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Appendix I: Building Code issues

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The Submission of the Ontario Human Rights Commission Concerning Barrier-Free Access Requirements in the Ontario Building Code[5]was made in March 2002 to the Ministry of Municipal Affairs and Housing in regard to that Ministry’s review of the provisions of the Building Code Act: The following is a summary of concerns raised by the Commission:

  • The Commission was very concerned to learn that the standards for barrier-free design that are already contained in the Building Code Act are often not met by builders or enforced by inspectors.
  • Technical compliance with these standards does not necessarily result in substantive equality, i.e. usability, dignity, ease, timeliness, convenience.
  • If a building is made accessible because of renovations to entrances, under the Building Code other systems do not have to be renovated. The ‘system’ method of retrofitting a building appears illogical insofar as it requires a building to make the entrance accessible but not the doors, washrooms, etc.
  • Elevators are not required under the Building Code; no elevator access to a floor also means no barrier free path requirements.
  • Tactile signage is not required.
  • Signage and directional indicators for exits, elevators, etc. located at eye level would be helpful for persons with memory disabilities, those with low vision and even the public in general.
  • At present, fast food restaurants in Ontario can construct service counters at a height that poses a barrier to persons using a wheelchair. By way of contrast, the American Uniform Federal Accessibility Standards (see Appendix II) prescribe more detailed and specific requirements for cafeterias and restaurants such as the amount of accessible seating and how it should be distributed, height of food service areas, etc.
  • Alarm systems do not appear to require visual signals.
  • Where renovations are undertaken, though it may not be necessary to address accessibility under the Building Code, there still may be an obligation to do so under the Human Rights Code.
  • Standards under the Building Code need to be more comprehensive.
  • Persons with disabilities should have a similar choice as other individuals.
  • Stronger provisions regarding upkeep and renovation of facilities are required.
  • Those responsible for advising on or abiding by the Building Code do not receive sufficient training and evaluation

[5] The full Submission is available on the Commission’s web site at

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