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As people with disabilities are entitled to the same rights as people without those disabilities, they should not have to wait for assistance, while others are evacuating a building. They are entitled to the same level of safety as people without disabilities.

Add the words, or rented, after the word, leased. a. b. the design, construction and occupancy of all new buildings; C. the alteration, major renovation (as defined by the NBC), . reconstruction, D. relocation and F. occupancy of all existing buildings, including leased and rented facilities; G. both site-built and factory-constructed buildings; and H. buildings with single stairwells.

Merge this clause with 7.1, or at least make them say the very same thing.

Add this section :7.1.1 other inclusions This scope includes but are not limited too. Shopping centers Multi use buildings which have retail at the ground level, parking at levels 2, 3 or four, businesses at levels, 5, 6 and seven, and residential units above, or any combination. Sports stadiums Schools Parking garages Transit terminal, such as airports Hospitals and medical centers Venues for large gatherings, such as concert halls Structures that are close to flammable materials, such as a forest, or fuel storage. Factories Warehouses

Merge these two definitions, or create a note explaining the differences. Also 1. in the first definition, the word, terminology, does not seem to be correct. 2. The definition calls up the muster point. This should be expanded to, refuge, shelter, and waiting.

Individual dwelling units are structures, such as a cottage, bungalow, semi detached, or town houses, residential only, each housing several people If the structure is a cottage, although it might be two or three stories, as long as it has related persons in it, this standard does not apply to it. If the structure is used largely as rental units for unrelated persons, such as a boarding house, or dormitory, then they are covered by this standard. If the structure is multistory, such as a duplex, triplex, or quadruplex, then it is covered by this standard as it is multi story. If a cottage or bungalow has been converted to a non-residential use, then it is covered by this standard.

Facility accessibility panel A panel of 3 to 7 persons, selected by the facility, emergency manager in cooperation and coordination with all persons with disabilities in the facility. Each person in this panel shall have a term of one year, and the panel will be re-selected every year by the facility, emergency manager in coordination and cooperation with all persons with disabilities in the facility

In the definitions of accessible, and, barrier free, remove the three or four words that describe some disabilities.

What we should change it to. Facility emergency manager This person shall be appointed by the building owner, or should there be shared ownership, such as a condominium or cooperative, by the governing body, such as the board of directors They will have the mandate to plan for, execute, improve, and do continuous improvement on every aspect of emergencies, including PEEP and risk assessment and mitigation. This would include selecting, training, and ensuring availability of buddies and floor wardens.

The phrase, fire compartment, is used once or twice in this standard, but not defined. I do not have the technical expertise to define it, but either do this, or change it to a more familiar term.

Split up this section for clarity. Note. Some section renumbering might be necessary. 10. Emergency egress , training, and inspection 10.1 inspection As the NFC) and the Provincial Fire Codes require that all buildings have a fire safety plan that includes information on emergency and egress for all occupants, including people with disabilities. 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. A. the facility, emergency manager, with the facility, accessibility panel, shall ensure that all personal emergency evacuation plans, conform with the NFB and provincial codes B. whenever an inspector from a fire department or other building code inspector does and inspection, they shall ensure that all Communication systems, egress routes, mustard, points, shelters, refuge and other structures that enable a person with a disability to evacuate safely or other items included in this Standard are in place and operate correctly. C. The facility accessibility panel Will participate in all inspections. .. This inspection shall take place no less than every 12 months, and if there are more than 200 occupants, twice per year. D. any part of the inspection that is shown as not in place or not operating correctly, either by the building code inspector, or fire department inspector, or by the facility accessibility panel , shall be treated by the fire department inspector or building code inspector with the same seriousness as a violation of their code , with the same due process. All documentation and due process concerning violations shall be copied to the facility accessibility panel. 10.2 Training A. a training program on the subject of this standard shall be developed by accessibility standards Canada within one year of the final standard being approved. B. The training program shall be mandatory for the facility, accessibility panel, facility, emergency manager, , emergency coordinator, buddies,officials and inspectors to attend this course as part of their orientation and on boarding, and have a refresher whenever a major part of the standard is changed. C. should a particular building have a violation found by the fire department inspector or building "inspector, then a training memorandum will be sent out to all the above concerned, persons with procedures to assure the violation does not occur again.

Planning from the fire department Roles and responsibilities Personal emergency evacuation plan Before during and after an emergency And others.

Use the role of the facility, emergency manager, instead of floor warden.The role of the emergency wardens Emergency wardens are individuals who are responsible for the safety of the people in their building or on their designated floors.They work under the authority of the facility, emergency manager. In some cases, the facility emergency manager might also be the emergency warden. New text ends here The emergency wardens shall do the following:

Add the following at the letter H. H. Be available for nomination to the facility, accessibility panel, and if chosen, ensure that all standards are met I. know who are the members of the facility, accessibility panel and facility, emergency manager and report to them any concerns about emergency egress, procedures, or conformity to standards J. As part of on boarding and orientation , with the appointed buddy, ensure you know the paths of egress, refuge, muster, shelter, points, and method of communication, and Test, the method of communication. K. if you are a visitor, ensure the facility emergency manager is aware that you are in the facility, has a copy of your PEEP, and with a buddy, review the appropriate emergency egress procedures

Add the following starting with letter I . I. as part of on boarding and orientation, practice the egress roots, muster, shelter, and refuse points, and test the method of communication with the person with a disability. J. If there are any parts of the standard that are not met , communicate immediately with the facility, emergency manager and the facility accessibility panel. K. If you are assigned to a visitor, ensure that you know, the PEEP, and, if applicable, practice the egress method, shelter, muster, and refuse points, and test the method of communication.

After the words, Potential improvements should be discussed frequently and openly, Add another sentence. 11.4.3 Post-emergency: Evaluation and improvement After an emergency situation has taken place, an in-depth review shall be conducted on the effectiveness of the procedures that were developed and implemented. All drills and emergencies shall be documented to facilitate improvement. Potential improvements should be discussed frequently and openly. If the in-depth review shows areas of concern that are life-threatening, these should be reported to the fire department inspector, or building code inspector, and be treated as serious violations with the due process of the inspection agency. These serious violations shall be reported to the facility, emergency manager and the facility accessibility panel.

Change the title of the section by enlarging it to those who need assistance 11.2.1.3 The role of the person with a disability or who requires assistance that impacts emergency egress.

Change the title to include all those who are not visitors 11.3.2 occupant, residence, and full and part time Employee Personal Emergency Evacuation Plans

Add a clause, H, at the end about risk mitigation 11.2.1.3 The role of the person with a disability Some information on emergency egress issues that relate to individuals with various disabilities is provided in Annex A (https://accessible.canada.ca/creating-accessibility-standards/can-asc-22-emergency-egress-exit/18-annex-emergency-egress-issues-persons- disabilities). A person with a disability shall: a. develop a PEEP in conjunction with the emergency warden and buddies; b. ensure that emergency wardens and buddies know and understand their personal situation and how to best assist; c. describe their preferences as to lifting or transferring; d. describe any areas of concern such as loud noises, the use of assistive devices, areas of pain, etc.; e. know the location of the accessible egress routes and the areas of refuge;f. know how to use an evacuation device, if applicable; and g. be aware of the location of the muster points. New text starts here H. Discuss the risk profile of the facility with the facility, emergency manager, which may include age of the building, combustible materials in the building, sprinklers or not, which building codes are older, grandfathered, and not up-to-date, code violations, received from the fire department or other authorities, proximity to other dangers, and anything else the facility manager may be aware of. If appropriate, discuss reducing the risk by changing the location of the work, occupation, or residence , by increasing the proximity to refuge, shelter, waiting, exit doors, elevators, stairs, egress pads, or selecting other facilities.

Add a sentence describing what happens if it is a one story building, such as a factory, warehouse, or logistics hub. Also, expand refuge area, too, muster , shelter, or waiting areas. 12.1.1 Application Buildings shall be provided with areas of refuge, muster, shelter, and waiting areas on levels above and below the level served by an immediate accessible exit and egress path of travel leading directly outside. In the case of one story buildings, the areas of refuge, muster, shelter, and waiting shall be located in such a way that they are safe from the situation of the emergency, and close to the path of egress.

Add conditions at the end, indicating that the number of persons occupying or employed in the building shall be part of the consideration of number of refuge areas. 12.1.1.1 Number of areas of refuge 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. Note: Decimal numbers should be rounded up to the nearest whole number. Other considerations: a. the building use; and b. the anticipated number of visitors. New text starts here C. Number of persons occupying or employed in the facility D. the proportion of staff available to eat in evacuation, such as buddies, compared to the number of persons employed in or occupying the building.

Add specifications after the words,includes an elevator lobby Note: An example of a fire compartment in this Clause includes an elevator lobby, New text starts here only if the elevator lobby is protected from the emergency situation, such as fire, and compliant with clause 12.1.3 It will be marked in the same way as refuge area in a prominent way.

Add other conditions to make it more survivable as a place of refuge starting with letter E. 12.1.3 General Areas of refuge shall be: a. located on an accessible route; b. smoke-protected; c. illuminated at a minimum of 200 lux; and d. provided with an evacuation device nearby New text starts here E. Full range of communication systems backed up by fire resistant and emergency power f. have separate emergency lighting and ventilation systems supported by a backup generator.

In C Add a phrase after the words, alternate power so that a door can be manually operated. 12.1.4 Doors serving an area of refuge A door serving an immediate area of refuge shall: a. b. be leakage-rated complying with NFPA 105; have a clear width complying with CSA/ASC B651; c. be equipped with a power door operator capable of being activated in the event of a loss of power via emergency power or alternative power New text starts here or manually.

Add letter G , indicating that the size of this area should be calculated according to the appropriate code or the number of people that might use it. 12.1.5 Interior of areas of refuge The interior of an area of refuge shall: a. provide a minimum of two waiting spaces to accommodate a clear unobstructed floor space not less than 900 mm by 1500 mm for each space; b. be served by a 2100 mm turning radius; c. be located clear of any adjacent door swing; d. be illuminated, minimum 200 lux; e. be connected to the backup power; and f. be free of protrusions. New text starts here G. have a size calculated according to the appropriate fire or building code or number of people who might use it.

Add letter G and H G. be safe and used in those cases where the person's exiting the facility need to pause , for any reason, between their original spot, for a short period of time on their path to egress the emergency situation. H. Have complete access to all communication, facilities, backed up by emergency power

Harmonize this signage standard to all areas, not just refuge. Add requirements that sign must have location information. 12.1.8 Signage An area of refuge, shelter, muster point, or waiting area shall have an identification sign on the door or appropriate place stating the AREA with the International Pictogram of Access. An additional sign shall be posted on the side of the door, or appropriate place complying with CSA/ASC B651.12.1.8.1 New text starts here All of these signs will have information on them, which gives the location in a way that emergency personnel can easily locate them. All signage will Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats.

Add a line after the description of directional signage. 12.1.8 Signage 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 B651.12.1.8.1 Every Directional signage Emergency egress directional signage to the area of refuge shall be provided at decision points throughout the building. New text starts here directional sign at every decision point shall have an additional identification that identifies the location of the decision point in a way that makes it easy for emergency personnel to know the location of whoever is referencing that particular decision point. Each directional sign shall be self luminous. This location identification shall also be in braille and large print

The standard should be made consistent, especially being able to open the door manually, when all else fails.

Add extra conditions starting with D. 12.3.1 Interior egress path of travel The interior egress path of travel shall comply with CSA/ASC-B651. Static escalators, stair lifts and moving walks shall not be permitted as part of the interior egress path of travel. All elements in the interior egress path of travel shall be accessible, including: a. to and from all floor areas of a building; and b. to and from all interior doors to exterior exit doors. In addition, the interior egress path of travel shall: a. where there is a rise over 13 mm, have a slope of no steeper than 1:25. See Ramps 12.7; b. be free of protrusions to a height of 2100 mm; c. be illuminated to a minimum level of 200 lux; andd. be free of overly patterned carpeting. New text starts here D. Have lighting connected to emergency back up power, which will also light up directional signs at every decision point. E. Where possible, egress paths will have illuminated, or self luminous directional markings on the floor. F. Signage identifying the egress pads shall be identified on the emergency fire safety map posted throughout the building.

Add conditions starting with letter E. , 12.4 Muster points All buildings shall have muster points served by an accessible exterior egress path of travel. The muster point shall be a minimum of 3000 mm x 3000 mm. Signage with the muster point symbol shall be provided between 1600 mm and 2500 mm above the ground surface. Signage identifying the muster points shall be identified on the emergency fire safety map posted throughout the building. Benches or seating provided for the muster point shall comply with CSA/ASC B651. The muster point shall: a. be provided with a rest area equipped with a bench or seating alternative; b. have a pavement marking not less than 1 m by 1 m identifying the international symbol of muster points, where located on a hard surface; c. be illuminated; and d. be recessed away from and served by an exterior egress path of travel complying with Clause 12.3.2. New text starts here E. have a size that is calculated with information about the use of the building, the size of the building, number of occupants or visitors, distance from the egress door, factors that might make the speed to get out of the building important, availability and numbers of of buddies or staff members to aid in persons with disabilities. F. be connected with all communication facilities, which will be backed up by battery or emergency generators. H. Be connected to emergency ventilation systems

Add a phrase, D, that the signage on the underside should also indicate the location of the stairwell. 12.6.1 Tactile information on stair and ramp handrails Stair and ramp handrails shall have raised characters with braille permanently fixed on the underside of the horizontal section, at the beginning and at the end of every handrail on stairs indicating: a. the floor number; b. the direction of egress; and c. the exit floor shall be indicated by a tactile star. New text starts here D. the location of the stairwell Will be marked in such a way that emergency personnel can easily identify the exact location of that particular railing.

Harmonize the condition, such as lighting, emergency power, signage, Communications, and size

Add one more condition, letter I. I. all communication systems that a person with a disability might use will be available, resilient, and fire resistant in this and all areas used in emergency situations.

Add more description at the end of this item to make it more clear to a person with a disability through the appropriate communication channels, and updates until all clear signals are given 13.1.1 Single-stage system A single-stage system is designed so that, when activated, the alarm signal shall be immediately transmitted throughout the building to warn the occupants that an emergency exists. New text starts here The alarm signal that is transmitted will use Barrier free communication systems that are compatible with the needs of persons with disabilities. Because there is no action necessary when this signal is transmitted, a subsequent, all clear, signal will be transmitted to indicate that the emergency has been resolved. To ensure that the system is failsafe, if a period of more than three minutes passes before the, all clear, signal is transmitted, another signal, indicating that the emergency is still pending, but not resolved, will be transmitted every three minutes. If possible, when the, pending signal is transmitted, a description of the emergency, location, seriousness, action, being taken, would also be helpful.

Add a paragraph at the end. The alarm signal that is transmitted will use Barrier free communication systems that are compatible with the needs of persons with disabilities. Because there is no action necessary when parts of this signal is transmitted, a , all clear, signal will be transmitted to indicate that the emergency has been resolved. To ensure that the system is failsafe, if a period of more than three minutes passes before the, all clear, signal is transmitted, another signal, indicating that the emergency is still pending, but not resolved, will be transmitted every three minutes. If possible, when the, pending signal is transmitted, a description of the emergency, seriousness, action, being taken, would also be helpful. If there are any Voice announcements, there will be a identical transmission of this message in a barrier freeway that works for the communication systems used by persons with disabilities.

There are a few statements in this section that should be clarified. 1. Note: A two-stage system is used in facilities where the immediate evacuation of the occupants is neither desired nor practical. Can you give some examples? Prisons? Hospitals? This signal is not when there is an immediate need for an evacuation, but how long might it take before that need becomes necessary. 2. Alarm signals to evacuate occupants do not sound. Notification is via a voice announcement. If notification is given using voice, what about persons who are deaf, or DEF Blind. 3. Like the single stage system, there must be communication while the emergency is pending as updates, on a frequent basis, as well as an all clear signal. 4. Clarify that the, how to proceed, signal, might be a signal to evacuate, although this is neither immediate, planned nor desirable

Add this line at the end of each of these two sections. The visible strobe signal in the event of a fire, shall also be accompanied by a communication Barrier free systems that use communication systems used by persons with disabilities.. C-section 13 point XX.

Add letter F 13.1.4.1 Emergency communication formats Building managers shall ensure communication systems that can alert all building occupants are in place in the event of an emergency. Note 1: Clear and efficient communication with everyone, including regular occupants and visitors, will enhance the safety of all building users during an emergency. All building occupants shall: a. b. receive emergency egress information in the format of their choice; and Receive egress information in the format selected during the preparation of an individual’s personal emergency egress plan. Some building occupants may need information in various formats, including: a. large print; b. electronic messaging; c. speech synthesizers; d. an electronic pager; or e. sign language interpretation. New text starts here F. ensure barrier free communication systems backed up by emergency power or generators are available that are compatible with all communication systems used by persons with disabilities

Replace the following phrase. Some building occupants may need information in various formats, including: a. large print; b. electronic messaging; c. speech synthesizers; d. an electronic pager; or e. sign language interpretation. And replace with Some building occupants may need information in a format identified in the personal emergency evacuation plan, or any other Barrier free format that works with communication systems used by persons with disabilities.

Add a sentence before Lower frequency audible alarms should be provided for people who are hard of hearing Add the following This standard works in certain situations, but other technologies and devices shall be used in particular, those Communication barrier free systems and devices that are suitable for persons with disabilities.

Add a phrase at the end Every visible signal Location shall also have technologies that enable any person with a disability to receive the same message as if they were able to receive the information from the visible signal device in a barrier freeway compatible with the technology used by persons with disabilities.

Add a sentence at the end indicating the difference between the standard listed in annex C, which is a general, widespread notification system, and the notifications necessary in and particular facility during an emergency. 13.2.3 Smart phonesCommunication tools such as smart phones or mobile phones are increasingly being used by everyone. They are an excellent form of communication as they can receive audio and tactile alerts to notify of an incoming message and can be used in text and voice (audible) formats. Alert signals shall be transmitted via the National Public Alert System by all telecommunications providers. See Annex C (https://accessible.canada.ca/creating-accessibility-standards/can-asc-22-emergency-egress-exit/20-annex-c-emergency-alerting-and- communication-technologies-persons-disabilities) for information on national and provincial alert systems. New text starts here the notification system described in NXC is used for widespread announcements of emergency situations. every facility must also have an notification system suitable for use by persons with disabilities at the beginning, during, and at the end of any emergency. smart phones and devices are suitable for this notification system, but there might be certain persons with disabilities who require other devices or systems to be aware of emergency egress and exit instructions during an emergency

Add a few conditions at the end starting with letter F to enable all persons with disabilities, particular, blind, or deaf, to have a safe emergency egress. 13.3 Emergency telephones 13.3 Emergency telephones Where provided, an emergency telephone shall: a. b. c. d. e. display the symbol for an Emergency Phone; provide its operable parts not more than 1200 mm from the floor; have the illumination level measured at the operating devices at least 200 lux; be hearing aid compatible; and have a volume control with amplification of (30-50 dB). New text starts here F connected to an emergency backup generator or emergency backup battery system G. have signage indicating the exact location of the emergency telephone so that emergency personnel can easily identify the position of any caller H. Ensure that for any person with a disability for whom the emergency telephone is not suitable, that every other system used in a barrier free way by persons with disability of communication works in the same location as the emergency telephone..

Add a line starting with letter E to ensure that whatever communication system is used, that there be a communication system that works for every person with a disability. 13.4 Public announcements Whenever a public announcement is provided in an audio format, it shall be provided at designated areas on all floors of a building in text display and transmitted electronically to building occupants. All public announcements relating to emergency egress shall be provided in a variety of formats, including: a. audible announcements; b. broadcasting to hearing technologies and implantable devices; c. visual announcements; and d. electronic announcements. New text starts here E. Every public announcement or message Board notification will also be communicated using Barrier free communication systems and devices that are compatible with those used by persons with disabilities. New text ends here Note: Variable message boards should also be used. When provided, variable message boards shall: a. b. not use pre-recorded messages for emergency information; utilize a well-contrasted characters (avoiding red and green or blue on a black background); c. be mounted at a maximum height of 1500 mm; and d. be centrally located.

Add a line starting with letter E 13.5 Audio systems (assistive listening systems) A permanent assistive audio system shall be provided where there is an exchange of emergency information, including in the following floor areas: a. in elevators; b. as part of emergency warning intercom systems; c. as part of all public announcement systems; and d. at security checkpoints. New text starts here E any assistive system that meets the conditions of this clause shall also be integrated with all communications systems that are necessary for persons with disabilities to receive the appropriate instructions during an emergency egress in a barrier free way. situation.

Add the words, muster, waiting, or shelter, after the word, refuge. 14. Illumination and emergency power Illumination of accessible egress paths of travel and Areas of Refuge Muster, waiting, or shelter shall be: a. no less than 200 lux at floor level; b. be placed to avoid glare; and c. supplemented by emergency power. Separate emergency lighting and ventilation systems shall be supported by a backup generator. Emergency electrical power will ensure adequate emergency lighting for the use of elevators and key operating components or other systems during a power outage. A photoluminescence lighting system along the floor should be provided to indicate the accessible egress path of travel. Illumination in elevators shall be a minimum of 100 lux.

Enlarge the choice of using this type of elevator during an emergency By adding to the phrase after, using the stairs.. 15.1 General The use of elevators for evacuation is one key strategy for evacuation of people who are unable to use stairs. New text starts here and for evacuation of people who decide that this type of elevator is a safer or more rapid method of egress then stairs during an evacuation

Enlarge the choice of using this type of elevator during an emergency By adding to the phrase after,. Use the stairs.. 15.3 Occupant evacuation elevators An Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. New text starts here and for evacuation of people who decide that this type of elevator is a safer or more rapid method of egress then stairs during an evacuation.

Enlarge the use of this type of elevator by adding to the phrase, people unable to use the stairs. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. New text starts here and can be used by people who decide that this type of elevator is a safer or more rapid method of egress then stairs

Add a phrase after Alternately, Wi-Fi availability can facilitate communication. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. A two-way text/communication system shall be provided inside and outside the OEE elevators. A two-way text communication system inside and outside elevators are available that will provide a visual screen to connect with security. Alternately, Wi-Fi availability can facilitate communication. New text starts here Any two way system or visual screen shall also have technologies, integrated, or nearby in a failsafe manner, such that persons with disabilities using Barrier free accessible and usable, technologies will receive all notifications and announcements, before, during, and after an emergency or evacuation.

Add a line at the end enhancing the ability to locate this type of elevator during an emergency. Just a sign is not sufficient. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. A two-way text/communication system shall be provided inside and outside the OEE elevators. A two-way text communication system inside and outside elevators are available that will provide a visual screen to connect with security. Alternately, Wi-Fi availability can facilitate communication. Information on its use shall: a. be incorporated into the fire safety plan; b. be incorporated into the PEEPs, when appropriate; and c. be included in the posted fire safety evacuation plan. Occupants of a building shall be instructed in how to use and when to operate an OEE. There shall be signs posted on all floors adjacent to each elevator call station for OEEs. New text starts here In addition to signs posted on every floor for this type of elevator, there shall be notification and announcement Barrier free, accessible, and usable, systems suitable for persons with disabilities, such as voice alerts, identification, flashing light, and tactile markings on the floor to announce this type of elevator.

Replace, additional space for two persons, with a clause indicating how this number is to be calculated. 15.4.1 Space 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 New text starts here and additional space for the number of persons that is appropriate for the number of occupants, residence, and visitors, as well as the number of elevators and floors.

Add a clause at the end, indicating that the elevator of this type must be identified in a way that works for persons with disabilities. 15.4.3 Identification An elevator that is designed to accommodate a stretcher or OEE shall be clearly identified on every level the elevator serves. New text starts here In addition to signs posted on every floor for this type of elevator, there shall be notification and announcement Barrier free, accessible, and usable systems suitable for persons with disabilities, such as voice alerts, identification, flashing light, and tactile markings on the floor.

Change clause E to a height that fits the general population. 15.5 Elevator controls Elevator car controls shall: a. b. c. d. be mounted on the front and side walls of the elevator cab; be mounted at a maximum height that matches the median height of occupants and residence;

Add a line F, , indicating function appropriate for emergency use. 15.5 Elevator controls Elevator car controls shall: a. b. c. d. be mounted on the front and side walls of the elevator cab; be mounted at a maximum height of 1200 mm; be equipped with braille and raised characters on buttons located to the left of the operation button; and have a well-contrasted operation button. F. Any elevator of this type must have a Barrier free, accessible, and usable system that enables persons with disabilities to direct it to the floor that has the safest evacuation route.

The note at the end about red, green and blue lights should be harmonize with signage standards for persons with low or no vision. 16.1 Application All signage and way finding relating to emergency egress shall be accessible and shall include text, visual, tactile and Braille characters. There are different types of signage that relate to emergency egress for various purposes: a. regulatory signs, which include information, including safety and emergency signs; b. mandatory signs which denote an order requiring an action; and c. warning signs such as caution and danger signs denote a potential hazard and a definite hazard. Note. All signs shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats.

Clarify the different lettered phrases, and add, areas of shelter, muster, and waiting. 16.2 Directional signage The following signs shall be posted indicating the accessible egress route to : a. an exit, B. an area of refuge, waiting, shelter, or muster C. a horizontal separation, if it is used as an area of refuge , shelter, waiting, or mustard ; b. an occupant evacuation elevator. Emergency egress signage shall be identified by directional signage indicating the accessible egress path of travel to the final exit.

Change and merge c. provided with legible, clear font not less than 16 pt; and d. available in alternative accessible formats, upon request. 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. All signs shall Conform and harmonize two standards for usability and legibility for font style, size, color, and contrast as well as standards for alternate formats.

Add some lettered clauses to ensure these signs are are usable and legible at all times, including power outages Starting with E. in this standard. 16.2 Directional signage 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. E. be self illuminated, externally illuminated, or glow in the dark. Any power for illumination shall be from emergency backup generators. F. every directional sign shall also have identification Marker on it that shows the location of the sign, so that emergency personnel can easily locate a person who calls in needing assistance and references this identification marker. The identification marker shall also be in tactile and braille. G. directional signs shall be surrounded by tactile floor surface, large enough for a person with low or no vision to locate it, and small enough not to interfere with evacuation procedures. H. directional markers shall emit a sound loud enough for a person with a disability to locate it, but not loud enough to interfere with evacuation procedures.

Shorten the list.

Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats. For those persons with disabilities for whom a map is not suitable, list and have a contact person to explain and demonstrate, and practice, the necessary information that will lead to a successful emergency egress. . Use only approved ISO pictograms. Have a legend that explains in an accessible format what each pictogram is.

Add a clause G , ensuring that user feedback is incorporated into each revision, and continue this process until users are satisfied. G in the spirit of continuous improvement, as soon as possible, after the opening of the facility, survey the users of this tactile map on a regular basis and revise the map, consistent with suggestions, until users and the facility accessibility panel are satisfied..

Add additional items to facilitate emergency egress. 16.5.1 Enclosed stairway signage A. An enclosed stairway shall have a sign identifying the storey in raised characters and braille with a high luminance contrast to its background at each landing that provides access to a floor area. New text starts here The sign shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, colour, and contrast and standards for alternate formats. C. On those floors where there is exit, refuge, shelter, or waiting areas, this shall be marked on the door in formats that conform with the standard for accessibility. D. each sign shall have an identification marker in an accessible format that locates where the door is in a way that emergency personnel with this information could easily locate a person.

Add a sentence after clause, A clarifying the standards to be met 16.5.2 Exit door signage An accessible exit door discharging to the exterior of a building or another building shall: a. have a sign with raised characters and braille; New text starts here the sign shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, colour, and contrast and standards for alternate formats.

As people with disabilities are entitled to the same rights as people without those disabilities, they should not have to wait for assistance, while others are evacuating a building. They are entitled to the same level of safety as people without disabilities.

Add the words, or rented, after the word, leased. a. b. the design, construction and occupancy of all new buildings; C. the alteration, major renovation (as defined by the NBC), . reconstruction, D. relocation and F. occupancy of all existing buildings, including leased and rented facilities; G. both site-built and factory-constructed buildings; and H. buildings with single stairwells.

Merge this clause with 7.1, or at least make them say the very same thing.

Add this section :7.1.1 other inclusions This scope includes but are not limited too. Shopping centers Multi use buildings which have retail at the ground level, parking at levels 2, 3 or four, businesses at levels, 5, 6 and seven, and residential units above, or any combination. Sports stadiums Schools Parking garages Transit terminal, such as airports Hospitals and medical centers Venues for large gatherings, such as concert halls Structures that are close to flammable materials, such as a forest, or fuel storage. Factories Warehouses

Merge these two definitions, or create a note explaining the differences. Also 1. in the first definition, the word, terminology, does not seem to be correct. 2. The definition calls up the muster point. This should be expanded to, refuge, shelter, and waiting.

Individual dwelling units are structures, such as a cottage, bungalow, semi detached, or town houses, residential only, each housing several people If the structure is a cottage, although it might be two or three stories, as long as it has related persons in it, this standard does not apply to it. If the structure is used largely as rental units for unrelated persons, such as a boarding house, or dormitory, then they are covered by this standard. If the structure is multistory, such as a duplex, triplex, or quadruplex, then it is covered by this standard as it is multi story. If a cottage or bungalow has been converted to a non-residential use, then it is covered by this standard.

Facility accessibility panel A panel of 3 to 7 persons, selected by the facility, emergency manager in cooperation and coordination with all persons with disabilities in the facility. Each person in this panel shall have a term of one year, and the panel will be re-selected every year by the facility, emergency manager in coordination and cooperation with all persons with disabilities in the facility

In the definitions of accessible, and, barrier free, remove the three or four words that describe some disabilities.

What we should change it to. Facility emergency manager This person shall be appointed by the building owner, or should there be shared ownership, such as a condominium or cooperative, by the governing body, such as the board of directors They will have the mandate to plan for, execute, improve, and do continuous improvement on every aspect of emergencies, including PEEP and risk assessment and mitigation. This would include selecting, training, and ensuring availability of buddies and floor wardens.

The phrase, fire compartment, is used once or twice in this standard, but not defined. I do not have the technical expertise to define it, but either do this, or change it to a more familiar term.

Split up this section for clarity. Note. Some section renumbering might be necessary. 10. Emergency egress , training, and inspection 10.1 inspection As the NFC) and the Provincial Fire Codes require that all buildings have a fire safety plan that includes information on emergency and egress for all occupants, including people with disabilities. 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. A. the facility, emergency manager, with the facility, accessibility panel, shall ensure that all personal emergency evacuation plans, conform with the NFB and provincial codes B. whenever an inspector from a fire department or other building code inspector does and inspection, they shall ensure that all Communication systems, egress routes, mustard, points, shelters, refuge and other structures that enable a person with a disability to evacuate safely or other items included in this Standard are in place and operate correctly. C. The facility accessibility panel Will participate in all inspections. .. This inspection shall take place no less than every 12 months, and if there are more than 200 occupants, twice per year. D. any part of the inspection that is shown as not in place or not operating correctly, either by the building code inspector, or fire department inspector, or by the facility accessibility panel , shall be treated by the fire department inspector or building code inspector with the same seriousness as a violation of their code , with the same due process. All documentation and due process concerning violations shall be copied to the facility accessibility panel. 10.2 Training A. a training program on the subject of this standard shall be developed by accessibility standards Canada within one year of the final standard being approved. B. The training program shall be mandatory for the facility, accessibility panel, facility, emergency manager, , emergency coordinator, buddies,officials and inspectors to attend this course as part of their orientation and on boarding, and have a refresher whenever a major part of the standard is changed. C. should a particular building have a violation found by the fire department inspector or building "inspector, then a training memorandum will be sent out to all the above concerned, persons with procedures to assure the violation does not occur again.

Planning from the fire department Roles and responsibilities Personal emergency evacuation plan Before during and after an emergency And others.

Use the role of the facility, emergency manager, instead of floor warden.The role of the emergency wardens Emergency wardens are individuals who are responsible for the safety of the people in their building or on their designated floors.They work under the authority of the facility, emergency manager. In some cases, the facility emergency manager might also be the emergency warden. New text ends here The emergency wardens shall do the following:

Add the following at the letter H. H. Be available for nomination to the facility, accessibility panel, and if chosen, ensure that all standards are met I. know who are the members of the facility, accessibility panel and facility, emergency manager and report to them any concerns about emergency egress, procedures, or conformity to standards J. As part of on boarding and orientation , with the appointed buddy, ensure you know the paths of egress, refuge, muster, shelter, points, and method of communication, and Test, the method of communication. K. if you are a visitor, ensure the facility emergency manager is aware that you are in the facility, has a copy of your PEEP, and with a buddy, review the appropriate emergency egress procedures

Add the following starting with letter I . I. as part of on boarding and orientation, practice the egress roots, muster, shelter, and refuse points, and test the method of communication with the person with a disability. J. If there are any parts of the standard that are not met , communicate immediately with the facility, emergency manager and the facility accessibility panel. K. If you are assigned to a visitor, ensure that you know, the PEEP, and, if applicable, practice the egress method, shelter, muster, and refuse points, and test the method of communication.

After the words, Potential improvements should be discussed frequently and openly, Add another sentence. 11.4.3 Post-emergency: Evaluation and improvement After an emergency situation has taken place, an in-depth review shall be conducted on the effectiveness of the procedures that were developed and implemented. All drills and emergencies shall be documented to facilitate improvement. Potential improvements should be discussed frequently and openly. If the in-depth review shows areas of concern that are life-threatening, these should be reported to the fire department inspector, or building code inspector, and be treated as serious violations with the due process of the inspection agency. These serious violations shall be reported to the facility, emergency manager and the facility accessibility panel.

Change the title of the section by enlarging it to those who need assistance 11.2.1.3 The role of the person with a disability or who requires assistance that impacts emergency egress.

Change the title to include all those who are not visitors 11.3.2 occupant, residence, and full and part time Employee Personal Emergency Evacuation Plans

Add a clause, H, at the end about risk mitigation 11.2.1.3 The role of the person with a disability Some information on emergency egress issues that relate to individuals with various disabilities is provided in Annex A (https://accessible.canada.ca/creating-accessibility-standards/can-asc-22-emergency-egress-exit/18-annex-emergency-egress-issues-persons- disabilities). A person with a disability shall: a. develop a PEEP in conjunction with the emergency warden and buddies; b. ensure that emergency wardens and buddies know and understand their personal situation and how to best assist; c. describe their preferences as to lifting or transferring; d. describe any areas of concern such as loud noises, the use of assistive devices, areas of pain, etc.; e. know the location of the accessible egress routes and the areas of refuge;f. know how to use an evacuation device, if applicable; and g. be aware of the location of the muster points. New text starts here H. Discuss the risk profile of the facility with the facility, emergency manager, which may include age of the building, combustible materials in the building, sprinklers or not, which building codes are older, grandfathered, and not up-to-date, code violations, received from the fire department or other authorities, proximity to other dangers, and anything else the facility manager may be aware of. If appropriate, discuss reducing the risk by changing the location of the work, occupation, or residence , by increasing the proximity to refuge, shelter, waiting, exit doors, elevators, stairs, egress pads, or selecting other facilities.

Add a sentence describing what happens if it is a one story building, such as a factory, warehouse, or logistics hub. Also, expand refuge area, too, muster , shelter, or waiting areas. 12.1.1 Application Buildings shall be provided with areas of refuge, muster, shelter, and waiting areas on levels above and below the level served by an immediate accessible exit and egress path of travel leading directly outside. In the case of one story buildings, the areas of refuge, muster, shelter, and waiting shall be located in such a way that they are safe from the situation of the emergency, and close to the path of egress.

Add conditions at the end, indicating that the number of persons occupying or employed in the building shall be part of the consideration of number of refuge areas. 12.1.1.1 Number of areas of refuge 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. Note: Decimal numbers should be rounded up to the nearest whole number. Other considerations: a. the building use; and b. the anticipated number of visitors. New text starts here C. Number of persons occupying or employed in the facility D. the proportion of staff available to eat in evacuation, such as buddies, compared to the number of persons employed in or occupying the building.

Add specifications after the words,includes an elevator lobby Note: An example of a fire compartment in this Clause includes an elevator lobby, New text starts here only if the elevator lobby is protected from the emergency situation, such as fire, and compliant with clause 12.1.3 It will be marked in the same way as refuge area in a prominent way.

Add other conditions to make it more survivable as a place of refuge starting with letter E. 12.1.3 General Areas of refuge shall be: a. located on an accessible route; b. smoke-protected; c. illuminated at a minimum of 200 lux; and d. provided with an evacuation device nearby New text starts here E. Full range of communication systems backed up by fire resistant and emergency power f. have separate emergency lighting and ventilation systems supported by a backup generator.

In C Add a phrase after the words, alternate power so that a door can be manually operated. 12.1.4 Doors serving an area of refuge A door serving an immediate area of refuge shall: a. b. be leakage-rated complying with NFPA 105; have a clear width complying with CSA/ASC B651; c. be equipped with a power door operator capable of being activated in the event of a loss of power via emergency power or alternative power New text starts here or manually.

Add letter G , indicating that the size of this area should be calculated according to the appropriate code or the number of people that might use it. 12.1.5 Interior of areas of refuge The interior of an area of refuge shall: a. provide a minimum of two waiting spaces to accommodate a clear unobstructed floor space not less than 900 mm by 1500 mm for each space; b. be served by a 2100 mm turning radius; c. be located clear of any adjacent door swing; d. be illuminated, minimum 200 lux; e. be connected to the backup power; and f. be free of protrusions. New text starts here G. have a size calculated according to the appropriate fire or building code or number of people who might use it.

Add letter G and H G. be safe and used in those cases where the person's exiting the facility need to pause , for any reason, between their original spot, for a short period of time on their path to egress the emergency situation. H. Have complete access to all communication, facilities, backed up by emergency power

Harmonize this signage standard to all areas, not just refuge. Add requirements that sign must have location information. 12.1.8 Signage An area of refuge, shelter, muster point, or waiting area shall have an identification sign on the door or appropriate place stating the AREA with the International Pictogram of Access. An additional sign shall be posted on the side of the door, or appropriate place complying with CSA/ASC B651.12.1.8.1 New text starts here All of these signs will have information on them, which gives the location in a way that emergency personnel can easily locate them. All signage will Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats.

Add a line after the description of directional signage. 12.1.8 Signage 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 B651.12.1.8.1 Every Directional signage Emergency egress directional signage to the area of refuge shall be provided at decision points throughout the building. New text starts here directional sign at every decision point shall have an additional identification that identifies the location of the decision point in a way that makes it easy for emergency personnel to know the location of whoever is referencing that particular decision point. Each directional sign shall be self luminous. This location identification shall also be in braille and large print

The standard should be made consistent, especially being able to open the door manually, when all else fails.

Add extra conditions starting with D. 12.3.1 Interior egress path of travel The interior egress path of travel shall comply with CSA/ASC-B651. Static escalators, stair lifts and moving walks shall not be permitted as part of the interior egress path of travel. All elements in the interior egress path of travel shall be accessible, including: a. to and from all floor areas of a building; and b. to and from all interior doors to exterior exit doors. In addition, the interior egress path of travel shall: a. where there is a rise over 13 mm, have a slope of no steeper than 1:25. See Ramps 12.7; b. be free of protrusions to a height of 2100 mm; c. be illuminated to a minimum level of 200 lux; andd. be free of overly patterned carpeting. New text starts here D. Have lighting connected to emergency back up power, which will also light up directional signs at every decision point. E. Where possible, egress paths will have illuminated, or self luminous directional markings on the floor. F. Signage identifying the egress pads shall be identified on the emergency fire safety map posted throughout the building.

Add conditions starting with letter E. , 12.4 Muster points All buildings shall have muster points served by an accessible exterior egress path of travel. The muster point shall be a minimum of 3000 mm x 3000 mm. Signage with the muster point symbol shall be provided between 1600 mm and 2500 mm above the ground surface. Signage identifying the muster points shall be identified on the emergency fire safety map posted throughout the building. Benches or seating provided for the muster point shall comply with CSA/ASC B651. The muster point shall: a. be provided with a rest area equipped with a bench or seating alternative; b. have a pavement marking not less than 1 m by 1 m identifying the international symbol of muster points, where located on a hard surface; c. be illuminated; and d. be recessed away from and served by an exterior egress path of travel complying with Clause 12.3.2. New text starts here E. have a size that is calculated with information about the use of the building, the size of the building, number of occupants or visitors, distance from the egress door, factors that might make the speed to get out of the building important, availability and numbers of of buddies or staff members to aid in persons with disabilities. F. be connected with all communication facilities, which will be backed up by battery or emergency generators. H. Be connected to emergency ventilation systems

Add a phrase, D, that the signage on the underside should also indicate the location of the stairwell. 12.6.1 Tactile information on stair and ramp handrails Stair and ramp handrails shall have raised characters with braille permanently fixed on the underside of the horizontal section, at the beginning and at the end of every handrail on stairs indicating: a. the floor number; b. the direction of egress; and c. the exit floor shall be indicated by a tactile star. New text starts here D. the location of the stairwell Will be marked in such a way that emergency personnel can easily identify the exact location of that particular railing.

Harmonize the condition, such as lighting, emergency power, signage, Communications, and size

Add one more condition, letter I. I. all communication systems that a person with a disability might use will be available, resilient, and fire resistant in this and all areas used in emergency situations.

Add more description at the end of this item to make it more clear to a person with a disability through the appropriate communication channels, and updates until all clear signals are given 13.1.1 Single-stage system A single-stage system is designed so that, when activated, the alarm signal shall be immediately transmitted throughout the building to warn the occupants that an emergency exists. New text starts here The alarm signal that is transmitted will use Barrier free communication systems that are compatible with the needs of persons with disabilities. Because there is no action necessary when this signal is transmitted, a subsequent, all clear, signal will be transmitted to indicate that the emergency has been resolved. To ensure that the system is failsafe, if a period of more than three minutes passes before the, all clear, signal is transmitted, another signal, indicating that the emergency is still pending, but not resolved, will be transmitted every three minutes. If possible, when the, pending signal is transmitted, a description of the emergency, location, seriousness, action, being taken, would also be helpful.

Add a paragraph at the end. The alarm signal that is transmitted will use Barrier free communication systems that are compatible with the needs of persons with disabilities. Because there is no action necessary when parts of this signal is transmitted, a , all clear, signal will be transmitted to indicate that the emergency has been resolved. To ensure that the system is failsafe, if a period of more than three minutes passes before the, all clear, signal is transmitted, another signal, indicating that the emergency is still pending, but not resolved, will be transmitted every three minutes. If possible, when the, pending signal is transmitted, a description of the emergency, seriousness, action, being taken, would also be helpful. If there are any Voice announcements, there will be a identical transmission of this message in a barrier freeway that works for the communication systems used by persons with disabilities.

There are a few statements in this section that should be clarified. 1. Note: A two-stage system is used in facilities where the immediate evacuation of the occupants is neither desired nor practical. Can you give some examples? Prisons? Hospitals? This signal is not when there is an immediate need for an evacuation, but how long might it take before that need becomes necessary. 2. Alarm signals to evacuate occupants do not sound. Notification is via a voice announcement. If notification is given using voice, what about persons who are deaf, or DEF Blind. 3. Like the single stage system, there must be communication while the emergency is pending as updates, on a frequent basis, as well as an all clear signal. 4. Clarify that the, how to proceed, signal, might be a signal to evacuate, although this is neither immediate, planned nor desirable

Add this line at the end of each of these two sections. The visible strobe signal in the event of a fire, shall also be accompanied by a communication Barrier free systems that use communication systems used by persons with disabilities.. C-section 13 point XX.

Add letter F 13.1.4.1 Emergency communication formats Building managers shall ensure communication systems that can alert all building occupants are in place in the event of an emergency. Note 1: Clear and efficient communication with everyone, including regular occupants and visitors, will enhance the safety of all building users during an emergency. All building occupants shall: a. b. receive emergency egress information in the format of their choice; and Receive egress information in the format selected during the preparation of an individual’s personal emergency egress plan. Some building occupants may need information in various formats, including: a. large print; b. electronic messaging; c. speech synthesizers; d. an electronic pager; or e. sign language interpretation. New text starts here F. ensure barrier free communication systems backed up by emergency power or generators are available that are compatible with all communication systems used by persons with disabilities

Replace the following phrase. Some building occupants may need information in various formats, including: a. large print; b. electronic messaging; c. speech synthesizers; d. an electronic pager; or e. sign language interpretation. And replace with Some building occupants may need information in a format identified in the personal emergency evacuation plan, or any other Barrier free format that works with communication systems used by persons with disabilities.

Add a sentence before Lower frequency audible alarms should be provided for people who are hard of hearing Add the following This standard works in certain situations, but other technologies and devices shall be used in particular, those Communication barrier free systems and devices that are suitable for persons with disabilities.

Add a phrase at the end Every visible signal Location shall also have technologies that enable any person with a disability to receive the same message as if they were able to receive the information from the visible signal device in a barrier freeway compatible with the technology used by persons with disabilities.

Add a sentence at the end indicating the difference between the standard listed in annex C, which is a general, widespread notification system, and the notifications necessary in and particular facility during an emergency. 13.2.3 Smart phonesCommunication tools such as smart phones or mobile phones are increasingly being used by everyone. They are an excellent form of communication as they can receive audio and tactile alerts to notify of an incoming message and can be used in text and voice (audible) formats. Alert signals shall be transmitted via the National Public Alert System by all telecommunications providers. See Annex C (https://accessible.canada.ca/creating-accessibility-standards/can-asc-22-emergency-egress-exit/20-annex-c-emergency-alerting-and- communication-technologies-persons-disabilities) for information on national and provincial alert systems. New text starts here the notification system described in NXC is used for widespread announcements of emergency situations. every facility must also have an notification system suitable for use by persons with disabilities at the beginning, during, and at the end of any emergency. smart phones and devices are suitable for this notification system, but there might be certain persons with disabilities who require other devices or systems to be aware of emergency egress and exit instructions during an emergency

Add a few conditions at the end starting with letter F to enable all persons with disabilities, particular, blind, or deaf, to have a safe emergency egress. 13.3 Emergency telephones 13.3 Emergency telephones Where provided, an emergency telephone shall: a. b. c. d. e. display the symbol for an Emergency Phone; provide its operable parts not more than 1200 mm from the floor; have the illumination level measured at the operating devices at least 200 lux; be hearing aid compatible; and have a volume control with amplification of (30-50 dB). New text starts here F connected to an emergency backup generator or emergency backup battery system G. have signage indicating the exact location of the emergency telephone so that emergency personnel can easily identify the position of any caller H. Ensure that for any person with a disability for whom the emergency telephone is not suitable, that every other system used in a barrier free way by persons with disability of communication works in the same location as the emergency telephone..

Add a line starting with letter E to ensure that whatever communication system is used, that there be a communication system that works for every person with a disability. 13.4 Public announcements Whenever a public announcement is provided in an audio format, it shall be provided at designated areas on all floors of a building in text display and transmitted electronically to building occupants. All public announcements relating to emergency egress shall be provided in a variety of formats, including: a. audible announcements; b. broadcasting to hearing technologies and implantable devices; c. visual announcements; and d. electronic announcements. New text starts here E. Every public announcement or message Board notification will also be communicated using Barrier free communication systems and devices that are compatible with those used by persons with disabilities. New text ends here Note: Variable message boards should also be used. When provided, variable message boards shall: a. b. not use pre-recorded messages for emergency information; utilize a well-contrasted characters (avoiding red and green or blue on a black background); c. be mounted at a maximum height of 1500 mm; and d. be centrally located.

Add a line starting with letter E 13.5 Audio systems (assistive listening systems) A permanent assistive audio system shall be provided where there is an exchange of emergency information, including in the following floor areas: a. in elevators; b. as part of emergency warning intercom systems; c. as part of all public announcement systems; and d. at security checkpoints. New text starts here E any assistive system that meets the conditions of this clause shall also be integrated with all communications systems that are necessary for persons with disabilities to receive the appropriate instructions during an emergency egress in a barrier free way. situation.

Add the words, muster, waiting, or shelter, after the word, refuge. 14. Illumination and emergency power Illumination of accessible egress paths of travel and Areas of Refuge Muster, waiting, or shelter shall be: a. no less than 200 lux at floor level; b. be placed to avoid glare; and c. supplemented by emergency power. Separate emergency lighting and ventilation systems shall be supported by a backup generator. Emergency electrical power will ensure adequate emergency lighting for the use of elevators and key operating components or other systems during a power outage. A photoluminescence lighting system along the floor should be provided to indicate the accessible egress path of travel. Illumination in elevators shall be a minimum of 100 lux.

Enlarge the choice of using this type of elevator during an emergency By adding to the phrase after, using the stairs.. 15.1 General The use of elevators for evacuation is one key strategy for evacuation of people who are unable to use stairs. New text starts here and for evacuation of people who decide that this type of elevator is a safer or more rapid method of egress then stairs during an evacuation

Enlarge the choice of using this type of elevator during an emergency By adding to the phrase after,. Use the stairs.. 15.3 Occupant evacuation elevators An Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. New text starts here and for evacuation of people who decide that this type of elevator is a safer or more rapid method of egress then stairs during an evacuation.

Enlarge the use of this type of elevator by adding to the phrase, people unable to use the stairs. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. New text starts here and can be used by people who decide that this type of elevator is a safer or more rapid method of egress then stairs

Add a phrase after Alternately, Wi-Fi availability can facilitate communication. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. A two-way text/communication system shall be provided inside and outside the OEE elevators. A two-way text communication system inside and outside elevators are available that will provide a visual screen to connect with security. Alternately, Wi-Fi availability can facilitate communication. New text starts here Any two way system or visual screen shall also have technologies, integrated, or nearby in a failsafe manner, such that persons with disabilities using Barrier free accessible and usable, technologies will receive all notifications and announcements, before, during, and after an emergency or evacuation.

Add a line at the end enhancing the ability to locate this type of elevator during an emergency. Just a sign is not sufficient. 15.3.1 InformationAn Occupant Evacuation Elevator (OEE) is designed to be used for evacuation purposes by people unable to use the stairs. A two-way text/communication system shall be provided inside and outside the OEE elevators. A two-way text communication system inside and outside elevators are available that will provide a visual screen to connect with security. Alternately, Wi-Fi availability can facilitate communication. Information on its use shall: a. be incorporated into the fire safety plan; b. be incorporated into the PEEPs, when appropriate; and c. be included in the posted fire safety evacuation plan. Occupants of a building shall be instructed in how to use and when to operate an OEE. There shall be signs posted on all floors adjacent to each elevator call station for OEEs. New text starts here In addition to signs posted on every floor for this type of elevator, there shall be notification and announcement Barrier free, accessible, and usable, systems suitable for persons with disabilities, such as voice alerts, identification, flashing light, and tactile markings on the floor to announce this type of elevator.

Replace, additional space for two persons, with a clause indicating how this number is to be calculated. 15.4.1 Space 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 New text starts here and additional space for the number of persons that is appropriate for the number of occupants, residence, and visitors, as well as the number of elevators and floors.

Add a clause at the end, indicating that the elevator of this type must be identified in a way that works for persons with disabilities. 15.4.3 Identification An elevator that is designed to accommodate a stretcher or OEE shall be clearly identified on every level the elevator serves. New text starts here In addition to signs posted on every floor for this type of elevator, there shall be notification and announcement Barrier free, accessible, and usable systems suitable for persons with disabilities, such as voice alerts, identification, flashing light, and tactile markings on the floor.

Change clause E to a height that fits the general population. 15.5 Elevator controls Elevator car controls shall: a. b. c. d. be mounted on the front and side walls of the elevator cab; be mounted at a maximum height that matches the median height of occupants and residence;

Add a line F, , indicating function appropriate for emergency use. 15.5 Elevator controls Elevator car controls shall: a. b. c. d. be mounted on the front and side walls of the elevator cab; be mounted at a maximum height of 1200 mm; be equipped with braille and raised characters on buttons located to the left of the operation button; and have a well-contrasted operation button. F. Any elevator of this type must have a Barrier free, accessible, and usable system that enables persons with disabilities to direct it to the floor that has the safest evacuation route.

The note at the end about red, green and blue lights should be harmonize with signage standards for persons with low or no vision. 16.1 Application All signage and way finding relating to emergency egress shall be accessible and shall include text, visual, tactile and Braille characters. There are different types of signage that relate to emergency egress for various purposes: a. regulatory signs, which include information, including safety and emergency signs; b. mandatory signs which denote an order requiring an action; and c. warning signs such as caution and danger signs denote a potential hazard and a definite hazard. Note. All signs shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats.

Clarify the different lettered phrases, and add, areas of shelter, muster, and waiting. 16.2 Directional signage The following signs shall be posted indicating the accessible egress route to : a. an exit, B. an area of refuge, waiting, shelter, or muster C. a horizontal separation, if it is used as an area of refuge , shelter, waiting, or mustard ; b. an occupant evacuation elevator. Emergency egress signage shall be identified by directional signage indicating the accessible egress path of travel to the final exit.

Change and merge c. provided with legible, clear font not less than 16 pt; and d. available in alternative accessible formats, upon request. 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. All signs shall Conform and harmonize two standards for usability and legibility for font style, size, color, and contrast as well as standards for alternate formats.

Add some lettered clauses to ensure these signs are are usable and legible at all times, including power outages Starting with E. in this standard. 16.2 Directional signage 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. E. be self illuminated, externally illuminated, or glow in the dark. Any power for illumination shall be from emergency backup generators. F. every directional sign shall also have identification Marker on it that shows the location of the sign, so that emergency personnel can easily locate a person who calls in needing assistance and references this identification marker. The identification marker shall also be in tactile and braille. G. directional signs shall be surrounded by tactile floor surface, large enough for a person with low or no vision to locate it, and small enough not to interfere with evacuation procedures. H. directional markers shall emit a sound loud enough for a person with a disability to locate it, but not loud enough to interfere with evacuation procedures.

Shorten the list.

Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, color, and contrast and standards for alternate formats. For those persons with disabilities for whom a map is not suitable, list and have a contact person to explain and demonstrate, and practice, the necessary information that will lead to a successful emergency egress. . Use only approved ISO pictograms. Have a legend that explains in an accessible format what each pictogram is.

Add a clause G , ensuring that user feedback is incorporated into each revision, and continue this process until users are satisfied. G in the spirit of continuous improvement, as soon as possible, after the opening of the facility, survey the users of this tactile map on a regular basis and revise the map, consistent with suggestions, until users and the facility accessibility panel are satisfied..

Add additional items to facilitate emergency egress. 16.5.1 Enclosed stairway signage A. An enclosed stairway shall have a sign identifying the storey in raised characters and braille with a high luminance contrast to its background at each landing that provides access to a floor area. New text starts here The sign shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, colour, and contrast and standards for alternate formats. C. On those floors where there is exit, refuge, shelter, or waiting areas, this shall be marked on the door in formats that conform with the standard for accessibility. D. each sign shall have an identification marker in an accessible format that locates where the door is in a way that emergency personnel with this information could easily locate a person.

Add a sentence after clause, A clarifying the standards to be met 16.5.2 Exit door signage An accessible exit door discharging to the exterior of a building or another building shall: a. have a sign with raised characters and braille; New text starts here the sign shall Conform and harmonize with signage standards for accessibility, usability and legibility including font style, size, colour, and contrast and standards for alternate formats.

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.

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. • Section 7.1(a) notes that the standard shall apply to “all new buildings.” o 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

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.