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To learn more about proportionate universalism in early childhood settings, you can read our lab’s recent publication here: https://journal.fi/jecer/article/view/156649. In section 6, consider adding a section specific to the promotion of accessible physical activity or active play. This could outline ways in which a childcare centre should thoughtfully incorporate opportunities for children of all abilities to engage in play opportunities.

N/A. We are currently developing an e-learning module on inclusive activity play and physical activity opportunities that could support your workforce.

Classrooms should be considered when discussing the need to flexibly support children’s participation and engagement in various activities. Increasing the minimum requirements for classrooms or detailing that those without additional spaces should have additional accommodations/features in their classrooms is needed. Relatedly, Section 12.4.6 states that multi-purpose rooms “may function as a sensory room, quiet room, play area, classroom, therapy room, meeting room, or dining area,” which also suggests that a play area is presented as an optional function. The wording could potentially be strengthened in Section 12.4 or 12.4.1 to indicate that classrooms must be conducive to play.

This might look similar to point H in 12.4.6 – “where provided, furniture and equipment shall be lightweight and movable (e.g., on locking casters) for easy reconfiguration to support different uses.”

A point could be added to emphasize that this may include classroom spaces. Moreover, play at different intensities (e.g., light and moderate-to-vigorous physical activity) is crucial to children’s wellbeing and development. Language should be added that play areas should support meaningful play engagement of all abilities at various intensities (i.e., all play opportunities are available for all). Section 12.5 could also clarify that the requirements for indoor play areas also apply to classrooms as having a classroom is a requirement for all centres. Another point to consider is whether the language could be refined to make clear that indoor play areas should also be accessible to ECEs with accessibility requirements, so they are able to support and participate in educator-led play. As the primary daytime role models of children in their care, the participation of ECEs in active play opportunities is positively associated with children’s physical activity levels.

Outdoor play can significantly impact a child’s physical activity levels and overall wellbeing. The literature suggests that parents of young children with disabilities have reported concerns that children with disabilities are not taken outside for play opportunities. While minimum accessibility standards may support this during good weather, as childcare centres in Canada are encouraged to bring children out in all weather, this should include children with disabilities. Our lab has previously engaged in work to help audit existing playgrounds for inclusion, which may be a helpful addition: https://doi.org/10.3389/fresc.2023.1102490 Moreover, in addition to the outdoor play space being accessible, the equipment (both loose and fixed) should also be accessible. This could include, for example, providing opportunities for safe ground-based play and supportive seating should be included to promote accessible playscapes of all children, at all heights. This is crucial as research consistently demonstrates that portable play opportunities outdoors are more supportive of movement than fixed equipment. As was indicated in feedback provided in 12.5, language could be refined to make clear that outdoor play areas should also be accessible to ECEs with accessibility requirements, so they are able to support and participate in educator-led play.

Because it doesn't force vendors to do anything.

Add requirements that procurement policies and procedures shall: Require structured Accessibility Conformance Reports at the solicitation/RFP stage, preferably using OpenACR or an equivalent structured ACR format: https://acreditor.section508.gov/⁠� Require accessibility requirements to include measurable acceptance criteria, including the applicable standard, scope, testing method, responsible party, and evidence required for acceptance. Require remediation roadmaps to include specific barriers, affected users, applicable criteria, milestones, deadlines, interim mitigations, and reporting obligations. Require evaluation of both product conformance and supplier capability, including accessibility expertise, testing processes, QA practices, and remediation workflows. Align procurement governance with maturity-based models such as the U.S. Section 508 Assessment approach, which addresses governance, acquisition, testing, monitoring, and reporting: https://www.section508.gov/manage/section-508-assessment/2025/reading/⁠�

Add requirements that procurement information, websites, applications, forms, and supporting documents shall: Be provided in accessible, structured, open formats by default, such as HTML for web-based content. Avoid PDF and proprietary editable document formats as the primary format unless there is a clear operational need. Require justification when PDF or proprietary formats are used as the primary format. Require any PDF or proprietary document that is used to comply with applicable accessibility requirements and be validated before publication or distribution. Ensure that procurement platforms, forms, notices, amendments, debriefs, and document repositories support accessible participation by bidders, including disabled-owned businesses and businesses employing people with disabilities. Include accessible metadata, headings, structure, labels, error identification, and navigation for all procurement documents and digital workflows.

Add requirements that planning activities shall: Define accessibility requirements using recognized standards and methodologies, including: reference to the latest WAI WCAG recommendation definition of scope, components, and user journeys to be evaluated Require that accessibility evaluation methods be specified during planning, including: use of WCAG Evaluation Methodology (WCAG-EM) for conformance validation: https://www.w3.org/WAI/test-evaluate/conformance/wcag-em/⁠� identification of sampling approach, evaluation criteria, and expected evidence Require structured vendor disclosure at the solicitation stage, including Accessibility Conformance Reports (ACRs), preferably using OpenACR: https://acreditor.section508.gov/⁠� Require planning for evaluation of vendor capability, including: accessibility expertise and roles testing and QA processes remediation practices and timelines Require that testing requirements defined in planning are: included in solicitation documents tied to evaluation criteria tied to acceptance criteria in resulting contracts Require that evaluation panels include accessibility expertise and lived experience, and that evaluation timeframes account for accessibility review. Align procurement planning with maturity-based approaches such as the Section 508 Assessment Framework, which integrates accessibility into acquisition planning, testing, and governance: https://www.section508.gov/manage/section-508-assessment/2025/reading/⁠�

Add requirements that contract management activities shall: Define accessibility acceptance criteria tied to recognized standards (e.g., latest WCAG recommendation), including: scope of evaluation success criteria required evidence for acceptance Require formal validation of deliverables using a structured methodology such as WCAG-EM: https://www.w3.org/WAI/test-evaluate/conformance/wcag-em/⁠� Require that validation results are: documented reviewable retained as part of the contract record Require enforceable remediation obligations, including: defined timelines for fixing accessibility defects severity classification for issues interim accommodations where immediate fixes are not possible Require ongoing monitoring of accessibility throughout the contract lifecycle, including: integration with development and QA processes tracking and reporting of accessibility issues periodic reassessment of accessibility Require that responsibility for accessibility outcomes is clearly assigned, including: vendor responsibility for delivery and remediation client responsibility for validation and acceptance Align contract management practices with maturity-based approaches such as the Section 508 Assessment Framework, including continuous monitoring, reporting, and governance: https://www.section508.gov/manage/section-508-assessment/2025/reading/⁠�

Add requirements that bidding and contract award activities shall: Require bidders to submit structured Accessibility Conformance Reports (ACRs) aligned with EN 301 549 requirements, preferably using a standardized format such as OpenACR: https://acreditor.section508.gov/⁠� Require that accessibility claims referencing EN 301 549: clearly identify applicable clauses and scope distinguish between fully supported, partially supported, and not supported criteria include known limitations and planned remediation Require that evaluation criteria explicitly assess conformance to EN 301 549, including: mapping of requirements to evaluation criteria minimum acceptable conformance thresholds treatment of non-conformance Require evaluation of vendor capability to meet and maintain EN 301 549 conformance, including: accessibility expertise testing and QA processes remediation plans and timelines Require that demonstrations, proofs of concept, or testing during evaluation include validation of accessibility claims against EN 301 549 criteria. Require that accessibility requirements tied to EN 301 549 are carried forward into the contract, including: acceptance criteria validation requirements remediation obligations Ensure that solicitation timelines account for the additional effort required to prepare accessible bids and supporting documentation.

Revise training requirements to ensure that training shall include practical, role-based procurement capabilities, including: How to define accessibility requirements in procurement documents, including: use of the latest WAI WCAG recommendation translating user needs into testable acceptance criteria How to evaluate vendor accessibility submissions, including: interpreting Accessibility Conformance Reports (ACRs), including structured formats such as OpenACR: https://acreditor.section508.gov/⁠� assessing both product conformance and vendor capability How to validate accessibility of deliverables using structured methodologies such as WCAG-EM: https://www.w3.org/WAI/test-evaluate/conformance/wcag-em/⁠� How to integrate accessibility into procurement lifecycle activities, including: planning solicitation evaluation contract management How to enforce accessibility requirements through contracts, including: defining acceptance criteria managing remediation obligations monitoring compliance over time How to apply accessibility within digital procurement tools, documentation formats, and workflows. Align training with established procurement training models such as the Digital IT Acquisition Professional (DITAP) curriculum, which embeds accessibility into real procurement scenarios and decision-making processes: https://github.com/usds/ditap-curriculum-update⁠�

Add references to the following resources: W3C WCAG Evaluation Methodology (WCAG-EM), which provides a structured approach to accessibility evaluation: https://www.w3.org/WAI/test-evaluate/conformance/wcag-em/⁠� OpenACR and structured Accessibility Conformance Report approaches, which support consistent vendor disclosure: https://acreditor.section508.gov/⁠� U.S. Section 508 Program Assessment Framework, which provides a maturity model for governance, acquisition, testing, and monitoring: https://www.section508.gov/manage/section-508-assessment/2025/reading/⁠� Digital IT Acquisition Professional (DITAP) curriculum, which demonstrates how accessibility can be integrated into procurement training and workflows: https://github.com/usds/ditap-curriculum-update⁠�

a.iii. ensure that the bidders commit to remediating their proposed solution seeking to reach full conformance to the EN 301 549.

ensuring that the ICT equipment (video equipment, microphones, controls to operate the equipment, etc) are at an accessible location

v. use the mandatory justification for excluding accessibility set out in Clause 10.1.4 with extreme caution. Always try to work towards conformance to the En 301 549

d. the purchase of what works for the individual is paramount and consideration of whether the En 301 549 applies, is not applicable.

accessibility conformance testing.

Paths of travel that do not form part of the emergency path of travel shall comply with clause 5 of CSA/ASC B651:23 and shall include multi-sensory wayfinding supports, including tactile walking surface indicators, tactile and high contrast stair and curb edges, auditory cues, and, where appropriate, digital navigation supports (e.g., accessible navigation technologies).

Signage — Information provided in the form of visual and tactile communication that incorporates one or more of the following elements: a) alphanumeric characters; b) pictograms; c) illustrations (plans, etc.); or d) braille; e) and shall include both tactile and braille elements as mandatory components for permanent signage, with large print and high contrast, consistent placement, height, and formatting requirements.

Accessible entry systems including but not limited to keypads and intercoms shall comply with clause 5.7.4.3 of CSA/ASC B651:23 and shall provide non-visual access, including audible feedback, speech output, and tactile controls, ensuring full operability by individuals who are blind or partially sighted.

Clear, large print and high-contrast signage, simple visuals, universally recognizable symbols as recommended in CSA/ASC B651:23 - Accessible Design for the Built Environment, as well as tactile, auditory, and digital navigation supports, and predictable layouts aid navigation for individuals with visual or cognitive disabilities.

Touchscreen only controls shall not be used, and elevator buttons must meet CSA B44.1:25/ASME A17.5-2025 appendix E requirements for tactile features including raised characters and Braille, and shall also include audible floor announcements and audible control feedback.

Bidders are now all "offerors". Bids are Offers Agreements are Standing Offers or Contracts. Tenders are now all solicitations

Frame as aspirational

frame as aspirational.

remove this entirely

Business Owners

Committee must decide if this is a "should" or a "shall".

Committee to decide if this is a "should" or a "shall".

Remove this section or consider rewriting.

Possibly remove

Consider changing the word "must" to something like "should".

Consider removing the quotation marks.

"Shall/should/may" phrase needs to be added.

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No comment

No comment.

Prioritizing accessibility mitigates...play and learn together with appropriate support.

No comment.

No comment.

Child size change table

No comment.

No comment.

No comment.

No comment.

Consider CSA/ASC B651.2:23

Add bullets h-m from page 50

No comment.

Change maximum to more than two or remove max all together.

Remove.

No comment.

Lower the space requirements

Add bullet B from 12.5.2.2 in Note 1

Lessen the requirement.

Add bullet B from 12.5.2.2 in Note 1

No comment.

No comment.

Remove

Remove.

Remove/adjust

Suggest in adult washrooms only

Remove adjustable height toilets

Do not require the need for adjustable change table

Do not require the need for adjustable change table or storage system.

No comment

Add safety measures for children or remove.

Consider who the sink is for?

Remove

Keep responsibility more broad

Reconsider this scope for inclusion, by providing clarity on which centres are mandated to be accessible, and by encouraging more centres to embrace accessibility.

Consider changing bullet point d) to say "braille and raised characters"

Consider if CSA B651:23 or CAN-ASC 2.3 should be referenced here, and why CAN-ASC 2.3 is not the primary reference for this Standard.

Instead of creating sub-sections on specific aspects of parking and referencing specific sub-clauses of CSA B651, consider simply saying: "10.2 Parking Accessible parking spaces, connected accessible routes, parking signage and payment machines shall comply with Clause 9 of CSA/ASC B651:23." If there are exceptions or modifications to the clause, those can also be pointed out here.

Consider referencing Clause 9.3 from CSA B651 and only pointing out the differences.

Consider changing the language in bullet point a) to say: "be adjacent to the accessible route;..."

Change the language in bullet point b) to say: "provide a parallel access aisle at street level that is connected to the accessible route and is a minimum of 1,500 mm wide and 14,000 mm long to accommodate two vehicles;..."

Consider changing the language in bullet point e) to also mention the height clearance along the vehicular route from site entrance and to be identified with signage indicating clearance height, as noted in CSA B651 Clause 9.3.2.

Consider adding another safety/security requirement - protect and separate pedestrian paths adjacent to a vehicular route by installing bollards, as per CSA/ASC B651:23 Clause 8.3.9.

Consider adding another requirement for adequate colour contrast. Can refer to Clause 5.2.10 of CSA/ASC B651:23 for guidance on glazed panels of a door, or refer to Section 5.5 of CAN-ASC-2.3.

Consider adding this as a requirement or note: "Common areas should incorporate technology and assistive features to enhance accessibility. This includes, but is not limited to, assistive listening devices (e.g., hearing loops, FM systems, or other wireless technology) for children who are hard of hearing, as well as other forms of assistive technology (e.g., AAC devices, tactile output devices, adaptive switches). Voice-controlled or touchless controls for lighting, temperature, and sound adjustments should also be considered to accommodate diverse needs."

Consider clarifying in an explanatory note why a sensory room is not required (and not on this list), and if it is a space that is recommended to have.

Consider also mentioning the need for chairs with and without armrests.

Consider providing an explanatory note to clarify what a "safety bed and chair" are.

Please provide clarity on this statement, and which situations to consider. Also, please consider always requiring some variety in seating to accommodate different users of the space.

Please expand this bullet point, or add another bullet point, to require different seating options, with and without armrests. Also clarify the requirement the previous bullet point that requires furniture with wheels for easy reconfiguration, and require some chairs without wheels.

Consider referencing ASC 2.4 Clause 10.4 for additional guidance on colour patterns.

Please provide clarity on this statement, and which situations to consider. Also, please consider always requiring some variety in seating to accommodate different users of the space.

Consider changing the title to "Child change tables".

Consider including additional considerations as noted in CSA/ASC B651:23 Clause 4.7, as well as operating controls and power outlets to be in easy reach as noted in CSA/ASC B651:23 Clause 4.3.

Consider reviewing and rephrasing to also mention that in addition to providing the appropriate goods and services, at minimum the space should be designed with Universal Design principles to remove potential barriers and provide flexible options.