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Section 13.2.1 discusses the effectiveness of visible signal devices for waking sleeping people. However, the standard limits visible signal requirements to fire alarm systems, which are typically not installed inside sleeping rooms where they would be needed. This leaves a gap for residential suites that rely on standalone smoke alarms.

Section 13.1.4 states that when a fire alarm system is not provided, the visible signaling system must consist of strobes conforming to CAN/ULC‑S526. This excludes the option of using smoke alarms that already incorporate visual signaling technology.

The current scope in Section 7.1(a) applies to “all new buildings,” but does not clearly address new single‑family homes, which typically lack fire alarm systems and rely solely on smoke alarms.

(whole section 7)

(addition to the section)

Sub-clause title "10.1.1.4 Types of emergencies requiring horizontal evacuation"

(applicable to whole section)

(addition to the section)

The role of the building owner/manager needs to be added as a subsection.

"Emergency wardens are individuals who are responsible for the safety of the people in their building or on their designated floors."

11.2.1.1 c) "Be responsible to ensure the safe evacuation of people with disabilities."

Add note about warden's knowledge of how to use evacuation devices.

"A person with a disability shall: a) develop a PEEP in conjunction with the emergency warden and buddies"

"A person with a disability shall: ..... f) know how to use an evacuation device, if applicable"

Add another item to the list.

"The NFC and the Provincial Fire Codes that require that all buildings have a fire safety plan state that information on emergency egress for all occupants, including people with disabilities be developed."

"A person with a disability together with their manager, and those responsible for the safe evacuation procedures for the building shall: a) develop an employee PEEP for an employee with a disability who identify as needing assistance in an emergency."

"The employee PEEP or at least the name of the individual that requires assistance needs to be included in the overall Registry List for the emergency warden that has a direct link to the Fire/Police/Paramedics in an emergency."

"Privacy concerns shall be discussed to ensure that information in the PEEP is not shared inappropriately."

"At the check-in or security desk: ... b) a sign requesting visitors who need assistance in an emergency to complete the visitors PEEP shall be posted..."

(applicable to whole section)

(applicable to whole section)

"Other considerations: a) the building use; and b) the anticipated number of visitors."

"A door serving an immediate area of refuge shall: ..."

"b) be served by a 2100 mm turning radius;"

"be free of protrusions"

"An area of refuge shall have an identification sign on the door stating AREA OF REFUGE with the International Pictogram of Access. An additional sign shall be posted on the side of the door, complying with CSA/ASC B651."

"In addition, the interior egress path of travel shall: ... d) be free of overly patterned carpeting."

Add note about shelter.

(Applicable to all of 12.5, 12.6, and 12.7)

(Applicable to all of 12.5, 12.6, and 12.7)

(Applicable to all of 12.5, 12.6, and 12.7)

"All stairs shall comply with CSA/ASC B651, the NBC, and relevant provincial codes and standards."

(applicable to whole section)

"b) include a tactile warning surface indicator at the top of the ramp;"

(applicable to whole section)

"Alarm signals to evacuate occupants do not sound. Notification is via a voice announcement."

(applicable to whole section)

(applicable to whole section)

(applicable to whole section)

"All elevators shall provide a clear floor area of 2,010 mm minimum in length and 610 mm minimum in width to accommodate a stretcher in the prone position and additional space for two persons."

"Emergency egress directional signage shall be: a) posted at all decision points throughout the building; b) mounted with its centre between 1200 mm and 1500 mm from the finished floor; c) provided with legible, clear font not less than 16 pt; and d) available in alternative accessible formats, upon request."

"Tactile maps of the posted emergency evacuation map should be provided at the building entrance."

"The map shall be posted in a consistent location throughout the building. It shall: ..."

(applicable to whole section)

Add note about pre-recorded instructions.

"An evacuation device shall be provided outside but nearby Areas of Refuge on each floor of a building but not at ground level."

"Evacuation devices shall: a) not be locked; and b) have a sign indicating its location."

"This form is PRIVATE AND CONFIDENTIAL. Information will be retained by the Emergency Warden."

(applicable to whole Employee PEEP)

"This form is PRIVATE AND CONFIDENTIAL. Information will be maintained only during the duration of the visit."

(applicable to whole Visitor PEEP)

(applicable to whole Visitor PEEP)

12th question where it says "Is the person you are visiting willing to assist you in an emergency? If not, notify security."

20th question where it says "Has this PEEP been developed in conjunction with you, the person you’re visiting, and the person responsible for emergency evacuation (receptionist)? If not, inform your manager."

(applicable to whole section)

The title makes it seem like several “types” of these emergencies will be introduced.

The first bullet "sounding the fire alarm". Given that not all fire alarms make sounds now, should this be changed to “activating the fire alarm”?

How does point f) work? How can someone know the location of someone in a building at all times?

The statement: "PEEPs shall be developed for each person who self-identifies as having a disability or who requires assistance that impacts emergency egress. "

This is a big consideration. Privacy is very important.

On point b: What if a person cannot read the sign? How can there be assurance that PwD visiting know how to get a PEEP.

The responsibilities of the building manager should be added to the list of “responsibilities” above. Also, what does it mean for a building manager to “provide that service” if no one volunteers? What if more than one person needs a buddy, how does the building manager provide that? Also, what if there are more than one tenant in a large building, a “building manager” is a very loose definition.

Section indicates that drills shall be practiced every 12 months. What about in hybrid workplaces? How do you make sure that everyone can participate in a drill?

It is putting a lost of trust in another individual to expect that they will fully assist in evacuating another person. How there be certainty that the buddy will not panic in the event of an emergency and evacuate the building without their PwD?

We have heard from wheelchair users that TAIs at the top of ramps can be destabilizing. Are they truly necessary as ramps don’t necessarily pose a hazard? Also, is contrast necessary on the full ramp or only to indicate the changes in slope (at the landings)?

When you say "number of areas of refuge", is it referring to the number of spaces of the number of clusters (spaces that are considered AoRs)?

There are a lot of fire alarms in some buildings, adding each of them to an emergency evacuation map might clutter the map. Is it necessary to have them, do they provide any useful information?

I. assisting in assigning a buddy J. ensuring all people who requested a buddy and a back-up buddy have one assigned. S. ensuring that the personal emergency evacuation plans (PEEP) for occupants with a disability are included in the fire safety plan

see document for all comments

Does not clearly distinguish policy goals from the technical purpose of the Standard.

The tone and structure established in Clause 6 set expectations that the Standard functions both as an advocacy document and as a technical standard.

The Introduction reads largely as explanatory and justificatory, rather than establishing a clear framework for enforceable technical requirements.

Throughout the standard, the scope is incompatible with the regulatory framework of the built environment.

• Accessible: The definition provided differs from the broader and more inclusive definition commonly used in other ASC standards. • Area of refuge: The definition limits areas of refuge to locations with direct access to an exit, which may unintentionally exclude accepted configurations such as designated areas near elevators. This narrower definition conflicts with common AHJ interpretations and could restrict design flexibility without a clear technical rationale. • Barrier-free: The definition largely duplicates concepts already captured by commonly accepted definitions of accessible. This overlap is inconsistent with NBC terminology and introduces redundancy that may cause confusion when applying requirements. • Emergency: The definition differs from that used by other ASC standards. • Evacuation: The definition restricts evacuation to movement toward an exit and muster point, whereas other ASC definitions describe evacuation as movement to a safe place. • Exit: The NBC clearly defines an exit as one component of a means of egress. This inconsistency may lead to misinterpretation when applying requirements related to egress design. • Major renovation: The definition is vague and lacks alignment with how alterations and renovations are typically defined and applied by AHJs. The definition creates potential for inconsistent interpretation and application. • Occupant evacuation elevator: The definition does not sufficiently acknowledge that occupant evacuation elevators are regulated through CSA B44 and are not intended for use in all buildings for all persons. Without clear alignment to B44, the definition risks implying broader applicability than is supported by existing elevator safety standards. • Definitions form the foundation for interpretation and enforcement. Where definitions diverge from established codes, AHJ usage, or referenced standards without clear justification, they introduce ambiguity and risk inconsistent application. Greater alignment with NBC terminology, AHJ practice, and referenced standards—particularly CSA B44—would improve clarity, reduce conflict, and strengthen the Standard’s credibility and enforceability.

Rewrite

Clause 11 assumes that a fire safety plan is universally required for all buildings and occupancies, which is not the case under applicable fire codes.

Clause 11 assigns responsibilities to various individuals, including building occupants, support persons, emergency wardens, and first responders, using mandatory language. Assigning mandatory duties to individuals who are not parties to the Standard, and who may not be under the control of the building owner or designer, exceeds the reasonable scope of a technical standard.

Clause 11 blends fire code compliance, organizational policy, and emergency response practices into a single set of mandatory requirements without clearly establishing jurisdiction, authority, or enforceability.

Clause 11.3 imposes administrative, behavioural, and privacy-related obligations that cannot be reliably implemented, audited, or enforced through a technical accessibility standard.

The clause assumes the existence of organizational structures (e.g., wardens, coordinators) that may not exist in many building types or occupancies.

Assigning mandatory duties to emergency personnel or first responders, whether explicit or implied, exceeds the authority of a standard and conflicts with how emergency services operate in practice.

Change this section

Change the way this section is written as applicable.

Rewrite

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Reword

Confusing requiremenets

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Confusing reword

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Fix and clarify, or remove

Rewrite and reformat

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Needs fixing

The requirements/responsibilities for parties outside the scope of this standard.

13.1.1 and 13.1.2

13.1.1 and 13.1.2

The requirement for building managers

This clause

Remove this clause

Clause 14

Since some wardens are responsible for a designated floor and not an entire building, paragraph d) should refer to “in their building or on their designated floor …”.

Operationalizing the parts of paragraph e) that refer to sign language interpreters and translators would essentially require organizations to have these capabilities on-site or standby. This could impose a significant financial burden on small organizations. Could these requirements instead be tied to the requirements of PEEPs that are in place for occupants of or visitors to the warden’s building or designated floors?

Is this intended to refer to “every person with responsibilities in the emergency evacuation or drill” such as wardens, buddies and those with PEEPs? If not, organizations can’t force all building occupants to participate in a post-emergency or post-drill discussion. Should this instead refer to the discussion being “open for participation by every person involved in the emergency or drill”?

The number of areas of refuge on each storey shall be provided based on half the number of exits required by the applicable building code serving that storey.

Referring to section D. This is not provided in the National Building Code of Canada (NBC). Considerations should be made to include the same requirements in NBC as outlined in this draft standard.

Alarm sequences and messaging are not standardized. At the Senate, the first notification is sent only to a certain team, who assesses whether the situation is an emergency. If it is confirmed as an emergency, the second-stage notification is then sent to all employees. Because of this, the wording that refers to a “second notification” advising occupants on how to proceed is misleading and should be revised. In addition, the standard indicates that evacuation alarm signals do not sound and that communication is provided only by voice announcement, which conflicts with references to alarm signals prompting occupant response.

The standard says alerts must be sent through the National Public Alert System to people’s phones. Our Emergency Notification System is only used inside the Senate and by its partners, not the public. If we are required to use the national system, this could be a problem and would be very hard to put in place. We need to better understand what this requirement means and whether it applies to internal systems like ours. Having two systems could also be an issue for other organizations that use their own security alert systems, since multiple alerts could confuse people during an emergency.

In the standard is says that “Elevators are now permitted and available that are specifically designed for independent use by people evacuating a building.” Currently NBC does not address this requirement of independent use of elevators for evacuation purposes. This is suggesting that this standard is going beyond existing Canadian codes. There is no baseline requirement in the NBC to design and install or maintain such elevators. Compliance obligations are unclear without corresponding changes to the NBC and the Canadian Safety Standard for elevators (CSA B44).

Edits to: Defines appropriate procedures and processes

Edits to: The ability of a person with a disability to safely evacuate a building is dependent upon the appropriate design of the building and the development and implementation of emergency procedures and practices that accommodate all building occupants.

Edits to: Emergencies requiring shelter-in-place

Edits to: Practices and procedures: During an emergency that requires occupants to exit the building, the general population will follow the evacuation routes that are clearly naked, or they will exit the building the same way they entered.

Edits to: People with disabilities will need to follow their PEEP procedures and have more information about the options to exit quickly and safely.

Edits to: appointing an organizing of designated supervisory staff to carry out emergency safety duties.

Edits to: (i) assisting in assigning a buddy and (j) ensuring all people who requested a buddy and a back-up buddy have one assigned.

Edits to: a copy of that plan is required to be provided to the arriving emergency services - typically through a fire safety box plan.

Edits to: The role of emergency wardens:

Edits to: The role of first responders:

Edits to: The role of the person with a disability:

Edits to: The role of the buddy:

Edits to: (d) the procedures for alerting others of the work location.

Edits to: Personal Emergency Evacuation Plane

Edits to: Before an emergency occurs, each person having been identified as needing assistance shall be assigned a buddy and a backup buddy who is willing to assist in an emergency. It is the responsibility of the building manager to ensure that buddies are assigned.

Edits to: In these cases, the emergency egress procedure should be executed to the greatest degree possible.

Edits to: There are different types of signage that relate to emergency egress for various purposes. And page 77: Emergency egress directional signage shall be:

Edits to: Non verbal

Edits to: Assistive communication techniques

Edits to: People with cognitive disabilities

Edits to: for people who suffer from anxiety or some other mental health issues, their behaviour may become unpredictable.

Edits to: it is important to consider that the person with the disability may have a variety of issues.

Edits to: Other signage

The statement addressing people with environmental sensitivities in the emergency egress section.

The treatment/addition of air quality within emergency egress requirements.

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