December 14, 2021
The BC Government is working to update the province’s Building Code to make new buildings more accessible. In late 2021, the provincial government was consulting the public, including people with disabilities, accessibility experts and advocates, to receive feedback on the barriers and priorities to enhance accessibility requirements.
Based on March of Dimes Canada’s work as a service provider, resource and advocate for people with disabilities in BC, we submitted the following response to help inform the updates to the BC Building Code.
Feedback on accessibility requirements
March of Dimes of Canada welcomes the opportunity to provide input on the planned updates to accessibility requirements in the BC Building Code. In developing this feedback, we draw on our on-the-ground experience delivering programs and services to diverse British Columbians with disabilities, as well as our expertise in barrier-free design resulting from the delivery of programs such as our national Tech for Good program and Ontario-based Home and Vehicle Modification Program. In addition, in the past, March of Dimes Canada was proud to help shape the development of accessibility requirements for the Ontario Building Code.
We applaud the Attorney General and Minister Responsible for Housing and the Parliamentary Secretary for Accessibility for embarking on this important work to update the BC Building Code to make new buildings more accessible. We appreciate the invitation for people with disabilities, disability-serving organizations and accessibility experts to provide feedback to inform this work. We understand that the voices of people with lived experience of disability will be prioritized in this engagement, and we strongly encourage you to ensure that those voices have a seat at the table throughout the process.
Areas for accessibility enhancement
It goes without saying that barrier-free access should be guaranteed in all spaces to enable safety, dignity and inclusion for people with disabilities in all aspects of life. That said, specific settings can be prioritized for accessibility improvements in British Columbia, as outlined below.
Residential buildings
Given BC’s housing crisis, residential buildings of all kinds should be prioritized for accessibility enhancement. Without access to accessible, affordable housing, many people with disabilities in our province experience a lack of choice in housing options and are forced to live in subpar conditions, such as basement suites or secondary housing units which are unsafe or poorly renovated. Housing is not only a human right, but also often acts as a precursor to exercising other rights, and so this is an area in which accessibility improvements will have a significant impact on people with disabilities’ quality of life.
Specifically, accessibility should be prioritized for all residential settings including high-rise residential buildings, condos, townhouses, care homes, supportive housing, transition shelters, student housing, congregate living settings, hotels and vacation rentals. All new residential units should be designed using universal design principles, to enable greater choice for people with disabilities.
While it may be assumed that settings such as care homes and supportive housing would be accessible, quite often they do not offer a sufficient number of accessible units or else prioritize accessibility with regard to mobility. More attention must be provided to accessibility for sensory, cognitive, and communication disabilities.
Commercial and retail stores
Commercial buildings should be more accessible to people with varying disabilities, enabling them to enter, use facilities and access the services specific to that establishment, including access to washrooms, path of travel, seating and resting areas, as well as accessible parking.
Other settings
While accessibility can always be improved in all settings, many government or institutional settings already meet minimum access standards, and so may not have as far to go to achieve barrier-free access. That said, the needs of people with disabilities should be considered in the design of all new buildings.
Lastly, it is worth noting that, in a province like British Columbia, where the natural environment is so treasured, the notion of the built environment should be expanded to include parks and trails, enabling people with all abilities to enjoy the beautiful outdoors.
Accessibility features
In terms of the specific building features which should be prioritized for accessibility enhancements, the following factors should be considered:
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Ability to enter: The first barrier to access is simply the ability to enter the building. As such, elements that enable universal access to the building are essential, including entryway width, ramps and automatic door openers. This also includes the availability of sufficient accessible parking spots within a short distance of the entrance. It is unacceptable for an accessible entrance to stigmatize individuals who use it, such as offering a freight elevator as the only accessible entryway.
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Path of travel: Once someone has entered a building, the path of entry becomes the second barrier. Features must enable an accessible path of travel, including hallway width, interior door width, access between floors (i.e. elevators and lifts), and accessible points of rest along longer paths of travel. Attention must also be paid to remove protruding objects that are not cane-detectable, especially at head height.
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Washroom access: Access to a washroom is another essential accessibility feature that enables safe and dignified use of buildings. Every building must have an accessible washroom, near the entrance or clearly marked, with an accessible, short path of travel. In the washroom, there must be grab bars, adult changing spaces, and sinks and switches at an accessible height. An often-overlooked factor is the placement of bathroom accessories: the location and height of paper towel, toilet paper and soap dispensers must all be considered.
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Navigability: Spaces should be easily navigable by all. This means offering clear, accessible signage (including for emergency exits) and presenting directional and wayfinding information in multiple formats (e.g. visual, auditory, tactile). A consistent plan layout can also support navigability, such as locating bathrooms in the same place and with the same interior layout on each floor. Visual cues such as colours or patterns to distinguish the same features on each floor are also helpful.
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Sensory accessibility: Sensory barriers are another often-overlooked feature. Factors to consider include providing sufficient lighting (e.g. wattage/lumens) for people with vision loss, managing acoustics via soundproofing, and having an emergency alert system that is accessible for those with vision or hearing loss.
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Access to service: Lastly, in commercial or institutional settings, consideration should be given to the primary service counter by which customers or clients access services. The primary counter should be accessible (e.g. lowered counter height, seating arrangements) to avoid segregation of those using mobility or assistive devices. There should be a clear, short path of travel to the main service counter.
Universal design principles for homes
The question of whether new homes should be built in such a way to enable accessible modifications at a later date is an interesting one; our answer to the question is a nuanced yes.
Firstly, we agree that homes should be built to be more easily modified in the future. At March of Dimes Canada, we know firsthand from our more than 20 years of experience with Ontario’s Home and Vehicle Modification Program that accessible home modifications can be very costly and difficult for people with disabilities who wish to remain in their homes. Through this program, individuals with disabilities receive provincial government-funded grants to modify their home and/or vehicle to enable them to stay safe and independent at home and participate in the community. Building homes with adaptable housing requirements, as is the standard in Nova Scotia, would mean that these renovation projects can be less extensive and expensive. For example, lower plumbing rough-ins in the kitchen can later accommodate different counter heights, and wall reinforcement in bathrooms can later allow the installation of a grab bar.
However, far too often, the home modifications needed could be prevented altogether if the home were originally built using universal design standards. Universal design means designing spaces in such a way that they can be used by anyone who wishes to do so, rather than treating accessibility as an accommodation to be provided on a case-by-case basis. Applying universal design principles not only benefits people with disabilities, but everyone who uses the space. For example, a house built with widened doorways and an entryway ramp will not only be more accessible to someone who uses a wheelchair or walker, but also a family with a young child in a stroller, or someone with a broken leg who is temporarily using crutches.
As such, all new homes should be built using universal design principles to maximize accessibility for residents’ constantly changing needs. Some of the key elements include having an accessible entrance, access to a washroom on the main floor, and wide entryways, doorways and hallways to essential areas of the home. Notably, building using universal design principles is more cost-effective than retrofitting for accessibility.
Universal design is not a final destination for access, but it does represent a flexible approach to access that facilitates for various needs, regardless of one’s ability. That said, there may always be unique individual needs requiring customized modifications, making it important to design in such a way to easily facilitate these modifications when needed.
The cost of accessibility
Often, accessibility is perceived as an additional building cost. However, there is no inherent cost to designing using universal design principles. Constructing an accessible unit does not need to be more expensive than a non-accessible one. Many universal design elements incur no additional installation or materials costs, such as placing electrical receptacles higher and light switches lower.
Moreover, if universal design principles are treated as standard operating procedure, this practice alleviates the cost of retrofitting to meet accessibility standards when renovating in the future. Building owners should consider the future savings of investing in accessibility upfront.
Where updates to existing buildings are required to comply with accessibility standards, it is often possible to focus on low-cost updates that will have a big impact. However, the type of barrier must be considered. For example, with an entrance barrier that prevents people with disabilities from entering the building, the necessary resources must be invested to ensure this barrier is removed. It is worth noting that, by removing barriers so everyone can access their store, restaurant, or other business, owners are opening themselves up to a wider customer base.
Overall, while expense should not be spared to enable everyone to access and use public spaces, there are no- and low-cost means of enhancing accessibility. The Government of BC may also wish to explore opportunities to offset the costs of accessible renovations via rebates and incentives for businesses that exceed minimum accessibility standards.
A minimum standard for BC
While tailoring to individual community needs is always important, it is crucial that BC develops a minimum standard for accessibility that will enable people with disabilities to experience barrier-free access across the province. Importantly, assumptions should not be made about which communities have greater accessibility needs, as the makeup of a community today may look quite different tomorrow.
Establishing a minimum provincial standard is important for ensuring that some communities do not suffer from insufficient accessibility, and that local standards cannot be watered down. A provincial standard should be objective and measurable to ensure consistency across the board, as well as promote shared understanding amongst professionals like builders, designers and occupational therapists who may operate in more than one location.
Building upon a base standard, individual regions, municipalities, or establishments may wish to review whether to add or enhance accessibility of their space, depending on their specific context and population.
It is worth noting that exceptions are often made for heritage buildings when it comes to accessibility standards. However, globally, there is an increasing number of innovative solutions to retrofit heritage buildings for accessibility without compromising their historical aesthetic.
Additional comments
While outside of the purview of the Building Code, it is worth noting two additional enablers for meeting accessibility requirements:
- Maintenance and upkeep: Building and renovating for accessibility is an important first step, but attention must always be paid to sustaining accessibility. For example, ensuring timely removal of snow, or maintaining lifts and automatic door openers, can be the deciding factor in whether a space is accessible. Standards for maintenance of accessibility should accompany and complement amendments to the Building Code.
- Public education: With any change to regulations, sufficient public education is required to ensure compliance and understanding. We often hear from business owners who consider accessibility standards overwhelming. Work must be undertaken to ensure all relevant professionals – developers, designers, architects, owners, and operators – are properly educated and supported to implement any proposed changes to the Building Code.
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