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12.1.4 Doors serving an area of refuge A door serving an immediate area of refuge shall: a) be leakage-rated complying with NFPA 105; b) have a clear width complying with CSA/ASC B651; c) be equipped with a power door operator in compliance with either ANSI/BHMA A156.10 (Power Operated Pedestrian Doors) or ANSI/BHMA A156.19 (Power Assist and Low Energy Power Operated Swinging Doors), capable of being activated in the event of a loss of power via emergency power or alternative power source; and d) be located clear of any adjacent door swing and away from pedestrian exit routes.

All doors along the egress route shall comply with CSA/ASC B651 and the NFC. They shall be equipped with power operators in compliance with either ANSI/BHMA A156.10 (Power Operated Pedestrian Doors) or ANSI/BHMA A156.19 (Power Assist and Low Energy Power Operated Swinging Doors).

An accessible exit door discharging to the exterior of a building or another building shall have a sign with raised characters and braille.

However, the challenge is that the fire alarm systems that this standard includes, unlike smoke alarms, are not located in sleeping units. Fire alarm systems are generally in apartment buildings (rental and condo) and are generally required in corridors, common areas, and other non-sleeping units. As an additional element in Ontario, for example, in the residential suites within these large buildings are generally smoke alarms that are specific to that suite and not connected to the building fire alarm system. This is one reason why Ontario’s smoke alarm requirement implemented in its 2015 provincial Building Code in section 3.2.4.22 included the requirement for residential standalone smoke alarms in each sleeping room (sub-section 3.a). Since subsection 13 also required visual signaling component, this is where the value in waking sleeping people occurs and why Ontario made the decision to include a comprehensive fire alarms systems and smoke alarm requirement so that safety and accessibility was increased for all residents of these new buildings

SIGNAL system shall consist of strobe lights conforming to CAN/ULC-S526.” o We believe that this is an opportunity to include a requirement for smoke alarms with visible signal devices as a cost-effective method of including the accessibility technology in a manner that includes the additional benefit of an audible device

In this case, there is a gap in application on single-family homes, which do not require fire alarm systems, but rather smoke alarms. The benefits of visible signal technology are clear: • Enhanced visibility: Strobe lights are highly visible due to their intense and rapid flashing. They can cut through visual clutter, effectively capturing attention and conveying urgent messages. In emergency situations or high-noise environments, strobe lights provide a visual cue to help ensure people are alert and respond appropriately. They are also synchronized at 1hz for safety and accessibility and to address concerns that were discussed around epilepsy when Ontario put its provincial requirement in place ten years ago. o Added visibility: Kidde has also received reports from firefighters in British Columbia that visible signals have increased their response times in large apartment buildings or condo, where flashing lights from individual units seen from the street has enabled them to locate the fire earlier, and respond faster. • Accessibility and inclusivity: Strobe lights benefit individuals with hearing impairments. By providing a visual component to alarm systems, strobe lights ensure that those who may not hear or have difficulty hearing audible alarms can still receive crucial alerts. This enhances accessibility and promotes the safety of individuals with hearing disabilities. As Proposed Change 2252 states, “Statistics Canada reports in 2021 that “overall, 60% of Canadians aged 19 to 79 have a hearing health problem,” and 38% have hearing loss. The percentage of the population reported to have hearing loss was reported to be 10% in 2001.” The problem has clearly been growing. o Added inclusivity: Beyond the growing segment of the population with hearing disabilities, visible signals also have an added benefit of waking sleeping children, who have a tendency of deep sleep that can tune out sounds such as smoke alarm tones.1 • Increased effectiveness in noisy environments: Traditional audible alarms may be difficult to hear in loud or noisy environments, such as construction sites or industrial settings. Strobe lights overcome this limitation by providing a visual signal that can be easily noticed amidst high noise levels. They can help ensure that important alerts are not missed due to ambient noise.

Adapt the solution to the new standards.

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Adding more guidance on how the turning radius can be taken into account and what room to maneuvre is available for companies in that regard.

More synchronisation with the building code.

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More synchronisation with the NBC.

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You could add the term “photosensitivity,” which the Government of Canada uses re light sensitivity disability (e.g. archived Web 2.0 disabilities description)(never use “phobia.”)We are not afraid of lights. FYI, the Government of Canada lists light sensitivity on its website regarding concussions.

Please add above comment to the effect indicated.

Add a comment about the necessity to maintain paper maps.

Not sure, but black/white photocopy test is good to confirm “70% contrast” recommended.

change all instances of "accessibility standards Canada" to "Accessibility Standards Canada"

consider adding content to explain the structure of the standard, including what constitutes a clause. Consider also using different language to distinguish clause, sub-clause, sentence, section, etc.

consider sorting the list in a more intuitive way (e.g., order in which topics appear in the standard, or alphabetically)

include the full "systeme internationale" in addition to the SI acronym

consider listing "Reaches" on this list, and then list the frontal, lateral and functional reach underneath

modify to "without losing their balance".

consider removing the word "efficient"

include the equation instead of the note

consider removing it

consider eliminating most of this section and just refer to CSA/ASC B651-23 clause 4.4.5, except where ASC 2.4. proposes something different or otherwise adds value

don't change, but coordinate with ASC 2.2 (standard on emergency egress)

consider specifying the relevant CSA/ASC B651-23 clauses

consider explicitly addressing benches and seating, which are important for people with mobility disabilities, hidden or otherwise

coordinate with ASC 2.2

consider being a bit more specific on the intent - something like "if lighting is installed in the handrail, the function of the handrail for balance and fall prevention should still be obvious" (not the best wording, but the essential point is that people still need to see the handrail and understand its purpose and utility as a handrail)

consider adding a pointer to CSA/ASC B651-23 and NBC 2025, which both prescribe higher illumination levels in certain contexts.

state the specific CSA/ASC B651 clauses that are intended to apply (I assume 8.3.9.(b)), along with any necessary qualifiers for the intended application to ASC 2.4

strike the language on "without feeling lost"

consider consolidating all of the types of signage in this section into a table

either remove them or add a major qualifier to indicate their sensitivity to the weather and maintenance - like "under dry conditions, the trail is firm. Conditions may change under rain and snow".

consider an exception for common acronyms and abbreviations (e.g., St. for street)

consider including a requirement that numbers be written with their relevant Arabic numeral (if the sign is in a language that uses Arabic numerals), instead of writing out the full word (e.g., 1 instead of One)

consider specifying how the floor number should be displayed on handrails (did you mean for this to address tactile numbering on the underside of the handrail?)

consider restructuring to better distinguish background information from provisions for a designer to follow - distinguish the last sentence in some way from the preceding stuff

move all of the publications to the "publications" section

correct the various document references to include full citation information, as well as correct individual author information for several of the resources that have been attributed to institutions rather than individual authors

consider a more precise word - something like "smooth" maybe?

"Tactile signs are installed close enough to the circulation or pedestrian area so that a person can reach them from the front or side without losing their balance".

consider adding an image to show how all the elements fit together

consolidate clauses b and d - perhaps by removing the "wall-mounted" restriction on clause d

consider expanding the application of clause d (and the general goal of tactile signs being reachable) to cover the entire section on tactile signage in Clause 12.7. and not just signs at eye-level

consider removing the definition of functional reach and the corresponding lateral and frontal reaches, and replace all instances of lateral, frontal and functional reaches in the text with the floor dimensions needed in front of a relevant sign or fixture to achieve the intended goal (in clause 12.7.3.(d))

split this up so that the need for graphical symbols and pictograms are not restricted to signs installed within lateral or frontal reach

for the elements related to tactile text and braille, use plain language - "when the sign is reachable from the front and side from the pedestrian path" or "when the sign is installed X height above and Y distance from the stance surface"

consider giving more guidance on appropriate lateral and frontal reach distance (e.g., minimum clear floor area in front of the sign, per clause 12.7.3.(d))

consider adding a bit more specificity on the intent of "approachable within 100 mm" - e.g., prescribe a clear floor area that needs to be provided within 100 mm of the sign, similar to the wall mounted sign requirements below in Clause 12.7.3.(d)

n/a - big-picture comments

Remove it, or add the content this sentence describes.

Add examples such as use of QR codes NFC, and RFID tags.

include locations in the draft standard, because searching the document for "technologies" and "emerging" there does not to be any content.

An eye condition can also affect a person's lighting needs. Lighting also impacts people who having hearing limitations as they need to see for lip reading or seeing signed language.

When facilities are operational, exterior lighting shall:

Specify minimum lighting levels. Current wording requires exactly 50 or 100 lx.

Effective wayfinding enables individuals to discover and use destinations and services independently by allowing them to:

Replace "extensive areas" with a term that limits the application to buildings and highly developed areas or include a definition of "extensive areas" that clarifies its meaning.

for buildings comply with CSA/ASC B651:23 and for outdoor spaces comply with ASC Standard on Outdoor Spaces.

for buildings not have wayfinding or signage elements obstruct the path of travel in accordance with CSA/ASC B651:23 and for outdoor spaces not have wayfinding or signage elements obstruct the path of travel in accordance with the ASC Standard on Outdoor Spaces.

For buildings be placed in accordance with CSA/ASC B651:23 and for outdoor spaces be placed in accordance with the ASC Standard on Outdoor Spaces.

Remove this specification.

Remove all design and placement requirements covered by other standards.

Change e to read "have a consistent profile throughout their height from ground level.:

Walking surfaces of exterior paths of travel shall comply with the ASC Standard on Outdoor Spaces. Walking surfaces of interior paths of travel shall:

Remove this requirement as it is specified in the ASC standards for the built environment.

Remove this requirement.

support orientation and wayfinding at critical navigation points through additional illumination, increased visual contrast, or tactile elements,

Paved exterior paths of travel shall: a) incorporate distinctive surface materials, such as tiles, at intersections or key decision points in outdoor plazas to help users identify critical areas and make informed navigation choices; b) include two white transverse lines bordering the crosswalk (for all crosswalks); and c) be simple and facilitate safe street crossings that are not impacted by the colour, design, imagery, texture or materials used to enhance aesthetics. Note 1: Architectural elements may be included to help maintain visibility of wayfinding and signage elements during different seasons. Note 2: Decorative crosswalks should be avoided across roadways that have high volumes of traffic or a high percentage of truck traffic, or both, specifically, major and minor arterial roadways.

Remove all specifications related to multi-user facilities (here and throughout the standard).

be simple and facilitate safe street crossings that are not impacted by the colour, design, imagery, texture or materials used to enhance aesthetics.

be placed in areas inside buildings lacking constructed or natural navigation cues

b. be arranged in a clear and structured sequence, with well-defined start and end points that are easily identifiable, marking intersections, decision points, or potential hazards along the way; c. be of enough depth in the direction of travel to provide adequate detectability and appropriate response by the users, such as stopping and turning; d. be aligned with constructed and natural navigation cues;

Remove the requirement for slip resistance.

Remove this text/requirement.

Specify whether the cast iron material is sufficient to provide recognition even if it is black with little colour contrast with the surrounding surface or whether it also has to have the truncated domes and/or be yellow (if that is possible/available).

an attention indicator shall be installed to identify when a hazard exists at the following locations:

Remove the requirement.

b. In outdoor spaces comply with the ASC Standard on Outdoor Spaces.

c. Indoor paved and unprotected drop-off edge where:

Curb ramps and depressed curbs as required by the ASC Standard on Outdoor Spaces.

Remove this requirement.

Remove this requirement.

The same standard for light reflectance that is required for accessibility.

Remove this option

have a top diameter between 12 mm and 15 mm

be installed cross the full width of the hazard

In large or open spaces within a building or building complex, a tactile pathway or guiding line for navigation is required

Note 1: Direction indicators are recommended for safety and guidance in the outdoor environments surround a complex of buildings.

Remove this note.

Remove or clarify who is qualified to do this work.

for signs intended to be read by pedestrians, include tactile characters alone or in conjunction with braille in

identification signs regulatory signs; and warning signs;

for signs intended to be read by pedestrians, include audible sign technologies or tactile characters

be placed in a location that does not intrude into the path of travel

be placed in a location that does not reduce accessibility and is appropriate to the intended effect of the sign

12.2.9 Trailhead signs for outdoor spaces

The section should specify the requirements for signs (other than trailhead signs) in outdoor spaces.

Remove this text.

allow for side-by-side format, languages may appear one above the others which is known as over-under format. Whether side-by-side or over-under format, all languages should be presented equally in all respects

Clarify what these may be used for. If they are included as alternative communication methods why are they not in c?

100 lx

be produced using materials that will continue to meet accessibility requirements throughout the anticipated life cycle

Specify what is meant by "in such cases".

Revise to align with a)

for outdoor toilet facilities with walls

For example, at trail intersections it may be possible to position the signage consistently in advance of the intersection, located to the right at a fixed height above the ground.

Be more specific as it is unclear.

This clause is well-written. This requirement should be made consistent throughout the entire Standard.

when the sign’s location makes providing tactile elements impractical;

be produced using materials that are durable to ensure that the tactile sign continues to comply with accessibility requirements throughout the sign's expect life cycle.

The specified height range should be higher for outdoor areas where individuals may have to be wearing gloves.

Remove this requirement.

These include orientation signs, such as directories; identification signs, such as washroom signs, regulatory signs, such as no smoking, and warning signs, such as area closed for cleaning.

Have a viewing time according to the amount of text or length of the message as specified in the table. (add table)

Remove this requirement.

Electronic and digital signage design and installation shall provide clear, accessible communication regardless of variations in: i. noise level and time-of-day traffic considerations; ii. proximity to reflections by ambient lighting; iii. proximity to reflective acoustic surfaces; iv. proximity to physical obstacles to access within the built indoor or outdoor environment; v, direct placement in the path of sunlight; and vi. installation considerations for indoor built environments (i.e., lighting and visual contrast).

enable video brightness settings to be adjusted

Remove the design specification for a backlight feature

Remove this requirement.

If pixel pitch determines the accessible viewing distance then this should not be a note. There should be a requirement that specifies the pixel pitch to be used depending on the viewing distance. Create a table of viewing distances with the required pixel pitch.

Display surfaces of electronic and digital signs, whether used indoors or outdoors, shall be designed with materials that ensure clear visibility and perception in varying lighting and environmental conditions;

Remove a.

Create a table of viewing times per amount of test/length of message.

grade 4 reading level

The timbre and tone required for accessibility across age demographics should be specified as a requirement.

The information displayed should be based on a study and understanding of users' needs, including their location, language proficiency, and specific route requirements.

Map design and readability should: use cartographic design elements to enhance clarity and usability such as title/subtitle, neat lines, legend, and orientation indicators when appropriate;

conveyed at a Grade 4 reading level.

Where multiple similar facilities are provided, maps shall include an index as part of the location plan or guide map.

Remove this text.

Remove this requirement.

Maps

Currently there is no perfect solution.

An eye condition can also affect a person's lighting needs. Lighting also impacts people who having hearing limitations as they need to see for lip reading or seeing signed language.

When facilities are operational, exterior lighting shall:

Specify minimum lighting levels. Current wording requires exactly 50 or 100 lx.

Effective wayfinding enables individuals to discover and use destinations and services independently by allowing them to:

Replace "extensive areas" with a term that limits the application to buildings and highly developed areas or include a definition of "extensive areas" that clarifies its meaning.

for buildings comply with CSA/ASC B651:23 and for outdoor spaces comply with ASC Standard on Outdoor Spaces.

for buildings not have wayfinding or signage elements obstruct the path of travel in accordance with CSA/ASC B651:23 and for outdoor spaces not have wayfinding or signage elements obstruct the path of travel in accordance with the ASC Standard on Outdoor Spaces.

For buildings be placed in accordance with CSA/ASC B651:23 and for outdoor spaces be placed in accordance with the ASC Standard on Outdoor Spaces.

Remove this specification.

Remove all design and placement requirements covered by other standards.

Change e to read "have a consistent profile throughout their height from ground level.:

Walking surfaces of exterior paths of travel shall comply with the ASC Standard on Outdoor Spaces. Walking surfaces of interior paths of travel shall:

Remove this requirement as it is specified in the ASC standards for the built environment.

Remove this requirement.

support orientation and wayfinding at critical navigation points through additional illumination, increased visual contrast, or tactile elements,

Paved exterior paths of travel shall: a) incorporate distinctive surface materials, such as tiles, at intersections or key decision points in outdoor plazas to help users identify critical areas and make informed navigation choices; b) include two white transverse lines bordering the crosswalk (for all crosswalks); and c) be simple and facilitate safe street crossings that are not impacted by the colour, design, imagery, texture or materials used to enhance aesthetics. Note 1: Architectural elements may be included to help maintain visibility of wayfinding and signage elements during different seasons. Note 2: Decorative crosswalks should be avoided across roadways that have high volumes of traffic or a high percentage of truck traffic, or both, specifically, major and minor arterial roadways.

Remove all specifications related to multi-user facilities (here and throughout the standard).

be simple and facilitate safe street crossings that are not impacted by the colour, design, imagery, texture or materials used to enhance aesthetics.

be placed in areas inside buildings lacking constructed or natural navigation cues

b. be arranged in a clear and structured sequence, with well-defined start and end points that are easily identifiable, marking intersections, decision points, or potential hazards along the way; c. be of enough depth in the direction of travel to provide adequate detectability and appropriate response by the users, such as stopping and turning; d. be aligned with constructed and natural navigation cues;

Remove the requirement for slip resistance.

Remove this text/requirement.

Specify whether the cast iron material is sufficient to provide recognition even if it is black with little colour contrast with the surrounding surface or whether it also has to have the truncated domes and/or be yellow (if that is possible/available).

an attention indicator shall be installed to identify when a hazard exists at the following locations:

Remove the requirement.

b. In outdoor spaces comply with the ASC Standard on Outdoor Spaces.

c. Indoor paved and unprotected drop-off edge where:

Curb ramps and depressed curbs as required by the ASC Standard on Outdoor Spaces.

Remove this requirement.

Remove this requirement.

The same standard for light reflectance that is required for accessibility.

Remove this option

have a top diameter between 12 mm and 15 mm

be installed cross the full width of the hazard

In large or open spaces within a building or building complex, a tactile pathway or guiding line for navigation is required

Note 1: Direction indicators are recommended for safety and guidance in the outdoor environments surround a complex of buildings.

Remove this note.

Remove or clarify who is qualified to do this work.

for signs intended to be read by pedestrians, include tactile characters alone or in conjunction with braille in

identification signs regulatory signs; and warning signs;

for signs intended to be read by pedestrians, include audible sign technologies or tactile characters

be placed in a location that does not intrude into the path of travel

be placed in a location that does not reduce accessibility and is appropriate to the intended effect of the sign

12.2.9 Trailhead signs for outdoor spaces

The section should specify the requirements for signs (other than trailhead signs) in outdoor spaces.

Remove this text.

allow for side-by-side format, languages may appear one above the others which is known as over-under format. Whether side-by-side or over-under format, all languages should be presented equally in all respects

Clarify what these may be used for. If they are included as alternative communication methods why are they not in c?

100 lx

be produced using materials that will continue to meet accessibility requirements throughout the anticipated life cycle

Specify what is meant by "in such cases".

Revise to align with a)

for outdoor toilet facilities with walls

For example, at trail intersections it may be possible to position the signage consistently in advance of the intersection, located to the right at a fixed height above the ground.

Be more specific as it is unclear.

This clause is well-written. This requirement should be made consistent throughout the entire Standard.

when the sign’s location makes providing tactile elements impractical;

be produced using materials that are durable to ensure that the tactile sign continues to comply with accessibility requirements throughout the sign's expect life cycle.

The specified height range should be higher for outdoor areas where individuals may have to be wearing gloves.

Remove this requirement.

These include orientation signs, such as directories; identification signs, such as washroom signs, regulatory signs, such as no smoking, and warning signs, such as area closed for cleaning.

Have a viewing time according to the amount of text or length of the message as specified in the table. (add table)

Remove this requirement.

Electronic and digital signage design and installation shall provide clear, accessible communication regardless of variations in: i. noise level and time-of-day traffic considerations; ii. proximity to reflections by ambient lighting; iii. proximity to reflective acoustic surfaces; iv. proximity to physical obstacles to access within the built indoor or outdoor environment; v, direct placement in the path of sunlight; and vi. installation considerations for indoor built environments (i.e., lighting and visual contrast).

enable video brightness settings to be adjusted

Remove the design specification for a backlight feature

Remove this requirement.

If pixel pitch determines the accessible viewing distance then this should not be a note. There should be a requirement that specifies the pixel pitch to be used depending on the viewing distance. Create a table of viewing distances with the required pixel pitch.

Display surfaces of electronic and digital signs, whether used indoors or outdoors, shall be designed with materials that ensure clear visibility and perception in varying lighting and environmental conditions;

Remove a.

Create a table of viewing times per amount of test/length of message.

grade 4 reading level

The timbre and tone required for accessibility across age demographics should be specified as a requirement.

The information displayed should be based on a study and understanding of users' needs, including their location, language proficiency, and specific route requirements.

Map design and readability should: use cartographic design elements to enhance clarity and usability such as title/subtitle, neat lines, legend, and orientation indicators when appropriate;

conveyed at a Grade 4 reading level.

Where multiple similar facilities are provided, maps shall include an index as part of the location plan or guide map.

Remove this text.

Remove this requirement.

Maps

Currently there is no perfect solution.

Add visual graphics to support written text

clarify further how the signage should be installed

It is not always possible to have tactile characters and braille for warning signs intended to be read by pedestrians because of existing infrastructure limitations, thus other indicators are required to be present in areas to alert visually or hearing impaired.

add visual graphics to support the written text

how to display braille when two languages are present. Does braille follow each language or does braille follow at the bottom of sign panel after all languages in the same order as the text? Example: English text tactile letters French text tactile letter English braille French braille

A pictogram (also pictogramme, pictograph, or simply picto[1]) is a graphical symbol that conveys meaning through its visual resemblance to a physical object. Pictograms are used in systems of writing and visual communication. A pictography is a writing system[2] which uses pictograms. Some pictograms, such as hazard pictograms, may be elements of formal languages. A pictograph is a visual representation of data using images or symbols. It is a form of communication that has been used for thousands of years, dating back to ancient civilizations. Pictographs are often used to convey complex information in a simple and easy-to-understand way. On the other hand, a pictogram is a specific type of pictograph that uses a graphic symbol to represent a concept or object. Pictograms are commonly used in signage and wayfinding systems, as they can quickly convey information without the need for words. Pictogram and pictograph are both pictures that represent a word or an idea12. However, there is a difference between the two: • Pictograph is a picture that represents a word or an idea by illustration12. • Pictogram is a specific type of pictograph that uses a graphic symbol to represent a concept or object pictograph is a picture that represents a word or an idea; while pictogram is a picture that represents a word or an idea by illustration. Pictogram and pictograph are especially useful for persons with developmental disabilities

see comment above on 9.1