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

When facilities are operational, exterior lighting shall:

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

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

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

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

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

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

Remove this specification.

Remove all design and placement requirements covered by other standards.

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

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

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

Remove this requirement.

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

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

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

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

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

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

Remove the requirement for slip resistance.

Remove this text/requirement.

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

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

Remove the requirement.

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

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

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

Remove this requirement.

Remove this requirement.

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

Remove this option

have a top diameter between 12 mm and 15 mm

be installed cross the full width of the hazard

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

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

Remove this note.

Remove or clarify who is qualified to do this work.

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

identification signs regulatory signs; and warning signs;

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

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

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

12.2.9 Trailhead signs for outdoor spaces

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

Remove this text.

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

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

100 lx

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

Specify what is meant by "in such cases".

Revise to align with a)

for outdoor toilet facilities with walls

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

Be more specific as it is unclear.

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

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

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

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

Remove this requirement.

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

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

Remove this requirement.

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

enable video brightness settings to be adjusted

Remove the design specification for a backlight feature

Remove this requirement.

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

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

Remove a.

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

grade 4 reading level

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

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

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

conveyed at a Grade 4 reading level.

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

Remove this text.

Remove this requirement.

Maps

Currently there is no perfect solution.

Add visual graphics to support written text

clarify further how the signage should be installed

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

add visual graphics to support the written text

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

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

see comment above on 9.1

i. install window treatments to prevent glare from sunlight and reflections, as necessary j. avoid installation of highly reflective surfaces on floors and walls that will increase glare from light sources.

- Patterns can cause difficulty with the processing and interpretation of visual information. - Bold/busy patterns and too many bold colours can also add too much visual stimulation to the environment and be overwhelming to someone who has challenges processing visual information. -Choosing calming colour palettes and low low volume patterns can help to create a calming atmosphere. -Using contrasting colours can make important functional features in the environment stand out (e.g., a white light switch on a contrasting wall, a dark toilet seat on a white toilet fixture, which contrasts with the wall and floor) -strong contrast in flooring (e.g., when there is a change from one flooring type to another) can be perceived as a step or a hole by someone with visual perception challenges. Choose one colour/tone for all flooring types and use throughout the same level of your space. -Avoid flooring with strong contrast and visual patterns, as it may be perceived as objects on the floor, an uneven/moving surface or a change in level.

5. Remember their purpose, and provide them cues as to where to go, or what action is required next - guiding them one step at a time.

Include guidelines on size of raised edges, appropriate contrast levels, flush installation, slope of bevelled edges and spacing to reduce falling/tripping hazard.

It should be recognized that trees, planters and other objects (e.g., public art installations) are not simply decorative - they have an important function in helping to create a distinctive and familiar environment for people who have challenges with orientation and wayfinding, and they can act as a steet-level buffer to sound and visual stimulation for people with sensory processing difficulties.

Add: e. walking surfaces should contrast with walls of buildings, and any objects on the ground to improve depth perception within the environment and increase visibility of obstacles (e.g. furniture, planters, etc.).

Attention indicator surfaces should not cover the entire curb surface, so that the direction of travel is clear to the person needing it.

Add to the end of the sentence "...to ensure their effectiveness when in use and to reduce the potential for these indicators to become tripping/falling hazards for people with mobility challenges."

a. be concise and written using direct and plain language. It can be helpful to think of 2-3 key words that convey the message. (e.g., "Do not enter", etc.)

Note 4: Along the interior path of travel where the line of sight is impeded, accessible paths of travel should include convex mirrors. They may be installed in the corners of ceilings at high-use areas or at unobstructed passing areas.

b. be positioned 300 mm back from the road or parking lot side of the curb, when used to indicate a curb ramp or depressed curb at a pedestrian crossing; d. be positioned 300 mm back from the road or parking lot side of the curb, when used to indicate at-grade curb faced walkways.

ii. have a continuous clear visual and tactile detectable delineation between pedestrian and cycling zones, such as a 300 mm wide grass section for easy detection, or be on different levels such as the street and the sidewalk;

12.2.8.e.i.1. is at least 300 mm wide by 450 mm high, and where required, includes a 300 mm wide by 150 mm high sign below the standard sign to identify the wider accessible parking space as "van accessible" 12.2.8.e.ii.3 [add information to explain that the sign shall be placed in a manner that is centred on the accessible parking space]

ii. use Arabic numerals, not Roman numerals. iii. have a width-to-height ratio between 3:5 and 1:1 to ensure characters do not appear too narrow or too wide. iv. have a stroke width-to-height ratio between 1:5 and 1:10 to ensure characters do not appear too thin or too thick. viii. do not use italics font and avoid oblique, script, highly decorative or other unusual forms of characters Note 3: [add text to explain character heights should also be based on mounting height, in addition to viewing distance.] Also add: 1. Use horizontal text orientation, not vertical or diagonal orientations. 2. Avoid long lines of type.

c. be installed on the latch side of the door for wall-mounted room identification signs, located 150 mm from the leading vertical edge of the door frame. Where there is no wall space on the latch side of the door, including at the double leaf doors, be placed on the nearest adjacent wall. [similar to content in 12.7.2] Also consider adding: 1. provide minimum 75 mm of clear space around the sign; [similar to content in 12.7.2] 2. do not mount on swinging doors; and 3. where tactile messaging is included, be located to facilitate a clear floor space of 900 mm wide x 1500 mm long for a front approach, or 900 mm wide x 2200 mm long for a side approach.

[Add a requirement for stairwell signage on the room side of stairwells, complete with the requirement to have a pictogram of a stair] [Consider if similar requirement is needed for escalators]

d. require a clear area of 900 mm wide x 1500 mm long for a front approach, or 900 mm wide x 2200 mm long for a side approach

[not sure if this is the right location in the standard, but consider adding text that explains "raised pictograms shall have a minimum field height of 150 mm"]

a. have dots that are domed or rounded shape, not pointy or flat, and provide Also consider adding: 1. have grade 1 Braille placed directly below the corresponding raised text and pictograms. Use grade 2 Braille for messaging with 10 words or more.

Move the sentence to terms of reference

and repair are *all* crucial for accessibility.

if you don't have a exact time to leave a message up give a range at least they have some place to start from. refining can happen in the maintenance stages of the document

tactile and braille should be include on all button of the elevators esp. the phone

move that to the definition block of the standard

this two point should be broken up into two points

change the tittle to Map Orientation

propose changing the word to something else more direct like background or adding a diagram which visually describes the different descriptions used in d., and e..

remove this sentence

change the word to where possible

The paint must have anti skid texture added in the paint

remove the point

add more examples and remove the wording,.

A complete list under a

change it to trail head sign

Move to under 12.1

The new section should be labeled as "SOP" (Standard Operational Procedures). Especially with TWSI and indicator strips can lose colour, can be damaged, because of normal day to day use especially in outdoor spaces. I.e. snow-plowing, a plow hitting the TWSIs and removing it from its' location which. Indicating a procedure for clearing and maintaining the TWSIs especially during and after weather events in outdoor settings.

that a cover or plug should be concealed in the construction or within the structure so that the grade remains flat when bollards are removed or replaced

CSA/ASC B651 for clause details is appropriate for indoor standards but for outdoor standard it should reference the outdoor spaces instead - the correct clause needs to be researched and added

lighting requirement should be in place a half a hour before sun set to a half hour after sunrise as well, when lights cannot be manually turned on, a photosensitive switch should be installed especially in an outdoor setting. for awnings this sensor should be able to see the sun even in a forested area

Studies have proven that lighting along park walkways cause safety concerns for user walking from a well lit area to dark area at night

Recommendation Clarify: • Whether these standards are intended to exceed current building codes • How jurisdictions should reconcile conflicts between this standard and existing provincial codes

The Introduction does not clearly differentiate between: • New construction • Major renovations • Existing buildings

Specify how affordability and scalability will be applied in real-world implementation, especially for smaller and rural communities.

Because without clear distinctions and scalable pathways, smaller and rural communities may face uncertainty, disproportionate retrofit costs, and inconsistent application of the standard.

Clearly distinguish in the Inclusions section between mandatory “shall” requirements and advisory “should” best practices to improve implementation clarity.

Expand the Exclusions section to clearly explain whether excluded topics such as tactile maps, acoustics, and assistive listening systems will be addressed in future standards, are governed by existing standards, or are intentionally outside the scope, and provide practical interim guidance so practitioners understand how to manage these elements during planning and procurement.

Clarify in the General Requirements for Lighting and Contrast how compliance is to be measured in practice, provide simplified field verification methods, and distinguish expectations for new construction versus existing facilities to reduce implementation and retrofit uncertainty.

Revise the lighting section to clearly outline acceptable measurement methods, define how requirements apply to new construction versus existing facilities, allow phased or risk-based compliance for retrofits, align thresholds with existing building codes where possible, and provide scalable options that reflect the financial and technical capacity of smaller and rural municipalities.

Revise the Application subsection to specify to what types of facilities, projects, and environments the lighting requirements apply, including distinctions between federally regulated buildings, new construction, major renovations, existing facilities, and low-complexity or rural settings.

Change "letters and numbers" to "characters" to be more all-encompassing.

No change required in document, simply a suggestion.

“Le code braille français uniformisé pour la transcription des textes imprimés” (CBFU)

See CSA B651-23 for information to add, add all information required so that a reader can know how to calculate the Michelson contrast.

Add a mathematical formula, that is clear and properly formatted.

Add abbreviation definition for 'SI".

Add information about how lighting is to be added in a handrail, what is acceptable and what is not. When it should be added and when it should not be.

Add definition and calculation details.

Add detailed explanation on calculations.

Add more applicability and specificity information.

Change to be clearer, stating clearly which colour should not be combined or paired.

Combine both statements d) and c).

CSA B65-23 clause that is referenced.

Add reference figures (visuals).

Combine i) and ii).

b) be standard and consistent within a building, facility, site or complex of buildings..

Consider removing or clarifying the need of TAIs at the top of ramps.

Revise note to make intention clearer.

Define what "high" means.

Revise to clarify that it is the entire plate that is meant.

Add specificity to the applicability statement... How large? How open?

Remove not or add detail for clarity.

Remove, move to the notes or add details on what an "established need" is.

Consider engaging with officials from the Province of Quebec to ensure that this note does not conflict with their laws (especially for federally owned buildings applying this standard).

Combine requirements.

Consider combining point d) and e).

Specify contrast calculation methodology applicable.

Instead of referring to the CSA B651-23 table 7, describe specific minimum character heights directly in standard.

Remove Note 3 and keep point f).

Have requirements instead of Notes.

Add it as a note, add it to different section or refer different section.

Add information (or refer location in document that contains information) on what is required to be tactile.

Clarify statements and applicability.

Specify from where the 600 mm is measured.

This requirement should be revised to indicate that it is for characters that are tactile ONLY and that characters that are tactile but also meant to be read visually shall adhere to clause 12.4 n) v) above.

Revise statement to make it very clear that this is for characters that are tactile ONLY. If they are tactile and visual (a combination of both) then they must adhere to clause 12.4 n) vii) and have combination of both lower and upper cases. This is very important to state to avoid conflicts and confusion.

Please clarify.

Clarify applicability.

"code braille français uniformisé" -> “Code braille français uniformisé (CBFU)”

"on bilingual and trilingual signs" -> "on multilingual signs"

Add information.

Provide much more detail and information on the application of audible signs.

Add more information about engagement and testing.

Add reference to clauses 12.11.4, 12.11.5 and 12.11.6.

Add specific information on contrast calculation methodology to be used.

Add a specific minimum font size for digital and electronic signs to this standard.

Elaborate on requirements for digital and electronical colour contrast.

Adopt a language more proper to requirements.

Modify language to be more proper for requirements.

Edit language.

Edit language used.

Consider adding further requirements and recommendations for non-tactile maps.

"Orientation features, such as a north arrow or a “you are here” pin, shall be used to assist users in understanding the map's orientation and their current position." -> "Orientation features, such as a north arrow and a “you are here” pin, shall be used to assist users in understanding the map's orientation and their current position."

Refer to plain language standard and clauses on characters.

Include a clear introduction paragraph defining wayfinding and signage, outlining their importance and operational definitions, and explaining how both concepts interrelate within built environments, and how outdoor spaces requirements may differ from built environment requirements.

Tactile diagrams, tactile maps, and acoustics are excluded from this Standard as they are addressed in separate specialized accessibility standards; only Tactile Walking Surface Indicators (TWSI) and tactile signage are included here due to their direct link with spatial orientation.

Add a note to 7.3c to provide the reason for exclusion and ensure consistency between 7.3 and 6.1 note.

consider including Tactile maps and diagrams rather than excluding

Lighting affects people with hearing limitations who rely on visual cues (e.g., lip reading, signed language).

10.1.5 Lighting requirements apply only when facilities are open or operational. Maintain natural darkness at night in non operational or ecological areas.

Exterior lighting shall: a. be a minimum lighting level of 50 lx during the hours the facility remains open for use, except in main driveways where lighting may be reduced to 30 lux

Differentiate between built environment exterior lighting and outdoor spaces lighting or refer to Outdoor Spaces standard.

10.1.5d Exterior lighting shall, for built environment only, maintain a minimum lighting level for facilities outside of daylight hours at 50 lx (dusk to dawn).

Suggested: An extensive area is a large, complex, or multi‑zone environment where a person cannot easily understand the layout, locate destinations, or maintain orientation without structured wayfinding support.

reference Outdoor Spaces Standard for consistency

Note: This Standard uses the terminology of two sub-terms to Tactile Walking Surface Indicator, “attention indicator” and “direction indicator”, to align with other National Standards of Canada.

13.10e Location plans shall provide a feedback mechanism for reporting accessibility issues, per CAN ASC 2.1 Clause 9.4.

Built environment paths of travel shall: a-d Outdoor spaces paths of travel shall: a. comply with CAN-ASC-2.1 b. not have wayfinding or signage elements obstruct the path of travel in accordance with CAN-ASC-2.1 c.... d...

12.4n-v have letters and numbers that have the character height sized relative to the intended viewing distance, for built environments in accordance with CSA/ASC B651:23, clause 4.6.3, table 7 and for outdoor spaces aligning with CAN/ASC 2.1 clause 10.2 note 2;