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Everyone will have access to the. material, and be able to find, understand and use the standard. All ASC materials should be in plain language.

remove a barrier to understanding

Remove a glaring barrier to access and understanding.

So everyone has. access to egress instructions.

The scope section is written as a built environment standard - only applying to new builds, renos, or new occupancy. However parts of the standard, such as section 11, are applicable to all occupied buildings regardless of the timing of the last changes.

Evacuation is also applicable in outdoor spaces, especially given the breadth of the types of evacuations that the standard refers to. Eg national parks and forest fires.

What is section 10? It’s numbered as though it’s a substantive section but it has no requirements. It’s written like definitions, but isn’t in the definition section.

When the public visits somewhere, they will rarely have a PEEP. This suggests it will always exist.

In public buildings, visitors with disabilities rarely have a peep or an assigned buddy. This would typically only be in place where people are regularly visiting somewhere (their workplace)

In large buildings, a fire warden may have responsibility for an area smaller than the whole floor.

This section assumes a person with a disability regularly comes to The building. Visitors will not have a PEEP, for example, and should not be required to develop one.

There’s a lot of mention of peeps elsewhere and it would be useful to reference where to find more info

The visitor peep section seems to assume a visitor to an office building. This is both an extreme expectation of someone with a disability every time they visit any space and unrealistic. Someone goes to apply for a passport, visits a federal museum, goes to the bank, or goes to the CN tower. This is simply not possible.

Not all buildings will have a checkin or security desk that visitors will be checking in at.

Signs are often not accessible and therefore are not a great means of identifying visitors that may need a PEE.

Again - given the numbers of visitors and sizes of some buildings, visitors are not going to have a buddy with them who can be responsible for this. I'm imagining large museums, or airports, etc. What is the alternative? As written, it says that everyone who needs assistance SHALL have a buddy.

Clarify who is responsible for completing various activities. make it a shall instead of "is responsible for"

Clarify who owns the requirement and convert additional information into a note.

Clarify the responsibility - the drill isn't responsible for anything.

As written, this is just informative. There is no requirement here.

The first sentence in this section is a note, not a requirement. The subsequent items are aimed at people assisting and buddies. Are they the audience of the standard? I would think this needs to be written that building managers shall ensure... Or occupants shall ensure...

The section now has shall requirements for PWD and their buddies. But again, are they the audience that is implementing the stndard? OR should it be that building managers or occupants shall...

Clarify who is responsible for this. The drills and emergencies cannot document themselves.

It is not clear who is responsible for ensuring that the discussion includes these things. The discussion can't do it itself.

Clarify responsibility

Clarify responsibility

If the communication system is too low, its also inaccessible.

Should this be a note? It doesn't have any normative requirement

The name of this Annex isn't clear - isn't the whole standard about this? And "issues" seems to put the responsibility on the person with a disability.

Its not just for PWD. So remove.

To clarify the responsibility.

Too long.

Because otherwise the draft reads like its just for internal employees in the building.

This verbiage is in line with the first part of the sentence, A single-stage fire alarm system is ... Adding "fire emergency" is inline with the general definitions in the ULC fire alarm standards.

Expand on the first sentence to align with the fire alarm standard and provide additional context that not all people in the building are notified of the alert signal.

This clarifies that the fire alarm system does not "advise occupants on how to proceed." The second stage signal is to notify occupants that a fire emergency exists and that they need to implement the procedures noted in the fire safety plan.

Not all fire alarm systems are required to transmit a signal to the fire department or monitoring station (fire alarm receiving centre or 9-1-1 Centre). This is a common misconception. If there was a specific intent of the original sentence, maybe that can be explored and additional verbiage can be added.

Not all buildings are provided with a voice communication system. Typically only high buildings, as required in the NBC, or provincial codes.

The National Building Code of Canada and provincial building codes provide the technical requirements for the installation of fire alarm systems. CAN/ULC-S524 provides the technical requirements for the installation of fire alarm systems.

Not all fire alarm systems are provided with visible signaling devices.

Further explanation of how a visible signalling system will be installed is required. What device/s will initiate the visible signals? What are they connected to? How does this system operate?

Clauses 22.5.1 through 22.5.5.4 appear to be related to emergency communication rather than Occupant Evacuation Elevators.

Firefighters elevators can be used to evacuate more than one occupant if required.

The word "some" indicates that not all high-rise buildings require a firefighters elevator. The Canadian buildings require firefighter elevators in all high-rise buildings, not just some.

Unless every employee is completing the questionnaire, the question is redundant. They are completing the form because they require assistance. The subsequent questions establish the type of assistance required.

There is no question confirming that the employee has been made aware of the location of the area of refuge. The same can be added to the visitor PEEP.

The employee may not only go to other buildings, but may also go to other floors, or floor areas in the same building. The details may be important for them, and also responding emergency services.

It is important to follow up with the individual to ensure that if they answered NO to a specific question, that they then are educated and can answer YES to the follow up confirmation. It is important to close the loop.

It's important to document that the buddy has been established and who the buddy/back up are. There should also be some confirmation from the buddy that they are aware of their voluntary obligation.

Emergency services do not have time to flip through pages to determine who may be in danger when responding. Firefighters can prioritize assisting evacuation if required if they know where the individuals are located.

Adding additional context after visitor to include employees reiterates that the Visitor PEEP is not just for visitors, but also includes employees that may not work in the building on a full time basis.

The employee may have a buddy during normal work hours. But they may also work after hours when a buddy is not available. The employee should understand and have knowledge of the procedures for evacuating in both situations.

Emergency evacuation in this context is more of an event or situation rather than a process.

A PEEP is more general.

The manufacturer's may have specific information related to the inspection, testing and maintenance of the devices to ensure they are operational. In addition, as the devices will be identified, not locked and accessible, they may be moved or stolen. It's important to ensure they are replaced, or relocated back to their intended location.

There are no official pictograms for fire safety plans in Canada. The pictograms provided in sample fire safety plans from province-to-province and from various municipal fire departments differ. There is no "official" pictograms.

This is to clearly indicate which devices are at specific locations.

Manual pull station is the old term. Manual station is the new term referenced in the NBC, and ULC fire alarm standards.

It is not clear what "fire alarms" is referring to. A fire alarm system is installed throughout a building. Manual stations, the manual device used to activate the fire alarm system is identified in clause e). If this clause is referring to the locations of smoke detectors, or heat detectors, there is no added benefit to these being on an emergency evacuation map. They would add clutter to the map.

The term floor plan is more appropriate for the context.

For consistency.

What signs are being referenced? Signs indicating how to use the OEE? If so, that should be specified. Maybe another sentence at the end. The sign shall provide information on how to operate the OEE.

If the intent is to post the operating procedures for the OEE on all posted procedures throughout the building, this will additional information that is not relevant to most people, and is not appropriately located. The last sentence in this clause indicates that signage should be posted adjacent the OEE. This is the appropriate location. Also, the operational procedures should be inside the elevator.

Work is ongoing in relation to establishing renovations and major renovations in the NBC. However, major renovation is not currently referenced in the 2020 NBC.

Consider rewording the sentence to clarify the intent. Consider, Installation of a fire sprinkler system in a building does not negate the need for compliance with this Standard. While fire sprinklers provide a degree of fire safety, this standard is intended to provide life safety for people with disabilities that is commensurate with that provided to other occupants of the building.

Volunteer and friend should be separate to denote that volunteer applies to the position. In addition, add that a family member can be a buddy.

These terms are used but not defined.

This term is defined in the NFC and provincial fire codes. The term can used in this standard rather than warden.

There are various references to shelter-in-place, but there is no definition. In addition, there are no procedures identified for shelter-in-place, or how it differs from an area of refuge. While some people may understand, others may not.

The path to the muster point should also be included.

The definition is too vague, and subject to interpretation.

The PEEP should outline the conditions under which an individual may need to shelter-in-place, or proceed to area of refuge if they cannot evacuate the building. These options should be identified in the definition.

These abbreviations are used in the standard but not noted in this clause.

Not all buildings require a fire safety plan.

A hazardous material response is different than a response to an explosion. A haz mat incident is more inline with clause e) toxic fumes/gas leaks.

Terminology for supervisory staff (as defined in the NFC) may differ. Some may use wardens, others may use other terms. Supervisory staff is generic.

The clause outlines a horizontal evacuation, not the types of emergencies that may require a horizontal evacuation.

The terms used were unclear and not necessarily specific to horizontal evacuation. Horizontal evacuation does not require taking individuals to the exterior of the building.

This clause does not outline all of the requirements for fire safety plans specified in the NFC and provincial fire codes.

Grammar

It is important to review the FSP and PEEPs at regular intervals, and when there are changes to the building, or changes to the occupants and their abilities.

Available is a more accurate term than provided.

The fire safety plan can be used in fire emergencies and emergencies requiring evacuation. But it is an overstatement to say that FSP is intended to be used during all emergencies.

Change emergency wardens to supervisory staff throughout. This aligns with the NFC terminology.

This places the responsibility on the supervisory staff to advise of any changes that may effect a PEEP.

Various terms have been used. First responders, emergency personnel, emergency services. Consider a review of the document and consolidate terms where appropriate.

Should this Standard dictate the operational priorities of first responders? The clauses state that the fire department will assist them to evacuate. Evacuation may not be warranted at the time, however there are no options provided. Consider revising.

Many provinces require that fire safety plans be submitted to the fire department for review. Note that the FSP is submitted to the department, but it's not under the role of first responder. Is it intended that the fire department review the PEEPs as well. If so, this should be included in the Standard. Possibly add another clause for the submission and review of PEEPs

There are inconsistencies throughout the document.

This puts the responsibility on the individual to notify the supervisory staff of any changes.

This places the responsibility of notifying the appropriate people of any changes.

The term fire drill is used in the NFC. Several terms are used in the document including emergency drill. Considering reviewing the document and using a single term.

There was a redundant "that" which should be deleted. Not all buildings require a fire safety plan.

Consider not providing a specific number of days. Consider using a term such as intermittently.

Provide the additional Short Term to be specific. Some people don't read the text that accompanies the form.

Another comment was provided in the Annex information regarding the registry list and providing a template document.

This is the first time that the term emergency response plan is noted. Should the term be defined? Should emergency response plan be identified elsewhere in the document?

Consider a review of the document for the various terms. Maybe consolidate to supervisory staff so that the terminology is in line with the NFC.

11.3.2. notes that the manager and person with the disability will prepare the PEEP. Is the manager or FSP provider working with the person?

It's redundant.

changes may occur and it's important to capture the changes in the FSP and PEEP as soon as possible.

It may be important to practice more often.

Or should be changed to and to identify that both equipment and procedures should be tested, not one or the other.

By identifying the manual station locations the individual knows where to manually activate the fire alarm system.

It is important that occupants know where the manual stations are located so that they can manually activate the fire alarm system.

Reworded for ease of reading.

The NFC and Provincial Fire Codes require more fire drills at least annually but more often for specific buildings.

Some individuals may need to practise a drill at a different time or more often. This should be stated in the standard.

Buddy should be added as they are assisting individuals in evacuation.

Call boxes is not a term used in Canada.

It is important to ensure that all occupants know, understand and participate in drills.

There is no indication to proceed to the area of refuge.

It's important to capture feedback after drills as well as after emergency situations. Add similar statement throughout section.

The original statement is only confirming that the communication was effective. If the communication was not effective, there should be follow up.

Consistency

The abilities of a buddy may change over time. If they are no longer able to assist as noted in the PEEP, the PEEP should change.

The term "area of refuge" is used. But then the term refuge is used. Consider revising to use the term area of refuge rather than refuge.

The area of refuge should be separated from the remainder of the building by the required fire separation rating. The fire resistance rating of the fire separation should extend not only to the walls, but also the floor and ceiling above.

Is this an average level? where is the measurement taken? The NBC specifies the average level of illumination at floor or tread level, etc with a minimum level of illumination.

Vague language results in future issues. Clarifying a distance will help with enforcement, and provide guidance in complying. Consider specifying that the evacuation device at an area of refuge should be the one noted in a persons PEEP for that area. Considering providing language for what devices, if any, are required in areas where there are no PEEPs with specified devices.

All hardware used on fire doors must be rated, however this is often overlooked.

Clarify what specifically needs to be connected to backup power. Clarify what dimensions need to be free from protrusions. Is it from floor level to ceiling, etc?

Clause f notes that the ventilation system is separate. But there are no design parameters, or additional information. Should there be a note somewhere in the standard indicating that the ventilation system must be designed in conformance with the NBC, or other design parameters?

Is it worthwhile specifying that the max height is to the top of the device, (if that is the intention)? Some standards state from the top, while others such may reference the mid point of a device.

What is an emergency response system? There is no definition, nor is it a common term used in the building code or fire code. Provide clarification.

Provide clarification as to the intent of this clause. A security system may not have an immediate response from anyone. Security systems and fire alarm systems have different installation standards; fire alarm is much more stringent. Are there inspection, testing and maintenance requirements for the communication system?

The requirements pertain to both exit and egress doors, not just exit doors.

There is only one bullet point, so it is a single sentence.

There should be emergency lighting at the horizontal exit.

What is the intent? Can a door be equipped with a lock, or not have a lock installed? May also encounter electromagnetic locking devices. Provide further clarification of intent.

Is the intent that all areas of a floor area within a building need to be accessible? The current wording states that only access to the floor is required. I've had discussions with architects in which they want to provide access to the floor only, and not throughout a floor area. Provide clarification.

Similar note provided previously. Clarify the 200 lux, similar to the NBC.

Specifying two maximum distances is confusing. To me, you can only have one maximum distance. The noted distances may exceed the travel distances in the NBC. Provide clarification as to the intent.

Why reference NFPA 72? There has been no mention of NFPA 72 in the standard.

editing required

to increase accessibility

incomplete instructions

technical information missing

Clarification required that evacuation devices should be nearby evacuation stairwells.

Information was missing on the number of devices required.

Editing required.

inaccurate

putting an actual brake on a chair is very counter intuitive and very dangerous. Can affect the chair’s use.

I have an evacuation chair at home, and due to my condition, it was decided a device with braking aggrevated my condition, so we went with a device that had a self-braking mechnism.

To make it more than a tick box exercise, which I fear is it how it can be used.