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We recommend maintaining alignment with the Accessible Canada Act definition of disability, while supplementing it with strengths-based, inclusive language that reflects evolving best practices. Suggested addition: “While disability is defined in accordance with the Accessible Canada Act, Accessibility Standards Canada recognizes that children and individuals may also identify using strengths-based language, including neurodiversity and other affirming terms. This includes children with visible and invisible disabilities, whose needs may not be immediately apparent but are equally important to recognize and support. Accessibility efforts should respect and reflect diverse ways of understanding and describing human differences.”

You could add language such as: “This standard is intended to be applied across a range of childcare settings, and implementation should consider differences in scale, location, and available resources while maintaining the intent of accessibility.”

Add a short statement recognizing the role of group size and staffing. For example: “Accessible design in childcare centres should also consider group size and staffing ratios, as these directly impact a child’s ability to regulate, participate, and receive appropriate support, particularly for children with invisible disabilities such as sensory sensitivities, communication differences, or attention-related needs.” One policy idea would be to assign weighted ratios based on the needs of children within the group and their support needs.

Define who the authorities are and also set out expectations of equitable access across the country. I.e.: “For the purposes of this standard, ‘authorities having jurisdiction’ should be clearly defined and applied consistently across provinces and territories.” And/or: “Implementation should aim for consistent expectations across jurisdictions to support equitable access to accessible childcare in Canada.”

Add a short statement such as: “Implementation should consider workforce capacity, including access to trained staff in rural and remote areas. Consideration should be given to training and other supports to enable consistent application of this standard.”

Add a short clarification such as: “Acoustic design should support children’s ability to regulate, communicate, and participate in programming, particularly for those who are sensitive to noise or auditory input.”

Add language such as: “Implementation of this standard should include staff training on a range of neurodiverse profiles and support needs, as well as tools to document and communicate individual accessibility requirements.” In addition, consideration should be given to structured tools that support consistency across staff. Horizon Education Foundation is developing a Canada Student Support Plan (CSSP) prototype document embedded in its National Education Framework initiative, which outlines key information such as student strengths, communication preferences, sensory sensitivities, triggers and effective supports. “The use of individualized child profiles (e.g., a ‘child passport’) can support continuity across staff, reduce reliance on informal knowledge, and improve consistency in how accessibility supports are applied.” In practice, accessibility often breaks down due to inconsistency. Families are required to repeatedly explain their child’s needs, and supports vary depending on staffing. Standardizing both training and how information is captured and shared improves consistency, reduces gaps in care, and leads to better outcomes for children. Tools like the Student Passport provide a practical way to operationalize accessibility beyond the physical environment and ensure that supports are actually implemented day to day.

Empowerment and independence: Wayfinding and signage in its various forms allow for autonomy and independent navigation, providing timely, accurate, and clear information in multiple formats when necessary, without the need for human assistance.

k. User consultation: Implementers and designers carry out consultation and user testing with user groups representing a diversity of lived disability experiences and communication methods when establishing/determining or altering the wayfinding and signage solutions. Individuals with lived experience must be meaningfully engaged throughout projects from the outset, including design, testing, implementation, and evaluation phases.

Include an additional principle (i.e., subsection 6.2.l) stating that regulated entities shall aim for the highest level of accessibility and usability possible, rather than minimum requirements for technical compliance.

iii. consistency and dispersion of luminance throughout interior and exterior spaces and along paths of travel.

Add language clarifying that supplementary lighting must be maintained across key environmental elements such as doors, stairs, handrails, elevators, and decision points, as well as supporting the visibility of architectural and navigational cues.

Designers shall prevent glare and shadow by: … and include an additional point specifying that light sources should not be partially or fully obstructed, as this can create shadows on the illuminated target and reduce visibility.

Revise subsection (b) to state that wayfinding systems shall provide supportive measures that include audible, visual, and tactile features together, rather than in partial combinations, wherever possible.

Include an additional subsection (i.e., 11.1.g) stating the need to ensure wayfinding systems should be applied consistently across buildings and facilities to improve predictability.

Include an additional subsection (i.e., 11.1.h) stating that the design of wayfinding solutions must consider the spatial needs of guide dog users, persons travelling with guides, and those communicating side-by-side using sign language.

Revise the wording to reflect that detectable paths of travel should include visual contrast in all cases, with particular consideration required for highly complex buildings and extensive areas.

Revise the note to include a requirement that protruding objects must also be cane-detectable where they cannot be removed or recessed.

d./e. have maintenance plans with provisions for the clearing and repair of all wayfinding and signage elements that are part of the space, ensuring accessible routes and wayfinding elements remain available, consistent, and detectable at all times for all users, including white cane users and guide dog handlers.

Include an additional requirement specifying that information about the meaning of textural changes or tactile elements should be made available in accessible formats (e.g., website, accessibility page, or other communication methods).

Revise the introduction to include clear definitions of TWSIs and the different types (e.g., attention and directional indicators), including their purpose and use.

Include an additional subsection (i.e., subsection 11.4.1.1.f) specifying that TWSI design and implementation must involve user testing with persons who are blind, Deafblind, or have low vision, including white cane users, to ensure effectiveness and usability.

Include additional guidance referencing standardized definitions, layouts, and detection methods for different TWSI types to support consistent application.

Revise the note to clarify placement requirements and ensure consistency with the primary requirement that TWSIs are installed at the top of stairs and ramps.

Revise the setback distance from 300 mm to 150–200 mm, consistent with CNIB Clearing Our Path recommendations.

Revise the note to provide clearer guidance on colour differentiation, including recommended colour use for each type of TWSI to support consistency.

c. be installed within lateral reach or frontal reach wherever possible, and when installed within lateral or frontal reach shall include tactile text, graphical symbols, pictograms, and braille.

Include an additional subsection (i.e., subsection 12.1.j) specifying that signage should incorporate multiple communication systems (e.g., audible, visual, tactile) whenever possible, and that alternatives for signage should be made available where possible.

Include an additional subsection (i.e., subsection 12.1.k) specifying that effective signage should support independent navigation without the need for human or staff assistance.

Revise the note to clarify that where accessibility requirements are not applied, alternative accessible methods (e.g., staff or volunteer assistance) must be provided to ensure access to information.

Include an additional subsection (i.e., subsection 12.3.d) specifying that signage should include a QR code, website link, or contact information (preferably a phone number) to access additional information in accessible formats.

Include an additional subsection (i.e., subsection 12.3.d) specifying that information provided by signs should be validated through user testing with persons with disabilities, including individuals who are blind, partially sighted, and Deafblind, to ensure clarity, comprehension, and usability.

Include an additional requirement specifying that tactile signage should be regularly inspected and maintained to ensure that tactile elements (e.g., raised text and braille) remain legible, intact, and effective over time.

Revise the clause to clarify that audible signage must provide information that is equivalent in content and timeliness to visual and tactile signage, ensuring equal access to all users. Revise subsection (a) to include that audible signage must also use an appropriate speech rate and clarity to ensure information is understandable.

Revise subsection 12.11.1.a to specify that digital signage must conform to recognized accessibility standards (e.g., WCAG Level AA or higher) and be compatible with assistive technologies.

Include an additional subsection (i.e., subsection 12.11.2.d) specifying that digital signage must provide auditory output or compatibility with assistive technologies to ensure access for individuals who cannot perceive visual information.

Include an additional requirement specifying that maintenance must prioritize critical accessibility elements such as tactile signage, braille, audible systems, lighting, and digital accessibility features.

Revise the clause to specify that periodic reviews must include consultation with persons with disabilities, including individuals who are blind, partially sighted, and Deafblind, to assess real-world usability and effectiveness.

recognizes the equity rights of all persons with disabilities in Canada

Any images reproduced in the final published document will have alt-text describing those images.

Remove this definition and replace all instances in the standard with “Accessible Format”.

Remove above text.

Cane-detectable — An object or surface texture modification that is within the reach of a long white cane tip, at or near ground level, that can be reliably identified.

Large print — text that is 16 to 18 point or larger.

a) incorporate the following: I) colour rendering (minimum Ra > 90); ii) colour temperature around 3000 K; and iii) colour rendering index between 90 CRI and 100 CRI; and

v) lighting should be down-cast and not directed horizontally into lines of sight.

e) ensure indoor spaces are lit to a minimum of 200 lx for interior paths of travel, stairs, ramps and escalators.

b) ensure that the UGR value does not exceed 16 in circulation areas and does not exceed 13 in habitable rooms

b) integrate artificial and natural lighting to provide comfortable, evenly distributed light at floor level and circulation routes, to minimize pools of light or shadows;

f) rooms and spaces should have multi-zoned lighting fixtures and options for spot lighting to support tasks for work surfaces, identifying hazards, reading signs, navigating spaces, increase visibility to speakers and interpreting sign language; and

Remove above clause

Note: Prioritize matte finishes. Use non-glossy or matte paint to minimize glare and reflections.

Note: Use bold contrasting colours like safety yellow for stair edges, handrails, door frames, and tactile warning tiles.

Note: Keep sign colours and layouts consistent throughout the environment.

Wayfinding is facilitated by well-designed indoor and outdoor environments that incorporate clear paths of travel, along with constructed and natural navigation cues such as edges, landmarks, signage, surface textures, lighting, and acoustics that can be detected through visual, tactile, and auditory means, as well as through the use of digital, smart technology.

a) be in an accessible format for the types of signage identified in Clauses 12.2.1, 12.2.2, 12.2.3, 12.2.4, 12.2.5, 12.2.6, and 12.2.7, with some exceptions.

Signs in outdoor spaces shall be provided at the start of trails and wherever trail conditions change significantly and include:

C. include alternative communication methods, i.e., an audible technology, braille booklet or similar accessible format.

A) Information signs should be placed in stairwells to identify all entry and exit points. B) Floor numbers should be displayed on each level at both the top and bottom of staircases.

Note 2: In some cases, signs that include variable messages shall display tactile elements for the permanent portion of the sign message. Note 3: Variable information shall be presented in an accessible format.

Remove note.

I will cite just one example of conflict, and how it causes issues in a somewhat circular fashion. I don’t necessarily propose a specific solution here, as I believe it should come from a consensus basis from the committee. This situation is specifically referring to outside, on a street corridor at a intersection or road crossing. A truncated dome tactile pad at a ramp letdown in Canada currently has (covering most situations) three different colours in practice. Most certainly, there are more with ‘one-offs’ that people can point to elsewhere beyond these three. The three colours that are all, generally speaking, compliant with surface contrast are yellow, safety red, and a rust/dirt red. The current draft standards do not specify a specific colour, only the contrast. However, there is a clause that suggest the colour should also correspond to the societal implications of meaning. So, is the intent of a truncated dome tactile pad a warning, or to stop before proceeding? This clause is important, as there are technical standards in Canada, in the form of the Manual of Uniform Traffic Control Devices in Canada (MUTCDC) produced by others that specify colours for those purposes. (Red means stop, yellow means warning). Hence, this document should specify what the intent is of the purpose of this device, then choose a corresponding colour. The confusion is furthered when within this standard, it is assumed that a directional wayfinding tactile pad CANNOT be yellow, to avoid confusion with a truncated dome warning tactile pad. This then applies that a truncated dome pad should be yellow, yet, much of central and eastern Canada regions use red or rust as the colour for the tactile. However, referring back to the MUTCDC, is a directional tactile indicator then not a warning? Or is it something else? Would yellow not be an appropriate colour for such a device? Irrespective, the MUTCDC specifies specific colours for our transportation system (which includes sidewalks and pathways) and should be a considered parallel standard that needs to be followed. Either way, said devices must provide specific contrast on different surface types and colours, specifically concrete (sidewalks) and asphalt (sometimes sidewalks, walking, paths, and multi-use paths). Finally, one must also consider the practical implications of what is currently being manufactured versus what could be in the future. Most manufacturers in Canada do not produce a significant variety of colours in each of the truncated dome and directional indicators that offer both the contrast and the durability for our climates. There are many many more examples like this, regarding positioning, placement, etc. that I have identified within this draft guide that will cause real problems for implementation, and the standard does not provide specificity to one to apply the standard effectively and consistently.

Statements about exactly how to measure this, the uniformity ratio, the surface area to measure, and more.

Needs to be determined; some of the items are in contrast with one another.

Please contact me at peter.truch@me.com or (778) 215-3879 to discuss all of them, and to being to identify appropriate solutions.

Please email peter.truch@me.com or call (778) 215-3879 to discuss.

These should be included.

This ensures that more members of the population have universal access to the map.

10.1.2 a.ii. colour temperature at or less than 2700K using full spectrum lamps

Add a. ensure indoor spaces are lit to a minimum of 100 lx, and not more than X b. ensure outdoor spaces are lit in compliance with Clause 10.1.5, and not more than X

10.1.5.a maintain lighting levels of 50 lx and not more than X over frequently used paths of travel, including walkways, paths of travel, stairs, and ramps, measured at the ground;

This clause should be revised and could include language about window treatments to reduce glare and harsh lighting transitions (e.g., films, Low-E coatings, reflective coatings, etc), rather than fully removing the window.

General comment – PAS 6463:2022 Design for the mind – Neurodiversity and the built environment – Guide includes many good resources about colour and pattern selection that could be referenced by this standard. Further, the 2025 National Building Code of Canada in Sentence 3.8.3.6.(17) requires that “except for facilities for persons with cognitive disabilities such as dementia, doorways leading from a public corridor or a corridor used by the public that provide access to a public area or an exit shall be provided with a door or door frame that has a readily apparent visual contrast with adjacent wall surfaces.” It may be a good idea to include some guidance on cognitive disabilities, where colour may be overwhelming or create safety concerns, in addition to a general reference to PAS 6463.

Suggest phrasing as: "Where technically feasible, avoid shared infrastructures, including cycling paths between access points to buses and public transportation, as they represent challenges for the accessibility community".

Not sure. Needs more background info.

"at the top of flights of stairs and ramps"

Remove this clause, or expand it with a technical criteria for the depth/hazard.

Delete the clause.

Should incorporate language that automatic announcements are required to have a mute button or other means to cancel playback.

This standard should reference to CSA B44, which already covers audible announcements and chime tones for elevators.

TWSI shall:

12.2.7 Parking Signs

Empowerment and independence: Wayfinding and signage in its various forms allow for autonomy and independent navigation, providing timely, accurate, and clear information in multiple formats when necessary, without the need for human assistance.

User consultation: Implementers and designers carry out consultation and user testing with user groups representing a diversity of lived disability experiences and communication methods when establishing/determining or altering the wayfinding and signage solutions. Individuals with lived experience must be meaningfully engaged throughout projects from the outset, including design, testing, implementation, and evaluation phases.

Add a word to the last sentence. Everyone in Canada has the right to interact with environments effectively, safely, and efficiently. While the standard will apply initially only to federal facilities, other jurisdictions will be encouraged to adopt this standard and develop regulations to implement it. Modified text starts here Added one word. Acceptance. Consultation, and acceptance, with and testing by persons with disabilities is an essential part of whatever is being considered.

There should be a separate section recommending standards for this new style of building and living. We have added this in our comments

Add two sentences. After designers have included this information, and considered these principles, they shall consult with an accessibility advisory panel to ensure that the information and principles are implemented to the satisfaction of this panel. In the event of a discussion about cost and difficulty of an accommodation, the Canadian legal precedent of ' reasonable accommodation and undue hardship' shall inform the decision

Add a sentence These best practices apply not only to the design of new indoor or outdoor spaces, but also to the renovation of existing spaces.

Replace this sentence with two sentences.The practice of design and renovation, , involves more than consideration for usability. It also includes the principle of accessibility, ensuring that existing barriers are removed, and no new barriers are created.

j) Awareness and education: Implementers, designers, New text starts here or any person responsible for barrier-free and accessible signage and wayfinding shall New text ends here provide ongoing public awareness and education of the purpose and intent of inclusive wayfinding and signage to ensure everyone understands their meaning and intent

This Standard: ● recognizes the equity rights of persons with disabilities Remove the following As Canadian citizens.

Add the following definition: Accessibility advisory panel A group of persons with disabilities at the federal, provincial, municipal, or facility level to test all accessibility features to ensure and verify with full authority that they are barrier-free. They will be chosen in the same way as Committee members for accessibility standards. Canada is chosen and will be involved at any stage, including design, implementation, renovation, or engagement when reports of barriers that are recurrent and important are received. They could be an accessibility advisory panel that is used for another standard. If the facility is large enough, the facility should have its own panel. If the facility is small, perhaps a group at the municipal, provincial or federal level could be used. If necessary, the Canadian litigation and precedent set in cases about reasonable accommodation and undue hardship shall inform any discussion where cost or difficulties are used as a reason not to implement accommodation.

accessible or alternate format — Information presented in braille, in large print, electronically (e.g., on removable or portable media), or in a barrier-free way compatible with adaptive technology.

Reasonable accommodation, and undue hardship This is a Canadian evolving legal concept in our courts that has created a framework or guidelines to help establish decisions about accommodations that might be costly or difficult to implement

Continuous improvement Continuous improvement is a process aimed at consistent improvement, using incremental and well-defined steps to receive feedback, evaluate, change, and continue until chosen targets are reached.

Add 10.5. User testing and approval 10.5.1 Testing body The testing body shall be either users selected by statistically significant methods, or an accessibility advisory panel, if one is available for this facility. 10.5.2 Testing Add every stage where barriers might exist, or be created, the testing body shall be asked to test all the lighting parameters, including, but not limited to, usability, luminance, glare, shadows, tone, position, color, and contrast, and report to the authorities that have jurisdiction to remediate any barriers of their findings to the satisfaction of everyone

Add the following paragraph Recent smart technology has added to wayfinding by enabling the creation of navigation cues available in accessible format on a smart device. The cues are created, using lidar, photos, GPS or beacons as landmarks, by persons or organizations interested in wayfinding. There are also technologies that recognize and interpret addresses, street signs, surroundings, paths, doorbells, doors, knobs, signage, obstacles, and give immediate , real-time feedback to the user through tactile, visual, or audible signals.

iii) in outdoor plazas, incorporate distinctive surface materials, such as tiles, at intersections or key decision points to help users identify critical areas and make informed navigation choices;

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h) have all signs tested by people who will use them to confirm they are barrier-free, accessible, usable, and clear.; All signage and its accessible equivalent shall be approved by the accessibility advisory panel , if such a panel is available in a particular facility. Users for testing shall be selected in a statistically significant way.

Add two more clauses. j. To assist persons who are lost, prominent signs and those at intersections shall have on them appropriate accessible information that identifies the location of the sign, so that when assistance is contacted, the current location can be identified. k. Every prominent sign shall have on it appropriate accessible information about the name and contact information of the authority in charge of accessibility.

Widen the use of this clause by removing “vertical” and “when installed outdoors.” c) for any sign: i) not create an obstruction within the path of travel; ii) be placed in a location that does not intrude into the path of travel; and iii) maintain at least 70% luminance contrast with its surrounding environment, including mounting elements, such as the pole.

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Change the last clause, c) include alternative communication method so that every sign is available in accessible and barrier-free format.

Remove these clauses. Note: In most outdoor settings, signs should be mounted to materials such as matte-coated metal, wood, or powder-coated aluminum posts. Retroreflective mounting is typically reserved for vehicular signs or remote locations where visibility at night is critical. d) be produced using materials that are durable and resistant to wear or vandalism (see also Clause 12.7.1); Note: Materials should be selected based on environmental conditions and anticipated public interaction. Outdoor and high-traffic areas may require UV-resistant, weatherproof, or anti-graffiti finishes and tamper-proof mounting systems. e) be applied (attached, secured, mounted, adhered) using materials that are durable and resistant to wear or vandalism (see also Clause 12.7.1);

Add the following: The text size, font, style, contrast, and color shall be suitable for those that are of median height, and in a standing position.

Replace it with one clause. g) be cane detectable when the sign is freestanding Why you think we should change it. This would be consistent with previous text, and of more general description.

Add a sentence at the end. The signage that describes the floor number shall also identify the location of the stairwell, allowing confirmation of position in difficult navigation situations, as well as information for assistance personnel.

a. Information signs shall be placed in stairwells to identify all entry and exit points. b. Floor numbers shall be displayed on each level at both the top and bottom of staircases, as well as on handrails.

Add clause G. g. Be placed in such a way that if the adjacent door is opened fully, or at high speed, then a person accessing the tactile sign shall not be in danger of being smashed by the opening door.

What we should change it to. Electronic signs are characterized by their ability to have the message easily changed by an administrator using an app, internally, using pre-programmed messages and images, such as a pedestrian walk, signal, or from some other control system, such as real-time information in an airport terminal. The actual display technology is evolving rapidly, and includes, plasma, LED, and LCD. Currently, plasma is rarely used, and LCD and LED are in a continuous race. The lighting and formation of electronic signage help increase its visibility, making it easily visible

12.11 Electronic Signage

b) be tested by people with various abilities to find the right amount of time needed, as well as other properties for usability. If users are selected, they shall be selected in a statistically significant way. If available, the accessibility advisory panel shall form part of the users who are doing the testing.

Remove this section

Add a phrase at the beginning: New text starts here: for signage that is interactive and requires input from users, New text ends here: The screen size of the unit and the size of the chassis, the accessible controls, feedback confirmation for actions like pressing buttons, and easy maintenance and repair are crucial for accessibility

12.11.4 luminance Electronic signage luminance design shall:

Remove letter, C, and notes one and two c) favor display technologies such as LED displays that economize on electricity consumption. Note 1: Factors such as the display size, the expected hours of operation, and pixel pitch are considered to help determine and lower energy consumption.

Remove the note in this part of the standard. Note: Large text is defined as having a point size of 18 points or 14 points bold and larger, while regular text is consistent with font sizes usually found in body text.

Add a sentence at the end. Floor numbering or any other signage on handrails shall only be done if accessible signage is not close to the handrail. If signage on handrails is necessary, it shall be done in such a way that it does not harm a person using the handrail while grasping it.

Add two clauses e. Every location, plan, and map shall have on it contact information for users to report missing or confusing information, or if the user became lost, what was their experience, and suggestions to changes to the map or location plan to ensure this does not happen again. f. All reports received by the authorities from users, reporting confusing maps or location plans or becoming lost, shall be shared with the accessible advisory panel, if such a panel is part of the facility.

Section 13 is about maps, but section 13.10 introduces location plans. The difference should be clarified, perhaps in the definitions. Or, perhaps, this section should have the words, location, plans, or maps, whenever one or the other is referenced.