In December 2024, Accessibility Standards Canada (ASC) released a draft Accessible Ready Design Standard for public review. In response to these consultations, March of Dimes Canada provided the following submission to ASC on January 31, 2025.
March of Dimes Canada (MODC) is pleased to share our response to Accessibility Standards Canada (ASC) public review of the draft Accessible Ready Housing Standard.
According to Statistics Canada’s most recent Canadian Survey on Disability (2022), 27 percent of Canadians aged 15 and older identified with having at least one disability – an increase of 4.7 percent from 2017. This trend is likely to continue as Canada’s population ages. In 2017 at least 13 percent of those with physical disabilities were unable to obtain the accessibility features and aids that they needed in their homes. We can assume this is increasing as Canada’s population grows and people with disabilities comprise a greater proportion thereof.
For over 20 years, MODC has administered the Home and Vehicle Modification Program in Ontario, first on behalf of the Ministry of Children, Community and Social Services, and now on behalf of the Ministry of Seniors and Accessibility. Our service users and staff have seen firsthand how important it is that homes be built in easily adaptable ways for people with disabilities and seniors to meet their needs change as they age. Too often, we have seen our service users lose the ability to make independent choices for adaptations that best meet their needs because of the need to pay for additional renovations that make the adaptation possible. By prioritizing adaptable, accessible home construction, we can ensure more people can remain independent in their homes and communities and out of long-term care and hospital when they do not need to be there.
The requirements in this standard offer practical solutions to creating accessible and adaptable homes that will not significantly increase costs to builders. It is clearly evident that ASC has engaged people with living experience of a range of disabilities to inform this standard. Based on our decades of experience, we would like to commend the inclusion of the following requirements in the standard in particular:
- The overall practical, flexible approach to the standard that enables builders to design and build either adaptable or accessible homes depending on the specific and potential future needs of residents.
- Blocking and reinforcement of bathroom walls to enable the future installation of appropriate grab bars. One of the most common challenges our service users face when installing these aids is insufficient wall reinforcement, which requires costly renovations.
- The requirement for construction of straight staircases, rather than curved, to make it significantly easier and cost-effective to install a stairlift at a future point.
- The requirements for accessible exits and pathways outside the building.
- The inclusion of 15.1 (Accessible form) and 15.2 (Accessible Ready Drawings), which will ensure the specifications of the home are readily accessible for people who need to refer to them to create adaptations in future.
We are pleased to see that ASC has addressed a wide range of building requirements to make new builds accessible and adaptable. MODC supports this standard, with the following suggestions:
- Clause 9.3.10.5: Bathroom wall reinforcing
Although ‘note 2’ in this clause refers to additional reinforcement for lifts if specifications are known, it would be ideal to include a separate section, ‘Bathroom ceiling reinforcing’ that would direct builders to reinforce the ceiling / add blocking. This would significantly reduce the cost of installing a ceiling lift in future, similar to blocking in bathroom walls to support grab bars. - Clause 18.5: Plumbing systems
Add to this clause, or elsewhere as deemed appropriate in the standard, the requirement for a centralized water shut off system that is an accessible height for all users.
- It is unclear to what extent this standard can be enforced. It does refer to the ‘authority having jurisdiction’ regarding jurisdictional building codes. However, in the absence of harmonized building codes across the country, and notwithstanding the possibility builders will see this standard as a guide to create accessible ready housing on their own volition (as a selling point, and to generally meet best practices to improve accessibility), responsibility for enforcement and strategies should be planned and articulated.
This proposed standard is a positive and significant step towards enabling people with disabilities and seniors in Canada to easily and affordably retrofit their dwelling units to accommodate their changing health status and live at home for as long as possible.
We thank ASC for bringing forward this proposed standard, and for the opportunity to respond to this important consultation.
