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Does the standard not also apply to federally regulated industries?

The standard is silent on the concept of digital maps. They present a different use case than physical and tactile maps, and somewhat different accessibility considerations apply.

There's another aspect to "safe" that might be relevant and important: That I, as a person with a disability, am not in harm's way when accessing the information in the signage. For example - I'm not obstructing pedestrian traffic in trying to read or otherwise access the information in the signage.

It is implicit that "signage" doesn't only refer to directional, location and navigation signage. However, this is what people might gravitate to when thinking about signage - directional signage to rooms or wings in a building, a room number next to a door, etc. As a result, all sorts of other signage might be in scope, but inadvertently excluded - for example, signage in a science lab or a work setting, which might "look and feel" different from the kind of signage we tend to think about. If this is really in scope, I recommend calling it out as such. If it's not in scope, I recommend saying so.

See my previous comment in Clause 6.1 Are digital maps in scope or out of scope? If out of scope, they need to be added here.

As with my comment from Clause 6.1 - the standard is silent on the inclusion of certain kinds of signage, such as you would find in a working science lab or other kind of working environment. If this is out of scope, these changes are not necessary, but it should be made explicit that this is the case. The language recommended assumes that it is in scope, but that will be up to the technical committee.

Natural lighting can be variable, depending on the presence of windows, the angle of the sun, the time of day, the time of year, and even inclement weather conditions. The interaction between natural and artificial lighting indoors, and the variability of natural light outdoors, is often not considered when contemplating lighting requirements. It may be important in the introductory text of Clause 10.1 to allude to this issue, and note that the requirements provide a baseline that shall be adhered to at all times of day and year, where applicable.

This section alludes to digital maps, include those incorporated into self-service kiosk-type devices. Those devices should be compliant with CSA/ASC B651.2.

If digital maps are indeed in scope, there are a set of requirements in between the accessibility of digital maps and their usability which get at whether a user with disabilities accesses and perceives equivalent information - that is, that they get the same information outcome as a person without disabilities. This is the aspect of accessibility and usability that often gets omitted from consideration. Attached to this note is a submission from Brandon Biggs, CEO of XR Navigation, with some proposed language to address this gap, which the committee can consider.

If looking to create a standard that will be followed, "encouraged" is noncommittal. The same as "suggestion". In general people/businesses won't take the initiative to change existing structures/business principles if they don't have to. If the standard is required, then it's a structure in place to follow. Rules of procedure

Both terms can mean obligation but "Shall" can more commonly be considered as a suggestion. It's more subjective in its meaning interpretation. "Must" is more definitive.

The language should be changed because is assumes able-centric societal structures are preferable. Difference is equated with deviance and deficit. A policy that prioritizes ablism will not work and then we will be puzzled by why it doesn't work. The paradigm has to change - inclusivity cannot be created with exclusive language. Please feel free to reach out for a conversation - but the real experts are above.

It shows that government is not connected to the sector or to current research. Please see the NB Early Learning Curriculum Framework as an exemplar. It is one of the best in the world and the scholars and Early Childhood Educators who created it are some of the best in the world. https://www2.gnb.ca/content/gnb/en/departments/education/elcc/content/curriculum/curriculum_framework.html

ibid

An inclusion policy that states exclusions within the sector it aims to support is an inherent contradiction.

It is difficult to address Early Learning and Child Care with engaging with educators, families and children themselves.

Please add a way to simply upload a document for overall comments. I have dyslexia and print materials and then compile. Going through and entering one by one is difficult., I simply upload a doc on the first opportunity but it would be amazing if there was a button to upload in a way that does not attach to one section. Thank you for including a space between bullets (this helps enormously in reading). I know it feels like you are saving space by using many acronyms but I spent so much time going back and forth trying to sort out all the acronyms in this draft.

Often this comes up for events or for guests attending meetings at offices. There is a need to communicate this to attendees or to co-workers. It might be worthwhile to have direction for temporary or situational requirements versus signage for offices where an employee is regularly on location. I have seen many different ways that this is handled, and at times successfully keeps attendees as safe as possible, and at times, methods are confusing. I think that sometimes, communications teams think this is a design issue and try to make the signs meet branding and look visually attractive, and second, I think sometimes, folks creating these signs think that they need to make apologies about the accommodation. Clear direction would help avoid these issues. For example, I have seen signs created that take weeks of approvals and basically tell a long story on letter sign posters in complicated designs: many times, inaccessible for people with dyslexia and astigmatism, and so long that no one even notices that there is important information that all folks need to know. I have also seen signs that use clear image with the red circle and slash across an image and/or words. My suggestion is to create a standard that uses other established norms that clearly guides businesses on how to keep folks safe. Could fall under temporary signs, also falls under Quality of Information. **Note: that I am affected by this comment, and I know many folks who are affected by airborne allergies or severe scent sensitivities and allergies. I am happy to meet and discuss as I have experience personally, and as an event coordinator on occasion. I also think there is a need for education on allergies and sensitivities but perhaps out of the scope of this (except that many people attempting to accommodate and create signage do not understand what is needed).

Not specifying this is an issue, especially for folks with dyslexia, intellectual and developmental disabilities, and for those who use Apps to help read information (e.g., there are Apps that the user can snap a photo, and it translates but often won’t work if language separation is not obvious).

Note that all contrast is not equal. Folks who like to use dark mode on their technology think this is always the best choice, but this is literally not readable for many folks with dyslexia and those with astigmatism. As well, large blocks of text, and print quality can further affect readability.

Please provide guidance on consistent pictograms, with a library of images that can be added to. Examples: peanuts, perfume and scents, oranges, fish. Certain allergies and sensitivities are on the rise and change (when my own airborne allergy to oranges and all-round citrus fruit began, it was rare. I recently spoke with a teacher who has 5 students in her school alone that have this emerging allergy). Clear pictograms and guidance is important for the safety of folks with allergies.

It will be easier for a reader to comply with relevant clauses if the ASC 2.9. standard specifies what they are - don't make the reader guess at the intent of the committee.

Clause 10.1.1. seems redundant when it is the only clause under 10.1. Also, it's not immediately clear how 10.1. is distinct from 10.1.1., since Clause 10.1 doesn't specify any substantive requirements. ** if there are specific requirements under 10.1 to follow from CSA/ASC B651, then clarifying what these are will help distinguish 10.1 from 10.1.1.

14 m is a lot easier to visualize and plan for than 14,000 mm. Also, I don't think you need mm-level precision for a 14 m length - a 13,999 mm-long pick-up zone will likely serve the same function without any loss of performance.

keypads, card readers and electronic locking doors serve different functions from motion sensors and security cameras. It's not clear why they are handled together - a motion sensor without a door lock isn't likely to facilitate supervision and security all that well.

it's not clear how this clause is relevant to accessibility - it seems like a good idea for all cihldcare centres (and honestly any building), but I'm not sure why it's listed here as a specific accessibility feature. I think the explanatory Note 2 does a good job of simply flagging that multiple features are useful to support people with different disabilities.

It may not be necessary to revise; I'm just flagging that I've seen multiple different ground level illumination values across different draft standards by ASC in the last 4 months, and it might be useful to ensure they are aligned.

CAN-ASC 2.3 has not yet been published and doesn't really add to the clause. The key is to comply with the 950 mm dimension, whether CAN-ASC 2.3 is published before this standard or not.

as written, clause b would prohibit a handrail that is more than 30 cm long, potentially some signage, and other essential features for accessibility and safety during egress.

As written, the clause would exclude some important features in buildings, such as water fountains or seating.

Clause 4.2 of CSA/ASC B651:23 prescribes different numbers from 30% (some below, some above, depending on which table one is looking at and what design feature is being addressed). It's not clear what number a designer is supposed to comply with and in which context, since CSA B651 prescribes different numbers for different contexts whereas the 30% number in clause e does not seem to have further specificity in its application.

This requirement is at odds with Clause 12.4.6.(b) (multi-purpose rooms), which can function as quiet rooms but (according to clause 12.4.6(b) need to be designed for a minimum of 2 people. Also, if the room is designed to include multiple seating options (per note 3), then there will necessarily be seating space inside the room with seating for more than 2 people.

CSA/ASC B651 Clause 4.2 prescribes a range of numbers for luminance contrast that depend on the context (both below and above 30%). It's not clear what a reader is supposed to do to comply with this requirement.

it's not clear why clause a and clause c have different upper-boundary heights when the function of the tables is the same (accommodate use by adults).

all of the other analogous clauses direct the reader back to the dimensions for the stationary position, and it would be really helpful to do the same here too.

it will be difficult to affix many of the materials described in clause a (e.g., sand and water). Also, furniture like tables are not supposed to be fixed in order to comply with clause 12.4.6(h) (requiring furniture to be moveable). I suspect the committee's intent is regarding items like tablets - either way, it will help to clarify.

As written, an accessible washroom intended for children and adults would only need to comply with clause 6.2.6.1(a) of CSA/ASC B651:23, but would not need to comply with any other accessibility features (e.g., requirement to provide grab bars and a power operated door). I suspect this wasn't the intent of the committee. It would seem to make sense to instead position clause (b) as a set of modifications to clause (a) when the washroom is also intended to address the needs of children.

Clause b reads like the most "flexible" option, but a 250 to 280 mm toilet sounds incredibly low for an adult. This would not be accessible for an adult who is transferring from a wheelchair or who has compromised lower limb balance or strength (especially if the requirement for a grab bar beside the toilet is not re-introduced per my previous comment).

It's not clear which portion of the toilet the requirement applies to. I assume it is the top of the seat (since "top of the tank" would put the seat at or below the floor height), but it would be really helpful to clarify.

a 150 mm-high privacy screen or door (measured from the floor to the top of the screen or door) would be a tripping hazard + not very useful for the privacy function + make it physically impossible to install the door hardware at an accessible height.

presumably these features are useful for adults too, and should be provided in all washrooms presented as accessible

it will be easier for a reader to comply with the standard if the requirements for clear floor space are handled together. Since clause (j) already prescribes clear floor space, it's not apparent why clause (d) is also necessary. If it is important to keep clause (d), then consider specifying which stationary position clear space (clause 12.1.2 (a) or (b)) a reader should comply with.

clause 12.1.2 prescribes 2 sets of dimensions. It will help if the relevant one is prescribed for a reader.

clause 12.6.1 doesn't prescribe any form of stationary position clear space, at least in the way that it is currently written.

kitchens intended for public use usually have doors for safety reasons. I can see why they are discouraged in home kitchens, but I think they provide a necessary barrier to entry to kitchens in commercial spaces. (It goes without saying that doors would need to be designed for adult accessibility in this context).

clause 4.2 of CSA/ASC B651 prescribes different nubmers from 30%.

Assuming that the committee did intend for the accessible children's/adult's toilets to have grab bars (per CSA B651 clauses 6.2 and 6.3), then the height needs to be modified to align with the lower toilet. A horizontal grab bar installed at a CSA-compliant height (750 to 850 mm high) will not be usable with a 250 mm-high toilet - it needs to be lower.

In academic publishing, authors typically publish on behalf of themselves, not their institution; the citation format should reflect this. This is especially important for publications that involve authors from multiple institutions.

I can see that details of the codes are behind a paywall. What is the point of asking for feedback if the details cannot be accessed without paying for them?

If those reviewing cannot access these clauses and codes, then we don't have context to provide feedback!

As currently written, the standard risks allowing designs that are technically compliant but not functionally accessible. Loose-fill materials such as engineered wood fibre may meet definitions like “firm and stable” when freshly installed, but in practice they: Shift and displace, limiting independent mobility Require frequent maintenance to remain usable Create resistance that prevents access for many wheelchair and mobility aid users Additionally, requirements from CSA Z614—such as containment borders—introduce physical barriers that directly conflict with accessible design goals. This creates a disconnect between safety compliance and accessibility outcomes. Focusing primarily on accessible routes to the play area, without requiring accessible surfacing within it, can result in children being able to reach a playground but not meaningfully participate in it. To achieve the intent of an accessible childcare environment, the standard must ensure equitable, independent, and consistent access to play spaces. Strengthening the requirements around surfacing will help bridge the gap between compliance and real-world inclusion, ensuring children of all abilities can fully engage in play alongside their peers.

Variation in available seating options is important for kids with different mobility and/or sensory needs.

Gallaudet University is a good university for guidelines on creating Deaf spaces because this university delivers all their programming in ASL for Deaf students.

This may be covered in OBC or the CCEYA, but gates must be "secure" but also usable, so I see there being conflict between those two things.

It includes built environment features impacting cognitive and emotional experiences.

Harmonization and consistency.

It is important for the people who build and work inside of childcare centres to understand the function of accessible features or elements so that they do not cut corners, misuse the space, or miss opportunities for expanding accessibility.

Accessibility is limited if there is only enough space for one person with a mobility device to move through a space at a time. It is not realistic.

There is a need for childcare for older children into the elementary years and beyond.

Children with complex health issues requiring health equipment or medical support also need accessible childcare centres and have particular needs.

Surfaces should be accessible for all.

Children are especially sensitive to light and this can greatly affect accessibility. Specifying only "LED fixtures" is too broad to ensure accessibility in lighting.

High volume or vibration levels and sudden loud sounds can cause accessibility barriers for children and staff with sensory sensitivities.

Many childcare services include cooking and food prep activities with children so excluding that possibility may create a gap in accessibility guidance/requirements.

Lighting levels and types are important for accessibility

We are over-lighting because we can, not because we should.

Spaces may be designed to be quiet but maintenance may be needed to ensure they remain quiet over time. Signage can help users enforce the exclusion of loud play in quiet spaces.

This is an important consideration for accessibility

Alternatives for emergency alarms for Deaf or hard-of-hearing people is often flashing lights which can be dangerous for individuals with epilepsy

Adjusting lighting through controls is not the only way to affect the visible sensory environment. Alternatives should also be considered.

Young children with disabilities often face significant barriers to movement in early childhood education (ECE) settings, resulting in fewer opportunities for engaging in active play. Research suggests that without targeted efforts, universal programs alone are insufficient to meet the needs of children with disabilities. Proportionate universalism in childcare provides universal opportunities for all children, while offering tailored support for children with disabilities to bridge activity gaps. This approach combines universal policies (e.g., active, accessible environments) with targeted strategies (e.g., individual activity modifications) to ensure equitable inclusion, addressing the disproportionately low activity levels of disabled young children.

The limitations acknowledged include the need for staff training as a priority. Based on our lab’s work surrounding supporting training and development for ECEs to engage children of all abilities in active play, we agree that this is a crucial priority and should be maintained in the final version of the standard.

When multi-purpose spaces do not exist in childcare settings, and in general, classrooms can be used for a wide variety of activities in childcare, including for active play. Moreover, in our experience working with childcare centres across Canada, most childcare centres don't have multi-purpose rooms.

This is one way that ECEs can use a proportionate universalism approach to support integration of children with all abilities in the classroom. Moreover, this could be positioned in a way to facilitate active play in these rooms, as active play is critical to children’s overall wellbeing and development in childcare. Specifically, the literature indicates that more space leads to more opportunities for physical activity.

Please see above.

Please see above.

508 Maturity Concept: Defined roles, responsibilities, and oversight for accessibility. Procurement Application: Assign accountability for accessibility requirements within procurement processes Require named roles responsible for accessibility compliance on both buyer and vendor sides Include accessibility reporting obligations tied to contract management Gap in current draft: No clear accountability model for accessibility outcomes.

Section 10 is the foundation for the rest of the standard. If it only says accessibility must be considered, implementation will vary widely and procurement teams will not have enough direction to apply it consistently. Structured ACRs support comparable vendor disclosure at the RFP stage. Measurable acceptance criteria and remediation roadmaps make accessibility enforceable after award. Supplier capability assessment helps avoid treating accessibility as a one-time product claim rather than an ongoing delivery responsibility.

Accessible procurement cannot rely on inaccessible document practices. PDFs and proprietary Word formats often create barriers for screen reader users, keyboard users, people using reflow or magnification, people with cognitive disabilities, and people using mobile or low-bandwidth environments. Using accessible open formats by default improves accessibility, interoperability, long-term preservation, and public-sector control over procurement information. It also reduces the need for later remediation. This would make Section 11 stronger by treating document format and digital workflow design as accessibility requirements, not just publication details.

Planning is where accessibility either becomes enforceable or is lost. If accessibility requirements are not defined in a structured, testable way at this stage, they cannot be evaluated consistently or enforced later. Specifying evaluation methods such as WCAG-EM ensures that accessibility is verifiable, not just described. Requiring structured ACRs ensures comparable vendor disclosure. Including vendor capability assessment ensures accessibility is treated as an ongoing delivery responsibility, not a one-time claim. This would make Section 12 actionable and align it with established procurement and accessibility maturity practices.

Accessibility is not achieved at contract award. It must be verified, enforced, and maintained throughout delivery. Without defined acceptance criteria, structured validation methods, and enforceable remediation requirements, accessibility issues are often identified but not resolved. Relying on general confirmation creates inconsistency and weak accountability. Adding these elements ensures that accessibility becomes a measurable and enforceable contract obligation rather than a best-effort expectation.

Referencing EN 301 549 is not sufficient if it is not tied to evaluation and enforcement. Without structured ACRs, vendors interpret EN 301 549 inconsistently, making comparison difficult. Without defined evaluation criteria, accessibility becomes subjective. Without validation, accessibility claims are not verified before contract award. Using EN 301 549 as the basis for structured disclosure, evaluation, and validation ensures that accessibility requirements are applied consistently and can be enforced throughout procurement. This would make Section 13 aligned with established accessibility procurement practices and ensure that EN 301 549 is used as an operational standard

Training is the mechanism that determines whether this standard will be implemented in practice. General awareness training does not change procurement outcomes. Procurement professionals need practical skills to define, evaluate, and enforce accessibility requirements. DITAP demonstrates that accessibility training is most effective when embedded into procurement workflows and real-world scenarios. Aligning with this approach ensures that accessibility becomes part of standard procurement practice rather than a separate or optional consideration. Strengthening Section 15 in this way would ensure that organizations build the capability required to implement the standard consistently and effectively.

The bibliography shapes how organizations interpret and implement the standard. Including these references would: provide procurement teams with practical methods for evaluation and validation support consistent vendor disclosure and comparison align the standard with established international practices reinforce the need for training and capability development Without these references, the standard risks being interpreted as high-level guidance rather than a framework supported by proven implementation approaches.