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The only distinction between the two seems to be that "accessible" applies to all types of disabilities, whereas "barrier-free" is written in the draft as if it only applies to physical, sensory or cognitive disabilities (I'm not sure if this is a mistake). The two words are used interchangeably in the standard and it probably makes sense for the definitions to reflect this.

The current definition is tautological (defining "accessible" as something that is "without barriers"), since "barrier-free" and "accessible" have nearly identical definitions.

CSA, ASTM and other standards are referenced throughout ASC 2.2. These abbreviations should be clarified.

The logistics of managing the PEEP alongside the fire safety plan are unclear, but have significant implications for how the standard would operate in practice. Since the NFC requires that fire safety plans be retained for the fire department and authorities having jurisdiction, and this standard also asks that all building occupants with disabilities fill out a PEEP every time they enter the building, there may be significant logistical challenges with managing personal information and enabling building operators to comply with the standard.

personnel who are responsible for the safety of other building occupants may not necessarily be in the building at the time. For example, multiple clauses in the standard put the responsibility on a building manager or employer, who may be physically elsewhere during an emergency. The use of "building occupants" to mean different things in the same sentence is also a bit confusing, especially when that term also appears in (a).

As written, this provision would require the development of a PEEP every time a person with a disability runs errands in federal occupancies, especially mercantile occupancies that tend to be ground-level (e.g., a bank or Service Canada centre). It doesn't seem very practical and requires the disclosure of a lot of personal information that may not be critical for safety during common everyday activities.

It seems impractical to ask a hybrid employee to fill in a PEEP every time they show up at an office (and then change the fire safety plan, and delete all the information at the end of the day when you know the employee will return soon). The "employee" route seems to be a lot more practical since you only have to fill in the form once.

The ASC 2.2 requirement to not share personal information in their PEEP (which is part of the fire safety plan) with individuals other than their buddy and the building manager/floor warden is at odds with the NFC requirement to retain the information in the fire safety plan for review by the fire department and the AHJ. (see NFC 2020, Sentences 2.8.2.1.(1) and 2.8.2.12.(1). It will help for readers to be aware of this requirement so they can plan accordingly.

The fire safety plan is only intended to be used during fire emergencies. The NFC, which focuses on fire, does not address non-fire emergencies.

The Fire Safety Plan is intended for fire emergencies. Adding provisions for non-fire emergencies would constitute a major scope expansion that would need to be coordinated with the NFC and other provincial and territorial fire codes.

Several aspects of the standard highlight the importance of choice by the person with a disability in how evacuation takes place (e.g., if they should be transferred to an evacuation device or carried down the stairs while in their mobility aid). In workplaces, the buddy has a right to refuse unsafe work or other duties, which may be at odds with the desired evacuation method.

ASC's own name should be written correctly and with correct casing in its standards :)

The syntax of ASC's mandate makes it difficult to see which components are part of the mandate and which are the body text. This is especially important for the line on "ASC has a critical mandate to...".

Major portions of the standard are focused on areas of refuge. The design of the area of refuge is positioned early in the draft standard, highlighting its importance. This seems at odds with the content of this paragraph, which highlights the lack of willingness for people with disabilities to wait for assistance.

Under the current syntax, the comma separating people with disabilities from those assisting them behaves more as a colon: it implies that "those assisting people with disabilities and emergency personnel" is a description of people with disabilities. An Oxford comma will clarify that "those assisting people with disabilities and emergency personnel" are intended as list elements, rather than as a description of people with disabilities in this specific context.

It's not clear how the provisions in the standard mitigate risks to those assisting people with disabilities and emergency personnel. The content of the standard should be consistent with its scope.

The risk is not the same for all buildings; requirements should be calibrated in some way based on this. For example, the NBC has specific requirements for tall buildings to address their higher risk compared to a 1-storey strip plaza (e.g., Service Canada desk) where the risk is much, much lower. The risk profile for federal prisons in rural areas with volunteer fire departments would similarly be expected to differ from a bank next door to a fire station. The standard should reflect this somehow.

Adding specificity causes the application to lose robustness. Site-built, factory-constructed and single-stairwell buildings are captured under the "all buildings" provisions in Clauses a and b. The presence of clause d leads the reader to second-guess if the standard also applies to dual-exit-stairwell buildings.

It is incorrect to say that provisions of a referenced document do not supersede provisions in this standard. Where an authority having jurisdiction has legislated a referenced document (e.g., a building code), those are the provisions that should supersede. In the case of "more stringent", this is difficult to evaluate in practice because the standard does not clarify the intent of its provisions. For example, Clause 12.7.2 a (requiring a clear width of 1200 mm between handrails on ramps) is incompatible with CSA B651-23 requirements that handrails should be 1000 mm apart. The ASC guidance is more stringent from the perspective of providing enough width for a person using a mobility aid to pass through, while the CSA guidance is more stringent from the perspective of ensuring the handrails are close enough to allow a person to hold both of them and use them for safer and easier mobility. Clarifying the intent of each provision in this standard would make it easier for a reader to reconcile conflicts and relative stringency.

The fit is awkward. Sprinklering is never the only solution, and the NBC and NFC both recognize it. It feels a bit awkward under "inclusions".

It's confusing to see a section on "applications" in addition to "inclusions" and "exclusions. The applications element seems relevant to 7.1 (Inclusions) and would be more appropriately positioned there.

IT's not clear why distinct sections are needed for "terminology" and "definitions". They mean the same thing.

Strictly speaking, a mobility device could include a mobile phone, or a device for mobility between cities or communities. It would help to clarify that the goal and focus are assistance with safe and independent ambulation, transferring, or travelling between 2 proximal locations. (or other words to that effect.

The purpose of Section 10 isn't entirely clear. Beginning the section with an overview of the NFC leads a reader to feel like it's sufficient to comply with the NFC and move on, which (I suspect) isn't the intent). The introductory language is useful, but the purpose of the overall section needs to be introduced as well.

The section doesn't explain the types of emergencies requiring horizontal evacuation. Alternatively, you could keep the existing title and include examples of types of emergencies requiring horizontal evacuation.

The entire section depends on the Fire Safety Plan, but most of the general emergencies in Section 10 go beyond fire emergencies. The fire safety plan, as far as the NFC is concerned, is limited to fire emergencies. Clarifying the intended scope of this section will help a reader determine how non-fire emergencies should be handled and if different actions are needed.

Clause p already tells the reader to confirm that areas of refuge comply with Clause 12.1. There is no need to duplicate it in Clause r.

These parties are referenced later in the standard in pretty significant ways, so a common area to see their role would be helpful. This will also help reduce some of the confusion downstream on which responsibilities are that of the emergency warden vs building manager vs security personnel vs the person's employer.

This section puts a lot of responsibility on emergency wardens over matters that depend on people with disabilities having disclosed their disability and filled in a PEEP. I don’t think this is always a realistic expectation, especially in areas that provide a lot of customer service and have a lot of visitors (e.g., banks, Service Canada centres, Parks Canada information bureaus, and other mercantile occupancies). For a warden to deliver on this responsibility, they would need to ask all visitors if they have a disability – and if so, have they filled in a PEEP.

The current phrasing isn't entirely clear on how quickly these services need to be obtained. "Immediately" versus "with some delay" has major implications for how this requirement would operationalize in practice.

The current phrasing is a bit awkward

Given the fire department's primary responsibility of fire suppression, it seems unlikely that all firefighters on scene will take the time to review every single PEEP in detail.

There are several good ideas here, but they may not be practical for visitors to discuss with a warden and a buddy, especially if a new PEEP is developed every time a visitor enters the building. In the case of a visitor going to a bank for daily banking or performing other errands in federally-regulated buildings where they are unlikely to leave the entrance level, it may be more practical to consider a reduced set of responsibilities.

The current phrasing implies that the fire safety plan required by the NFC applies to all types of emergencies, which is not entirely accurate.

The current phrasing implies that people who identify as having a disability prepare a PEEP, which is different from "people who are willing to disclose a disability to their employer or host site and collaborate on safer options for egress". A person who identifies as having a disability but is unwilling to disclose it would presumably not develop a PEEP. It probably makes more sense to focus PEEPs on those who ask for them.

The type of employee intended to be captured by the employee PEEP form isn't clear. If the goal is to develop different requirements for hybrid employees than for 100%-onsite employees, then consider removing the "2-3 days/week" language for clarity and to avoid excluding people who are in on different days and times.

People aren't PEEP forms :)

Currently the draft standard doesn't distinguish between a visitor working on the roof of a 35-storey-building, and a visitor going to the bank for daily banking (or running other types of errands in federal mercantile occupancies that are low-risk with respect to being able to evacuate). The form in Annex B implies that the form would need to be filled out every time a visitor enters the building, which could get really cumbersome really quickly - for some, it will take longer to fill in the form and coordinate emergency measures than to just run the errand and leave. As another example, the current wording would require a visitor to Gatineau Park to fill in a PEEP form for the specific visitor's centre that they only enter for the purpose of purchasing a trail pass. The process of filling in the form for the visitor's centre exceeds the time to purchase the trail pass and leave.

Consider clarifying responsibilities - this will help people to implement the standard as intended. :)

It will be easier for an employer to apply the standard as intended if the delegation of responsibilities is internally consistent within the standard :)

The current wording is unclear. A backup buddy should be aware of the appropriate procedures that are relevant to their role. It will also be important to include them to help ensure that the back-up buddy is willing and able to execute the desired procedures without putting themselves at undue risk.

Reducing duplicated information will help with clarity.

Clause 11.3.5. essentially duplicates the last sentence of 11.3.4. It will be cleaner to merge them somewhere.

The current language assumes that a conveniently-located visitor check-in or security desk is present, which isn't always the case.

It will be easier for visitors to comply with the standard if the expectations within the standard are clear and consistent within the document. :)

Clause 11 puts the warden in charge of managing the fire safety planning, while this clause 11.3.6. doesn't address that responsibility. Clarity on how these responsibilities fit together will help all the involved parties understand their roles more effectively.

Check-in and security staff are unlikely to know the needs of the visitor before they arrive. This will make it challenging to implement this clause in practice, unless staff can be trained in advance in ASL, how to use all forms of assistive technologies and specialized equipment, and other devices relevant to a visitor that the site itself may not have in advance. I don't think the clause, as written, is a realistic expectation of front-desk staff or security personnel.

Clause 19.3 states that visitor PEEPs shall be destroyed when the visitor leaves the building. It is unclear how this would be executed in practice, especially for habitual visitors to mercantile occupancies.

You have no control over when an emergency occurs. The goal (I suspect) is to fill in the form early in a person's employment period or before/early in their visit).

The content is written such that it is more relevant to employees. Many of the procedures in this section may be a bit excessive for a visitor running errands at federal mercantile occupancies - the time to recruit and train a buddy and backup buddy will exceed that for the visitor to just complete their errand and leave).

It will be easier for people to comply with the standard if the roles and responsibilities of the various interested parties are clear and consistent. :)

The building manager may not be able or willing to act as a buddy, depending on the expectations of the person with a disability with respect to assisting with evacuation and the volume of requests (e.g., if the manager has to be a buddy for 5 people simultaneously). This sounds like a major expansion of responsibilities of building managers, and also assumes a certain level of ability of the manager (e.g., being able to lift someone down the stairs in their mobility device) that may not be appropriate.

All of these details are relevant to the development of a PEEP. They are also relevant to during an emergency, but should be addressed before an emergency occurs.

There are many other safety considerations for lifting that a person needs to be aware of (e.g., occupational load limits of 23 kg), that are not covered in this draft standard. It may be easier to stay up to date by directing the reader to the CCOHS guidance or something similar).

sentence (1) already specifies that the buddy and the person with a disability will collaborate on determining the best way to safely evacuate. The matter of evacuating while in a wheelchair would presumably come up in that discussion, which needs to consider the capabilities of the buddy as well as the preferences of the person with a disability

The current formula does not clarify what a designer should do to meet ASC 2.2's criteria for safety. It will be easier for a designer to comply with intended safety goals with clarity on how to handle numbers of exits, building uses, visitors, and other parameters that influence demand for an area of refuge.

"accessible egress path of travel" is a defined term, while "accessible exit is not". The suggested phrasing will avoid breaking up a defined term with a non-defined term and improve clarity for a reader.

It will help with clarity to keep location information in the same clause.

Clarifying the relevant clauses in NFPA 105 and CSA/ASC B651 will remove a source of confusion for a reader; help clarify the intent of the ASC 2.2 committee; and help increase the likelihood of a designer successfully complying with the standard.

Several requirements within clause 12.1 are not compatible with each other, or duplicated (more on that within my specific comments for areas of refuge). An image would help clarify the intent of these requirements to a reader, and also help the ASC 2.2 technical committee identify opportunities to revise incompatible requirements and improve clarity and compliance :)

Some of the requirements are not compatible with each other - Clause (f) restricts protrusions, while clause 12.1.4(c) requires the provision of a power door operator, which would presumably protrude. The same holds for a requirement for a communication system in 12.1.7. Illustrating how clauses a, b and c fit together will also help show a designer what a compliant space looks like.

the current syntax is a bit confusing - it's not entirely clear what the requirement is asking a designer to do

The language in the provision does not clarify what space needs to be provided, and why.

Most other standards describe turning diameters. A 2100 mm radius is very large - 4.2 m diameter circle, in addition to the waiting areas. I'm not aware of any wheelchairs that are 4 m long, let alone humans. If this is indeed the intent, an image to clarify would be extremely helpful, since the use of "radius" instead of "diameter" is inconsistent with the language in other standards.

the clause duplicates clause 12.1.3c

The language, as written, would prohibit the installation of a power door operator (required by clause 12.1.4(c), a communication system required by clause 12.1.7, and other useful features for accessibility (e.g., benches). Some relaxation on the existing language is needed for these required accessibility features to exist in the area of refuge.

There are several duplicated requirements that take away from clarity. A consolidated clause, perhaps with an image to illustrate the intent of the technical committee, would help with clarity.

clause 12.1.5 already states the requirements for the path of travel serving the clear waiting space. It is confusing to duplicate the requirement.

The current language reads more like a general requirement that is suitable for clause 12.1.3. It is unlikely that a lighting or ventilation system could be focused exclusively on the clear space and not the rest of the area of refuge.

clause 12.1.5(f) prohibits protrusions, which is incompatible with the existence of communication systems as they are currently described in this provision.

It is unclear why 2 signs are needed that communicate the same information in the same place.

It will be easier for a designer to comply with the standard, and for an enforcement body to enforce the standard, if the relevant requirements from CSA/ASC B651 are clarified.

minimum door widths are in the building code, not the fire code

The clause uses both terms and it is unclear if it is referring to the same thing (especially because the clause jumps back and forth between the two).

It will be easier for a reader to comply with the standard if the distinction between accessible egress paths of travel versus egress routes is clarified.

once a kick plate is installed, the door is presumably no longer transparent. It is unclear if high contrast strips would still be needed.

Federally-regulated buildings include federal prisons and detention facilities; CSIS; the RCMP; banks; and many other spaces (perhaps including ASC's own building) where a lock on the door is reasonable and necessary. Would an exit-only lock or a lock that disengages in emergencies be acceptable? Many buildings lock their doors, especially at night, for safety reasons - I do not think that a ban on locking entrance/exit doors will gain popular support.

There is no need to duplicate the detail that exit doors require power door operators

It will help with compliance and enforcement if the CSA/ASC B651 clauses that are relevant to this provision are clarified. Otherwise, the reader is left to judge for themselves in a way that may not be consistent with the intent of the ASC 2.2 technical committee.

A relaxation on the protrusion requirements is needed to permit power door operators, handrails, manual stations, communication systems, tactile signage, and other critical safety and accessibility features.

the current language is unclear as to whether ramps are permitted as part of the interior egress path of travel, despite being required fixtures elsewhere in the draft standard.

clarifying the specific CSA/ASC B651 provisions will help with compliance and enforcement in accordance with the intent of the ASC 2.2 technical committee.

the current provision, which provides a range between 45-60 m, does not clarify the exact maximum limits. It is unclear to a reader whether a distance of 50 m would be permitted.

a minimum illumination level of 200 lx sounds really bright, especially at night. Is the goal for this path to be illuminated to 200 lx at all points at all times and weather conditions?

telling a reader to make the space "free of barriers" leaves a lot of judgment to the reader as to what is required. If the goal is to standardize the accessibility of the exterior egress path of travel, providing more clarity on what constitutes "free of barriers" would help.

It is unclear why minimum dimensions are needed for a space that it outside.

signage is already required for the muster point, per sentence 3. It is unclear why this information needs to be duplicated on the ground.

clause (a) already states the need for benches :)

Moving the content in the note (on areas of refuge) to the portion of the standard addressing areas of refuge will help with clarity and consistency. Moving the note to the body of the standard will provide absolute clarity that it's meant as a requirement (consistent with the use of the word "shall" in the note) Moving the note to the clause 12.1.1 will also help the technical committee clarify if they intended to provide relaxations for single-egress-stair buildings but not multi-egress-stair buildings that are presumably less risky.

It is confusing to see the same requirement duplicated within clause 12.5

It is unclear why exterior stairs need to be designed to comply with interior stair requirements. CSA/ASC B651 provides additional requirements for exterior stairs to address aspects like drainage, which are essential for egress routes.

The requirement for a minimum number of risers is unclear. For a short elevation, forcing a designer to install additional short risers may create a tripping hazard.

the current requirements for clear space in a stair in ASC 2.2 contradict NBC requirements for reachability of handrails.

it is unclear why the requirement for clear height at a landing is 1.3 m higher than that of the staircase. 3.7 m high sounds really high - I don't think this is physically possible without extremely long staircases. It also sounds unnecessarily high. Regardless, an image would help clarify how these requirements fit together, if they are compatible with each other, and if/why they are needed.

Clarity will help with compliance, interpretation and enforcement

Sentence 1 already states that ramps shall comply with CSA/ASC B651, which means they will have handrails. Clause 12.6 further clarifies that handrails need to be designed in accordance with CSA/ASC B651.

It is common for buildings designed for accessibility to have handrails on level ground. It would be helpful if the standard clarified if these were subject to CSA/ASC B651 requirements too - and if so, which requirements.

requirements for floor slope should be consistent within the standard :)

The ability of a ramp to comply with the 30% luminance contrast requirement will depend heavily on the time of day (more difficult at night), the setting (interior vs exterior), and the weather (e.g., if the ground is snowy, grassy, covered with dirt for a garden, or something different). Clarity on how this should be designed and measured, perhaps with examples of what a compliant all-season ramp would look like, would be helpful.

CSA/ASC B651 prescribes a narrower width between handrails so that they can both be reached and used more easily at the same time. The ASC 2.2 requirement of a minimum clear width of 1200 mm between handrails on a ramp is at odds with this objective.

It is unclear why ramps need to be 10 mm (1 cm) wider under the handrails. Compliance and enforcement will be simplified if the two are consistent.

There is a large volume of explanatory content in this section that feels awkward among design and process requirements.

This is likely a typo, but should be corrected. Note that NBC 2020, Clause 3.2.4.4(2)(b) clearly states that alarm signals to evacuate occupants do indeed sound.

The correct code for fire alarm systems should be referenced :)

Authors from universities typically publish on behalf of themselves, not their institution. Some of the publications also include authors from multiple institutions, which is not captured in the current format.

editorial correction

it is unclear that this list is intended to supplement the preceding list of referenced standards

the current annex 22 is about elevators, while the content from 22.5.1 to 22.5.5 deals with communication systems and appears to be unrelated (or only peripherally related) to elevators

there doesn't seem to be enough content to necessitate distinct clauses. Also, clause 21.1.1 is called "manufacturers and suppliers" but instead lists types of emergency evacuation devices (and does not list manufacturers and suppliers).

Many visitors in federally-regulated buildings do not have managers

Particularly for mercantile occupancies under federal purview, the building manager is not going to know the needs of the visitors in advance. This sounds like a large volume of potential communication tools that would need to be prepared on the spot for people in relatively low-risk egress situations (e.g., day-to-day banking). It probably makes sense for some types of visits, but not for all of them. Also, unless an employee or visitor submits a PEEP, there is no way for a building manager to know their accessibility needs at all.

the standard explicitly excludes dwelling units where you might expect people to be sleeping. Clarifying the relevance of this note to the standard, or removing it altogether, would help a reader with clarity.

The syntax of the provision as written is awkward. It's not clear why a lone clause (a) is needed.

As written, the provision implies that alerts will be transmitted to all phones any time there's an emergency in Canada. This is probably not what's intended. It would help to clarify who should receive these alerts (e.g., other building occupants?), and what kind of emergency would prompt an alert.

clause 12 explicitly prohibits protrusions below 2100 mm above the ground, which conflicts with the clause 13.3b requirement that telephones (where provided) be a maximum of 1200 mm above the ground. Flexibility is needed in one or both of these requirements to allow a telephone to be installed in a reachable location.

there are some circumstances where pre-recorded messages are appropriate, especially when information needs to be transmitted quickly.

This clause is really useful. There are several instances in the standard where it is restated, and it doesn't need to be - it will simplify things for a reader to just point here for all illumination matters.

The purpose of clause 15 isn't clear, which makes it difficult to see how a reader should use the largely-descriptive clauses (e.g., 15.1 and 15.2). Language to explain the purpose, and moving the information-only portions to an annex, will help clarify to a reader what they need to do to meet the requirements of this standard

it's not clear what it adds to the document - it doesn't give a reader additional guidance beyond the minimum code requirements they need to follow to get a building permit if the technical committee disagrees with removing it, the suggested corrections will be helpful for readers.

The purpose of note 2 is unclear. If the technical committee feels they are relevant, they should say so. If the technical committee has not reviewed these standards (ISO/TR 25743 and ISO/TR 8101-10) and cannot comment on their relevance, then they shouldn't be listed in the draft ASC 2.2 standard.

In practice, we have no control over whether an occupant attempts to use a CSA B355-compliant platform lift for evacuation. I guess signage could be used to clarify that to an occupant, but the more essential point is that these types of lifts should not be seen as a replacement for evacuation methods when the building designers are deciding on which elevator to install.

I think this is an important provision, but it would help to clarify which occupants need education in which contexts, and delineate how this could be done in a practical way (e.g., sign posted by the OEE with instructions)? In practice, some occupancies (e.g., mercantile) will have many transient/short-term visitors who aren't likely to leave the entrance level and who probably don't need instruction in an OEE.

Elevators often have handrails for accessibility. It would be useful to clarify if these can encroach on the floor area.

this will help clarify that the exemption is specific to clause 15.4.1 alternatively, consider referencing clause 15.4.2 in clause 15.4.1 ("except as provided in clause 15.4.2, all elevators shall..." -- this will also help provide absolute clarity that these two clauses 15.4.1 and 15.4.2 should be interpreted together.

The current phrasing implies that both types of elevators are required to serve each floor. Rephrasing will help clarify that the clause is intended to focus on signage.

guidance on which components of the button need contrast with respect to the surroundings will help designers understand the intent. For example, is it sufficient for the number to contrast with the background? Or does the whole button need to contrast with the general background AND the number also need to look different?

it is common for the side-wall controls to be lower (and occupy a larger horizontal portion of the elevator wall), while the front-wall buttons can be higher to accommodate a larger range of numbers. It may be difficult to comply with the 1200 mm maximum on the front wall for buildings with many floors, but this is less of a concern if the side wall controls are all mounted at a lower height.

The purpose of this list isn't clear. The list of types of signs is not referred to elsewhere in the standard and does not seem to be relevant to the implementation of other provisions, so providing the list adds confusion.

Wayfinding systems use methods other than LEDs, such as photoluminescence.

ASC 2.4 has not been published yet (and is thus impossible to comply with), so it's unclear why it is listed here.

it is confusing to have 2 clause / subclause a's and b's under 16.2.

Presumably the egress signs are procured and mounted inside the building before you know who the occupants are going to be, especially for visitors. As written, the language implies that a 1-time visitor could request an overhaul of building signage to be provided immediately. It would be useful to clarify the intended application of this provision and where the committee sees it applying in practice.

The provisions under 16.3 apply to a map, not to a holistic plan. To be clear, I support inclusive emergency evacuation plans, but you address these elsewhere in the standard! It is confusing to repeat here.

The needs of all building occupants are not known when the map is developed. This will make the requirement impossible to enforce in practice. There is already a long list of essential components of the map that covers how a designer would make the design of the map more inclusive.

an example will help a building operator understand what types of alternate format maps exist, and who they are designed to serve

Earlier clauses in the standard prohibit protrusions below 2100 mm above the ground. Tactile maps must be installed at an angle, which would require some kind of protrusion or encroachment into the floor space. Note that the NBC and CSA relaxations on protrusions - that they are ok if something is provided to make them cane-detectable at a lower height - would address this issue.

these clauses are not related to signage and add confusion to the signage section

presumably the use of an evacuation device will need training between the person with a disability and their buddy. It makes sense for longer-term occupants, but may not be practical for short-term visitors to places like mercantile occupancies.

having multiple clause 17.1.a's and b's is really confusing

The section is written in a way that implies that all people living with dementia or who have other disabilities (e.g., related to learning; presumably also autism and ADHD?) cannot navigate buildings without a buddy. This is incorrect and comes across (probably unintentionally) as condescending.

I'm not clear on the usefulness of telling people to "remove [yourself] from the building as soon as possible". Otherwise, if there are relevant emergency egress considerations for people with environmental sensitivities that are unique to this circumstance, then consider noting them to improve the usefulness of this clause to a reader.

double negatives are confusing - positive language is easier to understand and more concise The word "issues" in this context has a negative connotation. The larger goal is to ensure that the persons' unique needs are considered in their emergency egress plan, so the standard should just say so directly.

I don't think it's practical to expect all building occupants to fill in this post-emergency review, particularly for mercantile occupancies where many occupants are one-time visitors unlikely to return 2 weeks after a drill or emergency to fill in paperwork.

This is a long list of valid emergencies, but the actual content of the draft standard is very focused on fire emergencies. It is confusing to see this list when the standard content addresses a narrower scope. Consider making these consistent - perhaps focus on fire emergencies and remove the long list so that readers aren't confused

I appreciate the opportunity to submit comments on this draft standard and extend my congratulations to the entire team for developing this draft. I support the development of a standard for emergency egress of people with disabilities, and all of my comments should be interpreted with this support in mind. I do have some big-picture concerns with this draft standard in its current form, and have noted some big-picture suggestions to help make the standard easier to implement and for others to comply with: 1) APPLICATION: The described application is all federally-regulated buildings, but the content seems to be more focused on office towers. Federal occupancies are broader, and include mercantile spaces with transient visitors (e.g., banks), detention centres, and other spaces where the proposed requirements do not apply cleanly (e.g., proposal for a visitor to fill in a PEEP every single time they enter a building, which is impractical for 1-storey mercantile spaces). I suggest limiting the application of the draft standard to the spaces that it was developed for, and perhaps consider other spaces in future editions. 2) CLARITY IN INTENT: In many places, I have suggested clarifying the intent of specific provisions - requirements are present but it's not clear to a reader why they are there and who they serve. Providing clarification will make it easier for a reader to comply with the standard in spirit if they cannot comply to the letter, and ultimately serve the needs of people with disabilities. 3) TYPES OF EMERGENCIES: The draft standard would benefit from focus in the emergency it is addressing. Many of the provisions focus on fire emergencies, though the scope seems to be defined for all emergencies. Consider limiting the scope to the context that the provisions are designed for: fire emergencies. Other types of emergencies can be addressed more thoroughly in future editions. 4) REFERENCES TO OTHER DOCUMENTS: The draft standard (appropriately) refers to other documents (e.g., CSA B651), and in several places makes a generic statement to the effect of "comply with relevant provisions in CSA B651". Don't make the reader guess on the intent of the technical committee; refer to specific provisions that the technical committee feels are relevant and necessary. This will increase the likelihood of a reader complying, and also help officials with enforcement if there are longer-term goals of bringing this into legislation. 5) INTERNAL CONSISTENCY AND COMPATIBILITY OF TECHNICAL REQUIREMENTS: In several places I have pointed out where parts of the standard aren't consistent with each other (e.g. who is responsible for the buddy system), or where requirements cannot be complied with simultaneously (e.g., protrusion bans need to be reconciled with requirements for power door operators and other protruding safety features). I would encourage the technical committee to include more illustrations to help show (and confirm to yourselves) how requirements would exist all together in practice, as well as test-drive some of the proposed procedures to help flag consistency issues. This is the responsibility of the technical committee - it shouldn't be left to public review comments to flag major internal discrepancies. 6) CLARITY AND PUBLIC READINESS OF THE DOCUMENT: I found this draft to be extremely difficult to read, as well as to understand and comment on. It is much longer than it needs to be because several provisions are repeated unnecessarily (which also probably made it more difficult for the committee to identify internal inconsistencies). The document should undergo editing before it goes to any subsequent public reviews. Similarly, numbering clauses and having some kind of hierarchy to the provisions will help with making the standard easier to read and understand, and also make it easier for individual provisions to be cross-referenced - thus reducing some of the repetition. Images will help a reader understand the intent of the committee and thus help with compliance.

This reads like an introductory paragraph that leaves a reader expecting further content on alert systems. It should be moved to introduce the alert systems listed upstream.

new editions of NBC come out every 5-ish years with lots of changes.

It is too vague/unspecific otherwise to simply reference a whole other document

it doesn't belong here

It is unclear.

creates confusion for no reason

could create conflicts and implementation difficulties.

It is very hard to follow, to tell what is part of a note or not, to reference specific provisions in other parts of the standard. There are many instances where there are multiple "(a)" or (b)" items under the same clause.

It leads to incorrect interpretation of what is in the NFC.

It is incorrect

it is not only federally regulated buildings who need a fire safety plan

awkward wording

liability, nothing is certain ("ensure") to work out, expectation that warden is an all in one first responder?

It is not enforceable, people will not waste time filling out paperwork every time they enter a building. Many data security concerns also.

these are not written as requirements, only as assumptions that the first responders have resources to do all these things, which may not be the case in many locations

This may only be applicable to people who are always in the building, not visitors

you need to read it many times before getting it.

so that readers know where to find the details of what is a PEEP while reading previous sections

See "what should we change"

creates misinterpretations, missing info

not everyone works full days, nor is "hybrid" the same as "2-3 days".

People will not waste their time filling out paperwork every time they enter a building, particularly paperwork full of personal/health data

Not enforceable, full of personal/health data collection with no particular data management plan, not all buildings have a front desk/staff assigned to collecting and then discarding paperwork every few minutes. Only asked of people with disabilities but nobody else. There are many problems with this concept.

So much personal data will likely be mismanaged.

Building safety for occupants should not rely on filling out paperwork.

The standard is not clear on what it is trying to do

Difficult to put into practice. Not enforceable.

A volunteer can just not do any of these things if they are not comfortable.

It will not be consistently done in practice

It is very hard to follow. The Standard is not consistently structured. Many "clauses" have doubles of a), b), etc but some just have a bunch of sentences and paragraphs...

only creates confusion and implies that the requirements for areas of refuge are not adequate to make this statement obvious.

Creates confusion, unclear

difficult to understand

There is too much crammed into one item. and is hard to follow/understand

It means nothing.

Not clear what is intended.

Why make someone open a second document and find an unspecified clause, when you can just state a single dimension?

Illustrating some examples for areas of refuge and where they could be located/their characteristics would really help visualize how this is supposed to play out.

As written, the emergency power can be acceptable if it lasts 2 minutes or if the door is activated once. Is this the intent?

Unless you are requiring everything to be recessed into the wall, you will not be allowed to have anything in the space like an emergency communication device, or a place to sit for a buddy.

Not clear if this is for emergency (power outage) lighting or regular lighting, how long it needs to last (1 minute or 3 hours?), etc.

Wording is not clear, but also intent is not clear either

The requirement is not clear and not structured correctly

It is not clear why you need the same sign on the door as beside the door right next to it

The building needs to have adequate management/operations support for this to be useful

Needs further consideration, and clarification on which doors this applies to. Consider adding diagrams of floor plans or size of vision panel allowed in fire doors.

The wording is not clear on how this requirement should be applied.

It makes it very hard to reference clauses in the standard when you have to say something like "Oh go see this clause, 3rd paragraph under a) but not the first a)"

it is confusing

It is too vague

This is not enforceable in practice - most buildings will lock their doors at some point in a day.

There are too many items here, making it confusing and difficult to follow

the title is about horizontal exits, but then the content includes all exit doors.

The standard may be introducing conflicts - ultimately, code will prevail in these instances.

It is not clear what the standard is asking.

A design could include a battery backup that lasts 1 minute or 15 hours..The 1 minute option will be cheaper

Just pointing to a whole standard (of unknown edition) is not helpful to the reader in finding what is actually asked.

It is difficult to follow a standard that is all over the place for numbers/letters of clauses

Realistically, there will be some amount of protrusions - the standard can outline what is acceptable (ex: cane detectable items, narrowing of path for a limited span like going through a doorway, etc)

Slope properties are inconsistent in the standard. A slope of 1/25 would not even be considered a ramp per NBC. It would have implications for the provision of landings, handrails/guards, etc.

It is not clear when this lighting is required

A design could just put wildly patterned linoleum and comply with this requirement.

Neighbours would not be thrilled to have bright lights turned on at all times outside their bedroom windows.

Unlikely to be needed

It is too vague

You could illuminate the space with a matchstick, or also some lamps, or also ultrabright spotlights..

Already covered at least in part in standard. Muster points are general areas - difficult to define what is "recessed" from the path.

feasibility in practice, pressure on building operations to ensure these spaces are always clear.

The intent is not clear. It is also not clear what requirements are supposed to be.

It is not clear how to apply this.

Requiring a minimum number of steps will be silly for small height differences

The stair will be cut into 2 sections and may not be what was intended for the standard.

Almost 4 meters of clear height at landings is questionable.

It doesn't make sense in all locations.

It is odd to say a ramp must be this steep, but also if it is not, it can be this other option.

This width may be challenging for a person using both handrails to go up the ramp. Also, it is different from CSA B651 but unsure why, and requirement says to otherwise comply with CSA B651.

Clarification of intent

It is ambiguous, not totally accurate and not clear on what a reader is supposed to do with this.

It is inaccurate and incorrect.

Seems the standard should consider CAN ULC S524 as a more relevant standard. Capitalizing "signal" for no obvious reason is confusing

Not sure how this would work in practice or what the intent is.

Not feasible in practice

one clause should not have 2 sub-clauses with the same ID.

It is not clear what is intended

Not clear what is allowed. Some jurisdictions require hardwiring (continuous power) but in some instances batteries are permitted for example.

If it is a simple requirement, might as well put it directly in the standard for easier reading. The requirement's location in the standard insinuates that the visible signal devices would be used for any kind of emergency. If it is the same signal as for fire emergencies, this may not be ideal.

Can the national public alert system be specific to a single building? Have the teams running this system been consulted on whether this is feasible?

Not feasible in practice. But also roles and responsibilities are inconsistent in the standard

Standard is inconsistent with itself

It is confusing to have multiple requirements with the same ID.

There is no clear reason to avoid this. Would be more inclusive to include various languages but staff present during an emergency may not be multi-lingual

It is not clear what this is - a 2 way communication device?

Much easier to follow, easier to keep track of requirements and avoids accidental conflicts/inconsistencies

Too vague to only say "provide emergency power". Technically a potato can power a lightbulb right? :)

Photoluminescent markings may not be useful if there is backup power for lighting already. Could introduce conflicts with energy efficiency requirements (needs lights to be kept on at all times to charge the passive photoluminescent markings)

Unclear why elevators can be lit with half the intensity as everywhere else in the standard.

It is incorrect.

It is not a requirement.

The provision is not clear

When there is a conflict, code prevails.

The standard may be introducing conflicts with requirements in various jurisdictions

Not sure this will work in practice unless a lot of obvious signage is provided.

A design will likely limit how many elevators are added to a floor plan if they all need to be very large.

If all elevators need to be stretcher sized, there is no need for signage to differentiate elevators. However, if size requirements are too onerous, there will simply be only one elevator instead of more (longer waits, less egress capacity by elevator, problem if elevator breaks down, etc)

Not clear what the difference is between operations/non-operation buttons

The standard is not published - it cannot be reviewed to see if the requirements make sense.

The standard doesn't talk about regulatory/mandatory/warning signage anywhere else in the standard. LEDs are not the only way to light up a screen. Suggest to remove or simply state the colour combinations that are not great, regardless of technology featuring the colours .

A person may not be able to see signage from some distance if there are other people around blocking the signs. Recommend to put the visual component higher.

It is difficult to follow or reference other provisions for no reason.

May not be feasible in practice without some idea of what these alternative formats might be

Not clear how this would be relevant to a building occupant (except perhaps a fire alarm technician)

"raised characters and braille" is not specific enough and could result in all kinds of different font sizes, colour choices, thickness of characters, etc. NBC points to CSA B651 for the specific features.

NBC already references CSA B651 for these types of signs. This Standard might as well do the same so everything is consistent.

The requirements are listed elsewhere and are not related to signage

"evacuation device" is a very general term that could mean a lot of things..

"loss" seems to be less preferred for terminology. A person wearing headphones may not be able to hear alarms, as would a person who didn't bring their hearing aids.

The title is not descriptive of what is in the rest of the item.

Just a consideration if it hasn't been discussed.

Is the standard effectively requiring that at least 2 stretcher sized elevators be provided in all buildings?

Unlikely to be feasible or used in practice.

It is difficult to follow what is a note or provision and to reference other provisions in the standard.

It is difficult to follow some requirements that are for fire safety or other types of emergencies. Many concepts would not apply well in some types of buildings (ex: PEEPs in high visitor turnover buildings, not locking doors in a correctional facility...)

It is unlikely to be feasible in practice. Many privacy concerns around personal information management. Ambitious to think people will fill out paperwork every time they enter a building.

A requirement is only useful if it can be put into practice with at least decent compliance rates.

Different sections require different things of the same building elements.

The standard still needs significant development work.

It is unlikely to work in practice.

I have also noticed that an actual hand brake system on an evacuation chair works contrary to what we have learned in previous training where a self-braking system is what is used worldwide. My colleagues and I have always found a self-braking system safer and easier to use.

When describing non powered units for standard evacuation, it might be helpful to note whether the evacuation chair includes arm rests and footrests for added stability. These details stood out to me when researching options, since they help keep someone feeling supported during an evacuation. Mentioning higher weight capacities, greater than 440 pounds, would also be helpful, as it allows more people to be safely accommodated. It appears the hammock style seating cradles the person being evacuated lowering the center of gravity making it much safer that a flat seat. I have found these Canadian Evacuation chair manufacturers include all of the above. Evac Chair Canada https://evac-chair.ca/evacchair-400h/ and Safety Chair https://safety-chair.ca/evacuation-chairs/safety-chair-ev-4000/

When going up the stairs, multi speeds are very important because with heavier person as a passenger you may need the speed controls assistance due to gravity. When we were in training, it was recommended that all battery-operated evacuation chairs should have a manual override in case the battery were to fail

This did help me have more confidence in the use of the evacuation chair.

This has been recommended to us in a previous training

These devices will hopefully never need to be used, but if they are needed, it could be five, ten, or even twenty years after installation. Having confidence that the evacuation chair is still under warranty and functioning properly feels important for safety and peace of mind. I also noticed that some evacuation chairs are offered with lifetime warranties, which seems like a reasonable expectation for government or public facilities making long term safety investments. A lifetime warranty could help avoid the need to replace equipment every five to ten years and ensure long term reliability. These evacuation chairs have all these features I mentioned: https://evac-chair.com/evacchair-power-900/

Change #1 - Reason for Change: The term "plus braking" is vague and implies an optional or separate manual brake, which is not standard and could be dangerous if misunderstood or misused in a high-stress evacuation. Global best practice relies on automatic, friction-based systems that provide constant, predictable control without operator intervention, maximizing safety and ease of use. Change #2- Reason for Change: A flat seat with only a lap belt presents a severe risk of the occupant sliding out or experiencing "submarining" under the belt. A 4-point harness distributes force and prevents forward slump, while a hammock seat provides crucial lateral and rearward containment. This combination is essential for safety, security, and occupant comfort, reducing panic and injury risk. Change #3 Reason for Change: Comfort is directly tied to safety and cooperation. A comfortable occupant is more likely to remain calm and still. Proper arm and foot support prevent limbs from dangling, which could cause injury, interfere with the tracks, or unbalance the chair. These features also show respect for the occupant's dignity during a stressful event. Change #4 Reason for Change: Evacuation chairs are life-critical safety devices that may sit unused for years but must perform perfectly in an emergency. A lifetime warranty ensures the manufacturer stands behind the product's longevity and durability, guaranteeing parts and support for its entire service life. Sourcing from established, high-regulation markets mitigates the risk of substandard materials or construction, ensuring a reliable product that will last.

21.1.1 - A Because the majority of chairs do not use a brake system, they use a self-braking system.

21.1.1 - D Because the majority of chairs do not use a brake system, they use a self-braking system.

21.1.1 - E To highlight key points like weight capacities and safety features like speed functions and harnesses.

If we do not add these safety features, when facilities are looking for evacuation chairs they will run into very cheap and unsafe products.

Fire alarm systems are usually located in corridors or common areas, not inside bedrooms. Therefore, their visual signals cannot reliably wake sleeping people, including those with hearing impairments. Residential suites rely on standalone smoke alarms—this is where visual signaling is actually needed. Ontario addressed this gap in its 2015 Building Code by requiring visible signaling on smoke alarms inside sleeping rooms, demonstrating precedent and feasibility. Adding this requirement improves accessibility and safety for hearing‑impaired residents and better aligns the standard with its stated intent to ensure effective waking from sleep.

Standalone strobe systems can add cost and complexity without providing an audible signal at the point of hazard detection. Smoke alarms with integrated strobes provide both audible and visible alerts directly in the room, offering improved accessibility and cost‑effective compliance. This approach is already in use in Ontario’s Building Code and would ensure consistent accessibility across provinces and territories.

Most new Canadian homes are single‑family dwellings whose only fire detection devices are smoke alarms. Without explicit language, these homes fall outside the standard’s accessibility improvements. Adding this clarification ensures that Canadians in all types of residences, not just large multi‑unit buildings, benefit from accessible alerting. This also aligns with Ontario’s existing requirement and supports national consistency in accessible fire safety.

ASC is encouraging all sectors to consider using this Standard, while it is currently only required to be used by the federally regulated sector. However, details such as section 11.3.6, requiring visitors to create a PEEP, only seems practical in buildings that require all visitors to go through security, or have appointments to visit. Also, section 11.2.1.1 places unrealistic expectations on wardens, unless the federal sector trains wardens differently then other sectors. Details like this are difficult to apply widely to other sectors and could create confusion. Please provide clarity about the application of this Standard, or provide additional guidance to sections such as 11.2.1 and 11.3.6 so it would be easier for this Standard to be used more widely.

It would be helpful to understand how ASC defines an Emergency Warden, especially since section 11.2.1 assigns certain responsibilities that some organizations may not assign to their own wardens. A clear definition, with clarity if there is an expectation for this role to have specialized training or be paid for their warden duties would help create consistency across organizations.

Remove "Types of" for consistency with the titles for 10.1.1.3, 10.1.1.5, and 10.1.1.6, and because "types of emergencies" implies that examples would be provided, rather than a description.

Unrealistic expectations are being put on people with disabilities, or on building staff who are not specially trained in emergency planning. This is not part of their paid job duties, but rather something they volunteer to do. Yet, accountabilities are not being assigned to building/facilities/security staff whose primary job function is safety and security. The draft Standard also reads as if there are only a handful of people with disabilities who may need support. Instead, the Standard should consider how to prepare the building and personnel for situations where there are lots of people with different types of disabilities, and not all have PEEPs. The Standard needs to be able to address those situations to welcome more people with disabilities into the spaces without fear that they will excluded in emergency planning.

To make this Standard successful, staff need appropriate safety training, especially training to support people with disabilities. This should be provided to all staff so they know how to get themselves out safely, and have the knowledge to guide others if needed. The section could outline the different training requirements for different roles (e.g., warden, buddy, other staff, etc.), as well as the regular schedule for updating knowledge and practice drills. Better preparation of all building staff can lead to better/positive outcomes when an emergency occurs.

The current wording implies that the wardens are responsible and accountable for the safety of occupants. In reality, most wardens are building employees who are volunteering in theses roles, and are not adequately trained to handle these situations. Supporting people with disabilities is not always discussed in training. So accountability needs to be assigned at the building owner/manager level so they can arrange for the provision of knowledge and resources for wardens/buddies to successfully carry out their tasks. Without this, there is a risk of putting unrealistic expectations on wardens, which could lead to unsafe outcomes. If preferred, the building manager can hire a Health and Safety Officer role who could take on these responsibilities.

Remove the responsibility of safety, as that is not realistic, unless wardens are professionally trained and resourced as first responders. Even if the Standard wants wardens to have this responsibility, the Standard then needs to place accountability at a senior level to ensure the wardens have the correct training, equipment, and are scheduled/located to provide adequate coverage throughout a building and throughout a day. Some wardens are trained to not assist occupants but rather to note the location of someone who needs support, and to leave the building themselves - so it is inconsistent. As an example, even on the Province of BC website, wardens are not given the responsibility of safety, instead they are "trained to assist in the event of an emergency": https://www2.gov.bc.ca/gov/content/careers-myhr/all-employees/health-safety-and-sick-leave-resources/workplace/planning/emergency-wardens

Similar to previous comment, it is unrealistic to assign wardens with the responsibility of safety, until training is adequate and consistent. The role of wardens it simply to assist. Again, as an example, even on the Province of BC website, wardens are not given the responsibility of safety, instead they are "trained to assist in the event of an emergency": https://www2.gov.bc.ca/gov/content/careers-myhr/all-employees/health-safety-and-sick-leave-resources/workplace/planning/emergency-wardens

There is no mention of wardens requiring to know how to use evacuation devices, which contradicts with the statement that wardens are responsible for people safety. Meanwhile a buddy is required to know how to use evacuation devices. Please review and update.

Current text implies that the responsibility to initiate and complete the PEEP is on the person with the disability. Instead, this should be the responsibility of the warden/buddy/building team, while the person with disability should only be responsible for providing their sections. This is because not all people with disabilities are fully aware or experienced in PEEPs or emergency plans, or even their own human rights as a person with a disability. So the emergency team should be the one looking out for and informing the disability community to ensure everyone is prepared with a PEEP.

Current text is putting responsibility on the person with the disability to have this knowledge, however, not everyone is aware of what evacuation devices are available and how to use them - these are not items that people have in their homes or that they can easily get access to and learn how to use. The emergency team needs to first provide that training and drills, as appropriate for the PEEP and the building.