National Building Code

March of Dimes Canada (MODC) is pleased to share our response to the Spring/Summer 2024 public review of the National Building Code (the Code) conducted by the Canadian Board for Harmonized Construction Codes (CBHCC), as it relates to the accessibility, visit-ability and adaptability of dwelling units.

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 are pleased to see that the CBHCC has proposed changes to the Code affecting dwelling units that will increase the supply of accessible housing and reduce future costs of modifications for governments and individuals. MODC supports the changes proposed by the CBHCC for publication, with no revisions, as follows: 

Div.B 3.8. Accessibility
  • 1882 Reinforcing Stud Walls in Washrooms for the Future Installation of Grab Bars: Showers and Bathtubs
  • 1884 Paths of Travel Within a Visitable Dwelling Unit 

Div.B 9.31.2.3. Grab Bars
  • 2030 Reinforcing Stud Walls in Washrooms for the Future Installation of Grab Bars: Structural Strength

Additionally, we support the following changes to the Code for publication proposed by the CBHCC with minor revisions, as follows:
  • 1958 Washrooms in Visitable Dwelling Units 
    • [3.8.5.2.] ---Washrooms: to increase the minimum diameter in [c] designed to permit a wheelchair to turn in a clear floor place from 1 500 mm in diameter to 1 650 mm in diameter
    • This change aligns with the turning space requirement in 1884 Paths of Travel Within a Visitable Dwelling Unit and is necessary to accommodate the turning radius of large power wheelchairs, and for the eventuality that wheelchair users may require a support person to assist them in the washroom. 

  • 2031 Reinforcing Stud Walls in Washrooms for the Future Installation of Grab Bars: Water Closets 
    • Figure [A-3.8.4.2.(2)] to modify the diagram to illustrate an example of L-shaped grab bars, which provide superior support for users, enable users to obtain a better grip, and make it easier for users to pull themselves up straight. 

These proposed changes are 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.

Furthermore, MODC supports Proposed Change 1766 for publication, which will change the existing standards in the National Building Code to introduce requirements for visual and tactile information signs for accessibility and occupant safety in Part 9 buildings.

We thank the CBHCC for bringing forward these proposed changes, and for the opportunity to respond to this important consultation.