Improving accessible built environment standards — 2025 final recommendations report

Letter from the chair

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

Dear Minister,

On behalf of the Design of Public Spaces Standards Development Committee, I am pleased to submit our Improving accessible built environment standards — 2025 final recommendations report.

With the submission of this report, the committee has fulfilled its mandate to review 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 (OBC).

As is evident by the amount of feedback the committee received on the initial report, Ontarians are passionate, determined and very committed to seeing accessibility improved in all aspects of the built environment across the province. The breadth and comprehensiveness of the thousands of unique responses received throughout the consultation on our initial report showed support for these changes from municipalities, building officials, organizations who develop policy, design spaces and those who support people with disabilities. These results demonstrated how this consultation was instrumental in providing a voice to Ontarians with disabilities, bringing to light barriers that are often overlooked.

The committee and I would also like to reinforce that many of the proposed changes to the OBC and AODA as outlined in this report echo what we’ve heard from the sector and the disability community, including the provincial and national organizations like the CSA Group, Accessibility Standards Canada (ASC) and previous Standards Development Committees. The Committee’s report highlights the need for alignment with requirements across the country to support the work of architects, designers, contractors, engineers and building officials in creating accessible spaces for all Ontarians.

The committee is confident that the recommendations outlined in this report provide a clear path towards removing barriers for persons with disabilities and ensuring a more inclusive and accessible Ontario for all.

While the committee recognizes that this report is intended to bring recommendations forward to government, we also understand that this work cannot and should not be left to government alone. It will take all of Ontario to recognize that barriers continue to exist in the built environment and that persons with disabilities have the right to live in a province that respects and supports their dignity and independence.

With this in mind, we firmly believe that this report has the potential to drive the change necessary to meet the government’s mandate of creating a more accessible Ontario.

Finally, I’d personally like to highlight the vast number of times that education on accessible design came up in discussions and in the feedback process. People who are planning, renovating, and building spaces in Ontario want to know more so they can do better — this can only be accomplished by including accessibility as a mandatory component of all post-secondary design and construction related programs and should also be a key part of any continuing education requirements for such professionals. We, as humans, learn best through education and experience; that is how, as a Province, we can actually move forward and make change happen.

Thank you for the privilege of allowing me to chair this committee. It has been among the most important milestones of my career. I look forward to this report being made publicly available to help raise awareness of the barriers faced by persons with disabilities everyday, and to support Ontario in advancing this important work.

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 standards 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 were adopted in 2012 and established 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.

Current state of accessibility in Ontario

The current regulatory and legislative framework in place to enforce accessibility in Ontario has not evolved fast enough. 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.

Design of Public Spaces Standards Development Committee and its initial recommendations report

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.

The committee was also provided with foundational documents and extensive research pertaining to accessibility in the built environment. It 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.

These contributions were instrumental in enriching the collaborative decision-making process and reinforced the need to apply a multifaceted lens that encompassed equity, diversity, inclusion and intersectionality to our recommendations. This culminated in the development of our initial recommendations report which was submitted to the Minister for Seniors and Accessibility.

Public consultation

Following the submission of the initial recommendations report, the Ministry for Seniors and Accessibility launched the report for public consultation from June 5, 2024 to August 29, 2024. This was an opportunity for all Ontarians to provide their input on the committee’s initial recommendations and was an instrumental element to this review.

The public feedback received was crucial throughout the process of working towards the final report, and the committee would like to thank all those individuals and organizations who took time to provide feedback, which was overwhelmingly positive and exceptionally robust.

The committee received approximately 2,500 unique responses throughout the consultation period. Each section of the report received an average agreement rating with the recommendations of approximately 90%.

Overall, there were several key principles identified from the public feedback including, but not limited to:

• There is no singular perspective on how to improve accessibility
  
  The committee had spent significant time to outline additional prescriptive requirements with the aim of improving accessibility, however, through the feedback we were reminded there is no “one-size-fits-all” solution. This reinforced the notion within the committee’s work that there is no singular and universal standard to ensure that the built environment is fully accessible and inclusive to all, and that these standards are minimum requirements and intend to work in conjunction with Ontario Human Rights Code.
  
  While the committee recognizes the challenges to meeting all people’s needs, it is critical for organizations to meaningfully consult with persons with disabilities to design, construct and maintain environments that strive for the highest level of accessibility.
  
  Harmonizing Ontario’s accessibility standards with well recognized and researched international best practice, anthropometric and academic research, other accessibility standards like CSA B651 – Accessible design for the built environment and International Organization for Standardization (ISO) standards, among other sources will help to advance accessibility without having to develop new standards completely from scratch.
  
  Furthermore, there were members of the public who self-identified as having a disability and expressed conflicting notions of how to advance accessibility across the province. With some suggesting that the committee’s initial recommendations did not go far enough while others felt that the committee had gone too far and that a more prioritized approach should be emphasized.
  
  That said, the committee recognizes that accessibility is an evolving journey and that this review is an instrumental first step towards making the province’s built environment more accessible -- not the endpoint.
• The needs of the broad spectrum of disabilities are not reflected in regulation
  
  The committee received a lot of feedback from various stakeholder groups and individuals who felt that the recommendations did not reflect their needs. Disability encompasses a broad spectrum from those with visual disabilities, Deaf, deafened or hard-of-hearing, pain-related disabilities, cognitive disabilities, among many others.
  
  The committee was made up of a diverse group of members, all with various lived experience with disabilities and expertise from various built environment sector-specific disciplines. It was also informed by various stakeholders including a wide variety of disability advocates. However, the committee acknowledges that it does not have the expertise to fully understand the specific and individual barriers that every person with disabilities from across the broad spectrum of disability regularly experience in the built environment. As such, the committee has purposefully and frequently recommended throughout this report that government enhance accessibility requirements based on the barriers identified in the report, international jurisdictional scans, best practice research, anthropometric data, among other sources. The committee firmly believes that more should be done to enhance built environment requirements to meet the needs of all Ontarians and look forward to the government continuing its leadership in advancing a more accessible Ontario.
• There is a need to educate and prioritize accessibility
  
  The committee received extensive feedback stating that more needs to be done to ensure that accessibility is prioritized at the beginning of the process and not left as an after-thought. While changing regulations is important, it is also vital to change mindsets about the importance of accessibility in the built environment and indeed all aspects of accessibility in daily life.
  
  As such the committee took to emphasizing recommendations outlining the need to train, educate and prioritize accessibility across impacted sectors as well as the public. A key priority is the need to educate the design and building sector as well as infrastructure professionals on accessibility needs beyond just the minimum requirements under the AODA or the Ontario Building Code, and having guidance materials that can assist in achieving these goals.

The committee also received a lot of feedback from municipalities and obligated organizations that expressed implementation and cost concerns, while also acknowledging the importance of this work. The committee thoroughly reviewed these concerns and ultimately felt that while there may be validity to some of them, there was a significant misconception that the initial recommendations suggest new or amended requirements be applied to both new developments and construction as well as existing infrastructure. The intent of these recommendations, unless otherwise specified, is to amend the current requirements for new developments and construction and to be applied on a go-forward basis. Given this misunderstanding the committee has ensured that all of the retroactive recommendations in this final report are clearly identified.

Recognizing the impact of these recommendations on the everyday lives of all individuals living with disabilities, the committee carefully considered each piece of feedback received and amended recommendations throughout the report as needed.

Final Report

This final report contains the committee’s comprehensive set of recommendations to the government and completes its mandate to the Minister for Seniors and Accessibility. It is the committee’s hope that this report will bring to light the barriers that persons with disabilities face on a daily basis and bring about concrete changes to the ways people consider accessibility across the varied spectrum of disability.

The committee acknowledges that among the most challenging barriers to address in the built environment are those already built. While the majority of the recommendations found in this report are intended as requirements for new construction and development, the committee has prioritized retrofit recommendations together in one section of the report. Retrofitting the built environment to become more accessible is paramount to advancing accessibility, and regardless of how challenging it might be to do so, the committee feels that the government needs to take leadership in promoting and supporting these changes so that all Ontarians can live with dignity and feel included in their communities.

Instrumental to the success of the recommendations in this report is a broader cultural shift towards more inclusive and accessible consideration and design. The committee feels that while progress has been made there is still a lot of work to be done.

It takes all of Ontario to take these steps and this work cannot be left only to the government to address. There is a significant economic benefit and overall business case for organizations to become more accessible. This work requires investment from all Ontarians: from building owners to tenants, from educators to students, from designers to builders and across institutions and agencies.

Now having reached the 20^th anniversary of the AODA, Ontarians with disabilities are expecting more than just consideration, especially as the population continues to age, increasing the need for accessible environments and spaces. As the committee has noted throughout this report, accessibility must be foundational to all the work being done across this province and not left as an after-thought.

With that, we welcome all to read the Design of Public Spaces Standards Development Committee’s Improving accessible built environment standards — 2025 final recommendations report.

Long-term objective

Introduction

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 to include both the design of public spaces standards as well as the Ontario Building Code, the committee proposes the following as its long-term objective:

• 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 ensure safety, independence and dignity
  • providing convenient and inclusive spaces that promote social engagement, physical activity and mental well-being, and
  • providing education to the broader public about the need to address additional barriers present it today’s society
• this objective will be accomplished by providing obligated organizations with the specifications, guidance materials and financial and informational resources needed to design, construct or renovate spaces governed by the Ontario Building Code and the design of public spaces standard 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.

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.

Of additional interest to the committee was the need to enhance training and education for the building sector on accessibility needs beyond the minimum requirements set out in design of public spaces standards and the Ontario Building Code, as well as establish a more accountable reporting process to ensure that barriers are not erected in new capital projects.

Recommendations

Recommendation 1: mandatory education for professionals

Intended Outcome: Students and current professionals in the design and construction industry must be required to learn disability awareness and accessibility best practices as a part of their training and on-going professional development.

The committee recommends:

• all post-secondary education institutions offering design and construction programs shall provide mandatory curriculum about:
  • disability awareness (that is, ableism, discrimination, invisible disability, equity and disability justice etc.)
  • current National and provincial accessibility standards
  • application of accessibility best practices
• all currently licensed design/construction professionals shall be required to complete rigorous accessible design training (for example, the Royal Architectural Institute of Canada’s “Introduction to Successful Accessible Design” course.)
• government shall require professional organizations to develop mandatory training on disability and accessibility for current professionals including but not limited to, BCIN holders, Interior Designers, Architects, Landscape Architects and Professional Engineers, Contractors, Inspectors, officials, facilities staff, parks supervisors, accessibility specialists, and require supplementary training when standards/regulations are amended
• such training shall include accessibility requirements in both the Ontario Building Code and the design of public spaces standards in Integrated Accessibility Standards Regulation as well as best practice design guidance materials featured in municipal and national standards

Implementation Timeline: Within 3 years of adoption of regulation.

Recommendation 2: guidance materials for all design/construction professionals

Intended outcome: To ensure that all design/construction professionals are more knowledgeable about all aspects of accessibility both inside and outside the building.

The committee recommends:

• government shall work with professional organizations to fund, develop, and update (as applicable) guidance and educational materials to help all building professionals including but not limited to designers, planners, officials, inspectors, etc. These guidance materials shall be in place for use by all organizations and professions responsible for implementing the built environment regulations, including anyone involved in the design, construction, renovation, maintenance, and operation of any site.
• they shall be freely available, well promoted and widely shared so that all relevant professionals 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. They shall also foster a clear understanding of the enforcement of relevant Integrated Accessibility Standards Regulation standards, the Ontario Building Code, and the design of public spaces standards.
• 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 and electric vehicle (EV) charging
  • the consideration of permeable surfaces, including a list of materials that firm and stable, and how to keep these surfaces level and maintained
  • clarify the application of rec trail requirements to other types of trails such as multi-use pathways/trails

Implementation timeline: Within one year of regulation being adopted.

Recommendation 3: public education

Intended Outcome: Educate the broader public on accessibility issues to improve awareness of persons with disabilities and their needs, and remove stigma around accessibility.

The committee recommends:

• government shall implement a public education campaign to address various barriers, including but not limited to:
  • ableism, invisible disability, equity and disability justice
  • seasonal maintenance of public spaces (for example, sidewalks)
  • inappropriate use of accessible parking spaces

Implementation timeline: Immediately upon adoption of regulation

Recommendation 4: accessibility report for site plan reviews

Intended outcome: Establish a consistent process to ensure that accessibility requirements are met and that there be additional accessibility considerations above and beyond the minimum requirement in the site plan review process.

The committee recommends:

• site and construction plan review process shall include a thorough review of design of public spaces standards and barrier-free Ontario Building Code requirements with the aid of a newly developed accessibility report to ensure infrastructure meets minimum requirements and does not create accessibility barriers
• government shall develop a template for the new accessibility report required to accompany all site plan approval submissions by applicant, and used by applicant, that will include all accessibility features planned
• municipal professionals responsible for drafting the accessibility report shall do so in consultation with persons with disabilities, or municipal Accessibility Advisory Committees (AACs) where one has been established under the AODA
• in addition to the consultation on the accessibility report, municipal AACs shall be consulted in a final review of site plans to ensure no accessibility barriers are constructed
• government shall develop guidance and training materials for AACs to assist in their reviews of site plans
• in addition, government shall ensure municipalities and AACs are supported with guidance materials to meet site plan review requirements 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

Implementation timeline: Within 1 year of adoption of regulation

Recommendation 5: 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:

• 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
• AACs 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
• government shall develop accessibility strategy guidance materials for municipalities to apply in this process

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 6: funding for AACs

Intended outcome: AACs should be funded to assist members in meeting with greater regularity to ensure organizations meet their consultation obligations.

The committee recommends:

• AAC members shall be provided a per diem for their work

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 7: specifications for indoor/outdoor stairs, ramps and handrails

Intended outcome: To provide specific requirements for the construction and installation of stairs, ramps and handrails to maximize their safety and utility.

The committee recommends:

• AODA and Ontario Building Code ramp and stair requirements be aligned with CSA B651 including additional features such as, but not limited to, handrails, tactile walking surface /attention indicators, etc. except in the following cases:
  • the maximum vertical rise of a ramp shall be 2500 mm
  • the maximum slope of ramps shall be 1:15
• government shall develop requirements to install alternatives to manage elevation changes greater than 2500 mm

Implementation Timeline: Immediately upon adoption of regulation.

Recommendation 8: 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:

• government shall require that obligated organizations ensure that accessibility is always maintained throughout disruptions to the built environment, including the provision of alternative accessible paths of travel with cane detectable barricades where construction, renovation, maintenance work, environmental barriers or other disruptions impede accessibility
• signage shall be provided to indicate where alternative accessible paths are installed and the route to them
• a method of providing feedback on the accessibility of renovations shall be provided as well
• where the organization is a municipality and the obstruction is long term (for example, longer than three months), municipal AACs shall be consulted along with persons with disabilities on temporary disruptions

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 9: signage

Intended Outcome: Improve accessibility of signage.

The committee recommends:

• where signs are provided under design of public spaces standards or Ontario Building Code, they must comply with requirements in CSA B651 - 4.6 Signage, except that signage must be bilingual and adopt Unified English Braille (UEB) and Code Braille Français Uniformisé (CBFU)

Implementation timeline: Immediately upon adoption of regulation

Recommendation 10: 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 post on-line and clearly demonstrate all accessibility features in their facilities
• obligated organizations must publicly post on the organization’s website, 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.)
• government shall develop a template(s) to assist organizations in providing this information.

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

Recommendation 11: affordability of barrier-free units

Intended outcome: To ensure persons with disabilities have access to affordable and barrier-free housing options.

The committee recommends:

• increase the number of accessible units in rent-geared-to-income and other social housing units to 30%.

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.

The committee identified the limited collection of defined terms, as well as the ambiguity of some definitions found in the design of public spaces standards, may lead to misunderstandings about their application, and felt that a thorough review of the definitions section of the standards is a necessity. The committee also felt that a lack of alignment in the terminologies 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 further confusion, non-compliance and reduced accessibility in buildings and outdoor spaces.

Recommendations

Recommendation 12: 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:

• government shall conduct interjurisdictional research of existing definitions from other standards (for example, National Building Code, the Ontario Building Code, municipal Facility Accessibility Design Standards, Accessibility Standards Canada and CSA B651) to develop an updated list of definitions relevant to the design of public spaces standards, including terms not currently defined in the existing standards, and provide this list as a glossary for the standards. These shall include, but are not limited to, new definitions for the following terms:
  • accessible pedestrian signal
  • boardwalk
  • exterior path of travel
  • firm and stable
    • shall include performance requirements for different elements covered by the standards (that is, firm and stable shall have different performance requirements for exterior paths of travel than outdoor play spaces, etc.)
  • maintenance
  • passing area
  • public use eating area
  • recreational trail
  • redevelopment
  • service counter
  • trail head
  • tactile walking surface indicator
  • waiting area

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 13: clarify redevelopment

Intended outcome: To clarify redevelopment to ensure accessibility of infrastructure is enhanced during planned changes to public spaces.

The committee recommends:

• government shall replace the term “redevelopment” with “material alteration” which shall be defined as “any planned change to public spaces, not including maintenance activities, environmental mitigation or environmental restoration”
• 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
• 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.) will be provided to increase the performance and accessibility of current infrastructure

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 14: guidance materials for consultation

Intended outcome: To provide organizations with information on best practices for consulting with persons with disabilities.

The committee recommends:

• create new best practice guidance materials on how to conduct consultations where required by the design of public spaces standards. These guidance materials shall provide details on:
  • who is responsible for conducting consultations
  • number and diversity of end-users consulted via percentage of impacted community
  • targeted outreach to include diverse perspectives which may include community representatives
  • who to engage in consultations and how to make the process accessible and inclusive (for example, in different languages to meet community needs, 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 and privacy maintained
  • what timelines are required when the consultations must happen
  • what specific feedback is needed for each section of the design of public spaces standards
  • what will be done with the information gathered from 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

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 everyone to enjoy natural spaces in Ontario. The design of public spaces standards lays out accessibility requirements for both recreational trails and beach access routes.

The committee worked to identify existing issues related to beach and trail access and considered different solutions and tactics to increase accessibility such as recommending non-regulatory approaches including developing guidance materials. Some solutions identified by the committee included amending the technical requirements for recreational trails to increase the widths of trails and require the provision of accessible surfaces like mobility mats to allow access to beaches and waterfronts.

Recommendations

Recommendation 15: recreational trail and beach access widths

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

The committee recommends:

• government shall increase minimum width for all recreational trails to allow people using mobility aids or travelling with service animals to pass one another
• government shall require rest/passing areas (for example, a bench, a detour short trail leading back to the main trail) where minimum width requirements cannot be met

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 16: requirements for beach access routes

Intended outcome: To require the installation of accessible surfaces that allow for access to water for persons with disabilities.

The committee recommends:

• require the installation of permanent or temporary accessible surfaces (for example, mobility mats) on beaches/soft surfaces where public access to an outdoor waterfront is provided
• accessible surface endpoints must reach beach amenities such as boardwalk, sidewalk and/or parking area
• require the provision of a water safe mobility device to get from the accessible surface to the water

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 17: guidance materials for rest areas located along recreational trails and beach access routes

Intended outcome: To provide organizations with information on best practices in the development of rest areas located along recreational trails and beach access routes.

The committee recommends:

• government shall develop best practice guidance materials for obligated organizations, created in consultation with AAC members and members of the public, on the development and installation of recreational trails, including the following specifications:
  • rest areas be constructed as fixed seating on a firm, solid and level landing pad
  • rest areas include clear space on one end of seating areas that is a minimum of 1500 mm wide for the storage of mobility devices as well as clear space in front of seating to ensure unobstructed travel
  • edge protection be installed if the rest area is near a slope or a drop off, such as along water
  • rest areas be placed in shaded areas when possible
  • seating include armrests and backrests and space below for a service animal to lay down
  • passing areas and rest areas be installed at regular intervals appropriate to the slope of the recreational trail or beach access route
  • communication through signage at trail entrance and in other formats of rest areas and other amenities along trail or route
  • installation of tactile surface changes to alert persons who are blind or low vision of the transition between the path of travel and the rest area

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.

The committee agreed that current requirements for public use eating areas lack sufficient measures to guarantee accessible and inclusive gatherings, including the provision of accessible tables, sufficient clear space between tables, among other suggested changes.

Recommendations

Recommendation 18: 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, 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. These amendments shall include that:
  • all tables, regardless of style or design, shall be accessible at public use eating areas and have a minimum clearance under the table of at least 800 mm wide by 430 mm deep by 685 mm high
  • a minimum 2000 mm clear space shall be required around each table
  • the area around and under the table and all accessible seating spaces shall be level, firm and stable to allow continuous and unobstructed access by a person with a mobility device
  • gradient around public eating areas shall be no steeper than 2% — cross slope and running slope
  • larger obligated organizations shall be required to consult with persons with disabilities, including the public or municipal AAC, 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)
  • government shall develop 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
  • where feasible, organizations shall prioritize the installation of sheltered public use eating areas
  • best efforts shall be made to ensure washrooms and water fountains are in close proximity to the public use eating area, where they are provided
  • where temporary washrooms are provided in public use eating areas, an accessible temporary washroom shall be provided

Implementation timeline: Within two years of regulation being adopted.

Recommendation 19: extend 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 extend the application requirements of outdoor public use eating areas to include small organizations as defined in the Integrated Accessibility Standards Regulation (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 or fitness 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 incorporate accessibility features such as sensory and active components so that these spaces are designed inclusively for children and caregivers of all abilities.

The committee found that the current requirements for these spaces do not adequately ensure a fully accessible experience for all users. 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.

Recommendations

Recommendation 20: improve accessibility design requirements for outdoor play spaces

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

The committee recommends:

• 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, AACs, and members of the public to ensure new requirements meet the needs of people with a variety of disabilities. These requirements shall consider:
  • outdoor play spaces, including play space and fitness equipment, shall use materials that prevent barriers and enable interactive participation for the broad spectrum of persons with disabilities, considering both children and caregivers
  • 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 and consistent tactile surface and visual contrast elements
  • delineation of play space so that people can travel safely around the play space
  • outdoor play spaces, including the space around play space equipment, shall provide an accessible route as per requirements under exterior paths of travel
  • 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)
  • 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

Implementation timeline: Within two years of regulation being adopted.

Recommendation 21: 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:

• government shall 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.

Recommendation 22: guidance materials for outdoor play spaces

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

The committee recommends:

• government shall develop, in collaboration with accessibility stakeholders (including accessibility professionals, AACs, members of the public) and obligated organizations, a resource of comprehensive guidance materials that include the minimum requirements in regulation, as well as best practices, universal design principles and relevant research to assist obligated organizations in creating accessible outdoor play spaces

Implementation timeline: Within three years of regulation being adopted.

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 to navigate freely and safely, promoting their independence and participation in community life.

The committee discussed how the current standards for external paths may lead to inconsistent accessibility experiences across municipalities. Updating the standards to widen sidewalks and ensure a clear and easily identifiable path of travel would help allow more Ontarians to connect to their communities. Tactile walking surface indicators, stairs and considering rest areas during path consultations were also discussed.

Recommendations

Recommendation 23: wider exterior paths of travel

Intended outcome: To ensure wider paths of travel that 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 1800 mm or 1500 mm where site/physical constraints exist (for example, restricted space, heritage/environmental concerns)
• installation of above ground permanent or temporary infrastructure such as street furniture, garbage cans, utility poles, seasonal decorations, EV charging stations etc. cannot obstruct or impede the barrier-free path of travel

Implementation timeline: Immediately upon adoption of regulation

Recommendation 24: expand requirements to small organizations

Intended outcome: To require that small organizations comply with the exterior path of travel standards.

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

Implementation timeline: Within five years of regulation being adopted.

Recommendation 25: requirements for upgrades on existing streets as part of redevelopment

Intended outcome: To require municipalities to upgrade sidewalks and other affected infrastructure when redeveloping thoroughfares where none are provided.

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 or no accessible exterior path of travel
• government shall develop mobility study (active transportation) standards where matters of uninterrupted connectivity and safety are addressed and guide the redevelopment and widening of thoroughfare in a coordinated, phased manner
• as intersections are redeveloped, municipalities shall ensure that all corners of an intersection have accessibility features installed for safe travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 26: pathways to accessible areas

Intended outcome: To require the design and construction of connections between accessible spaces to have a continuous, stable, firm and slip resistant 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, stable, firm and slip resistant surface with no barriers to access

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 27: wider allowances for exterior gates and entryways

Intended outcome: To require gates and entryways to allow passage by persons with disabilities.

The committee recommends:

• entrances to exterior paths of travel must provide a clear opening of 1200 mm (for example, gates, bollards or other outdoor entrance-restriction infrastructure)
• entrance infrastructure (for example, bollards, gates) shall have colour contrast to surrounding environment

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 28: visual and tactile identification of bike paths

Intended outcome: To provide clearly marked biking infrastructure to improve safety for persons with disabilities, especially those with vision loss.

The committee recommends:

• install tactile walking surface indicators where all pedestrian and bike lane infrastructure intersect (for example, cross over) to ensure that people are alerted of non-pedestrian traffic (for example, vehicle or bicycle)
• 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 / multi-use trails (for example, bike lanes that are adjacent and level with pedestrian paths of travel, require a cane detectable half height curb (60–75 mm) between adjacent cycle tracks and sidewalks, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 29: 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:

• government shall conduct an interjurisdictional scan and consult with municipalities and organizations, including but not limited to, the Canadian National Institute for the Blind and Vision Loss Rehabilitation Services Ontario, to amend the accessible pedestrian signal requirements to ensure accessible placement and installation that also account for ease of use and orientation to the pedestrian crossings
• these requirements should consider foremost the safety and independence of persons with disabilities, along with factors impacting winter maintenance, and underground utilities, and a safe distance from roadways
• the following shall be considered in updating these requirements:
  • accessible pedestrian signals shall be placed away from parallel traffic and in a location that doesn’t impede a clear path of travel
  • poles shall be placed in a way that maintains a person’s safe, accurate and convenient crossing alignment
  • the default location for the accessible pedestrian signal button should be at the side of the curb ramp away from the parallel traffic and 600 to 900 mm behind the curb while not reducing the width of the accessible travel at this pinch point to less than 1200 mm
• government shall provide example images. An image shall be included showing a 1800 mm sidewalk, against a building, as a constrained example
• government shall create a guideline to ensure consistency across all Ontario jurisdictions

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 30: lighting requirements

Intended outcome: To ensure a safe and properly illuminated path of travel in locations where required for safety and navigation in non-daylight hours.

The committee recommends:

• government shall develop lighting requirements for a range of outdoor 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
  • consideration should be given to change of weather conditions, intended use and if lighting is not required from dusk to dawn (for example, day-use parks) and for “dark sky” locations

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 31: 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 improve 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 32: outdoor portable washrooms

Intended outcome: To require that portable washrooms be accessible and connected by accessible paths of travel.

The committee recommends:

• government shall review and amend the general requirements of outdoor public use eating areas and create a set of requirements based on an interjurisdictional scan of best practices for portable washroom use in parks and outdoor event spaces, including: a ratio of accessible portable washrooms, direct access to an accessible path of travel, and accessible hand washing that is not foot activated. When provided, obligated organizations shall create a portable washroom strategy based on these requirements

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 33: seasonal/temporary outdoor changerooms

Intended outcome: Ensure access to accessible outdoor public changerooms where changerooms are provided.

The committee recommends:

• government shall require accessible options to be provided in changerooms available for public use, including, at least one accessible changeroom with a bench and arm rest
• all changerooms shall be connected to facilities by an accessible path of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 34: guidance materials for mobility device charging stations

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

The committee recommends:

• government shall develop best practice guidance materials based on interjurisdictional scans and consultation with municipalities and persons with disabilities for the provision of accessible charging stations for mobility devices along exterior paths of travel and interior areas

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 35: guidance materials for portable ramps

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

The committee recommends:

• government shall create best practice guidance materials for the design and use of temporary portable ramps for businesses that have single-step barriers including:
  • specifications for their design (for example, edge guards, tactile strips, colour contrast, etc.), procurement and placement, etc.
  • customer service measures to ensure appropriate communication of availability of temporary access ramps (for example, signage, doorbell, website, etc.)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 36: guidance materials for accessible paths of travel on bridges

Intended outcome: To ensure that bridge development considers a minimum level of accessibility features.

The committee recommends:

• in collaboration with the Ministry of Transportation, due to implications under O. Reg. 104/97, the government shall develop guidance materials related to the installation of accessibility features on bridges (for example, ones on roadways, pedestrian bridges, etc.), which recognizes the unique constraints of this infrastructure
• these guidance materials 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.

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.

The committee discussed the requirements of accessible parking spaces such as accessible paths to these spaces, as well as protection of accessible on-street parking spaces. Additionally, the committee considered the barriers that occur from improper use of accessible parking spaces as well as how to increase the minimum number of accessible parking spaces in the standards and improve access to them for persons with disabilities.

Recommendations

Recommendation 37: clarify application of standards for off-street parking

Intended outcome: To promote application of accessible parking requirements for all types of facilities, both public and private.

The committee recommends:

• that the accessible parking requirements be applicable to both facilities intended for “public” and “private” use

Implementation timeline: Within one year of regulation being adopted.

Recommendation 38: parking lot and path of travel

Intended outcome: To ensure there is a direct and barrier-free path of travel from accessible parking to amenities and exterior path of travel.

The committee recommends:

• accessible parking access aisles be served by an accessible path of travel (be it curb ramps, depressed curbs or level transitions) onto pedestrian sidewalks or forming part of demarcated pedestrian paths of travel if crossing vehicular laneways
• access aisles shall not contain a slope/ramp that bypasses the need for a proper curb cut with Tactile Walking Surface Indicators
• access aisles be marked with the words or symbol “No Parking” in paint in addition to hatch lines
• catch basins, manholes and access to other underground utilities are not permitted in the access aisles or in the accessible path of travel, where not feasible, such features 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 39: on-street parking requirements

Intended outcome: Protect and increase accessible on-street parking.

The committee recommends:

• designating accessible parking spaces, upon request, where practical (for example, in front of a residence where no driveways are present)
• protecting/increasing existing on-street parking for persons with disabilities through a strategy detailed in municipal multi-year accessibility plans

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 40: 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:

• government shall increase the percentages of accessible spaces in the standards based on current demographic data
• a minimum of 4% of parking spaces in a lot be designated as accessible
• government shall develop a list of sectors (for example, medical, recreational facilities, seniors’ residences, cultural centres, post-secondary institutions, etc.) to meet a higher percentage of accessible parking spaces
• The placement of accessible parking shall be in closer proximity to building entrances and amenities (for example, elevators) than other prioritized parking spaces (for example, new parents, electric vehicle charging)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 41: accessible parking spaces be 3400 mm + access aisle

Intended outcome: To ensure sufficient space for accessible parking, and allow ease of retrofitting where three standard stalls can be made into two accessible stalls with an access aisle.

The committee recommends:

• amend the parking regulation to require that accessible parking spaces all be 3400 mm, and maintain the current access aisle width of 1500 mm.

Implementation timeline: Within one year of regulation being adopted.

Recommendation 42: repainting parking lots to trigger accessible parking requirements

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

The committee recommends:

• repainting lines shall trigger the installation of accessible parking requirements according to the design of public spaces standards when there are no other resulting infrastructure costs (for example, curb cuts, path of travel)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 43: 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 spaces 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 parking spots provide access to the accessible entrance and are adjacent and connected to elevator banks or higher floors

Implementation timeline: Within three years of regulation being adopted.

Recommendation 44: 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 design of automated kiosks be accessible (for example, consider reach range, dexterity needed for use, glare, etc.) and that they be placed on a barrier-free path of travel with signage indicating location, payment type, etc.)

Implementation timeline: Within three years of regulation being adopted.

Recommendation 45: electric vehicle charging stations

Intended outcome: To ensure the accessibility of electric vehicle charging stations.

The committee recommends:

• government shall develop best practice guidance materials for the installation of EV charging stations including:
  • all electric vehicle charging spaces shall meet the specifications in CSA B651, 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) with access aisles on both sides
  • 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 46: retrofits for specific sectors

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

The committee recommends:

• government shall identify and require specific sectors to retrofit their parking facilities to meet the existing accessible parking standards. Sectors may include, but are not limited to public sector, health care, education.

Implementation timeline: Within five years of regulation being adopted.

Recommendation 47: accessible passenger loading zones

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

The committee recommends:

• government shall develop regulations for signed and identifiable accessible passenger loading zones in highly trafficked urban areas, event centres, education, medical facilities, community centres, etc.
• government shall undertake an interjurisdictional scan of current research and predictions for future applications regarding connected/autonomous vehicles with particular consideration for safe travel (for example, designated pick-up/drop-off/loading zones with curb cuts, etc.)

Implementation timeline: Within one year of regulation being adopted.

Recommendation 48: guidance materials on accessible parking

Intended outcome: To provide obligated organizations with guidance materials on accessible parking requirements as well as best practices to assist compliance and promote levels of accessibility beyond minimum requirements.

The committee recommends:

• in collaboration with stakeholders, government shall develop a comprehensive guidance materials resource including design practices for:
  • signage (for example, directional) and visual cues such as posts or landscaping to replace the role of a painted access aisle if surfaces cannot be painted
  • prioritized placement of accessible parking over other users (for example, new parents, electric vehicle charging, etc.)
  • requirements for newly installed electric vehicle charging stations safe, design of on-street parking in alignment with CSA B651
  • multi-lot facilities (for example, distance from an accessible entrance/elevator, signage to accessible parking, etc.)
  • ensuring accessible routes do not require persons who have disabilities to cross a driveway aisle or travel through to interfere with vehicular routes
  • 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
  • clarifying information related to underground and covered parking facilities including location of spaces and overhead clearances

Implementation timeline: Within two years of regulation being adopted.

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 committee spoke about how obligated organizations often seek guidance to ensure compliance with regulations. For individuals who use mobility aids or are visually impaired, deaf, deafened or hard of hearing, accessing services can be challenging without the support of assistive technologies, tactile cues, adequate barrier-free path widths, turning radius, and service counter accessibility.

Recommendations

Recommendation 49: fixed queuing guides

Intended outcome: To ensure that those who are visually impaired and use a walking cane can safely access queuing guides to receive services.

The committee recommends:

• all newly installed fixed queuing guides must be wide enough to accommodate standardized barrier-free path widths and turning radiuses as well as be cane detectable in alignment with CSA B651 standards (5.1.4)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 50: provision of accessible service counters

Intended outcome: To ensure that accessible service counters are available and within reasonable distance to building entrances.

The committee recommends:

• everywhere a service counter is available, a minimum of one service counter and at least 50% of service counters meet accessible Ontario Building Code requirements (3.8.3.14.). Where an uneven number of counters are provided, the number shall be rounded up.
• ensure that the service counters closest to entrance meet accessibility requirements and placement of accessible counters be inclusive such that they are not placed away from other counters (for example, the first counter)

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 51: amending the current waiting area requirements

Intended outcome: To ensure waiting area requirements extend to all waiting areas, including those that are not fixed to the ground.

The committee recommends:

• clarifying waiting area requirements to mean that “accessible seating space” is an empty space intended for those in mobility devices to wait in the same area as the rest of the seating regardless of whether the seating provided is fixed to the floor or movable

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 52: provision of accessible communication devices

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 audio description of images used, tactile maps and buttons, and adaptive and evolving technologies
• 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

Recommendation 53: guidance materials 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 and consultation with accessibility stakeholders and obligated organizations, a comprehensive guidance materials 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, AACs, 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

Iplementation timeline: Within two 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 of accessibility related features, as well as procedures for temporary disruptions to accessible elements covered by the standard.

The committee discussed the need to clarify language in the regulation to ensure greater compliance and developing specific maintenance requirements for both indoor and outdoor public spaces.

Recommendations

Recommendation 54: 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:

• 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. 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 55: 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:

• government shall develop maintenance requirements for both indoor and outdoor public spaces. Each unique section of the design of public spaces standards shall have specific requirements for how the space shall be maintained. For example:
  • outdoor: debris shall be removed from wooden boardwalks and beach access routes, furniture, fixtures and equipment shall not be placed such that they create barriers, seasonal maintenance of sidewalks, etc.
  • indoor: removal of trip hazards, maintain clear floor space in path of travel or accessible washroom etc.
  • both indoor and outdoor: replacing colour contrast or slip resistance where it has faded from a step edge or riser, working order of power door openers, elevators, etc.
• maintenance of accessible elements/features 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 (PDF)
  • obligated organizations must maintain and repair accessible features in a reasonable timeline and keep a public record of requests and/or complaints for maintenance of accessible features

Implementation timeline: Within two years of regulation being adopted.

Ontario Building Code 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 access into and within buildings, including dimensions and accessibility features. Current standards include requirements that most buildings have a barrier-free path of travel throughout including between all floors for multi-unit residential and office buildings, and detail the design requirements for building entrances, ramp dimensions, minimum doorway and corridor widths, power door openers, emergency systems and tactile walking surface indicators.

While the updates to the new 2024 Code provide accessibility enhancements in these areas, the committee feels that requirements for barrier-free paths of travel in buildings need further improvement. Entrance width requirements under the Ontario Building Code do not adequately accommodate all persons with disabilities, while Tactile Walking Surface Indicators (TWSI) need to be consistently applied across the province. 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 56: maintain 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:

• The width of the barrier free path of travel shall not overlap or encroach the required clearances as prescribed under article 3.8.1.5

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 57: increase the width of exterior walkways

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

The committee recommends:

• Update in accordance with prescribed requirements in Recommendation 23 - wider exterior paths of travel

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 58: 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. These 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 appropriate signage and lighting (large print high-contrast, instructions, QR)
  • include types of surfaces to be used that are animal-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 ensure 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 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 59: update doorway and door requirements

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

The committee recommends:

• harmonize 3.8.3.3. Doorways and Doors with CSA/ASC B651 5.2, including requirements for door widths, space for maneuvering, different types of doors, thresholds, hardware, opening force and power assist to ensure the greatest level of accessibility. 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 or short in stature
  2. require luminance (colour) 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 60: tactile walking surface indicator consistency

Intended outcome: To apply ISO 23599, “Assistive Products for Blind and Vision-Impaired Persons – Tactile Walking Surface Indicators” in a consistent manner.

The committee recommends:

• Ontario Building Code Subclause 3.8.3.2.(3)(c)(ii) prescribes Tactile Attention indicator in compliance with Ontario Building Code Article 3.8.3.18
• 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 Sentence 3.8.3.2.(2) to ensure compliance with ISO Standard 23599: “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 conforming to Article 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 61: 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 Article 3.8.1.3 of the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 62: accessibility at fitness and recreation facilities

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

The committee recommends:

• government shall 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, City of Toronto Accessibility Design Guidelines (PDF), etc.) for fitness/recreation facilities for accessible changerooms, lockers, clear floor space, etc. into the Ontario Building Code

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 63: guidance materials for public area kitchens and kitchenettes

Intended outcome: To provide best practice guidance materials to improve safety and access to kitchen spaces in public buildings.

The committee recommends:

• government shall develop best practice guidance materials for workplace and public area kitchens and kitchenettes including specifications for millwork, knee clearance, sink access, appliance mounting height, storage and clear floor space. This resource shall consider an interjurisdictional scan of municipal design guidelines and manuals such as the City of Toronto Accessibility Design Guidelines (PDF).

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.), emergency systems and signage to provide equitable life safety and functionality for all building users.

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 as well as signage and wayfinding to assist with navigation.

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

Recommendations

Recommendation 64: indoor lighting requirements

Intended outcome: Create updated lighting requirements in public buildings.

The committee recommends:

• government shall amend lighting requirements under the Ontario Building Code to ensure safety and minimize based on CSA B651.

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 65: operating controls

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

The committee recommends:

• Amend 3.8.1.5(1)(a)(i) to 1100 mm above the finished floor
• Amend 3.8.1.5(1)(b) from 810 mm by 1370 mm to 1370 mm by 1370 mm

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 66: 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 (2019) of CSA B44-10 Safety Code for Elevators and Escalators
• government shall develop best practice guidance materials on supporting organizations with accessible intercom systems including elevator communication system design features for people with hearing loss or who are non-verbal and including information from CNIB Clearing our Path - Emerging Elevator Technologies

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 67: 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”
• amend Sentence 3.8.3.7. (2) to include care and treatment occupancies 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
• add new sentence to 3.8.3.14 in alignment with Recommendation 52: provision of accessible communication devices
• 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 an interjurisdictional scan of best practices to create guidance materials for assistive devices and other technical requirements necessary

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 68: navigation in public spaces

Intended outcome: To improve safety while travelling through large open areas within a public building.

The committee recommends:

• government shall develop requirements for the design and installation of accessibility features to support wayfinding and navigation which will include consideration for:
  • tactile directional wayfinding with luminance contrast
  • material choice (such as acoustic tiles) to improve environmental acoustics and efficient navigation by blind and low vision individuals in areas including but not limited building lobbies, open spaces, atriums and food courts
• these requirements 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 timeline: Immediately upon adoption of regulation.

Recommendation 69: 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 and 6.2.1:
  • include blade signs above the door frame as a part of signage requirements for accessible washrooms, to ensure visibility
  • for universal washrooms or all gender multi-stall 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 70: 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.. Placement of visual fire alarm shall allow for the alarms to be visible by occupants in all stalls

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 71: 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:

• government shall develop requirement for the installation of emergency call systems in universal washrooms based on an interjurisdictional scan of best practices (for example, University of Toronto FADS) including the location of the reset for de-activation. These requirements shall include:
  • 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 adjacent to the button/strip
  • the specifications shall include being within reach of an individual seated on the toilet and laying on the floor
  • requirements for the system to notify the user via audible and visual signal that the alarm has been activated
  • two-way communication shall be included as part of the emergency call system
• 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 72: 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 Clause 3.2.4.19 (4) (a) of the Ontario Building Code — Alert and Alarm Signals to 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 committee spent considerable time discussing public toilets, an essential facility for everyone that all too often presents barriers for persons with disabilities. The lack of prescribed and up-to-date requirements for washroom fixtures allows for too much interpretation leading to fixtures being placed in inaccessible locations, and there is a need to prescribe additional elements like automatic locks, adult size change tables and ceiling track lifts.

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.

Recommendations

Recommendation 73: washroom fixtures

Intended outcome: To ensure all washroom fixtures are accessible in both universal and multi-stall washrooms.

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 washroom fixtures not currently prescribed under the Ontario Building Code, such as infant change tables, shall not be located in the accessible stall

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 74: automatic locking controls

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 with self-closing doors install power operated lock systems 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
• including an audible and visual signal shall identify when the door is locked
• include tactile symbols and braille to distinguish the "push to lock" from the "push to open" door opening and locking devices
• accessible signage with tactile information on or directly adjacent to the controls shall be provided to help a user with operation of the locking system
• government 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 75: 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:

• amend 3.8.3.12.(3) and (4) and (5) of 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 in all:
  • educational facilities (elementary, secondary and post secondary schools)
  • hospitals, medical clinics, rehabilitation facilities
  • community facilities (recreation centres, libraries, seniors’ centres, etc.)
• organizations installing a universal washroom with a height adjustable adult change table will develop inclusive policies and procedures for the use of the washroom as well as the maintenance and replacement of the change table to ensure good working order
• government shall conduct an interjurisdictional scan of best practices (for example, Changing Places, etc.) to develop minimum requirements for the application and use of ceiling track lifts in publicly accessible universal washrooms

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

Recommendation 76: accessible washroom additional amendments

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:
  • Lower all references to maximum mounting heights for fixtures such as hand dryers, hooks, shelves, shower wands etc. to 1100 mm. See 3.8.3.8.(1)(e), 3.8.3.8.11.(1)(h), 3.8.3.8.11.(3)(a), 3.8.3.8.12.(5)(d)(ii), 3.8.3.8.13.(2)(h)(ii) and (i)(ii) and (5)(g) and (7)(g)
  • Table 3.8.2.3.-B amended to include minimum of one accessible stall in all multi-stall washrooms regardless of the presence or location of a universal washroom
  • Table 3.8.3.13. Amend to include minimum of one barrier free shower per group
  • require luminance contrast between:
    • 3.8.3.8.(1) stall partitions and washroom walls; walls and fixtures
    • 3.8.3.12. between walls and floor; walls and fixtures
    • 3.8.3.13. Between walls and floor; walls and fixtures
    • 3.8.3.10 Between urinal and mounting surface
    • 3.8.3.11 Lavatory and wall
  • alter 3.8.3.8.(1)(c)(iii) to read “unless turning circle is unobstructed by door swing”
  • 3.8.3.8.(1)(c) door hardware on accessible stall doors shall include occupancy indicators (such as red/green markers as well as text) to indicate vacancy
  • 3.8.3.8.(3) sanitary disposal receptacles shall be placed on the side wall beside all toilets
  • 3.8.3.8.(6)(b) lower horizontal grab bar height to max. 840 mm or 100 mm above the tank
  • 3.8.3.8.(5)(b) with the top horizontal component 750 mm above the finished floor
  • 3.8.3.8.(8)(a)(i) the top horizontal bar component shall be 750mm to 860mm above the finished floor when in the down position.
  • 3.8.3.8.(8)(b) shall require the installation of a fold-down grab bar (that is, not optional) and the fold-down grab bar shall be of the type that does not lock in place in the upright position
  • 3.8.3.8.(8) *(g) – new requirement – the fold-down grab bar shall maintain its position without a locking or latched mechanism to ensure the rail can be lifted or lowered with one hand in a single continuous motion
  • 3.8.3.9.(1)(a) be equipped with a seat located at not less than 460 mm minimum height above the finished floor
  • 3.8.3.11.(h)(iii) operable with one hand and a closed fist
  • 3.8.3.11.(h)(iv) (hand drying) located not more than 500 mm measured horizontally from the edge of the lavatory
  • add a new clause in 3.8.3.8. requiring that 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
  • 3.8.3.12.(2)(a) emergency call system be installed as a button or strip adjacent to the water closet in such a way that it can be reached by the user while they are seated or if they have fallen to the floor located 200 to 400 mm above the floor. (see University of Toronto Design Guidelines)
  • 3.8.3.13.(2)(i) (shower wand) within 300 mm of the front edge of the shower bench
  • 3.8.3.13.(2)(f)(iv) edge of seat withing 300 mm of the shower controls
  • 3.8.3.13.(2)(g)(iii) to read the same as 3.8.3.8.(5)(a) and (b) with 150 mm in front of the front of the shower bench
  • 3.8.3.13.(2)(h)(iii) located within 300 mm of the front of the seat
  • 3.8.3.13.(2)(i)(i) can be reached while seated (within 300 mm from front edge of shower seat)
  • 3.8.3.13.(2)(i)(ii) (shower wand) can be used at a range of heights from 1000 mm to 2000 mm
  • 3.8.3.13.(2)(j) recessed soap holder that can be reached while seated (within 300 mm)
  • 3.8.3.13.(5) shall have an audible and visual fire alarm (universal shower and dressing room)
  • 3.8.3.13.(7)(e)(iv) horizontal portion 100–180 mm above rim of tub
  • 3.8.3.13.(2)(i)(i) flexible hose on a height adjustable system where the base is not higher than 950 mm. Universal washrooms in schools shall include a shower in accordance with 3.8.3.13

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 77: single-user accessible washrooms

Intended outcome: To provide greater accessible toilet options.

The committee recommends:

• 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 78: 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:

• government shall amend 3.8.2.4 (3)(c) to require hotels be designed to include rooms with an accessible roll-in shower or accessible bathtub compliant with CSA B651 6.5.6 by a ratio of 2:1.

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.

Currently, 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.

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 greater level of accessibility within these units so they are built beyond current barrier-free requirements. Another common concern discussed was the need for safe and accessible use of elevator services during emergencies such as power outages.

Recommendations

Recommendation 79: 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:

• government shall amend 3.8.2.1 (5) to:
  • in a Group C major occupancy apartment building to specify that 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 the following rooms and spaces that shall be located at the same level as the barrier-free path of travel
  • enhance the provision of barrier-free paths from suite entrance to all areas located at the same level as the barrier-free path, including:
    • (a) all bedrooms
    • (e) all balconies if provided

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 80: 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 shall provide a back-up generator for elevator usage and power door operators during power outages

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 81: 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 CSA/ASC B652, Accessible Dwellings

The committee recommends:

• the Ontario Building Code shall meet all CSA/ASC B652 Accessible Dwelling 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 the standards in CSA/ASC B652, Accessible Dwellings

Implementation timeline: Within two years of regulation being adopted.

Egressibility

Recommendations under Ontario’s Building Code.

Introduction

Egressibility is the intention to provide an equal level of life safety for everyone in the case of emergencies. 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 occurring in a building. 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.

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.

The committee heard that persons with disabilities are very vulnerable in emergency events, such as fire or weather-related emergencies. 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. In these instances, persons are often directed to wait for emergency crews in spaces for temporary refuge, however, these spaces offer little comfort in the event of real emergencies.

As such, the committee feels very strongly in the development of policies and the provision of emergency devices like evacuation chairs to support immediate evacuation of persons with disabilities. Additionally, the committee heard that not all emergency exits on ground-level floors are accessible or step-free. This requires people with mobility devices to find an alternate exit.

Recommendations

Recommendation 82: improve accessibility of emergency egress

Intended outcome: To improve availability of and information to allow for safe egress during emergencies.

The committee recommends:

• government shall amend the Ontario Building Code 3.8.1.2.(1) to say “all pedestrian entrances and ground level emergency egress to a barrier-free storey of a building referred to in Sentence 3.8.1.1.(1) shall be barrier-free with a power-door operator and shall connect to a barrier-free exterior path of travel complying with Sentence 3.8.2.2.(1)."
• require signage indicating the accessible egress route where it is divergent from the ambulatory route on all floors of a building following CSA B651 5.7.2.2.2 : Accessible egress route.
• when emergency muster points are provided for a facility require an accessible path of travel to that location.

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 83: 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 5.7.2, Accessible design for the built environment
• remove the exception under Sentence 3.3.1.7 (1.2) as sprinklers do not limit the migration of smoke
• government shall research based on an interjurisdictional best practice and with specific consideration for persons with disabilities safety during emergencies, the possibility of dedicating an elevator for use by persons with disabilities during emergencies as well as a plan to ensure consistent implementation across the province.

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 84: emergency evacuation chairs

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

The committee recommends:

• government 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, staff training and maintenance of the equipment
• 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

To date, the regulations in the Ontario Building Code and the design of public spaces standards only apply when a building or space is being constructed or undergoing significant renovation or redevelopment. This prioritizes improvements on circumstances when work is already being planned, and makes it easier to introduce continuing improvements in spaces because it does not cause buildings or spaces built under older rules to fall out of compliance. At the same time, this leads to many older buildings and spaces that are compliant at the time of their development but that do not meet up-to-date accessibility requirements that better address the needs of persons with disabilities.

The Ontario’s Building Code does however establish requirements that areas of a building undergoing major renovation 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. Currently, existing buildings are not affected unless an extensive renovation is planned.

The committee feels strongly that Ontario cannot become accessible without addressing the retrofit of existing buildings and places. With the increased awareness of climate change and sustainable building practices, there is an increased effort to retain existing buildings. At the same time, businesses and organizations need guidance and financial assistance to remove barriers as they may not know where to start nor have the budget to do so.

Recommendations

Recommendation 85: retrofit of existing facilities

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

The committee recommends:

• government shall develop specific requirements and guidelines that address the accessibility retrofit of existing facilities

Implementation timeline: Within one year of regulation being adopted.

Recommendation 86: retrofit of emergency systems

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

The committee recommends:

• amend the Ontario Fire Code and electrical 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
• government 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 5 years of regulation being adopted.

Recommendation 87: retroactive washroom requirements

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

The committee recommends:

• government shall require the retroactive installation of accessible features in washrooms that meet the following existing conditions:
  • located on a barrier-free path of travel
  • have a minimum turning circle of 1500 mm
• Public washrooms that meet the above existing conditions shall:
  • install power door openers according to 3.8.3.3.(4) and 3.8.3.3.(6)
  • provide a lavatory according to 3.8.3.11.(1)(c), (d), (e), (f) and (h)
  • replacement of angled grab bar with a L-bar according to 3.8.3.8.(3)
  • install fold-down grab bar according to 3.8.3.8.(8)
  • installation of d-pulls on accessible stall doors in accordance with 3.8.3.8.(1)(v)
  • toilets be provided with back rests in accordance with 3.8.3.9(1)(c) where no tank or seat lid are provided
  • provide coat hooks in accordance with 3.8.3.8.(1)(e)
  • sanitary disposal receptacles shall be placed beside all toilets in universal, all-gender washroom stalls and cis-gender accessible stalls
  • 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) compliant with 3.8.3.8.(5)(b)
  • where the distance between the wall and the centre line of the toilet is 480 mm or greater 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 within 300 mm from the front of the toilet seat, but at least 100 mm from the grab bar to prevent the holder from impeding use of the grab bar
  • sanitary disposal be installed beside the toilet and below the L-shaped grab bar
  • install a fold-down bar on the transfer side of the toilet in all retrofit situations

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 88: 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:

• government shall review extensive renovation requirements under Part 11 of the Ontario Building Code to determine enhancing the accessibility of the existing built environment, including washrooms, to meet current Ontario Building Code requirements by, among other considerations, lowering the renovation threshold
• additionally, if there has been a material alteration or repair to a building in one area to make it accessible, through the means of the permitting process, the Ontario Building Code shall require full application of section 3.8 of the Ontario Building Code to remove all barriers to accessibility in the area of the building where material alteration is taking place

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 89: resources for retrofits

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

The committee recommends:

• government shall provide resources and information on how to retrofit:
  • government shall establish resources for businesses to know how to retrofit their spaces to remove barriers to accessibility and provide extensive examples of how accessibility upgrades can happen with very little investment of money (that is, “the low hanging fruit”)
• government shall develop new funding sources:
  • create a funding program for designated public sector, large, and small organizations as defined in the Integrated Accessibility Standards Regulation to allow for retrofits to happen in a timely manner
  • one time funding one-time funding per location of up to $100,000
  • 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
  • inspection by building official to ensure accessibility upgrades meet or exceed Ontario Building Code 3.8 standards

Implementation timeline: Immediately upon regulation being enacted.

Additional recommendations

Recommendations under the design of public spaces standards in the AODA and Ontario’s Building Code.

Introduction

In their discussions, the committee covered several issues that did not fit into the sections outlined in this report. These included addressing the exemptions allowed under the design of public spaces standards, which may lead to inappropriate use and the creation of new barriers for individuals with disabilities, as well as the benefit of including images and figures in the standards to aid in better understanding and compliance with the standards.

Recommendations

Recommendation 90: inclusion of diagrams and development of resource library

Intended outcome: To provide obligated organizations with easy access to illustrated representation and library of relevant resources to ensure standards are met.

The committee recommends:

• the standards shall include diagrams with alt text to clearly demonstrate technical requirements such as space, knee clearance, counter height, spacing of queuing systems and other requirements, as appropriate
• government shall develop and maintain 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 government shall immediately begin work on the public resource to collect online guidance materials.

Recommendation 91: improve AODA enforcement

Intended outcome: Improve the enforcement of the AODA

The committee recommends:

• government shall increase funding for AODA enforcement including the hiring of additional inspectors

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 92: 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 demonstrate that compliance would constitute an undue hardship according to the Ontario Human Rights Code
• government will develop a standard template for documenting exemptions
• exemptions shall be discussed according to established due processes with staff and/or accessibility experts, AAC or legal counsel
• organizations shall identify and document their exemptions to the requirements under the design of public spaces standards in their annual status reports
• information on exemptions implemented shall be included in an obligated organization’s compliance report to the government

Implementation timeline: Immediately upon adoption of regulation.

Recommendation 93: update the Ontario Building Code with inclusive language

Intended outcome: To improve the language of the Ontario Building Code to be more inclusive.

The committee recommends:

• government shall research interjurisdictional best practices to develop a revised term for "accessible", including consideration for the definition provided in the City of Toronto Accessibility Design Guidelines (PDF), and adopt this new term in place of "barrier-free" in the Ontario Building Code

Implementation timeline: Within a year of regulation being adopted.

Conclusion

The recommendations developed by the committee in this final report are intended to address barriers to accessibility that persons with disabilities may encounter throughout their everyday journeys through the built environment. The committee recognizes that becoming more accessible is a process with no end in sight because we are always learning more about how we can do it better. At this point in time these recommendations, when enacted, will lead to progress on improving accessibility for everyone in Ontario.

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
• Ute Maya-Giambattista
  Principal, O2 Planning + Design, OPPI Representative
  Ontario Professional Planners Institute
• Diane Morrell
  Accessibility Coordinator, City of Sault Ste. Marie
• Noor Ratansi-Iamurri
  Associate Director, Canadian Hearing Services
• Megan Richards
  Program Manager, Accessibility
  City of Ottawa/Association of Municipalities Ontario
• Ian Rogers
  Director, Facility Operations, Property Management and Performance,
  Canadian Blood Services
• 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
• James Ross, Ministry of Municipal Affairs and Housing