces shall be placed on the ground or entrance level, so the spots provide access to the accessible entrance and are adjacent and connected to elevator banks or higher floors
• where more than one parking facility is provided at a site:
  • ensure the number and type of accessible parking spaces provided is determined based on the number of parking spaces required for each of the separate parking facilities
  • locate and distribute accessible parking spaces among the off-street parking facilities in a manner that provides greater accessibility in terms of distance from an accessible entrance or user convenience (for example, protection from weather, accessible lighting, security, etc.)

Implementation timeline: Within three years of regulation being adopted.

Recommendation 57: connecting parking access aisles to sidewalks

Intended outcome: To ensure a safe path of travel is provided from accessible parking to exterior path of travel such as a sidewalk.

The committee recommends:

• wherever possible, accessible parking to be located adjacent to exterior path of travel
• accessible parking access aisles be directly connected to exterior path of travel with curb cuts
• any guidance materials on the design of public spaces shall include information on how to provide safe paths of travel in various situations

Implementation timeline: Within one year of regulation being adopted.

Recommendation 58: electric vehicle charging stations

Intended outcome: To ensure the accessibility of electric vehicle charging stations while not reducing the number of accessible parking spaces offered at a facility.

The committee recommends:

• all electric vehicle charging spaces shall be meet the specifications for Type A spaces for size and transfer aisle, but need not be designated for accessible use only
• electric vehicle charging stations and controls shall be accessible and be placed on a barrier-free path of travel (that is, no curb as a barrier)
• electric vehicle charging spaces shall be placed in locations close to a facility’s entrance, but priority must be given to accessible parking spaces
• municipalities that install electric vehicle charging spaces must include information on the protection of accessible parking spaces in their multi-year plan, and how electric vehicle charging will consider accessibility

Implementation timeline: Within two years of regulation being adopted.

Recommendation 59: repainting accessible parking spaces

Intended outcome: To require organizations to improve accessible parking when not making major renovations.

The committee recommends:

• require organizations to re-evaluate accessible parking spaces in existing parking lots to accommodate the design of public spaces standards requirements for Type A accessible parking spaces before repainting to align with new regulations, where parking lot conditions allow (for example, slope, surface)
• previously exempted organizations will also be required to create accessible spaces when repainting parking lots
• suggest that the province provide guidance/encouragement for all sectors to update their accessible parking layout to become compliant with current standards for accessible parking

Implementation timeline: Within two years of regulation being adopted.

Recommendation 60: retrofits for specific sectors

Intended outcome: To require obligated organizations to retrofit existing inaccessible parking facilities.

The committee recommends:

• require obligated organizations (for example, public sector, medical, education, commercial) to include in their multi-year plan actions to meet the current standards for accessible parking spaces
• implement a provincial task force to work with municipalities to revise parking standards to accept lower total parking numbers in existing lots in lieu of increasing the number of accessible spaces and allowing obligated organizations to bring the infrastructure into concordance with current AODA requirements

Implementation timeline: Within five years of regulation being adopted.

Recommendation 61: signage for access aisles

Intended outcome: To stop the misuse of access aisles and allow persons with disabilities to enter and exit their vehicle.

The committee recommends:

• where possible, require access aisles for accessible parking spaces to be identified by a sign as well as always maintained and cleared for access by persons with disabilities. When possible, vehicle access to the aisle shall be prevented (for example, with a bollard or signpost)
• the province shall undertake a communications campaign to improve public understanding of accessible parking and access aisles and provide information (for example, visual guidance, best practices) for obligated organizations

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 62: signage for accessible parking

Intended outcome: To require signage indicating the number and location of accessible parking spaces of a facility.

The committee recommends:

• parking facilities shall be marked at their entrances with the number and location of accessible parking spaces in relation to each accessible entrance

Implementation timeline: Within two years of regulation being adopted.

Recommendation 63: prevention of reduced access to accessible parking during temporary disruptions

Intended outcome: To prevent the loss of accessible parking spaces during temporary disruptions.

The committee recommends:

• obligated organizations shall create a parking strategy for temporary disruptions to accessible parking that shall be triggered by construction or site plan approval processes
• the province shall launch awareness campaigns outlining reasons to maintain accessible spaces (that is, change the way people think about the need for accessible parking)

Implementation timeline: Within one year of regulation being adopted.

Recommendation 64: passenger loading zones

Intended outcome: To address issues related to safe entry and exit from vehicles.

The committee recommends:

• signed and identifiable passenger loading zones shall be located at specified intervals in highly urban areas
• develop regulations for passenger loading zones for event centres, education, medical facilities, community centres, etc.

Implementation timeline: Within one year of regulation being adopted. To be implemented as areas are being redeveloped.

Recommendation 65: underground and covered parking facilities

Intended outcome: To ensure accessible parking is available in all parking facilities, including underground and covered parking facilities.

The committee recommends:

• the government shall include clarifying information in the design of public spaces standards related to underground and covered parking facilities
• all recommendations from this committee related to parking facilities would also apply to any underground and covered parking facilities
• underground and covered parking facilities shall also consider the use of convex mirrors as a safety measure
• where it is unfeasible to provide underground parking with accessible height clearance, alternative covered accessible parking shall be provided

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 66: overhead clearance for accessible parking

Intended outcome: To ensure all users of accessible parking spaces with larger vehicles have access.

The committee recommends:

• the government shall incorporate a minimum 3000 mm overhead clearance for type A accessible parking into the design of public spaces standards to align with national standards

Implementation timeline: Immediately upon adoption of regulation.

Obtaining services

Recommendations under the design of public spaces standards in the AODA.

Introduction

Accessibility in the design of service counters, fixed queuing guides and waiting areas is an important part of making services and products available for persons with disabilities. The requirements in this section address these customer service features.

The requirements in this section apply to all new counters and fixed queuing guides. They also apply to all new and redeveloped waiting areas with fixed seating. Any of these features can be located either indoors or outdoors.

Committee discussion

The committee spoke about how obligated organizations often seek authoritative guidance to ensure compliance with regulations. For individuals who are deaf, deafened or hard of hearing, accessing services can be challenging without the support of assistive technologies like audio induction loops, FM, infrared and Bluetooth systems.

Recommendations

Recommendation 67: authoritative guidance for obtaining services

Intended outcome: To provide specific guidance to obligated organizations for the design and construction of service counters and/or queuing guides in improving accessibility.

The committee recommends:

• government shall develop in collaboration with accessibility stakeholders and obligated organizations a comprehensive authoritative guidance resource that considers the requirements in the regulations in addition to best practices and universal/inclusive design principles to assist obligated organizations in creating accessible and convenient service features as outlined in the “obtaining services” section of the standard
• the development of this resource shall include a thorough scan of current guidelines and best practices, and consultation with accessibility professionals, Accessibility Advisory Committees and members of the public
• this resource will provide greater access for all persons with disabilities including people with mobility aids (for example, wheelchair, scooter), people with lower stamina or individuals who may need to set aside a walker, rolling case or stroller to use the counter surface
• This resource shall include consideration for:
  • a choice of counter heights and speaking ports. Specific consideration shall be made for lower counters with an available chair to benefit those with lower stamina or those that need to set aside a mobility device
  • sufficient knee and toe space is required to access the counter
  • sufficient clear floor/ground area must be provided for approach and so a person can turn around without having to back up
  • Point of Sale (POS) devices at service counters must be placed so that they can be independently reached and privately operated by all patrons

Implementation timeline: Within two years of regulation being adopted.

Recommendation 68: provision of assistive listening devices for obtaining services

Intended outcome: To ensure that deaf, deafened and hard of hearing individuals receive accessible service.

The committee recommends:

• obligated organizations shall be required to integrate adaptive technologies to support accessibility and communication, including public Wi-Fi, Bluetooth and adaptive and evolving technologies
• consultation with stakeholders is required, as part of an obligated organization’s development of their multi-year accessibility plan:
  • information on how an obligated organization is integrating technologies to ensure accessibility for persons who are deaf, deafened or hard of hearing will be outlined in the multi-year accessibility plan
• assistive listening device requirements under the design of public spaces standards shall be equivalent to or exceed requirements in the Ontario Building Code, such as requiring service counters to implement hearing induction loops

Implementation timeline: Within three years of regulation being adopted.

Maintenance

Recommendations under the design of public spaces standards in the AODA.

Introduction

The maintenance requirements currently outlined under the standards intend to ensure that obligated organizations consistently retain safe and accessible spaces. These requirements address the need for obligated organizations to document in their multi-year accessibility plans the procedures for preventative and emergency maintenance as well as procedures for temporary disruptions to accessibility elements covered by the standard.

Committee discussion

The committee revisited the issues of the maintenance of accessibility throughout their discussions. Specifically, members addressed issues and barriers typically found from interior hallways used as storage areas creating inaccessible paths for people in mobility devices to snow accumulation or the creation of snowbanks from snow removal reducing the width of sidewalks reducing accessibility.

The committee discussed enhancing maintenance requirements and providing guidance materials to the public to help in their understanding of maintenance barriers. Also addressed in discussions was the need to clarify language in the regulation and redefine the term “maintenance” in the standards to ensure greater compliance.

Recommendations

Recommendation 69: redefine maintenance

Intended outcome: To provide more specificity in the definition of “maintenance” in the design of public spaces standards.

The committee recommends:

• alter the definition of maintenance in s. 80.44 in order for it to be measurable addressing the specific risks/barriers that need to be mitigated (for example, construction, garbage, snow, leaves, water, ice, sand), and establish standards for care, cleaning and repair, to maintain accessibility elements, features and amenities in good order and safe condition
• ensure maximum level of usability, safety and operability of accessibility elements, features and amenities (for example, power door opener, accessible pedestrian signals, accessible path of travel) in conformance with the design of public spaces standards
• introduce requirements for maintenance plans that address inspections, testing and preventative maintenance, waste handling (for example, garbage, leaves, branches) and construction site protection (for example, hoarding, signage, alternative path of travel)
• when critical accessible elements (for example, power door openers, elevators, etc.) are inoperable, accessible alternatives shall be provided
• include requirements for maintaining required clear floor space in public spaces (for example, ensure that floor space is not used for storage purposes)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 70: language around intent to maintain

Intended outcome: To clarify sections of the standards regarding the “intent to maintain” to improve understanding, compliance and accessibility.

The committee recommends:

• the government shall remove “that an obligated organization intends to maintain” from all requirements in the design of public spaces standards so that all new or redeveloped elements follow all accessibility requirements pertaining to each section of the design of public spaces standards to be safe, convenient and accessible, as well as to be maintained
• for example, the following section would be reworded:
  • beach access routes
    80.7 this part applies to newly constructed and redeveloped beach access routes including permanent and temporary routes and temporary routes that are established through the use of manufactured goods, which can be removed for the winter months

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 71: Maintenance requirements

Intended outcome: To clarify expectations for obligated organizations, and prioritize accessibility in all maintenance activities, including temporary disruptions such as construction.

The committee recommends:

• each unique section of the design of public spaces standards (s. 80.44 — after each section of the standards refer to 80.44) shall have specific recommendations for how the space shall be maintained. For example:
  • beach access routes:
    • must be maintained to regularly (that is when the beach is being groomed) remove sand, stones or other debris that has collected on the surface of the access route (that is, boardwalk or Mobi-Mat)
  • parking lots:
    • parking stalls shall be repainted every year with the International Symbol of Accessibility (ISA), transfer aisles and vertical parking signs checked to be in place and in good working order
• maintenance shall consider both indoor and outdoor public spaces. For example:
  • outdoor: furniture, fixtures and equipment, etc.
  • indoor: plumbing, structural, electrical, doors, walkways, HVAC, etc.
  • both indoor and outdoor: replacing colour contrast where it has faded from a step edge or riser or top and bottom of slopes on ramps, etc.
• special circumstances or temporary disruptions to accessible areas (that is, construction) must always include a plan that allows people continuous barrier-free access to the site as well as egress during an emergency
• consideration shall be given to the process of completing maintenance. That is, when an area needs to be closed for non-emergency or planned maintenance, and this area provides barrier-free access, the alternative shall also provide barrier-free access
  • example: if washrooms are closed at a park, accessible portable units are brought in while maintenance is being completed
• maintenance and its relationship to accessibility must clearly be prioritized in master plans, operational plans and in budgets
  • (as outlined in Nova Scotia’s Recommendations on Accessibility Standard in the Built Environment: Phase 2)
• municipalities must consider accessibility and maintenance in their practices beyond snow removal, to include downed trees/branches, sand that has encroached on beach access and other temporary or seasonal disruptions
• obligated organizations must provide publicly accessible records of maintenance work done in their multi-year annual plan
• obligated organizations shall ensure that beach access routes that they construct or redevelop, include a maintenance program to meet the intent of maintenance requirements and ensure that the technical requirements are maintained according to the guidelines from the manufacturer of materials used and/or as per industry best practices

Implementation timeline: Within two years of regulation being adopted.

Recommendation 72: requirement for maintenance and/or creation of corresponding elements

Intended outcome: To ensure safe traversals for all users of intersections and crosswalks, and safe and consistent traversal planning.

The committee recommends:

• all corners of an intersection have accessibility features installed to ensure safe travel
• as intersections are maintained or redeveloped, municipalities must meet these requirements
• collaboration between ministries shall ensure that best practices are laid out and consistent with other jurisdictions

Implementation timeline: Within two years of regulation being adopted.

Additional recommendations

Recommendations under the design of public spaces standards in the AODA.

Committee discussion

In their discussions, the committee covered several issues that did not fit neatly into the sections outlined in the regulation. These included giving the design of public spaces standards more authority, similar to the Ontario Building Code, with mechanisms for compliance and monitoring built into the process, addressing the exemptions allowed under the Integrated Accessibility Standards Regulation, which may lead to inappropriate use and the creation of new barriers for individuals with disabilities, including images and figures in the standards to aid in better understanding and adherence to the guidelines, and emerging topics such as municipal challenges in planning and constructing environments that prioritize both sustainability and accessibility, and preparing public and private infrastructure for interoperability with automated vehicles is crucial to enhance mobility options for persons with disabilities throughout the province.

Recommendations

Recommendation 73: inclusion of diagrams in the standards

Intended outcome: To provide obligated organizations with easy access to illustrated representation of standards that must be met.

The committee recommends:

• the standards shall include diagrams to clearly demonstrate technical standards such as space, knee clearance, counter height, spacing of queuing systems and other requirements, as appropriate
• the province shall develop a resource, such as an online library, to collect all the design of public spaces standards related guidance materials together to ensure that obligated organizations have the information they need to properly implement the standards’ requirements

Implementation timeline: Immediately upon adoption of regulation and the province shall immediately begin work on the public resource to collect online guidance materials.

Recommendation 74: inclusion of images in the standards

Intended outcome: To provide obligated organizations with images and figures in the standards regulation to assist understanding of requirements.

The committee recommends:

• government shall include images and figures in the design of public spaces standards where images and/or figures may assist with the understanding of related requirements, and that alternate text be incorporated where images and/or figures are included for electronic versions of the standards

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 75: municipal enforcement of Integrated Accessibility Standards Regulation requirements

Intended outcome: To develop a process for compliance/monitoring of the design of public spaces standards that makes obligated organizations accountable for meeting their requirements and gives persons with disabilities an understanding of where to go for enforcement issues.

The committee recommends:

• the province shall require municipal licensing bodies to enforce the accessibility requirements in the Integrated Accessibility Standards Regulation in future re/developments
  • for example, authority shall be given to municipal licensing bodies to enforce the accessibility requirements in the Integrated Accessibility Standards Regulation in future re/developments

Implementation timeline: Within one year of regulation being adopted.

Recommendation 76: amend exemption section to prevent arbitrary decisions

Intended outcome: To ensure that organizations are accountable when applying exemptions under the design of public spaces standards.

The committee recommends:

• when deciding to apply exemptions, obligated organizations must have a process in place to mitigate any new barriers that may be created, by applying an accessibility lens
• exemptions shall be discussed according to established due processes with staff or experts with accessibility knowledge, with an Accessibility Advisory Committee and/or other committee, Council, legal counsel and/or the public
• organizations shall identify and document their exemptions to the requirements under the design of public spaces standards in their multi-year accessibility plans and annual status reports
• information on exemptions implemented shall be included in an obligated organization’s compliance report to the province

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 77: environmental sustainability and accessibility

Intended outcome: To ensure obligated organizations are supported to design for both environmental sustainability and accessibility.

The committee recommends:

• the government shall develop guidance materials related to environmental sustainability and accessibility that will include, but is not limited to:
  • how to weigh decisions related to the potential removal of mature trees to accommodate for wider sidewalks
  • the need for rest areas in shaded areas, and other amenities to ensure persons with disabilities are comfortable when using active transportation facilities
  • the protection of parking for persons with disabilities amidst competing priorities such as bike lanes
  • the consideration of permeable surfaces, including ensuring that these materials are maintained, level, firm and stable

Implementation timeline: Within two years of regulation being adopted.

Recommendation 78: impact of connected/autonomous vehicles

Intended outcome: To ensure persons with disabilities benefit from connected/autonomous vehicles for transportation, but still have access to “vehicle-free” areas as cities move towards more sustainable modes of traffic and redevelop their streets.

The committee recommends:

• the government shall undertake an interjurisdictional scan of current research and predictions for future applications regarding connected/autonomous vehicles with particular consideration for the following:
  • infrastructure shall be made available for connected/autonomous vehicles carrying a passenger with a disability to ensure seamless and safe travel (for example, designated pick-up/drop-off/loading zones with curb cuts allowing persons with disabilities to enter the vehicle with little to no assistance)
  • accessible parking shall be available within “vehicle-free” zones for persons with disabilities either driving or being transported by connected/autonomous vehicles, so they have equal access to facilities, stores, schools, hospitals, etc.
  • the design of connected/autonomous vehicles infrastructure ensures the safety and accessibility for persons with disabilities using mobility devices (for example, safe ramps for wheelchairs, walkers) and those who require visual and non-visual verification
  • lead ministries (for example, Ontario Ministry of Municipal Affairs and Housing, Ontario Ministry of Transportation) shall consult with the Ministry for Seniors and Accessibility and persons with disabilities in the development and approval of connected/autonomous vehicles infrastructure in Ontario
  • accessible connected/autonomous vehicle charging stations with particular attention to the convenience of locations

Implementation timeline: Immediately upon adoption of regulation.

Ontario Building Code general recommendations

Introduction

The Building Code Act and the Ontario Building Code establish definitions and the overall application new construction and extensive renovations. The Building Code also complements the design of public spaces standard.

The Building Code requires that most buildings except houses meet barrier-free standards when being constructed or in the areas undergoing major renovations. The Building Code sets out what areas of a building require a barrier-free path of travel and other accessibility features.

The ministry's qualification program establishes a minimum standard for individuals to show their knowledge of the Building Code in the technical area(s) in which they wish to work. Municipalities are responsible for additional training to support building officials in maintaining their knowledge.

Committee discussion

The committee had various discussions on topics that did not fit neatly into the existing requirements set out by the Ontario Building Code. Of note, were discussions around how best to support municipalities in meeting the barrier-free requirements under the code. These discussions focused on how to improve existing reporting and planning requirements that may support greater accountability and consideration for the accessible design of buildings.

Recommendations

Recommendation 79: update the Ontario Building Code with inclusive language

Intended outcome: To improve the language of the Ontario Building Code to be more inclusive by reinforcing the broad spectrum of disabilities, which may lead to more inclusive planning.

The committee recommends:

• require government to review and update the Ontario Building Code with more inclusive language to represent the broad spectrum of disabilities

Implementation timeline: Within a year of regulation being adopted.

Recommendation 80: accessibility strategy as a part of municipal land use studies

Intended outcome: To improve the application of accessibility best practices in the planning stages of municipal and private infrastructure.

The committee recommends:

• the government shall require municipal land use studies such as secondary plans and master plans to include a mandatory accessibility strategy as part of the tasks usually associated with such studies
• the government shall develop accessibility strategy guidelines and provide education to planners, staff, Accessibility Advisory Committees, etc., involved in the planning process, like recommendation 14 consultation:
  • this strategy shall identify the stages of a project where consultation is required
• the government shall require municipal planners to be educated about the design of public spaces standards requirements and apply them to the site review process
• Accessibility Advisory Committees shall be consulted in the development and update of master plans, including but not limited to transportation master plans and parks and facilities master plans

Implementation timeline: Immediately upon adoption of regulation.

Exterior and interior building elements

Recommendations under Ontario’s Building Code.

Introduction

The exterior and interior building elements requirements in Ontario’s Building Code establishes the minimum design and construction requirements to provide barrier-free access into and circulation within buildings, including dimensions and accessibility features. The intent is to ensure that a barrier-free path of travel is designed and constructed to address obstructions to allow for the passage of wheelchairs.

Current standards include requirements that most buildings must have a barrier-free path of travel throughout, and detail the design requirements for building entrances, turning spaces, ramp dimensions, passing and rest spaces, minimum doorway and corridor widths, power door openers and tactile walking surface indicators.

The Building Code requires that new buildings are required to provide barrier-free access between all floors. Barrier-free floor access is also required for residential and office buildings (except for houses).

Committee discussion

The committee heard that current requirements for barrier-free paths of travel in buildings are inconsistent, and there is a lack of mandate for power door openers on doorways leading to accessible spaces. Moreover, the entrance width requirements under the Ontario Building Code do not adequately accommodate persons with disabilities, while Tactile Walking Surface Indicators (TWSI) need to be consistently applied across the province.

In publicly accessible buildings such as workplaces and community centres, kitchen access is not consistently considered, and fitness and recreation facilities often lack design elements that cater to the needs of persons with disabilities, further limiting their accessibility and inclusivity. Public areas also need accessible signage, trash receptacles and gates to ensure reliability and convenience.

For individuals who use service animals, the provision of accessible relief areas with consistent features and amenities is crucial, either indoors or out.

Recommendations

Recommendation 81: doorways and doors on barrier-free path of travel

Intended outcome: To require all spaces on a barrier-free path of travel to have a power door opener.

The committee recommends:

• the government shall amend 8.3.3.3 (4) to say:
  • except as permitted by Sentence (12), every door that provides access to a barrier-free path of travel to a barrier free room or space through a barrier-free entrance required by Article 3.8.1.2. shall be equipped with a power door operator if the entrance serves a building containing a Group A, Group B, Division 2 or 3, Group C, Group D or Group E occupancy

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 82: harmonize width of barrier-free path of travel

Intended outcome: To ensure corridors and paths of travel to all amenities are wide enough to accommodate all users.

The committee recommends:

• sentence 3.8.1.3. (1) the width of the barrier-free paths of travel shall be increased to accommodate manoeuvring clearances around all amenities (for example, washrooms, etc.)
• the minimum clearance throughout paths of travel shall not overlap with required clearances in front of fixtures or operating controls (ensure terms are aligned with the Ontario Building Code)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 83: harmonize exterior accessible paths of travel

Intended outcome: To improve the accessibility of exterior barrier-free paths by aligning with current best practices.

The committee recommends:

• update Article 3.8.3.2 of the Ontario Building Code with the requirements for exterior accessible paths of travel found under CSA/ASC B651, Accessible design for the built environment, section 23

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 84: entrance width requirements

Intended outcome: To increase the clearances for accessible entrances/travel in the Ontario Building Code.

The committee recommends:

• the province shall amend the Ontario Building Code to enlarge clearance for accessible entrances
• government shall conduct research and jurisdictional scan, including anthropometric research, to identify the need for larger entrance width/clearance space requirements
  • consideration shall also be made for the spaces around entrances

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 85: service animal relief area

Intended outcome: To ensure that service animals and handlers alike can safely and reliably navigate and utilize indoor and/or outdoor animal relief areas.

The committee recommends:

• government shall review best practices, guidelines and other relevant research to develop a set of requirements for both the design of public spaces standards and the Ontario Building Code for the installation and maintenance of service animal relief areas for indoor and outdoor public areas
• this set of requirements shall include that service animal relief areas:
  • be installed in public buildings that are five storeys or larger than 14,000 m² (footprint threshold needs to be studied based on precedent cases)
  • be located adjacent to accessible paths of travel
  • be located at a convenient walking distance for service animals and their handlers (for example, be located no more than 300 m from all internal public use areas and accessible entrances)
  • include the installation of large print high-contrast signage to denote area and encourage responsible practices like keeping animals on a leash and cleaning up after use
  • signage shall also include a resource number or QR code for providing questions or feedback
  • include types of surfaces to be used that are pet-friendly while also providing difference in texture to assist those with vision impairment to identify the relief area
  • have good drainage and, where possible, a sprinkler system
  • be fenced and that the bottom of the fence be cane detectable as described by CNIB’s “Clearing our Path” resource
  • include a gate with magnetic latch that can be self-closed, and the gate be wide enough to allow for use by people with mobility devices
  • provide waste bag and trash receptacles consistently inside the entrance of the gated area
  • provide adequate lighting
  • provide sanitizing and handwashing stations
  • include prescribed size of relief area to allow for both the individual and animal to maneuver safely around the area
  • include requirements for the documenting of cleaning and maintenance and other operating procedures of the area

Implementation timeline: Within one year of regulation being adopted.

Recommendation 86: harmonize exterior ramps and stairs

Intended outcome: To improve the safety of stairs inside and outside buildings.

The committee recommends:

• the province shall harmonize the Ontario Building Code standards for stairs with CSA/ASC B651 5.4
• interior stair specifications shall align with CSA/ASC B651 5.4
• exterior stair specifications shall also align with CSA/ASC B651 8.2.8
• require for both exterior and interior ramps and stairs:
  • greater than 70% visual (luminance) contrast on the riser and nosing of stairs
  • handrail extensions provide the same level of contrast
  • visual contrast strips at the top and bottom of a ramp
  • continuous handrail along landings from floor to floor (where practical)
  • the handrail extension shall return to the post, wall or floor
  • stairs have no open risers

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 87: update doorway and door requirements

Intended outcome: To improve the safety for people navigating through and around doors inside and outside a building using recent best practices and research.

The committee recommends:

• align Article 3.8.3.3. Doorways and Doors with recent and relevant validated data on anthropometrics
• government shall complete a full review of the doorways and doors section of the Ontario Building Code (Article 3.8.3.3.) to ensure that doorways applicable to these requirements meet the needs of all people
• this review shall consider a jurisdictional scan and best practice research that includes CSA/ASC B651 5.2, including requirements for door widths, space for maneuvering, different types of doors, thresholds, hardware, opening force and power assist
• if this review finds that the Ontario Building Code requirements for doorways and doors are not wide enough to accommodate persons with disabilities and the variety of mobility aids used, government shall amend this section to ensure a greater level of accessibility is achieved
• examples include, but are not limited to:
  1. glazed doors shall have a continuous high-contrast strip that meets CSA/ASC B651 and is at two heights to provide visual cue for people who are seated, short in stature and for service dogs to see
  2. require luminance (colour) contrast (70% contrast) on door frames to help people locate doors more easily
  3. require swing path protection for outward opening doors (that swing out into a path of travel)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 88: update handrail requirements

Intended outcome: To improve the usefulness and safety of all handrail applications in public spaces.

The committee recommends:

• the province shall harmonize the Ontario Building Code standards for handrails with CSA/ASC B651 5.3 (handrails), 5.4.4 (stair handrails), and 5.5.8 (ramp handrails)
• Align with National Building Code regarding installation of second handrails

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 89: handrails and “rough surfaces”

Intended outcome: To ensure people can safely grasp a handrail, while preventing the railing from creating a hazard for persons with vision loss.

The committee recommends:

• amend Section 80.13.7.v to provide more clearance space between the handrail and any rough surfaced wall to which it is attached
• a space with clearance of 70 mm from the biggest protrusion on the wall

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 90: tactile walking surface indicator consistency

Intended outcome: To ensure tactile walking surface indicator rules are applied in a consistent manner.

The committee recommends:

• municipalities must apply tactile walking surface indicators (also called tactile attention indicators in the Ontario Building Code) following B552 4.5.5 including all aspects such as configuration, luminance, installation and location
• require compliance with Clauses 4.1.1 and 4.1.2 and Sentence 2 of ISO Standard 23599 — Assistive Products for Blind or Vision-Impaired Persons — Tactile Walking Surface Indicators, as per article 3.8.3.18
• update the language in the Ontario Building Code to ensure compliance with ISO standard 3.8.3.2. (2) “Where a difference in elevation between levels in a walkway is not more than 200 mm, a curb ramp conforming to Sentence (3) shall be provided so that:
  
  (3) The curb ramp permitted by Sentence (2) shall,
  1. have a running slope conforming to Table 3.8.3.2.,
  2. have a width of not less than 1 500 mm exclusive of flared sides,
  3. have a surface including flared sides that shall,
     1. be slip-resistant,
     2. have a tactile attention indicator in compliance with Art. 3.8.3.18, which will ensure consistent colour- and texture-contrast with the adjacent surfaces, and
     3. have a smooth transition from the ramp and adjacent surfaces, and
  4. have flared sides with a slope of not more than 1:10 where pedestrians are likely to walk across them.”

Implementation timeline: Within one year of regulation being adopted.

Recommendation 91: align with CSA/ASC B651 for floor and ground surfaces

Intended outcome: To improve safety and ability to navigate over floors and surfaces.

The committee recommends:

• incorporate the most recent iteration of CSA/ASC B651, Accessible design for the built environment standard, sections 4.4.1 (stable, firm, slip-resistant, minimal glare), 4.4.2 (changes in level), 4.4.3 (carpets) and 4.4.4 (gratings) into the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 92: public area kitchens and kitchenettes

Intended outcome: To improve safety and access to kitchen spaces in public buildings.

The committee recommends:

• the province will develop requirements for accessibility in all workplace or public area kitchens and kitchenettes and add to the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 93: fitness/recreation facilities

Intended outcome: To create facilities for fitness and recreation that work for everyone.

The committee recommends:

• the province will develop and implement specific accessibility requirements based on a scan of already existing guidelines and best practices (for example, Pan-am guidelines and Para Pan-am Game Guidelines, municipal guidelines, etc.) for fitness/recreation facilities for accessible changerooms, lockers, exercise equipment, etc. into the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Interior element services — building controls, alarms and signage

Recommendations under Ontario’s Building Code.

Introduction

The exterior and interior building elements provisions in Ontario’s Building Code establishes requirements to address the recognition, accessibility and operability of end-user building controls (electrical switches, alarm pulls, thermostats, etc.) to all people including persons with disabilities and to provide maximum independence to all building users equally. End user controls, operating mechanisms, alarms and signage shall be provided in a manner to provide life safety and functionality for all building users.

Committee discussion

The committee discussed at length the various needs that must be met for persons with disabilities to safely navigate the built environment and interact with the services provided. Discussion centered on accessible placement and operability of building controls and well as signage and wayfinding to assist those with mobility needs to easily find and navigate barrier-free paths of travel throughout the built environment.

Safety was also a significant aspect of these discussions. The committee discussed the use of emergency systems (for example, fire and smoke alarms, etc.) and how they could be made more accessible and inclusive for all.

Recommendations

Recommendation 94: clearance from return wall

Intended outcome: To ensure right- and left-hand approaches are provided for mounted controls.

The committee recommends:

• clause 3.8.1.5. (1) (a) to include clearance from return wall
• include diagrams for reference and guidance for mounting controls

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 95: operating controls

Intended outcome: To enhance the accessibility of operating controls to allow people with disabilities to access and operate the controls independently.

The committee recommends:

• incorporate all aspects of CSA/ASC B651 section 4.3 Operating controls into the Ontario Building Code:
  • exception 4.3.3: lower the maximum height of operating controls to 1100 mm
• this applies to all operating controls as outlined in section 4.4.3:
  • note this is in direct conflict with the new CSA/ASC B651 standard, which recommends a max height of 1200 mm

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 96: accessible systems controls

Intended outcome: To ensure that any systems control meant for use by the public is accessible by a person with a disability.

The committee recommends:

• the Ontario Building Code shall be amended to require any systems control meant for use by the public (for example, heating/cooling, life/safety services) to be accessible by a person with a disability:
  • examples include tactile markings on devices to reliably locate and use controls (for example, power button, up/down arrows)

Implementation timeline: Within three years of regulation being adopted.

Recommendation 97: elevator communication systems

Intended outcome: To update the Ontario Building Code to ensure compliance with new elevator standards outlined in CSA B44-10 Safety Code for Elevators and Escalators — 2019.

The committee recommends:

• column 2 of table 1.3.1.2 shall be updated with the latest edition of the Safety Code for Elevators and Escalators
• the current standards shall be updated

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 98: accessible door operator requirements

Intended outcome: To ensure side and front approach is provided for controls.

The committee recommends:

• amend 3.8.1.5. (1) (b) to require the accessible door operator to be adjacent to and centred on a dimension based on accessible turning diameter

Implementation timeline: Immediately upon regulation being enacted.

Recommendation 99: assistive communication devices for service areas

Intended outcome: To ensure that assistive communication devices and/or services are provided to accommodate a variety of needs.

The committee recommends:

• amend sentence 3.8.3.7. (1) to state, “In buildings of assembly occupancy, all classrooms, auditoria, meeting rooms and theatres with an area of more than 50 m² shall be equipped with assistive communication systems encompassing the entire seating area”
• proposed adding Sentence 3.8.3.7. (2) In buildings of care and treatment occupancies shall include Communication Devices that assist deaf, deafened and/or hard of hearing persons at service desks and service counters, and in areas of assembly greater than 50 m²
• in buildings of assembly occupancy, public address systems shall include real-time visual communications
• development of functional requirements shall be made in consultation with people that are deaf, deafened and/or hard of hearing as well as the organizations that serve the community and have expertise of assistive communication devices
• government shall conduct research and jurisdictional scan of best practices to create guidance materials for assistive devices and other technical requirements necessary

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 100: navigation in public spaces

Intended outcome: To improve safety while travelling through a building.

The committee recommends:

• the province will develop guidelines for the use of alternatives for wayfinding in large open areas which will include provisions/guidelines for tactile wayfinding
• these guidelines shall be developed:
  • in consultation with organizations, orientation and mobility specialists, and stakeholders with sight loss
  • with reference to the Crime Prevention through Environmental Design (for example, the use of convex mirrors in hallways and at high-traffic intersections)

Implementation guideline: Immediately upon adoption of regulation.

Recommendation 101: accessible washroom signage

Intended outcome: To allow people to easily find the washroom they need.

The committee recommends:

• washroom signage in the Ontario Building Code be updated to reflect CSA/ASC B651, section 4.6:
  • include blade signs above the door frame as a part of signage requirements for accessible washrooms, to ensure visibility
  • for accessible universal washrooms, gender-nonspecific signage (that is, toilet symbol) shall be used
  • applied to all public accessible washrooms

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 102: visual fire alarms in multi-stall washrooms

Intended outcome: To ensure the safety of those who are deaf, deafened and hard of hearing during emergencies.

The committee recommends:

• the Ontario Building Code shall be amended to require visual emergency alarms in multi-stall washrooms/changerooms/dressing rooms/etc.

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 103: emergency call systems in washrooms

Intended outcome: To ensure that emergency call systems be installed in a consistent location that makes them helpful to the widest range of needs.

The committee recommends:

• the function and location of the emergency call button/strip shall be indicated with a sign that includes braille and graphics. Sign shall be located within 300 mm above the button/strip
• include drawings and measurements in the Ontario Building Code that show where the emergency call button/strip and sign shall be located in a universal washroom
• the specifications shall include being within reach of an individual seated on the toilet (within 600 mm of front edge of toilet) and laying on the floor (450 mm above finished floor)
• requirements for the system to notify the user via audible and visual signal that the alarm has been activated
• the government shall investigate best practices for responding to emergency calls and this shall be reflected in the requirements in the Integrated Accessibility Standards Regulation
• two-way communication shall be included as part of the emergency call system
• the government shall investigate to ensure that a universal washroom door can be opened in situations where a person is obstructing access
• in addition to the above, the Integrated Accessibility Standards Regulation shall also require accessibility plans to have a procedure in place to respond to the activation of emergency call systems and include planning for staff to be trained to respond

Implementation timeline: For all new construction as of time of implementation into regulation.

Recommendation 104: visual signal devices in classrooms

Intended outcome: To ensure the accessibility and safety of alarm signals in classroom settings.

The committee recommends:

• remove “(a) a classroom, and” from Section 3.2.4.19 (6) (a) of the Ontario Building Code — Alert and Alarm Signals and require all classrooms to have visual alarms installed

Implementation timeline: Immediately upon regulation being adopted.

Publicly accessible washrooms

Recommendations under Ontario’s Building Code.

Introduction

The washroom provisions in Ontario’s Building Code establish requirements for the location and design requirements for universal and barrier-free washrooms and ambulatory water closet stalls. The provisions are intended to enhance the accessibility of barrier-free washrooms in publicly accessible buildings including the number of barrier-free washrooms and the design requirements to improve the functionality and safety of barrier-free washrooms. The Building Code requirements recognize that washroom facilities are an integral feature of a building and shall accommodate individuals with a range of abilities.

Newly constructed buildings must have barrier-free washrooms. The washrooms must be situated on a barrier-free path of travel and meet building code requirements addressing accessible features, emergency call systems, grab bars, signage, path of travel and turning space, counter heights and doorway widths.

Committee discussion

The committee spent considerable time discussing public toilets, an essential facility for everyone that all too often presents barriers for person with disabilities.

The lack of prescribed requirements for washroom fixtures allows for too much interpretation, leading to fixtures being placed in inaccessible locations. Additionally, there needs to be updated requirements for automatic locks, adult change tables and ceiling track lifts, and grab bar set-ups to prevent limits to accessibility.

Moreover, washrooms claiming to be accessible often lack essential low-cost features, and there is a lack of sufficient options for accessible toilets in most buildings, including hotel washrooms, which often do not meet the specific needs of all guests. Addressing these issues with clearer requirements and considerations for accessibility in washroom design would significantly improve the overall inclusivity and usability of public facilities.

Recommendations

Recommendation 105: washroom fixtures

Intended outcome: To ensure all washroom fixtures are accessible.

The committee recommends:

• clauses 3.8.3.8. and 3.8.3.12. shall include prescribed requirements for adjacencies of washroom fixtures and clearances between fixtures that align with the most recent iteration of CSA/ASC B651, Accessible design for the built environment, section 6.2 washroom facilities
• in addition, prescriptive mounting location and clearances of washrooms fixtures not currently prescribed under the Ontario Building Code, such as infant change tables, hand dryers, towel dispensers and sanitary disposal shall be included

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 106: automatic locks

Intended outcome: To ensure newly built or renovated public washrooms use automatic locks placed in a standard location for ease of use and improved accessibility.

The committee recommends:

• require that newly built or renovated public washrooms install automatic locks that are placed in a standard location (within 500 mm of the latch side of the door) that can be accessed from both a standing and seated position
• an audible and visual signal shall identify when the door is locked
• accessible signage with tactile information shall be provided to help a user with operation
• the province shall identify the design of an automatic locking button, which shall be distinct (for example, visually, tactually) from the push-to-open button

Implementation timeline: Within three years of regulation being adopted.

Recommendation 107: adult change tables

Intended outcome: To provide safety, dignity and independence for all people who require the use of an adult size change table in public settings.

The committee recommends:

• require the development of policies and procedures for the maintenance and replacement of adult change tables and ceiling track lifts to ensure good working order
• amend the Ontario Building Code to require the installation of height adjustable adult change tables in universal washrooms, not just the space for the change table
• mandate for newly constructed universal washrooms, one on each floor of the building, including:
  • educational facilities (elementary, secondary and post secondary schools)
  • hospitals, medical clinics, rehabilitation facilities
  • community facilities (recreation centres, libraries, seniors’ centres)
• province to do an interjurisdictional scan to research the application and use of ceiling track lifts in publicly accessible universal washrooms
• organizations installing a universal washroom with a height adjustable adult change table will develop inclusive policies and procedures for the use of the washroom

Implementation timeline: Immediately upon adoption of regulation for all new construction.

Recommendation 108: L-shaped grab bars

Intended outcome: To require retrofits to all public accessible washrooms that are currently legal non-compliant to have grab bars that are helpful to the wider community of persons with disabilities.

The committee recommends:

• all existing washrooms designated as accessible be required to be equipped with an L-shaped grab bar (750 mm long horizontal by 750 mm long vertical) and installed directly beside the toilet on the wall 300 mm above the top of the toilet seat
• where the distance between the wall and the centre line of the toilet is greater than 460 mm, then a fold down grab bar will be installed between the toilet and the wall
• toilet roll holders shall not be installed above the L-bar and must be more than 100 mm from the edge of the bar to prevent the holder from impeding use of the grab bar

Implementation timeline: Within two years of regulation being adopted. Applied to all public accessible washrooms on a barrier-free path of travel, universal washrooms and accessible stalls, including those that were constructed prior to 2015.

Recommendation 109: fold-down grab bars

Intended outcome: To require a secondary fold-down style grab bar to provide support for people who need to lean or have leverage on both sides of the toilet.

The committee recommends:

• all newly constructed universal washrooms and accessible stalls must install a fold-down grab bar on the transfer side of the toilet
• the fold-down grab bar shall be of the type that does not lock in place in the upright position
• the height of the top bar shall be installed at the same height as the horizontal portion of the L-bar on the wall on the opposite side of the toilet
• install a fold-down bar on the transfer side of the toilet in all retrofit situations
• height of the top portion of the fold-down bar shall be 300 mm from the surface of the toilet seat

Implementation timeline: Immediately upon adoption of regulation for all new construction.

Recommendation 110: universal and multi-stall washrooms

Intended outcome: To require all newly constructed washrooms to allow for ease of use, safety and dignity for the people who need them.

The committee recommends:

• amendments to the Ontario Building Code requirements for public washrooms to require the following:
  • Universal washrooms:
    • at least one shower in the universal washroom in schools
    • toilets in accessible stalls and universal washroom shall have toilet seat lids
    • two coat hooks colour-contrasting from the surroundings shall be placed at an accessible height, both on the side wall and the door
    • the toilet paper dispenser shall not impede the use of the toilet, knee space for transfer or space required for use of the grab bar but also be reachable by the water closet user
      • dispenser shall not be placed above the horizontal portion of the bar and shall be within 500 mm of the front of the toilet
    • sanitary disposal receptacles shall be placed on the side wall beside all toilets in universal all-gender washrooms and accessible stalls
    • there shall be colour contrast between door frames and walls inside and outside in all washrooms
  • Multi-stall washrooms:
    • there shall be colour contrast between door frames and walls inside and outside in all washrooms
    • sanitary disposal receptacles shall be placed on the side wall beside all toilets in universal all-gender washrooms and accessible stalls
    • change the number of accessible stalls in multi-stall washrooms to a minimum one regardless of location of a universal washroom. Ten or more stalls require two
    • there shall be colour contrast between stall partitions and walls in multi-stall washrooms
    • when an infant change table is installed in washrooms in public spaces, it shall not encroach into a clear space, shall be installed at an accessible height and not be installed within the accessible stall
    • the toilet paper dispenser shall not impede the use of the toilet, knee space for transfer or space required for use of the grab bar but also be reachable by the water closet user
      • dispenser shall not be placed above the horizontal portion of the bar and shall be within 500 mm of the front of the toilet
    • locking hardware on stall doors shall be sliding type, operable with a closed fist
    • the colour of urinals shall contrast with the adjacent surface
    • urinals shall have a tactile centre line indicator on the wall above the urinal
    • two coat hooks colour-contrasting from the surroundings shall be placed at an accessible height, both on the side wall and the door
    • amend Article 3.8.3.9. All toilets in accessible stalls and universal washrooms shall have toilet seat lids
      • government to task further investigation related to loading and seat lid/automatic flushometers interaction
    • the design of buildings with multi-stall washrooms shall place the women’s washroom on the left and men’s on the right
    • door hardware on accessible stall doors shall include occupancy indicators (such as red/green markers) to indicate vacancy

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 111: single-user accessible washrooms

Intended outcome: To provide greater accessible toilet options.

The committee recommends:

• the government shall develop guidelines for type B single use accessible washrooms (different from an accessible stall or universal washroom)
• the new type would be applied to new build designs that also have gendered or non-gender multi-stall and universal washrooms
• type B washrooms shall include all the accessible features of an accessible water closet and lavatory

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 112: hotel washrooms

Intended outcome: To require newly constructed hotels to be designed with rooms that have accessible bathtubs and rooms that have accessible roll-in showers.

The committee recommends:

• the government shall amend 3.8.2.4 (c) to require hotels to offer the choice of an accessible bathtub or an accessible roll-in shower
• rooms shall be designed to have an even split between tubs and showers

Implementation timeline: Immediately upon adoption of regulation.

Residential

Recommendations under Ontario’s Building Code.

Introduction

The provisions in Ontario’s Building Code for residential buildings are intended to increase the proportion of residential units in multi-unit residential buildings that have barrier-free features to improve circulation within the building for everyone and increase the adaptability and visitability of suites for persons with disabilities.

At least 15% of suites within multi-unit residential buildings must be designed with basic accessibility features such as a barrier-free path of travel from the building entrance into the suite and into the kitchen, bedroom, living room and bathroom. An elevator is normally required to provide barrier-free access to all floors in a multi-unit building. Suites with accessibility features must be distributed throughout the building and represent the type and size of suites available in the building.

The adaptability features in a barrier-free unit are intended to facilitate future adaptation of the suite so that it may be suitable for a person with a range of physical mobility restrictions.

Committee discussion

Among the areas of the Ontario Building Code that the committee felt needed most improvement were the requirements for residential accessibility. The committee discussed the immediate need for a greater supply of accessible housing in multi-unit residential buildings as well as specific regulatory changes to ensure a fully barrier-free experience in these units. Another common concern discussed was the need for safe and accessible use of elevator services during emergencies such as power outages.

Recommendations

Recommendation 113: percentage of barrier-free units

Intended outcome: To increase the supply of barrier-free residential units.

The committee recommends:

• increase the requirement for barrier-free units in newly built or redeveloped multi-unit residential buildings to 20%

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 114: areas requiring barrier-free path of travel

Intended outcome: To require all areas within a barrier-free unit to be on an accessible path of travel.

The committee recommends:

• the government shall amend 8.3.2.1 (5) to say:
  • in a Group C major occupancy apartment building, not less than 20% of all suites of residential occupancy shall be provided with a barrier-free path of travel from the suite entrance door into and throughout all areas located at the same level as the barrier-free path of travel and must include at least one bedroom and at least one bathroom conforming to Sentence (6), a kitchen or kitchen space, and a living room or space

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 115: back-up power in residential buildings

Intended outcome: To ensure residents of barrier-free units in multi-unit buildings are always able to access their residence, including access to elevators in multi-storey buildings.

The committee recommends:

• multi-storey buildings must provide a back-up generator for elevator usage during power outages

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 116: ensure the Ontario Building Code follows CSA/ASC housing requirements

Intended outcome: To inform decisions around residential design and construction regulated under the Ontario Building Code using the information present in Accessibility Standards Canada and CSA Group’s ASC/CSA B652, Accessible Dwellings.

The committee recommends:

• a thorough review of ASC/CSA B652, Accessible Dwellings shall be completed by the government
• the Ontario Building Code shall meet or exceed all CSA/ASC requirements for accessible housing in all aspects of the Ontario Building Code that regulate both short and long-term accommodations for persons with disabilities (that is, hotels, long-term care facilities, emergency shelters, rehabilitation facilities, etc.)
• the barrier-free requirements for multi-residential buildings shall be updated to meet or exceed the standards in ASC/CSA B652, Accessible Dwellings

Implementation timeline: Within two years of regulation being adopted.

Egressibility

Recommendations under Ontario’s Building Code.

Introduction

Ontario’s Building Code contains provisions for the safety of all persons including persons with a disability in the event of a fire or other emergency in a building occur. These include fire separations that allow for sheltering in place, and areas of refuge where a person with a disability can have a higher level of protection while evacuation is being arranged.

Egressibility means that, in case of an emergency, the occupants could leave a building or can reach an area of safety. Egressibility is the intention to provide an equal level of life safety for everyone. The Ontario Fire Code also provides a safety plan for the operation of all buildings to ensure that a plan is in place to assist persons with a disability to exit the building in case of an emergency.

Committee discussion

The committee heard that persons with disabilities are very vulnerable in emergency events, such as fire or weather-related emergencies. There is very little in Canadian building codes that addresses the appropriate minimum design solutions to accommodate persons with disabilities in evacuation.

Elevator access is essential to many people with disabilities and older adults, including those who use mobility devices. However, power outages or emergencies limit elevator access and leaves persons with disabilities and older adults not able to evacuate or leave a multi-storey building. Not all emergency exits on ground-level floors are accessible or step-free. This requires people with mobility devices to find an alternate exit.

The Ontario Building Code includes requirements to provide temporary refuge for persons with disabilities in an emergency setting. But it also acknowledges that it may be necessary to develop special arrangements to evacuate persons with disabilities from buildings.

Recommendations

Recommendation 117: improve accessibility of emergency egress

Intended outcome: To ensure all emergency exits that are on ground level shall provide barrier-free access to a means of egress.

The committee recommends:

• the province shall amend the Ontario Building Code to make all dedicated ground floor emergency exits that egress the facility be accessible and connected to an accessible path away from the building.

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 118: ground-level emergency exits

Intended outcome: To provide emergency exits for all people to be able to use to exit the building safely and quickly.

The committee recommends:

• amend the building code to require that ground-level emergency exits be step-free
• accessible emergency exits are signed with the International Symbol of Access in compliance with ISO Standard 7001 “Public information symbols”
• organizations are to provide information in alternative formats (for example, websites, etc.) about all emergency exits

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 119: areas of refuge during a fire event

Intended outcome: To ensure anyone who is unable to self-rescue during a fire event has access to an area of refuge at any floor levels above or below grade that offer a barrier-free path of travel.

The committee recommends:

• requirements for areas of refuge shall align with requirements under CSA/ASC B651, Accessible design for the built environment
• remove the exception under Sentence 3.3.1.7 (3) as sprinklers do not limit the migration of smoke
• investigate the possibility of a dedicated elevator
• government to define what independent egress during a fire event means for persons with disabilities living and/or working in high buildings
• when a building is retrofitted with an elevator, measures must be taken to require areas of safe refuge on each floor
• an area of refuge is to be defined as an enclosed area designated to persons who are unable to self-rescue, and it shall:
  • be separated from the building floor area by a fire separation with a fire resistance rating at least equal to that required for an exit
  • be smoke-protected
  • be served directly by an exit

Implementation timeline: Immediately upon adoption of regulation for all new construction.

Recommendation 120: emergency evacuation chairs

Intended outcome: To ensure persons who use a mobility device can evacuate a building in a safe manner.

The committee recommends:

• the province shall develop regulation requiring that an evacuation chair or related equipment be provided on each floor above and below the entrance level of all buildings
• require signage for location and instructions of use, and staff training on a bi-annual basis
• plans for use shall be included in evacuation plans and maps

Implementation timeline: Immediately upon adoption of regulation.

Existing buildings and retrofit

Recommendations under Ontario’s Building Code.

Introduction

Ontario’s Building Code establishes requirements that areas of a building undergoing major renovation must meet the requirements in Ontario’s Building Code for barrier-free design. These provisions are intended to increase opportunities for all Ontarians to access residential, commercial and employment spaces. Existing buildings are not affected unless an extensive renovation is planned.

Ontario has enhanced barrier-free design in buildings undergoing extensive renovation by making more proposed renovations subject to barrier-free design features, and by establishing priority accessibility features that must be provided in renovations that are not located on a fully accessible floor.

Committee discussion

Ontario cannot become accessible without addressing the retrofit of existing buildings and places. To date, the regulations in the Ontario Building Code and the design of public spaces standards apply only to buildings and places that are undergoing some level of renovation. With the increased awareness of climate change and sustainable building practices, there is an increased effort to retain existing buildings. At the same time, small businesses need assistance to remove barriers as they may not know where to start or may have no money in budget to do so.

Recommendations

Recommendation 121: retrofit of existing facilities

Intended outcome: To truly make Ontario accessible by addressing the multitude of inaccessible existing buildings and places.

The committee recommends:

• the government shall develop specific standards that address the accessible retrofit of existing facilities, as well as a plan to assist in the financing of the required alterations

Implementation timeline: Within one year of regulation being adopted.

Recommendation 122: material alteration requires compliance with barrier-free standards

Intended outcome: To ensure accessibility is prioritized when material alterations or repairs are conducted to a building.

The committee recommends:

• if there has been a material alteration or repair to a building in one area to make it accessible, the Ontario Building Code shall require full application of section 3.8 of the code to remove all barriers to accessibility

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 123: retrofit of emergency systems

Intended outcome: To ensure all buildings are equipped with accessible emergency systems.

The committee recommends:

• amend the Ontario Fire Code to require all buildings to be retrofitted with accessible emergency systems (for example, visual alarms, height and accessibility of fire safety equipment, pull stations, fire extinguishers)
• require all publicly accessible washrooms to be retrofitted with visual/auditory fire alarms
• the province shall undertake research to determine standards for elements such as visual emergency alarms (that is, not just fire) to ensure safety for all persons

Implementation timeline: Within 10 years of regulation being adopted.

Recommendation 124: retroactive washroom requirements

Intended outcome: To make a wider range of existing washrooms usable by more persons with disabilities.

The committee recommends:

• the government shall expand the scope of the AODA to require the retroactive installation of accessible features in washrooms, including:
  • on doors that have a closer, require addition of power door openers on washrooms along the barrier-free path of travel that have a minimum turning circle of 1200 mm
  • replacement of inaccessible faucets
  • replacement of older angled grab bar with a L-bar (following existing regulations) installed beside the toilet and with the toilet paper holder not impeding its use
  • addition of fold-down grab bar on transfer side of toilet
  • installation of d-pulls on accessible stall doors (one on the outside, and two on the inside (one near lock, one near hinge)
  • toilets in accessible stalls and universal washrooms shall have toilet seat lids
  • coat hooks shall be placed at an accessible height on side walls
  • sanitary disposal receptacles shall be placed on the side walls beside all toilets in universal all-gender washrooms and accessible stalls
  • exposed drainpipes under sinks shall have a barrier (partition or insulated wrap) to protect knees

Implementation timeline: Within two years of regulation being adopted.

Recommendation 125: ensuring access during temporary disruptions

Intended outcome: To enable all persons with disabilities to access and egress buildings, including housing, during renovation or construction.

The committee recommends:

• the province shall amend the Ontario Building Code to ensure that accessible paths of travel, entrances and other accessible features (that is, door openers, elevators) are maintained during temporary disruptions (for example, renovation and/or construction, etc.)
• municipalities shall be given authority to enforce this requirement
• any temporary disruptions limiting access, egress or accessible features outlined in the Ontario Building Code will be communicated to tenants in advance
• a method of providing feedback on the accessibility of renovations shall be provided as well

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 126: resources for retrofits

Intended outcome: To provide eligible businesses with the resources they need to make their spaces more accessible.

The committee recommends:

• government to provide resources and information on how to retrofit:
  • the province shall establish resources for businesses to know how to retrofit their spaces to remove barriers to accessibility
  • a great deal of accessibility upgrades can happen with very little investment of money (that is, “the low hanging fruit”)
• government to develop a new funding grant:
  • create a funding program for small businesses to allow for retrofits to happen in a timely manner
  • one time funding of up to $100,000 per location
  • available through an application process every fiscal year
  • organizations that receive funding must consult with an accessibility professional or committee prior to starting the retrofit

Implementation timeline: Immediately upon regulation being enacted.

Recommendation 127: accessibility features information

Intended outcome: To allow people to easily find the information they need to know about the accessibility at a facility before they arrive and can therefore be prepared.

The committee recommends:

• the Integrated Accessibility Standards Regulation shall be amended to require all organizations that have physical infrastructure and a website to clearly demonstrate all accessibility features in their facilities
• obligated organizations must publicly post, in accessible formats (including ASL/LSQ), a brief written description accompanied by photos and alt text describing all parts of the patrons’ experiences from parking, through all spaces, including bathrooms
• information shall also be provided about any assistive equipment that is at the site (that is, FM Systems, ceiling track lifts, etc.)

Implementation timeline: Within one year of implementation of the regulation.

Conclusion

These initial recommendations developed by the committee are intended to address barriers to accessibility that persons with disabilities may encounter throughout their everyday journeys through the built environment. The committee looks forward to the public feedback that will follow the posting of these initial recommendations. All input will be considered by the committee before final recommendations are made.

Committee members

Voting members

Julie Sawchuk (Chair)
CEO, strategist and educator, Sawchuk Accessible Solutions

Catherine Bell
Volunteer, March of Dimes of Canada

Kevin J. Collins
President and CEO, Easter Seals Ontario

Johanna Contreras
Senior advisor, Universal Design, Design Division, Metrolinx

Debbie Gillespie
Vice chair, Advisory Committee on Accessible Transit, Toronto Transit Commission

John W. Lane
Chief Building Official, City of St. Catharines
Ontario Building Officials Association

Kenneth D. Logtenberg
Project engineer, Principal, B. M. Ross and Associates

Ute Maya-Giambattista
Principal, O2 Planning + Design
Ontario Professional Planners Institute

Diane Morrell
Accessibility coordinator, City of Sault Ste. Marie

Noor Ratansi-Iamurri
Program manager, Canadian Hearing Services

Megan Richards
Program manager, Accessibility
City of Ottawa/Association of Municipalities Ontario

Ian Rogers
Senior director, Facility Management, Building and Transportation Services,
Holland Bloorview Kids Rehabilitation Hospital

Susan Ruptash
Architect, FRAIC
Ontario Association of Architects

Chris Stigas
Rick Hansen Foundation Accessibility Certification Professional
HandiHelp Accessible Innovations

Non-voting members

Coreen Chung, Ministry of Infrastructure

Mansoor Mahmood, Ministry of Municipal Affairs and Housing