Accessibility: CSA B651, provincial codes and the Accessible Canada Act

Accessibility requirements make buildings usable by people with disabilities: people who use wheelchairs, scooters and walkers, people with limited strength or reach, people who are blind or have low vision, people who are deaf or hard of hearing, and people with cognitive disabilities. About one in four adults reports some form of disability, and the share rises with age, so accessible design serves a large part of the population, as well as parents with strollers, delivery workers with carts and anyone with a temporary injury. Codes and laws require a minimum level of access in most new buildings and in many renovations.

In Canada, accessibility in buildings is mainly a matter of provincial building codes, which contain accessibility requirements based on the NBC's Section 3.8 or their own provisions, often referencing the CSA B651 standard. Human rights law adds a duty to accommodate that can go beyond the building code, and the federal Accessible Canada Act applies to federally regulated organizations. This lesson explains the main requirements, how they are applied and where construction errors commonly occur.

The legal framework in Canada

The NBC sets accessibility requirements in Section 3.8 for Part 3 buildings, and Part 9 refers to them for some small buildings. Since the 2015 edition the NBC has adopted many technical requirements from CSA B651, Accessible design for the built environment, and the 2020 edition expanded requirements for features such as power door operators and accessible washrooms. Provinces have gone further. Ontario's Building Code contains extensive barrier-free design requirements in Section 3.8, and the Accessibility for Ontarians with Disabilities Act (AODA) adds the Design of Public Spaces Standards for outdoor spaces, parking, paths of travel and service counters in public sector and large private organizations. British Columbia's code and the Accessible British Columbia Act, Manitoba's Accessibility for Manitobans Act and Nova Scotia's Accessibility Act add their own requirements. Quebec's Construction Code contains barrier-free provisions in its Chapter I.

Human rights codes in every province and the Canadian Human Rights Act prohibit discrimination in services, employment and housing on the basis of disability, and impose a duty to accommodate to the point of undue hardship. Compliance with the building code does not by itself discharge that duty: tribunals have found organizations liable for barriers in buildings that met the code. The federal Accessible Canada Act, passed in 2019, applies to federally regulated sectors such as banks, telecommunications, transportation and the federal government, and Accessibility Standards Canada develops standards, including CSA/ASC B651:23 for the built environment, which federal regulations can make mandatory.

Where access is required

Accessibility requirements apply in most new buildings, but not everywhere within them. Codes require an accessible route into the building and to the spaces people use, with exceptions for spaces such as equipment rooms, catwalks and some raised areas. The main scoping questions are:

• Entrances: which entrances must be accessible and whether power door operators are required.
• Accessible route: a continuous path connecting entrances, parking, public sidewalks, and the spaces and elements required to be accessible, including floor levels served by elevators or ramps.
• Washrooms: how many accessible washroom fixtures or universal washrooms, and where.
• Parking and passenger loading: how many accessible parking spaces, including van-accessible spaces.
• Assembly seating: wheelchair spaces and companion seats, dispersed through the seating.
• Residential units: how many units must be accessible or adaptable.
• Signage, assistive listening systems, counters, drinking fountains and other elements.

The NBC exempts some buildings and spaces from barrier-free requirements, such as houses, some industrial occupancies and spaces that are not intended to be occupied, and requires a barrier-free path of travel from the entrance to all normally occupied floor areas in most other buildings, subject to exceptions for upper floors of small buildings without elevators in some provinces. Ontario's code, for example, requires a barrier-free path of travel throughout the entrance storey and to other storeys in many buildings, with limited exceptions.

Accessible routes, ramps and doors

The accessible route is the backbone of accessibility. It must have a minimum clear width, a firm, stable and slip-resistant surface, limited changes in level, gentle slopes, and adequate space at doors and turns. Most construction errors occur here, because small dimensional errors, such as a threshold a few millimetres too high, a door closer set too strong or a ramp slope slightly too steep, can make a route unusable and fail inspection.

Doors need clear opening width, manoeuvring space beside the latch, hardware operable with one hand without tight grasping or twisting, and limited opening force. Interior door closers are often set too strong by the installer; codes limit the force for interior doors, and power door operators are required at many entrances. Thresholds must be low or have sloped edges.

Washrooms and other elements

Accessible washrooms require a turning space, an accessible water closet with grab bars and clearances, an accessible lavatory with knee space and insulated pipes, accessible accessories and mirrors at usable heights, and a door that meets clearance requirements. Universal or single-user washrooms, which can be used by a person with a companion of any gender, are increasingly required or preferred. Grab bar heights, water closet centreline distances from the side wall and accessory mounting heights are tightly specified, and errors of 25 mm (1 in) can fail inspection or lead to complaints.

Ontario's code, for example, requires a universal washroom in many buildings, a water closet centreline 460 to 480 mm from the side wall, and specific grab bar configurations, and the NBC requires at least one universal washroom in many buildings in recent editions. CSA B651 sets dimensions for counters, drinking fountains, signage, tactile walking surface indicators at stairs and platform edges, visual alarms and assistive listening systems.

Parking and residential units

Accessible parking requirements in Canada come from provincial codes, accessibility standards and municipal by-laws rather than the NBC alone. Under Ontario's Design of Public Spaces Standards, for example, off-street parking facilities must provide accessible spaces in proportions that rise with the number of spaces, divided between wider Type A van-accessible spaces and Type B spaces, with access aisles. Residential requirements also vary: the 2020 NBC and several provinces require a proportion of apartment units in larger buildings to be accessible or adaptable, and some municipalities require more through planning policies.

Renovations and existing buildings

Accessibility in existing buildings is one of the most complex areas of code practice. Codes generally require alterations to be accessible within the altered area, and sometimes require an accessible route to the altered area and accessible washrooms serving it, subject to limits on cost or technical feasibility.

Provincial codes treat existing buildings differently. Ontario's Part 11 generally does not require barrier-free upgrades for renovations except in some cases of extensive renovation or change of use, while Section 3.8 applies to new work and to extensive renovations of the type described in the code. British Columbia and other provinces have their own rules. Human rights obligations continue to apply to existing buildings regardless of the code, and organizations are expected to remove barriers where doing so does not cause undue hardship.

Common construction errors

Accessibility is a field where small errors cause big problems. The most frequent construction errors include ramps and sloped walks steeper than permitted because of formwork or finishing tolerances; thresholds and transitions too high; door closers set with too much force; grab bars and accessories at wrong heights or clearances; lavatory pipes not insulated or knee space obstructed; mirrors and dispensers too high; signage missing braille or raised characters or at wrong heights; and clear floor spaces blocked by furniture, waste bins or equipment installed later. Construction managers can prevent most of them by including accessibility checks in quality control plans, using mock-ups for typical washrooms, checking slopes with a digital level before finishes, and conducting an accessibility walk-through before the final inspection.