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Displaying 631 - 640 of 808

Individual 65355's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1778782026242_744
Heading id
12.4.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add two notes at the end after note 5.
What should we change it to?
Note 6. As musical instruments are sometimes connected to power outlets, or to each other with cables or wires, designers and facility managers must ensure that facilities and protective devices are easily available and installable such that these wires, cables, and connections are not a trip hazard, nor do they intrude on the path of travel, becoming trip hazards for persons with low or no vision or other disabilities that distract a user from considering items on the floor. Note 7. As musical instruments sometimes have batteries, the designer or facility manager must ensure that there are adequate and safe facilities for storing spare batteries, and recycling used batteries. For those instruments with rechargeable lithium, ion batteries, designers and facility managers must ensure that there are adequate places to recharge these devices with no heat buildup, and if possible, monitoring of the adjacent temperature in the recharging area.
Why should we change it?
Electrical cords and wires trailing on the floor from one device to another are a trip hazard, as well as being an electrical hazard if they are tripped on, and quickly pulled out of their socket. For this reason, they must be designed and installed and used in such a way that tripping on them or pulling them out of their sockets is not possible. Batteries are a known risk, given their chemical content, as well as their propensity to overheat when being charged. For this reason, facilities must ensure that neither of these conditions can happen.
Heading text
12.4.3 Music rooms
Heading number portion
12.4.3
Item id
1778782237728_875
Heading id
s11
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add a section about stroller parking.
What should we change it to?
12.10. Stroller parking It is beyond my expertise to create a clause about stroller parking, but I think it should include: - the place selected is on the emergency egress path of travel -there is adequate space for entrance and exit given the abilities and disabilities of users - there should be security cameras to enable return of strollers that are mistakenly taken, given the abilities and disabilities of users - the area is designed in such a way that persons with low or no vision can easily identify where their stroller is parked, and can easily locate their particular spot —there is water drainage in the area in case the stroller is dripping with rain creating a trip hazard - the floor surfaces are easily maintained from the outside conditions, such as rain and snow, that the strollers will bring in.
Why should we change it?
A childcare facility is a magnet for strollers, both for those that attend the facility, and siblings that are brought along. Users with disabilities may be less aware than they should be of these areas, posing a trip and fall hazard. For this reason, attention must be paid to the place where they are parked.
Heading text
12. Interior layout and circulation
Heading number portion
12.
Item id
1778782348716_712
Heading id
14.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note 2: When purchasing goods and services, accessibility specifications should be carefully considered. The operational requirements should consider accessibility for both the staff who operate the goods or services and the individuals who will benefit from them. Since accessibility needs vary on a case-by-case basis, specifications cannot be assumed. It is essential to evaluate the specific needs of the individuals who will operate and benefit from the goods or services, identifying requirements that are both accessible and practical for them. Selecting accessible technologies that accommodate multiple accessibility needs is often the most effective approach.
What should we change it to?
Move this note to its own section, section 19, and call that section, procurement.
Why should we change it?
This is a very important note, but I think that it belongs in its own section. It concerns procurement, a general specifications and not the subject covered in section 14.
Heading text
14.1 Accessible staff workspaces
Heading number portion
14.1
Item id
1778782530459_93
Heading id
s16
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
17. Wayfinding and signage Wayfinding and signage elements shall comply with CAN-ASC-2.4 or clauses 4.4.5 and 4.6 of CSA/ASC B651:23. Note: Consider incorporating multi-sensory wayfinding supports (e.g., auditory cues, textured surfaces, or scent markers) to enhance navigation for children with visual or cognitive disabilities.
What should we change it to?
Accessibility Standards Canada recently had a public review of a draft standard on wayfinding and signage. There were many good points in that draft standard that should be adapted to the childcare Standard
Why should we change it?
The timeline of this childcare standard, going to public review and then finalized, and the way finding and signage currently in progress are pretty close to each other, and so I feel most appropriate, and for harmonization purposes, to ensure that the appropriate clauses from the way finding standard be included or referenced in the childcare standard.
Heading text
17. Wayfinding and signage
Heading number portion
17.
Item id
1778782693003_7
Heading id
s18.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
18.2. Laundry areas Laundry areas, where provided, shall: a) be served by an accessible path of travel that complies with Clause 12.1.1; b) be served with a 2,100 mm turning diameter clear space; and c) contain both a washing machine and dryer that: i) are installed side by side and not stacked; ii) have doors that open away from each other; iii) have operating controls that comply with Clause 15.1; and iv) have a stationary space that complies with Clause 12.1.2 in front of each unit.
What should we change it to?
Add one more clause v) the laundry room shall have a lockable door that is childproof.
Why should we change it?
It is important that washers and dryers not be accessible to children, as when the door is open, they might see this as an invitation to find a comfortable spot, and go into the washer or dryer, and close the door behind them.
Heading text
18.2 Laundry areas
Heading number portion
18.2
Item id
1778782792056_848
Heading id
s18.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
18.3.Regular upkeep Childcare centres shall have a maintenance plan in place to ensure that all accessibility features and safety are kept fully operational. Maintenance plans include but are not limited to: a) quarterly feature testing; b) quarterly emergency egress drills; c) instant reporting system for damage or malfunctioning equipment; d) an established service network for fast repair of critical equipment; and e) annual accessibility audit. Note: Responsibility for accessibility upkeep should be assigned to a designated accessibility coordinator.
What should we change it to?
Replace e) annual accessibility audit. With a new clause. 18.4. Continuous improvement Every childcare facility shall institute a program of continuous improvement. a. On an annual basis, the facility manager shall engage an advisory panel, that uses the facilities to hear and implement their request to improve accessibility. b. The facility manager may also engage an accessibility subject matter expert as part of the continuous improvement process. c. In those cases where requests for accessibility features prove difficult because of budgetary, space, or other considerations, the principle of reasonable accommodation and undue hardship shall inform the decision.
Why should we change it?
Accessibility at the design or renovation stage is not once and done. Because different abilities and disabilities use a particular facility, and because the technology of adaptation to disabilities is changing, the accessibility features of every facility need to be reviewed and improved on a regular basis.
Heading text
18.3 Regular upkeep
Heading number portion
18.3
Item id
1778783055024_184
Heading id
s11.2
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
11.2. Main entrance The main entrance to the childcare centre shall: d) be immediately recognizable as a childcare centre, with clear and effective signage as per Clause 17; and e) have a service dog relief area that complies with clause 9.4 of CAN-ASC-5.2.1.
What should we change it to?
Move clause E somewhere else Perhaps a new section 12.11.
Why should we change it?
As this clause is about the main building entrance, it implies that the service dog relief area should be near that place. We feel there should be more flexibility in where the relief area should be and so, this clause, does not belong in this section.
Heading text
11.2 Main entrance
Heading number portion
11.2
Item id
1778783162402_302
Heading id
s11.2.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
11.2.1. Power-assisted doors and door width The main entrance to the building leading to the childcare centre, and the main entrance to the childcare centre shall have doorways with: a) power-assisted doors that comply with clause 5.2.9 of CSA/ASC B651:23; b) controls to allow for accessibility, while also maintaining the security and safety of the children in attendance; and c) a clear opening width of at least 950 mm complying with CAN- ASC-2.3. Note 1: Some people may have difficulty accessing or operating the door controls. In such cases, an automatic sensor-activated control that detects movement upon approach may be installed to improve accessibility. This sensor should be installed in such a way that children could not inadvertently open the door and leave or access a secure area on their own. Note 2: Any child-safety measures, such as disabling power door operators to prevent child use, should not compromise accessibility for adults, allowing parents with disabilities to operate door opening devices independently.
What should we change it to?
Add a clause. d. Notwihstanding 5.2.9 of CSA/ASC B651:23 guard rails shall not be used on either side of the powered door in the path of travel. A flashing light and an auditory alert system, either a voice announcement or a buzzer, loud enough to be heard over ambient noise, shall be installed to warn all users that the door is open, in motion, opening, or closing.
Why should we change it?
The clause for powered doors in clause 5.2.9 of CSA/ASC calls for cane detectable guard rails in the path of travel. However, persons with strollers or distracted by taking care of more than one child may find the guard rails specified in B651 difficult to traverse, or they may be a trip hazard. In addition, children may use these guard rails to climb upon or to use for skateboard practice. The clause in B651 was designed for adults in an adult setting. A different warning system that is more suitable for a childcare facility must be used.
Heading text
11.2.1 Power-assisted doors and door width
Heading number portion
11.2.1
Item id
1778783220219_262
Heading id
11.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
What we should change. Accessibility standards Canada has just finished a public review of their emergency egress standard. Although it is in draft form, I feel that there are many clauses from that draft standard that should be integrated into the childcare standard.
What should we change it to?
I feel that before the childcare standard is published, the draft standard on emergency egress should be integrated.
Why should we change it?
The Accessible Standards Canada draft standard on emergency egress includes many clauses that would greatly enhance emergency egress in childcare facilities. In addition, these two different standards would be harmonized.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1778783365851_975
Heading id
11.3.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
11.3.2. Audible and visible alarms What we should change. 11.3.2. Audible and visible alarms a) Visible alarms shall comply with clause 5.7.1 of CSA/ASC B651:23. b) Audible alarms throughout a childcare centre shall provide a Sound Pressure Level (SPL) of at least 65 dB(A) and not exceed 110 dB(A).
What should we change it to?
Add the following clauses: c. All audible alarms shall be accompanied by a voice announcement in both official languages of the nature of the alarm and recommended action. d. All visual alarms shall be configured so as not to cause distress to any person that uses the childcare facility. The building manager shall communicate with any person that might be triggered to ensure that the particular frequency of flashing that is chosen does not cause distress.
Why should we change it?
Audible alarms should be accompanied by a voice announcement to enhance action. Visual alarms are set to a frequency suitable for the general population, but can sometimes cause epileptic seizures in persons with that disability and must be confirmed with the user to avoid that situation.
Heading text
11.3.2 Audible and visible alarms
Heading number portion
11.3.2
Item id
1778783490219_350
Heading id
11.4
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
11.4.Access control and security systems Access controls and security systems shall comply with clauses 5.7.4.1 and 5.7.4.2 of CSA/ASC B651:23. Note: The access controls and security systems referenced in this Standard are intended to be accessible and operable by an adult, such as a staff member or caregiver accompanying children in the childcare facility. It is assumed that children will not operate the security systems.
What should we change it to?
Add a sentence at the end: Access controls and security systems shall be tested and verified by every person who uses the facility with a disability to ensure they are accessible and usable.
Why should we change it?
Meeting a standard does not necessarily mean that for a particular person, something is both accessible and usable. Given that the security systems are so important, these must be verified by every person with a disability to make sure they are accessible and usable. The general specifications of this standard are a starting point, but unless they actually work for everybody, based on being tested, they may be neither accessible nor usable.
Heading text
11.4 Access control and security systems
Heading number portion
11.4
Item id
1778783671330_633
Heading id
s6.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Assistive technologies, such as visual communication boards or hearing assistance systems, further enhance participation and inclusion.
What should we change it to?
Add the following sentence Infrastructure for Assistive technologies, Wi-Fi availability, is necessary as it allows adaptive technologies that enhance skills development, wayfinding, communication, and effective emergency egress. It also further enhances participation and inclusion.
Why should we change it?
Many adaptive technologies, especially those used by persons who are blind, deafblind, or partially sighted rely on a Wi-Fi connection. . Wi-Fi availability is more than a convenience to ensure adaptive technologies work. It is absolutely essential for Communications, and effective emergency egress depends on it. It is not unusual for children as young as three or four to arrive with a device , both for recreation, and skills development.
Heading text
6.2 Overview of accessible design in childcare centres
Heading number portion
6.2
Item id
1778783765635_854
Heading id
s6.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Designers would benefit from working with clients to identify these needs and determine which technology integrations should be incorporated as part of the overall design.
What should we change it to?
Designers shall consult with users with lived experience, configured as an advisory panel, as well as subject matter experts in accessibility, to identify all needs and determine which technology integrations should be incorporated as part of the overall design. The consultation shall include not only necessary technologies, but also the physical design as recommended by persons with lived experience and subject matter experts. All parties shall be satisfied with the outcome of all decisions. In the case of issues concerning cost or practicality of adaptive, technologies or physical design, the Canadian legal jurisprudence of reasonable accommodation and undue hardship shall be used to inform any decision.
Why should we change it?
The key principle of the Accessible Canada Act is nothing about us without us. For this reason, persons with disabilities with lived experience, or accessible subject matter experts must be consulted at the design stage to ensure that the facility is both accessible and usable. In addition, a framework to resolve differences is essential for effective governance
Heading text
6.2 Overview of accessible design in childcare centres
Heading number portion
6.2
Item id
1778783827986_614
Heading id
s6.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Accessible childcare centres should also have an accessible Web site and other accessible contact options.
What should we change it to?
Change should to shall. Accessible childcare centres shall also have an accessible Web site and other accessible contact options. Add the following phrase. In order for the website to be accessible, it shall be available in formats that are usable with adaptive technologies, such as screen readers, and accessible and alternative formats.
Why should we change it?
Persons with disabilities rely on accessible websites and accessible communication technologies. In today's tech, heavy environment, a facilities website gives in formation that all users, caretakers, parents, and staff must know, and for this reason the website and all other contact technologies must be accessible.
Heading text
6.2 Overview of accessible design in childcare centres
Heading number portion
6.2
Item id
1778783986891_891
Heading id
s7.4
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
While accessible childcare centres aim to create inclusive and supportive environments for children, parents, guardians, and staff with disabilities, several barriers can hinder their ability to fully meet the needs of all individuals. Implementing accessible features like ramps, specialized equipment, and sensory-friendly spaces can be straight forward with the guidance provided in this Standard.
What should we change it to?
Add new words several barriers can hinder their ability to fully meet the needs of all individuals. Implementing accessible features like ramps, specialized equipment, Add new words here Wi-Fi infrastructure, accessible formats and Communications and signage, Adaptive technology, New words end here and sensory-friendly spaces can be straight forward with the guidance provided in this Standard.
Why should we change it?
The draft standard includes descriptions of many physical items to ensure the facility is accessible, but leaves out a few. For this reason, the technologies that allow persons with disabilities to take full advantage of the facility must be included.
Heading text
7.4 Limits
Heading number portion
7.4
Item id
1778784087278_731
Heading id
s7.6
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
This Standard is intended to align as much as possible with accessibility codes and standards such as:
What should we change it to?
Add two more standards. ACS Wayfinding and signage draft ACS Emergency egress draft
Why should we change it?
These are two very important standards that make a facility accessible and usable. Although these are in draft mode currently, by the time the standard gets published, these might be in final form. And, for what it's worth, even if they are in draft form, I think they should be included.
Heading text
7.6 Other relevant restrictions or considerations
Heading number portion
7.6
Item id
1778784185629_827
Heading id
s9.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add several definitions
What should we change it to?
Accessible formats — other formats of communicating information including, but not limited to a. audio formats b. braille c. large print d. plain language e. Formats that work with screen readers f. Formats that can be magnified, dimmed or brighten, or change contrast on a screen g. Websites and apps that conform to the latest version of WCAG used by accessibility standards, Canada Note: CAPTCHA, scanned documents and images and certain PDF features are barriers to accessibility. Note. Accessible formats are sometimes called alternate or alternative formats Advisory panel A group of concerned stakeholders, preferably with lived experience in disabilities, to advise when design, renovation, or annual accessibility reviews take place. It would be preferable for this group to be taken from those who attend a particular facility, but not necessarily. They should be fairly compensated for their time. Child care facility It is beyond my expertise to create this definition, but I think it should include the age range of the children, as well as the episodic nature of their attendance, so it is clear that the facility is not one where the children regularly eat and sleep. A bit more difficult would be those facilities that are really childcare facilities, but use as a theme, gymnastics, athletics, music, language or similar activities. Continuous improvement, An incremental and continuous process that takes feedback from users and other concerned, stakeholders, and then create solutions and implements them. Subject matter expert in accessibility — means a person who has knowledge of a specified field such as the built environment, information and communication technology, and human resources based on a combination of the following factors, which may be weighted differently depending on the circumstances: a) Lived experience relating to accessibility. b) Relevant industry work experience. c) Formal education or training. d) Professional practice within the subject area. Reasonable accommodation, and undue hardship. A Canadian legal term that refers to jurisprudence and precedence set by Canadian courts to inform decisions on accessibility when constraints of budget, space, time, or other constraints are involved.
Why should we change it?
These definitions enhance the ability of the standard to make a difference in removing barriers and ensuring no new ones are created.
Heading text
9.1 Definitions
Heading number portion
9.1
Submission ID
65355
Submitted by
sweiner
Submitted on
Thu, 05/14/2026 - 14:45
Consent to contact
Yes

Individual 65360's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1778787475851_878
Heading id
12.4
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
A therapy room may be part of a multi-purpose or multi-functional room and space, however, at least one therapy space should provide visual and audible privacy screening.
What should we change it to?
Change to “therapy room shall have separation”
Why should we change it?
na
Heading text
12.4 Design of childcare activity rooms
Heading number portion
12.4
Item id
1778787603714_725
Heading id
s15
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
-all outdoor spaces and play equipment shall be accessible…it is exclusionary when parts of the indoor/outdoor space are inaccessible (language used around outdoor spaces was “should” not “shall” for accessibility
What should we change it to?
na
Why should we change it?
na
Heading text
16. Outdoor play areas and landscaping
Heading number portion
16.
Item id
1778787829435_694
Heading id
s5
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
this feedback is to apply to the entire document
What should we change it to?
-ensure all documents and information that goes to families is in plain language -provide visual supports around all spaces used by families and children (handwashing, where to return items, etc) -ensure that medical needs or behavior challenges are not a barrier to entry -provide training to all staff to ensure and “attitude of accessibility”
Why should we change it?
these are critical elements that will determine whether inclusion is realized
Heading text
6. Introduction
Heading number portion
6.
Submission ID
65360
Submitted by
tlevandier@inclusioncanada.ca
Submitted on
Thu, 05/14/2026 - 15:44
Consent to contact
Yes

Individual 65363's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1778859741992_181
Heading id
s11.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Include a clause for the main entrance
What should we change it to?
Include a provision requiring a minimum amount of floor space within the build at the main entrance, that is sufficiently large to accommodate a stroller and a wheelchair at the same time.
Why should we change it?
In our team's experience, entrance ways of childcare centres are typically quite small as the centre wants to maximise classroom capacity. Requiring a minimum floor space that can accommodate a stroller and a wheelchair simultaneously will greatly improve accessibility for parents using wheeled mobility devices.
Heading text
11.2 Main entrance
Heading number portion
11.2
Item id
1778859809864_548
Heading id
s18.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Include a provision under 18.2(c)
What should we change it to?
Include a provision under 18.2(c) that washing machine and dryer must be elevated a minimum of 250 mm and a maximum of 400 mm off the ground
Why should we change it?
Washers and dryers that are not elevated off the ground (either by way of a pedestal or architectural feature of the room) will require bending over for standing folks. If the proposed minimum/maximum recommendations are no good, then select a minimum/maximum range that supports works who are seated as well as those who are standing to comfortably access the machine drums without straining.
Heading text
18.2 Laundry areas
Heading number portion
18.2
Submission ID
65363
Submitted by
brittany.finlay1@ucalgary.ca
Submitted on
Fri, 05/15/2026 - 11:43
Consent to contact
Yes

Individual 65368's submission

CAN-ASC-4.1 Accessible Procurement
Feedback items
Item id
1778868631958_220
Heading id
11.4.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Note 2: "...Feedback should be shared (in an anonymized or appropriate form) with all participants, and organizers may present a timeline of next steps for improving accommodation effectiveness."
What should we change it to?
Might want to consider moving this up into main provisions for final standard.
Why should we change it?
This sounds like a requirement, which cannot appear in notes.
Heading text
11.4.3 Identifying accommodation needs
Heading number portion
11.4.3
Item id
1778868755974_637
Heading id
s5
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Above all and in the spirit of this Standard, people with disabilities are involved in procurement.
What should we change it to?
You may want to clarify how people with disabilities are involved in procurement or reference where in the Standard this will be stated.
Why should we change it?
Clarity and specificity
Heading text
6. Introduction
Heading number portion
6.
Item id
1778869969914_283
Heading id
9.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Bidder — a legal entity, person, joint venture or company that has submitted a bid in response to a solicitation.
What should we change it to?
You may want to define company or use organization and define that. What about non profits? How do they fit into the Standard? This is not sufficiently clear in definitions.
Why should we change it?
If you want to reference legislation to help with definitions section, we (ASC Legal Team) can assist with that. But we need to have clarity on what you mean in the context of “bid” and “bidder” and why this is relevant for the Standard.
Heading text
9.1 Definitions
Heading number portion
9.1
Item id
1778870040852_569
Heading id
9.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Binding agreement — an agreement between a procuring entity and a supplier that establishes the terms and conditions for the provision of goods or services. This agreement obligates both parties to fulfill their respective commitments as specified within the contract.
What should we change it to?
This should just read Agreement or contract.
Why should we change it?
An agreement is binding by nature.
Heading text
9.1 Definitions
Heading number portion
9.1
Item id
1778870148285_587
Heading id
9.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Contract — a binding agreement entered into by a contracting authority and a contractor to procure a good, service or construction.
What should we change it to?
Remove this definition.
Why should we change it?
Superfluous if you already have agreement. An agreement is binding by definition. Why do you define contract and agreement separately?
Heading text
9.1 Definitions
Heading number portion
9.1
Item id
1778870250249_968
Heading id
9.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Joint Venture — describes any arrangement whereby two or more persons agree to contribute goods, services, or capital to a common commercial enterprise. It is generally regarded as a temporary relationship that is more informal than a partnership.
What should we change it to?
Joint Venture -- describes any arrangement whereby two or more persons agree to contribute goods, services, or capital to a common commercial enterprise while they remain separate legal entities. It is generally regarded as a temporary relationship that is more informal than a partnership.
Why should we change it?
If you reference partnership here, you should also define that term in context of company or organization, and then also list the difference between partnership and incorporated entity, and non-profit.
Heading text
9.1 Definitions
Heading number portion
9.1
Submission ID
65368
Submitted by
sweiner
Submitted on
Fri, 05/15/2026 - 14:37
Consent to contact
Yes

Individual 65369's submission

CAN-ASC-4.1 Accessible Procurement
Feedback items
Item id
1778872656736_706
Heading id
11.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Clients shall be responsible for confirming that: a) accessibility requirements established by the contract are being met throughout the contract; b) any accessibility issues identified throughout the duration of the contract are resolved; and, c) any task authorizations, contract amendments, or work orders issued against the contact include applicable accessibility requirements.
What should we change it to?
Clients shall be responsible for confirming that: a) accessibility requirements established by the contract are being met throughout the contract; b) any accessibility issues identified throughout the duration of the contract are resolved; and, c) any task authorizations, contract amendments, or work orders issued against the contact include applicable accessibility requirements; d) vendors' accessibility needs are met by the client.
Why should we change it?
I also strongly recommend adding the d) clause (to be reformulated maybe, for more clarity) since, for example, vendors who are either PWD-owned or have PWD handling the contract are by default at an disadvantage compared to their non-disabled competitors (e.g., sign language interpreters coverage, accommodation provided, etc.). Here's one example, for reference only: https://canadacouncil.ca/funding/strategic-funds/access-support.
Heading text
11.1 General
Heading number portion
11.1
Submission ID
65369
Submitted by
sweiner
Submitted on
Tue, 05/19/2026 - 08:26
Consent to contact
Yes

Individual 65372's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1778881295900_781
Heading id
s5
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Communication standards should include signed language access, not solely spoken or written communication. We recommend: • Including ASL and LSQ within communication planning requirements • Providing access to sign language interpreters, either in person or through video remote interpreting (VRI) • Supporting visual communication systems throughout childcare environments • Ensuring communication is accessible in the child’s primary language Communication accessibility must recognize signed languages as complete and natural languages, not secondary supports.
Why should we change it?
Deaf children’s rights are ignored as it is written
Heading text
6. Introduction
Heading number portion
6.
Item id
1779161798406_587
Heading id
s16
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Communication standards should include signed language access, not solely spoken or written communication. We recommend: • Including ASL and LSQ within communication planning requirements • Providing access to sign language interpreters, either in person or through video remote interpreting (VRI) • Supporting visual communication systems throughout childcare environments • Ensuring communication is accessible in the child’s primary language Communication accessibility must recognize signed languages as complete and natural languages, not secondary supports.
Why should we change it?
Deaf access has not be included in Draft
Heading text
17. Wayfinding and signage
Heading number portion
17.
Item id
1779161922696_701
Heading id
12.4
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Shared spaces should support visual language use, not only hearing technology. We recommend: • Flexible layouts that support group signing • Video display tools and visual communication supports • Reduced visual barriers • Design considerations that prioritize visual interaction Accessibility should include visual language environments, not solely auditory accommodations.
Why should we change it?
Deaf Access has not been included
Heading text
12.4 Design of childcare activity rooms
Heading number portion
12.4
Item id
1779161951656_887
Heading id
12.4.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Shared spaces should support visual language use, not only hearing technology. We recommend: • Flexible layouts that support group signing • Video display tools and visual communication supports • Reduced visual barriers • Design considerations that prioritize visual interaction Accessibility should include visual language environments, not solely auditory accommodations.
Why should we change it?
Deaf Access has not been included in draft
Heading text
12.4.1 Classrooms and learning spaces
Heading number portion
12.4.1
Item id
1779162035594_486
Heading id
s13
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
add in
What should we change it to?
The standards should recognize that staff members may also be Deaf or hard of hearing. We recommend: • Visual alert systems such as flashing alarms and visual notifications • Workspaces designed for clear visual communication • Access to video-based communication tools • Support for sign language communication within staff teams • Financial accessibility supports for Deaf staff who require interpreters to communicate with hearing staff, families, or children who do not know ASL or LSQ We further recommend prioritizing: • Hiring educators with ASL or LSQ proficiency • Inclusion of Deaf educators and Deaf role models • Ongoing professional development in Deaf culture and visual communication strategies Deaf children benefit greatly from interaction with fluent signers and Deaf adult role models. Language access depends not only on the environment, but also on the people within it.
Why should we change it?
Deaf Access has not been included in Draft
Heading text
14. Staff areas and facilities
Heading number portion
14.
Item id
1779162070457_143
Heading id
s12
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Families should be able to communicate in signed language within childcare settings. We recommend: • Access to interpreters in reception and family meeting spaces, either in person or remotely through VRI • Staff awareness training on Deaf culture and communication strategies • Basic understanding of visual communication methods and ASL/LSQ Accessibility should ensure that Deaf parents and family members can fully participate in communication regarding their child.
Why should we change it?
Deaf Access has not been included in draft
Heading text
13. Reception areas
Heading number portion
13.
Item id
1779162110050_236
Heading id
s17
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Emergency systems must be visually accessible. We recommend: • Flashing visual alarms • Emergency procedures that do not rely solely on auditory instructions • Staff training in visually accessible emergency communication
Why should we change it?
Deaf Access has not been included in Drart
Heading text
18. Maintenance and cleaning facilities
Heading number portion
18.
Item id
1779162196374_575
Heading id
s15
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Add in
What should we change it to?
Lighting standards should support signed language communication. We recommend lighting that: • Allows clear visibility of faces and hands • Minimizes shadows and glare • Supports visual attention and communication throughout the environment
Why should we change it?
Deaf Access has not been included in Draft
Heading text
16. Outdoor play areas and landscaping
Heading number portion
16.
Item id
1779162520514_267
Heading id
s7.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
PLEASE ADD in (sorry, I am including here but there wasn't a general place for me to add additional suggestions)
What should we change it to?
Please consider adding: Additional Recommendations Visual Environment Design Childcare spaces should support visual communication as a primary mode of interaction through: • Open layouts and clear sightlines • Consistent visual access between children and educators • Visual group engagement strategies • Reduced dependence on verbal-only instruction Language Access and Communication Programs should: • Provide access to fluent signed language models • Support ASL and LSQ as natural languages • Incorporate visual communication strategies consistently • Ensure communication access during all activities and transitions Social Inclusion and Peer Interaction We recommend: • Introducing basic signed language to all children within programs • Supporting inclusive peer interaction • Using visual turn-taking strategies and visual engagement methods Materials and Learning Resources Learning materials should include: • Signed language-rich resources • Visual storytelling tools • Video resources featuring signed language • Representation of Deaf people and Deaf culture Implementation Guidance We recommend that implementation: • Apply universal design principles while specifically addressing visual language access • Engage Deaf communities and Deaf professionals in ongoing consultation • Recognize that language access is foundational, not optional, within accessibility planning  
Why should we change it?
Deaf Access has not been included in this draft. See attached PDF
Heading text
7.1 Inclusions
Heading number portion
7.1
Submission ID
65372
Submitted by
cecelia@fndc.ca
Submitted on
Mon, 05/18/2026 - 23:49
Consent to contact
Yes

Individual 65384's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1779107784773_313
Heading id
12.4
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Within the Note 1, there is no consideration of the quiet room and its need to be partitioned from the classroom to function as a quiet space.
What should we change it to?
Spaces listed above do not need to be separate rooms to comply with this requirement. However, if a therapy room and/or quiet room is included as part of any other space, visual and audible privacy separation should be considered.
Why should we change it?
Some children will require a properly designed quiet space to allow them to escape from overstimulation.
Heading text
12.4 Design of childcare activity rooms
Heading number portion
12.4
Item id
1779108985173_529
Heading id
12.4.6
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
There is less consideration of children moving in the space. Rather focus on the children being stationary.
What should we change it to?
"Indoor play areas and recreation zones shall b) have equipment served by clear spaces that comply with Clause 12.1.2 "
Why should we change it?
The 24-Hour Movement Guidelines for children in the early years recommend that children ages 0 to 4 years move for at least 180 minutes each day. This includes both indoors and outdoors.
Heading text
12.4.6 Multi-purpose rooms
Heading number portion
12.4.6
Submission ID
65384
Submitted by
kelly.arbour@utoronto.ca
Submitted on
Mon, 05/18/2026 - 09:01
Consent to contact
Yes

Individual 65398's submission

CAN-ASC-4.1 Accessible Procurement
Feedback items
Item id
1779286538307_438
Heading id
14.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Clients shall be responsible for confirming that: a) accessibility requirements established by the contract are being met throughout the contract; b) any accessibility issues identified throughout the duration of the contract are resolved; and, c) any task authorizations, contract amendments, or work orders issued against the contact include applicable accessibility requirements.
What should we change it to?
Clients shall be responsible for confirming that: a) accessibility requirements established by the contract are being met throughout the contract; b) any accessibility issues identified throughout the duration of the contract are resolved; and, c) any task authorizations, contract amendments, or work orders issued against the contact include applicable accessibility requirements; d) vendors' accessibility needs are met by the client.
Why should we change it?
I also strongly recommend adding the d) clause (to be reformulated maybe, for more clarity) since, for example, vendors who are either PWD-owned or have PWD handling the contract are by default at an disadvantage compared to their non-disabled competitors (e.g., sign language interpreters coverage, accommodation provided, etc.). Here's one example, for reference only: https://canadacouncil.ca/funding/strategic-funds/access-support.
Heading text
14.1 Monitoring contract progress
Heading number portion
14.1
Item id
1779286653471_230
Heading id
14.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Clients shall be responsible for confirming that the contracted business resolved any end-user reported accessibility issues in accordance with the contract.
What should we change it to?
Clients shall be responsible for: a) confirming that the contracted business resolved any end-user reported accessibility issues in accordance with the contract; b) covering accommodation requirements to allow the contracted business to complete the contract.
Why should we change it?
I also strongly recommend adding the b) clause (to be reformulated maybe, for more clarity) since, for example, vendors who are either PWD-owned or have PWD handling the contract are by default at an disadvantage compared to their non-disabled competitors (e.g., sign language interpreters coverage, accommodation provided, etc.). For example, a Deaf-owned business would need sign language interpreters to interact with hearing end-users to make sure that accessibility issues are resolved. Who should cover interpreting fees?
Heading text
14.3 Resolving end user issues
Heading number portion
14.3
Item id
1779286812886_964
Heading id
15.3.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Training shall be developed in consultation with people with disabilities and they shall be appropriately compensated for their time and expertise.
What should we change it to?
Training shall be developed in consultation with accessibility professionals or experts and they shall be appropriately compensated for their time and expertise.
Why should we change it?
Refer to comment for the clause 9.4.3
Heading text
15.3.1 Development
Heading number portion
15.3.1
Item id
1779286893755_282
Heading id
15.3.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Training development may include input from organizations with relevant subject-matter expertise that represent people with disabilities.
What should we change it to?
Training development must include input from organizations with relevant subject-matter expertise that represent people with disabilities.
Why should we change it?
Refer to comment for the clause 9.4.3
Heading text
15.3.1 Development
Heading number portion
15.3.1
Item id
1779286996318_777
Heading id
s5
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
"...including plain-language, American Sign language (ASL) and langue des signes québécoise (LSQ) summaries."
What should we change it to?
Expand the requirement to include full access to all documentation and application materials in LSQ and ASL, not just summaries.
Why should we change it?
Summaries in LSQ/ASL are appreciated, but to ensure full and equal participation, all relevant materials in the procurement process (e.g. application guides, forms, contracts) should be fully accessible in both sign languages, not only in summary form.
Heading text
6. Introduction
Heading number portion
6.
Item id
1779287184222_6
Heading id
11.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Whole clause
What should we change it to?
The clause provides a broad overview of accessibility requirements across various stakeholders, but it lacks specifics on how to implement these requirements.
Why should we change it?
Include more specific guidelines or examples for each group mentioned to clarify how they should engage with accessible information.
Heading text
11.1 General
Heading number portion
11.1
Item id
1779287302438_674
Heading id
11.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Whole clause
What should we change it to?
Requiring all websites and digital applications to comply with accessibility standards is crucial, but the clause could benefit from more information on how to monitor compliance or enforcement mechanisms.
Why should we change it?
Include a section on how compliance will be assessed, such as regular audits or checks of digital platforms to ensure ongoing accessibility.
Heading text
11.3 Websites and digital applications
Heading number portion
11.3
Item id
1779287399844_113
Heading id
11.4.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Whole clause
What should we change it to?
The idea of planning accessible engagement activities is valuable, but it may require a clear methodology for how engagement activities should be assessed for accessibility needs.
Why should we change it?
Develop a step-by-step process or checklist for planning and assessing accessible engagement activities.
Heading text
11.4.1 General
Heading number portion
11.4.1
Item id
1779287535574_913
Heading id
12.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Whole clause
What should we change it to?
Ensuring that all solicitation documents comply with accessibility standards is essential, but the clause could provide more practical examples of how to make solicitation documents accessible.
Why should we change it?
Include specific examples or templates of accessible solicitation documents to guide clients in meeting these requirements.
Heading text
12.3 Preparing solicitation documents
Heading number portion
12.3
Item id
1779287595361_933
Heading id
12.4.2
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Whole clause
What should we change it to?
Providing sufficient time for bid evaluation, especially to assess accessibility requirements, is critical, but it may not be clear how to balance time constraints with the need for thorough evaluation.
Why should we change it?
Offer guidelines or best practices for determining how much time is required to review accessibility features in bids, considering the complexity of the procurement.
Heading text
12.4.2 Determining the evaluation timeline
Heading number portion
12.4.2
Item id
1779287687800_10
Heading id
13.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Whole clause
What should we change it to?
The clause emphasizes providing reasonable time for submitting bids, but it could be challenging for clients to accurately determine the time required for people with disabilities to prepare accessible submissions.
Why should we change it?
Provide clearer guidance or tools for clients to estimate the additional time required for people with disabilities to prepare accessible bids, such as a checklist or a time estimation formula.
Heading text
13.1 Determining the solicitation period
Heading number portion
13.1
Item id
1779292243805_820
Heading id
13.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
iii) the time required to obtain the solicitation in an accessible format, prepare a bid, and submit a response to a solicitation.
What should we change it to?
Recommend providing a clear process for ensuring all formats of solicitation documents are made accessible, including braille, large print, and accessible digital formats.
Why should we change it?
Including the time required to obtain the solicitation in an accessible format is important, but the clause doesn't specify how to handle accessibility needs for all potential formats (e.g., Braille, large print, digital accessibility).
Heading text
13.1 Determining the solicitation period
Heading number portion
13.1
Item id
1779292325497_50
Heading id
14.1
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Clients shall be responsible for confirming that: a) accessibility requirements established by the contract are being met throughout the contract;
What should we change it to?
Provide clear metrics or checklists for monitoring accessibility compliance, such as regular accessibility audits or progress reports.
Why should we change it?
Ensuring that accessibility requirements are being met throughout the contract is crucial, but this clause may lack clear guidance on how to measure accessibility compliance in practice.
Heading text
14.1 Monitoring contract progress
Heading number portion
14.1
Item id
1779302813118_521
Heading id
11.4.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
d) respond to any other requirements including: i) dietary restrictions if meals are provided; ii) emergency evacuation procedures; iii) modifications to the physical environment (functional, sensory, environmental); and iv) other accessibility supports, as requested or required; e) proactively implement accessibility measures that support participants who may not feel safe disclosing their disability or accommodation needs. These measures should reference and align with CAN-ASC-5.2.1:Part 1 (draft standard). While not all accommodations can be universally applied, many can be adopted without overburdening the process or reducing the quality of engagement.
What should we change it to?
d) any other requirements including: i) dietary restrictions if meals are provided; ii) emergency evacuation procedures; iii) modifications to the physical environment (functional, sensory, environmental); and, iv) other accessibility supports, as requested and required. e) Proactively implement accessibility measures that support participants who may not feel safe disclosing their disability or accommodation needs. These measures should reference and align with CAN-ASC-5.2.1. While not all accommodations can be universally applied, many can be adopted without overburdening the process or reducing the quality of engagement.
Why should we change it?
1. d) iii) - This could be a significant task. Not sure that modifying the physical environment would be possible. Suggest removing this or making a recommendation that the meeting space is accessible to people with disabilities and if there’s a standard that is necessary to note, then use CSA/ASC B651 2. Universal design. This is the first mention of universal design it doesn’t quite align with the previous parts of this section. Several examples of accommodations have been provided. If the committee would like to keep this, I would suggest moving it to the beginning of the clause and to remove the mention of universal design.
Heading text
11.4.3 Identifying accommodation needs
Heading number portion
11.4.3
Item id
1779302933532_434
Heading id
13.6
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
c) if required, provide an equivalent accessible debrief, such as sign language translation of the debrief, in compliance with EN 301 549; and, d) if required, ensures sign language interpretation is provided to debrief meetings, and allow reasonable time extension past the deadline to unsuccessful bidders. Note: When accessibility or translation service is required, the steps should be taken to prevent any conflict of interest. Where possible the service should be provided in-house to the organization, or the bidder may be invited to propose a qualified interpreter or translator for approval. This may include the translation of written debrief to sign language video format to ensure accessibility while maintaining confidentiality and impartiality.
What should we change it to?
1. c) if required, provide an equivalent accessible debrief complying with EN 301 549; and 2. Note. This note is a little awkward.
Why should we change it?
Clarity
Heading text
13.6 Providing an unsuccessful bidder debriefing
Heading number portion
13.6
Submission ID
65398
Submitted by
sweiner
Submitted on
Wed, 05/20/2026 - 14:49
Consent to contact
Yes

Individual 65444's submission

CAN-ASC-2.9 – Accessible Childcare Centres
Feedback items
Item id
1779980207095_973
Heading id
10.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
The childcare centre shall be located such that the path from parking, transit, and drop-off zones to the building main entrance comply with the requirements of CSA/ASC B651:23, unless otherwise specified in this standard.
What should we change it to?
The childcare centre shall be located such that the path(s) from parking, transit, and drop-off zones to the building main entrance comply with the requirements of CSA/ASC B651:23, unless otherwise specified in this standard.
Why should we change it?
Recommend pluralizing path to paths; there may be more than one. There is no guarantee that the parking, transit and drop off zones are all in the same place.
Heading text
10.1 Accessible sites
Heading number portion
10.1
Item id
1779980249698_169
Heading id
s10.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
At least one drop-off and pick-up zone shall serve as a childcare centre
What should we change it to?
At least one drop-off and pick-up zone shall serve a childcare centre
Why should we change it?
Delete the word “as” – grammatically nonsensical.
Heading text
10.3 Drop-off and pick-up zones
Heading number portion
10.3
Item id
1779980300487_356
Heading id
s10.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
b) provide an access aisle at street level, a minimum of 1,500 mm wide and 14,000 mm long to accommodate two vehicles; c) be separated from the walkway by a curb, tactile attention indicator surface, or other physical indicators; d) where applicable, have access from the street level access aisle to the raised curb area via a depressed curb ramp that runs for the length of the drop-off zone that complies with clause 8.3.3 of CSA/ASC B651:23;
What should we change it to?
Consider making items b-d in Clause 10.3 “should” statements, not “shall” statements.
Why should we change it?
Would this clause as a whole actually hinder or restrict the placement of a childcare site? This clause is very difficult to implement under many circumstances. Particularly for childcare centres leasing space in commercial or apartment buildings, the availability of the space described is at the discretion of the developer/property manager, and may not actually exist.
Heading text
10.3 Drop-off and pick-up zones
Heading number portion
10.3
Item id
1779980353300_629
Heading id
s10.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
b) provide an access aisle at street level, a minimum of 1,500 mm wide and 14,000 mm long to accommodate two vehicles; c) be separated from the walkway by a curb, tactile attention indicator surface, or other physical indicators; d) where applicable, have access from the street level access aisle to the raised curb area via a depressed curb ramp that runs for the length of the drop-off zone that complies with clause 8.3.3 of CSA/ASC B651:23;
What should we change it to?
Also, would there be a way to encourage workarounds when b-d are not feasible? For example, the use of extra parking spaces near TWSIs and curb cuts?
Why should we change it?
Workarounds may be possible, but seem to be inappropriate, given how the standard is phrased. Why not add an item that facilitates the development of a workaround or workarounds, if b-d are not feasible?
Heading text
10.3 Drop-off and pick-up zones
Heading number portion
10.3
Item id
1779980411347_380
Heading id
s11.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
have illumination at least 50 lx at ground level
What should we change it to?
have illumination at least 50 lx at ground level during the hours of operation of the childcare centre, and in all weather conditions
Why should we change it?
Clarify that the minimum of 50 lx is for all hours of operation of the childcare centre. Ambient natural illumination changes substantially depending on time of day, time of year, and inclement weather. Consider a childcare centre in Yellowknife at 4 pm in December and in the middle of a snow storm, compared to the same location on a summer day in July at the same time.
Heading text
11.2 Main entrance
Heading number portion
11.2
Item id
1779980462763_600
Heading id
s11.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
have a service dog relief area that complies with clause 9.4 of CAN-ASC-5.2.1.
What should we change it to?
No change recommended to this item. A new requirement is proposed for Clause 14.2, which will be covered in a separate comment.
Why should we change it?
This requirement is commendable – however, service dogs may be used by parents and visitors to the centre, as well as by staff. There is currently no provision for where the service dog rests indoors when not with its handler (which, particularly for staff, absolutely can and does happen). The location for that requirement is likely not here, but rather in Clause 14.2.
Heading text
11.2 Main entrance
Heading number portion
11.2
Item id
1779980510934_552
Heading id
s11.2
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
have a service dog relief area that complies with clause 9.4 of CAN-ASC-5.2.1.
What should we change it to?
have a service dog relief area that complies with clause 13.4 of CAN-ASC-5.2.1.
Why should we change it?
Corrects numbering to the appropriate value (the clauses in 5.2.1 were renumbered to match the current standard layout for ASC standards – you should validate this with the committee’s PM).
Heading text
11.2 Main entrance
Heading number portion
11.2
Item id
1779980556699_974
Heading id
s11.2.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The main entrance to the building leading to the childcare centre, and the main entrance to the childcare centre shall have doorways with: a. power-assisted doors that comply with clause 5.2.9 of CSA/ASC B651:23; b. controls to allow for accessibility, while also maintaining the security and safety of the children in attendance; and c. a clear opening width of at least 950 mm complying with CAN-ASC-2.3.
What should we change it to?
Add a new item d: d. no interference from any other door or gate that may be adjacent to the main entrance.
Why should we change it?
Some childcare centres with their own exterior doors also have gates to play areas adjacent to the main entrance. In these cases, it’s important to ensure that the two doorways (or the door and the gate) don’t interfere with each other if they are opened simultaneously – or that the opening of one does not block the ability to open the second.
Heading text
11.2.1 Power-assisted doors and door width
Heading number portion
11.2.1
Item id
1779980612760_942
Heading id
11.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments. Note 2: The main entrance to the childcare facility might also be an emergency exit.
Why should we change it?
Could one of the emergency exits be the main entrance? If yes, a second note would be perhaps the best way to make this point.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980680216_795
Heading id
11.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual disabilities.
Why should we change it?
Recommend staying away from the term “impairments” which medicalizes disability lived experiences. “Hearing and visual disabilities” would be OK.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980737747_637
Heading id
11.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; and c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge. The childcare centre emergency egress should be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
Why should we change it?
Is item d always going to be practical? It is possible for a childcare facility to have emergency exits on opposite ends of the same side of the space (for example, if it is located in the middle of a row of units, and surrounded on three sides). Consider making it a should statement instead of a shall.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980788811_784
Heading id
11.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The childcare centre emergency egress shall: a. comprise an accessible egress path of travel as per Clause 11.3.1; b. comprise emergency provisions as per clause 5.7 of CSA/ASC B651:23; c. include a minimum of two emergency exits to the exterior of the childcare facility or to an area of refuge; and d. be located on different sides of the childcare centre. Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
Add a new item to this clause: There shall be a minimum of 2 emergency egress pathways to the exterior of the childcare centre.
Why should we change it?
Item d also implies that there needs to be at least two emergency egress points. Recommend that this also be explicitly stated.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980842091_377
Heading id
11.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
Childcare centres, in their emergency procedures, shall: a) include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments; and b) Comply with CAN/ASC 2.2 – Emergency Egress
Why should we change it?
Two suggested changes – one would be to point to the Emergency Egress standard (if it is published before this one is finished). And the second would be to make this note an actual requirement, if within scope of the standard.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980885841_30
Heading id
11.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Note: Emergency procedures should include provisions for assisting children with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
What should we change it to?
Note: Emergency procedures should include provisions for assisting children and staff with physical, sensory, and cognitive disabilities, including designated staff roles, accessible evacuation devices (where applicable), and clear communication strategies for children with hearing or visual impairments.
Why should we change it?
CAN/ASC 2.2 requires personalized emergency evacuation plans (PEEPs) for all users of a site – perhaps it’s also out of scope for this standard, but it is worth commenting somewhere that emergency evacuation procedures need to be posted in a public place, and there needs to be provisions in place for staff with disabilities, not just children. How parents and visitors with disabilities are accounted for is more likely in scope for a standard that looks at service provision at a childcare centre.
Heading text
11.3 Emergency egress
Heading number portion
11.3
Item id
1779980934021_931
Heading id
12.1.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
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 tactile wayfinding supports, such as tactile walking surface indicators.
What should we change it to?
Paths of travel that do not form part of the emergency path of travel shall: a) comply with clause 5 of CSA/ASC B651:23; and b) include tactile wayfinding supports, such as tactile walking surface indicators.
Why should we change it?
Editorial rewrite to make this a list, for ease of reference.
Heading text
12.1.1 Paths of travel
Heading number portion
12.1.1
Item id
1779980972471_588
Heading id
12.1.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
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 tactile wayfinding supports, such as tactile walking surface indicators.
What should we change it to?
The choice of language is up to the committee. One possibility would be to include a note about seasonal carpeting: Note: seasonal carpeting is itself a form of (not ideal) tactile walking surface indicator, since it tends to be laid down along the path of travel. Alternatively, if the choice is to explicitly recommend against seasonal carpeting, that should be a requirement.
Why should we change it?
What about the use of seasonal carpeting? This requirement seems to assume year round flooring, without use of seasonal carpeting. Notably, seasonal carpeting is itself a form of (not ideal) tactile walking surface indicator, since it tends to be laid down along the path of travel. If the intent is to recommend against the use of seasonal carpeting, this needs to be made explicit.
Heading text
12.1.1 Paths of travel
Heading number portion
12.1.1
Item id
1779981017525_191
Heading id
12.1.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The dimensions of a stationary position for people using a wheeled mobility device shall be: a. no less than 820 mm by 1,390 mm where it serves a single person (e.g., child, staff, parent, or guardian); and b. no less than 1,600 mm by 1,390 mm where it serves two people at the same time (e.g., teacher and child, parent / guardian and child, etc.).
What should we change it to?
No change to this clause
Why should we change it?
Recommend defining the term “Stationary Position” in the definitions. Childcare centre staff who are planning to use this standard are not likely to know the term.
Heading text
12.1.1 Paths of travel
Heading number portion
12.1.1
Item id
1779981053131_287
Heading id
12.1.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Wayfinding and signage shall comply with Clause 17.
What should we change it to?
Delete.
Why should we change it?
Is this not redundant? Why not simply move Clause 17 forward in the standard to make it clear that it applies everywhere? Or integrate the language directly from Clause 17 here, and then have a separate piece on wayfinding and signage in Clause 16?
Heading text
12.1.3 Wayfinding and signage
Heading number portion
12.1.3
Item id
1779981143537_715
Heading id
12.4
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
The number and type of childcare activity spaces within a childcare centre depend on its policies and program focus. However, a childcare centre shall have a space for at least: a. one classroom; b. one therapy room; and c. one quiet room.
What should we change it to?
See attached document restructuring Clause 12.4
Why should we change it?
From the perspective of staff who run childcare centres, the minimum requirement for space would be a multi-functional room, which can be converted into a classroom, a therapy room, a quiet space, etc. Multi-functional rooms have open-ended utilization, and promote flexibility to meet children’s needs on an as-needed and individualized basis. Additionally, there are staffing considerations childcare centre directors need to account for in considering the mumber of separate rooms onsite – each room requires a minimum number of staff, alongside the requirements for staff to child ratio.
Heading text
12.4 Design of childcare activity rooms
Heading number portion
12.4
Item id
1779981192905_174
Heading id
12.4
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Usage of the term “room”
What should we change it to?
Replace “room” with “space”
Why should we change it?
The clause, as written, uses the term room, as opposed to the more general term “space” – yet, the committee notes that, for instance, a therapy “room” doesn’t have to be a room, as long as a space in a multi-functional set up can be carved out with the appropriate dividers. To avoid the confusion of the reader, recommend using the more general term “space” (which could be a separate room, but doesn’t have to be).
Heading text
12.4 Design of childcare activity rooms
Heading number portion
12.4
Item id
1779981238857_999
Heading id
12.4.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
All classrooms in a childcare centre shall: a. comply with Clause 15.3; b. be designed to accommodate a specific or maximum number of children, teachers, and staff; c. provide non-overlapping stationary position clear space as per Clause 12.1.2 for the number of people to be accommodated as per item b) of this Clause; d. provide at least one turning diameter clear space of 2,100 mm permitted to overlap with the stationary positions
What should we change it to?
No suggested change to the language; see attached file for suggestions on how to re-organize this clause to be more easily readable
Why should we change it?
These four items are repeated throughout 12.4.1-12.4.6. Suggest pulling them out and making them a “general requirements” list at the beginning of the overall clause.
Heading text
12.4.1 Classrooms and learning spaces
Heading number portion
12.4.1
Item id
1779981284650_716
Heading id
12.4.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
“Classrooms and learning spaces”
What should we change it to?
“Classrooms” [delete reference to learning spaces] OR “Learning Spaces” AND insert a definition in Clause 9
Why should we change it?
“Learning space” seems to be the more general term than classroom, unless it is being thought of differently. Recommend defining it, or taking it out, since it’s not used consistently throughout the standard.
Heading text
12.4.1 Classrooms and learning spaces
Heading number portion
12.4.1
Item id
1779981376400_743
Heading id
12.4.2
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note 2: Flexibility in the design of multi-purpose and multi-functional spaces allows for the efficient use of spaces where the childcare centre space is limited, demographics are not known, or demographics are non-specific. The designer is encouraged to design spaces that comply with as many requirements as possible in Clause 12.4 to maximize the possible utility and flexibility of the space.
What should we change it to?
Note 2: Flexibility in the design of multi-purpose and multi-functional spaces allows for the efficient use of spaces where the childcare centre space is limited, demographics are not known, or demographics are non-specific. The designer is encouraged to design spaces that comply with as many requirements as possible in Clause 12.4 to maximize the possible utility and flexibility of the space.
Why should we change it?
No change to text; recommend a change in location, given the proposed reorganization of Clause 12.4 See attached file for placement.
Heading text
12.4.2 Therapy rooms
Heading number portion
12.4.2
Item id
1779981408743_400
Heading id
12.4.2
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
be designed to accommodate a specific and known number of children, teachers, and staff but not less than two people (e.g., one therapist and one child);
What should we change it to?
be designed to accommodate a specific and maximum number of children, teachers, and staff but not less than two people (e.g., one therapist and one child);
Why should we change it?
Change wording to be consistent with the language in the other room requirements. Practically, for childcare centre staff using this standard, there is no meaningful difference between “specific and known” and “specific and maximum.”
Heading text
12.4.2 Therapy rooms
Heading number portion
12.4.2
Item id
1779981450300_849
Heading id
12.4.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note 5: Flexibility in the design of multi-purpose and multi-functional spaces allows for the efficient use of spaces where the childcare centre space is limited, demographics are not known, or demographics are non-specific. The designer is encouraged to design spaces that comply with as many requirements as possible in Clause 12.4 to maximize the possible utility and flexibility of the space.
What should we change it to?
Delete
Why should we change it?
No change to text; recommend a change in location, given the proposed reorganization of Clause 12.4 (Move this language to a “general room requirements” section) See attached file for placement.
Heading text
12.4.3 Music rooms
Heading number portion
12.4.3
Item id
1779981498637_680
Heading id
12.4.3
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Note 5: Accessible instrument storage should not obstruct egress paths and should comply with fire safety and emergency egress requirements of the AHJ.
What should we change it to?
Note 5: Accessible instrument storage should not obstruct egress paths and should comply with fire safety and emergency egress requirements of the AHJ.
Why should we change it?
Why not make this a requirement? It reads as if it were a critical piece, as it has to do with egress and safety. (No change to wording recommended – having it stay as a pair of “should” requirements would be OK.)
Heading text
12.4.3 Music rooms
Heading number portion
12.4.3
Item id
1779981538547_661
Heading id
12.4.4
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note: Flexibility in the design of multi-purpose and multi-functional spaces allows for the efficient use of spaces where the childcare centre space is limited, demographics are not known, or demographics are non-specific. The designer is encouraged to design spaces that comply with as many requirements as possible in Clause 12.4 to maximize the possible utility and flexibility of the space.
What should we change it to?
Delete
Why should we change it?
No change to text; recommend a change in location, given the proposed reorganization of Clause 12.4 (Move this language to a “general room requirements” section) See attached file for placement.
Heading text
12.4.4 Sensory rooms
Heading number portion
12.4.4
Item id
1779981585190_127
Heading id
12.4.5
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
be designed to accommodate a maximum of two people;
What should we change it to?
The wording change is limited to the number of people the room is built to hold at maximum
Why should we change it?
Why only 2 people? This would imply that a student and a staff person are in the room simultaneously, and no more than that.
Heading text
12.4.5 Quiet rooms
Heading number portion
12.4.5
Item id
1779981631974_288
Heading id
12.4.5
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
provide a “safety bed and chair” within the space
What should we change it to?
Add a note describing what this is
Why should we change it?
What is a “safety bed and chair?” This terminology is unclear and needs to be defined. Has the committee checked this requirement against provincial public health and childcare guidance to ensure that this requirement aligns with existing policies?
Heading text
12.4.5 Quiet rooms
Heading number portion
12.4.5
Item id
1779981687114_860
Heading id
12.4.5
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note 2: Flexibility in the design of multi-purpose and multi-functional spaces allows for the efficient use of spaces where the childcare centre space is limited, demographics are not known, or demographics are non-specific. The designer is encouraged to design spaces that comply with as many requirements as possible in Clause 12.4 to maximize the possible utility and flexibility of the space.
What should we change it to?
Delete
Why should we change it?
No change to text; recommend a change in location, given the proposed reorganization of Clause 12.4 (Move this language to a “general room requirements” section) See attached file for placement.
Heading text
12.4.5 Quiet rooms
Heading number portion
12.4.5
Item id
1780076056716_218
Heading id
12.4.6
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Clause 12.4.6 and Clause 12.4.7
What should we change it to?
No recommended changes to text
Why should we change it?
In streamlining how Clause 12.4 is structured, recommend placing the two sections on multi-purpose and multi-functional rooms directly after a new general requirements section. See attached document for new suggested organization of this clause.
Heading text
12.4.6 Multi-purpose rooms
Heading number portion
12.4.6
Item id
1780076162716_38
Heading id
12.4.6
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Clause 12.4.6 and 12.4.7 (Language from 12.4.6 only) Multi-purpose rooms shall be designed to accommodate a variety of activities and adaptive uses. They may function as a sensory room, quiet room, play area, classroom, therapy room, meeting room, or dining area.
What should we change it to?
(Edited language from 12.4.6 only) Multi-purpose rooms shall be designed to accommodate a variety of activities and adaptive uses, one use at a time.
Why should we change it?
The distinction between a multi-purpose space and a multi-functional space is not clear in the current draft of this standard. It took several readings of the text to determine that a multi-purpose room can have many different, but sequential, uses, while a multi-functional room can have many different, but simultaneous uses. Commonly, childcare centres will have rooms that function as both a multi-purpose room and a multi-functional room, in that many different activities can be supported both simultaneously and sequentially.
Heading text
12.4.6 Multi-purpose rooms
Heading number portion
12.4.6
Item id
1780076208826_623
Heading id
12.4.8
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Spaces that are primarily designated for movement between adjacent rooms and spaces that are less than 1,800 mm in length shall: a. except as stated in item b) in this Clause below, comply with Clause 12.1.1 after the installation of all furniture, equipment, etc. (e.g., trash bins, office supply cabinets, mini fridges, etc.); or b. have a minimum clear width of 1,600 mm. Note: A clear width dimension of 1,800 mm is preferred to allow multiple wheeled mobility device users (e.g., teacher and child) to navigate the hallways more easily.
What should we change it to?
No recommended change to text
Why should we change it?
It was unclear on several read-throughs what this clause refers to. It doesn’t seem to refer to corridors, but rather to interstitial pathways between rooms, which may also contain furniture or other items. The committee should consider adding a note to provide greater clarity on what it was envisioning for these types of spaces, and how they differ from other spaces within a childcare centre.
Heading text
12.4.8 Space and movement considerations
Heading number portion
12.4.8
Item id
1780076336368_982
Heading id
12.4.9.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
c) be adjustable between 400 mm and at least 1,100 mm when they are intended to be used by both;
What should we change it to?
be adjustable between 400 mm and at least 860 mm when they are intended to be used by both;
Why should we change it?
The max height for adults only use is 860 mm, from item a. Why this greater height for combined use?
Heading text
12.4.9.1 Adjustable tables and desks
Heading number portion
12.4.9.1
Item id
1780076392732_374
Heading id
12.5
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Indoor play areas and recreation zones
What should we change it to?
Provide a less ambiguous title and description for what this clause refers to – or consider integrating it into the relevant sections of 12.4.
Why should we change it?
Can we define what an indoor play area is? A lot of play happens in what would be considered to be a classroom or a multi-purpose/multi-function room, so how is the notion of a play area or recreation zone different from that? Is this referring to an indoor gymnasium space?
Heading text
12.5 Indoor play areas and recreation zones
Heading number portion
12.5
Item id
1780076437199_425
Heading id
12.5.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Sensory zones
What should we change it to?
Consider integrating the requirements into the appropriate clause for sensory spaces in Clause 12.4, and deleting this section.
Why should we change it?
Are these intended to be sensory zones inside a gymnasium like space? Why not simply merge this set of requirements with those for sensory rooms in Clause 12.4?
Heading text
12.5.2 Sensory zones
Heading number portion
12.5.2
Item id
1780076512755_269
Heading id
12.6.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Bathrooms shall: a. where intended for staff and other adults: i. comply with clause 6.2 of CSA/ASC B651:23; or ii. comply with clause 6.3 of CSA/ASC B651:23 for universal washrooms. b. where intended for children and adults: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; ii. have stall privacy screens and doors no higher than 150 mm from the floor; iii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86; iv. have sanitary disposal receptacles that are not foot activated, are operable with a closed fist, and that are installed on the wall near the front of the toilet; and v. have sharps disposal containers installed at a maximum height of 1,100 mm from the finished floor, where provided. Note 1: For adult-assisted toileting spaces, adjustable-height toilets should be provided where feasible, to accommodate diverse needs, including mixed-age users and those requiring assistance. Note 2: The emergency call system should be located within reach of being seated on the toilet and 300 mm above the floor.
What should we change it to?
Bathrooms shall: a. where intended for staff and other adults: i. comply with clause 6.2 of CSA/ASC B651:23; or ii. comply with clause 6.3 of CSA/ASC B651:23 for universal washrooms. b. where intended for use by children, with adult assistance: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; ii. have stall privacy screens and doors no higher than 150 mm from the floor; iii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86; iv. have sanitary disposal receptacles that are not foot activated, are operable with a closed fist, and that are installed on the wall near the front of the toilet; and v. have sharps disposal containers installed at a maximum height of 1,100 mm from the finished floor, where provided. Note 1: For adult-assisted toileting spaces, adjustable-height toilets should be provided where feasible, to accommodate diverse needs, including mixed-age users and those requiring assistance. Note 2: The emergency call system should be located within reach of being seated on the toilet and 300 mm above the floor.
Why should we change it?
12.6.1b initially read as if both children and adults would use the toilet facilities in the same bathroom. We do not believe this was the intent, as that use case would never happen in non-home based childcare facility. Was the intent, rather, to have 12.6.1b refer to bathrooms used by children, with adult assistance or supervision? If yes, a simple wording change as recommended would address this.
Heading text
12.6.1 Accessible bathrooms
Heading number portion
12.6.1
Item id
1780076577254_996
Heading id
12.6.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
where intended for children and adults: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; ii. have stall privacy screens and doors no higher than 150 mm from the floor; iii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86; iv. have sanitary disposal receptacles that are not foot activated, are operable with a closed fist, and that are installed on the wall near the front of the toilet; and v. have sharps disposal containers installed at a maximum height of 1,100 mm from the finished floor, where provided.
What should we change it to?
where intended for use by children under the age of 6 years, with adult assistance: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; and ii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86 where intended for use by children over the age of 6 years, with or without adult assistance: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; ii. have stall privacy screens and doors no higher than 150 mm from the floor; iii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86; iv. have sanitary disposal receptacles that are not foot activated, are operable with a closed fist, and that are installed on the wall near the front of the toilet; and v. have sharps disposal containers installed at a maximum height of 1,100 mm from the finished floor, where provided.
Why should we change it?
Items ii, iv and v in this list do not apply for bathrooms intended for use by children under the age of 5 or 6 years. Older children would need privacy screens in shared bathrooms, true – but that use case needs to be separated out and given its own requirement.
Heading text
12.6.1 Accessible bathrooms
Heading number portion
12.6.1
Item id
1780076631406_136
Heading id
12.6.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Bathrooms shall: a. where intended for staff and other adults: i. comply with clause 6.2 of CSA/ASC B651:23; or ii. comply with clause 6.3 of CSA/ASC B651:23 for universal washrooms. b. where intended for children and adults: i. comply with clause 6.2.6.1 a) of CSA/ASC B651:23 except the toilet fixtures shall have the top located between 250 mm and 280 mm above finished floor; ii. have stall privacy screens and doors no higher than 150 mm from the floor; iii. have shatterproof mirrors complying with CAN/CGSB 12.5-M86; iv. have sanitary disposal receptacles that are not foot activated, are operable with a closed fist, and that are installed on the wall near the front of the toilet; and v. have sharps disposal containers installed at a maximum height of 1,100 mm from the finished floor, where provided. Note 1: For adult-assisted toileting spaces, adjustable-height toilets should be provided where feasible, to accommodate diverse needs, including mixed-age users and those requiring assistance. Note 2: The emergency call system should be located within reach of being seated on the toilet and 300 mm above the floor.
What should we change it to?
Recommendation for the committee to create a new requirement, with appropriate space considerations to account for adult assistance of children in the bathroom.
Why should we change it?
Missing from the set of requirements around accessible bathrooms is guidance around sufficient space for adults (especially adults who may use mobility aids) to assist children (especially children who use mobility aids). Clearance between toilets, for example, that allows an adult in between them. Width of the floor area separating toilets from sinks. Related to this issue is the notion that in practice, these are shared bathroom facilities that are in use by the children, and they should be designed with a specific and maximum number of children and adults in mind (similar to language used in Clause 12.4).
Heading text
12.6.1 Accessible bathrooms
Heading number portion
12.6.1
Item id
1780076679799_44
Heading id
12.6.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
have an adjustable table with the option to be lowered to 300 mm in height from the floor;
What should we change it to?
Consider making this a “should” statement, rather than a “shall” – OR, provide details on adjustable height change tables that meet the requirement in a note.
Why should we change it?
In principle, this is a good requirement – in practice, it is very difficult to implement in a childcare centre without additional guidance that accounts for the practical realities of the childcare setting.
Heading text
12.6.2 Change tables
Heading number portion
12.6.2
Item id
1780076722871_204
Heading id
12.6.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
be equipped with a safety strap to safely hold a person 75 kg in weight from accidentally rolling off;
What should we change it to?
Recommend deleting.
Why should we change it?
This contravenes public health guidance in Ontario (safety straps of this nature are next to impossible to keep clean; to mitigate germ transmission, they aren’t recommended), as well as poses a barrier to the child maintaining their dignity.
Heading text
12.6.2 Change tables
Heading number portion
12.6.2
Item id
1780076768567_683
Heading id
12.6.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
have a concave top surface or a lip;
What should we change it to?
have a concave top surface or a lip, with a minimum height difference of x mm between the top of the lip and the lowest point of the changing surface;
Why should we change it?
A degree of concavity should be recommended here; the concave surface here, if designed right, will do most of the work of preventing someone from accidentally rolling off.
Heading text
12.6.2 Change tables
Heading number portion
12.6.2
Item id
1780076853292_844
Heading id
heading-78
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
Privacy for both children and adults in a childcare centre is a priority. Childcare centres shall have at least one toileting assistance bathroom. Toileting assistance bathroom shall: a. comply with Clause 12.6.1; b. have the stationary position clear space required by Clause 12.6.1 that does not overlap with any other clear space requirements (e.g., turning diameter clear space, grab bar clearance, etc.); and c. not be located in direct view of the entrance, waiting areas, play areas, or other areas where children commonly gather to allow caregivers to provide assistance with minimal exposure during entry and exit. Note: Adults and children who are unable to activate the emergency call system should always be accompanied by another person.
What should we change it to?
Recommend to add a note: Note: The age and functional needs of children requiring toileting assistance should be taken into consideration when ensuring appropriate set up of bathrooms for toileting assistance; as such considerations around preservation of privacy and protecting the dignity of the child.
Why should we change it?
This clause is confusing, as it seems to imply a use case where adult caregivers (not childcare centre staff) will provide toileting assistance to their children, and that this will be done in a separate bathroom than the facilities that the child might use otherwise during their time at the childcare centre. (If this wasn’t the use case contemplated, it will be important to review the language for clarity.)
Heading text
12.6.3.1 Privacy considerations
Heading number portion
12.6.3.1
Item id
1780076902491_760
Heading id
12.7
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Kitchen and Dining Area
What should we change it to?
Kitchen and Dining Areas for Staff and Children
Why should we change it?
Is the dining area contemplated in this clause for staff? Or children? Or both? A separate, common, dining area for all staff and children seems to be what was in mind when this clause was written, but, again, that use case does not necessarily reflect reality…
Heading text
12.7 Kitchen and Dining Area
Heading number portion
12.7
Item id
1780076959961_363
Heading id
12.7.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Dining areas shall: a. be designed to accommodate a specific and known number of children, teachers, and staff; b. provide non-overlapping stationary position clear space as per Clause 12.1.2 for the number of people to be accommodated as per item a) of this Clause; c. be served by a path of travel that complies with Clause 12.1.1; d. have adjustable tables that comply with Clause 12.4.9.1; e. provide at least one turning diameter clear space of 2,100 mm permitted to overlap with the stationary positions; f. include a 30% minimum Michelson luminance (colour) contrast complying with clause 4.2 CSA/ASC B651:23 between key elements such as tables, walls, floors, door, etc.; g. have a transfer space of 900 mm x 1,500 mm where a transition from a wheeled mobility device to a solid chair is required; and h. have a sink that complies with clause 5.10.7 of CSA/ASC B652:23. Note 1: The flexibility of movable furniture, such as tables and chairs in the dining area, enhances the ability to create an accessible dining layout that accommodates varying occupancies and needs. Note 2: Consider a mix of chairs with and without armrests to accommodate different mobility needs. Note 3: Dining areas should be separate from high-risk kitchen zones to ensure child safety. This is best achieved in separate kitchen and dining area layouts. Note 4: Consider providing a separate quiet area or sensory-friendly seating option for children who require a low-stimulation environment.
What should we change it to?
Consider, at minimum, a note added to this clause that highlights that staff may eat with children in dining areas integrated into the children’s activity areas, but there is also the need to ensure that there is a dining area as part of the break room/staff workspace. Consider adding the sink requirement (12.7.3h) to the clauses describing requirements for classrooms, multi-purpose rooms and multi-functional rooms.
Why should we change it?
Given how this section is written, a few things were clear: First, a staff dining area was not contemplated (this should be integrated into 14.2, or given a separate subclause in 12.7.3). Second, this clause assumes a permanent dining area, which doesn’t match with common practice. In many childcare centres, the dining areas are repurposed from the classrooms/multi-functional rooms where activities go on – meals are just another activity. Indeed, in that context, would 12.7.3 not be better served being integrated into the language in 12.4? Third, clause 12.7.3h should also apply to classrooms, multi-functional rooms and multi-purpose rooms.
Heading text
12.7.3 Dining area
Heading number portion
12.7.3
Item id
1780077021143_519
Heading id
s12.9
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Locker rooms shall: a. have a total bench length (single or multiple benches) of 2,400 mm; b. have benches that comply with clause 6.4 of CSA/ASC B651:23, except for item d), where the top surface height from the floor is permitted to be as low as 305 mm where justified by the demographics of the childcare centre (see note below); and c. comply with clause 6.8 of CSA/ASC B651:23. Note: Clause 6.4 of CSA/ASC B651:23 requires that locker room benches be mounted with their top surface 480 mm to 520 mm from the floor. However, benches intended for children may be as low as 300 mm. Depending on the design and demographics of the childcare centre, the height of the benches will need to be mixed between those that comply with CSA/ASC B651:23 and those which are 305 mm above the floor. Where possible, particularly in smaller rooms, height-adjustable benches should be used to accommodate both adults and children.
What should we change it to?
Make this a “should” not a “shall”
Why should we change it?
Many childcare centres don’t have locker rooms at all for children, and don’t have space for locker rooms for staff.
Heading text
12.9 Locker rooms
Heading number portion
12.9
Item id
1780077110054_276
Heading id
14.1
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
14.1 Accessible staff workspaces Accessible staff workspaces shall: a. be served by a path of travel that complies with Clause 12.1.1; b. have a stationary clear space complying with Clause 12.1.2 for each workstation or equipment; c. have a turning diameter clear space of 2,100 mm that does not overlap with the stationary clear space; and d. have desks or tables that comply with Clause 12.4.9.1. Note 1: The turning space not overlapping with the stationary space allows one person in a wheeled mobility device to be moving while another person remains stationary in the workspace. Note 2: When purchasing goods and services, accessibility specifications should be carefully considered. The operational requirements should consider accessibility for both the staff who operate the goods or services and the individuals who will benefit from them. Since accessibility needs vary on a case-by-case basis, specifications cannot be assumed. It is essential to evaluate the specific needs of the individuals who will operate and benefit from the goods or services, identifying requirements that are both accessible and practical for them. Selecting accessible technologies that accommodate multiple accessibility needs is often the most effective approach. 14.2 Break rooms and rest areas Break rooms and rest areas shall: a. be served by a path of travel that complies with Clause 12.1.1; b. where provided, have seating that complies with clause 6.7.2 of CSA/ASC B651:23; c. have stationary clear space in accordance with Clause 12.1.2 for a known number of staff but not less than two people; and d. have a turning diameter clear space of 2,100 mm that does not overlap with at least one of the provided stationary clear spaces.
What should we change it to?
Recommend combining these two clauses into a single clause
Why should we change it?
In many childcare centres, from a practical standpoint, these are the same spaces. Consider merging into a single clause, and adding a note indicating that, while they could be separate spaces, they do not have to be.
Heading text
14.1 Accessible staff workspaces
Heading number portion
14.1
Item id
1780077169285_531
Heading id
14.1
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
14.1 Accessible staff workspaces Accessible staff workspaces shall: a. be served by a path of travel that complies with Clause 12.1.1; b. have a stationary clear space complying with Clause 12.1.2 for each workstation or equipment; c. have a turning diameter clear space of 2,100 mm that does not overlap with the stationary clear space; and d. have desks or tables that comply with Clause 12.4.9.1. Note 1: The turning space not overlapping with the stationary space allows one person in a wheeled mobility device to be moving while another person remains stationary in the workspace. Note 2: When purchasing goods and services, accessibility specifications should be carefully considered. The operational requirements should consider accessibility for both the staff who operate the goods or services and the individuals who will benefit from them. Since accessibility needs vary on a case-by-case basis, specifications cannot be assumed. It is essential to evaluate the specific needs of the individuals who will operate and benefit from the goods or services, identifying requirements that are both accessible and practical for them. Selecting accessible technologies that accommodate multiple accessibility needs is often the most effective approach.
What should we change it to?
14.1 Accessible staff workspaces or Offices Accessible staff workspaces or offices shall: a. be served by a path of travel that complies with Clause 12.1.1; b. have a stationary clear space complying with Clause 12.1.2 for each workstation or equipment; c. have a turning diameter clear space of 2,100 mm that does not overlap with the stationary clear space; and d. have desks or tables that comply with Clause 12.4.9.1. Note 1: The turning space not overlapping with the stationary space allows one person in a wheeled mobility device to be moving while another person remains stationary in the workspace. Note 2: When purchasing goods and services, accessibility specifications should be carefully considered. The operational requirements should consider accessibility for both the staff who operate the goods or services and the individuals who will benefit from them. Since accessibility needs vary on a case-by-case basis, specifications cannot be assumed. It is essential to evaluate the specific needs of the individuals who will operate and benefit from the goods or services, identifying requirements that are both accessible and practical for them. Selecting accessible technologies that accommodate multiple accessibility needs is often the most effective approach.
Why should we change it?
There is a provincial requirement in Ontario for staff to have an office at a childcare centre. Suggest using similar language so that the standard is easier to implement.
Heading text
14.1 Accessible staff workspaces
Heading number portion
14.1
Item id
1780077217719_926
Heading id
s14.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
14.2 Break rooms and rest areas Break rooms and rest areas shall: a. be served by a path of travel that complies with Clause 12.1.1; b. where provided, have seating that complies with clause 6.7.2 of CSA/ASC B651:23; c. have stationary clear space in accordance with Clause 12.1.2 for a known number of staff but not less than two people; and d. have a turning diameter clear space of 2,100 mm that does not overlap with at least one of the provided stationary clear spaces.
What should we change it to?
Include a provision for service dog rest area in this space as well.
Why should we change it?
A space is required for service dogs on site, whose handlers are staff, to rest when they are not working, or when it is not practical or permitted for them to be with their handlers when working with children.
Heading text
14.2 Break rooms and rest areas
Heading number portion
14.2
Item id
1780077285155_609
Heading id
15.2
What kind of suggestion are you making?
Technical such as dimensions or application of the standard
What should we change?
e) provide ambient light levels at least 200 lx in the dining area;
What should we change it to?
e) provide ambient light levels at least 200 lx in spaces that are used as dining areas;
Why should we change it?
This requirement assumes a separate dining area, and there may not be.
Heading text
15.2 Lighting (illumination) design
Heading number portion
15.2
Item id
1780077329678_669
Heading id
15.3
What kind of suggestion are you making?
Editorial such as spelling, grammar, formatting and accessibility
What should we change?
Note 3: Installing hearing loop, FM, or Bluetooth-compatible systems in reception areas, meeting rooms, and learning spaces are encouraged to enhance accessibility.
What should we change it to?
Note 3: Installing hearing loop, FM, or Bluetooth-compatible systems in reception areas, meeting rooms, and children’s activity spaces are encouraged to enhance accessibility.
Why should we change it?
The standard uses inconsistent terminology to refer to children’s activity spaces – “learning spaces” is used here, while this seems to be a classroom space as established in 12.4. “Children’s activity soaces” seems to be a broader term that could be used as an umbrella throughout the standard.
Heading text
15.3 Acoustic design
Heading number portion
15.3
Item id
1780077368989_782
Heading id
s18.3
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
Childcare centres shall have a maintenance plan in place to ensure that all accessibility features and safety are kept fully operational. Maintenance plans include but are not limited to: a. quarterly feature testing; b. quarterly emergency egress drills; c. instant reporting system for damage or malfunctioning equipment; d. an established service network for fast repair of critical equipment; and e. annual accessibility audit. Note: Responsibility for accessibility upkeep should be assigned to a designated accessibility coordinator.
What should we change it to?
Consider adding a requirement about timely snow removal during winter for exterior paths of travel, specifically those enumerated in Clauses 10 and 16.
Why should we change it?
There is nothing in this standard about exterior paths of travel (e.g., those referenced in Clauses 10 and 16) needing to be kept clear during all seasons. Particularly with winter, snow removal is both a safety and accessibility consideration.
Heading text
18.3 Regular upkeep
Heading number portion
18.3
Item id
1780077452638_951
Heading id
s5
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
n/a
What should we change it to?
n/a
Why should we change it?
There is no language or requirement in this standard for children’s rest areas. Many childcare centres repurpose a classroom into a communal rest area at naptime, and don’t have a dedicated rest area. Consider including a set of requirements to define how rest areas are designed and set up.
Heading text
6. Introduction
Heading number portion
6.
Item id
1780077483732_373
Heading id
s5
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
n/a
What should we change it to?
Minimum interior design needs for a childcare centre: A classroom or multifunctional room An accessible children’s bathroom A children's dining area, which might be integrated into the multi-functional room A children’s rest area, which might be integrated into the multi-functional room A staff office or workspace A staff break room or rest area An accessible adult washroom An exterior play area All other design elements described in this standard are good to have, but not essential. Include references to all appropriate clauses.
Why should we change it?
The standard would benefit greatly from a section that highlights the minimum components of a childcare centre.
Heading text
6. Introduction
Heading number portion
6.
Item id
1780077517522_610
Heading id
s5
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
n/a
What should we change it to?
n/a
Why should we change it?
The comments provided in this submission are jointly submitted by IDEA-STEM Consulting Inc and Unity Childcare Centres, based in Kingston, ON. They combine lived, living and professional experiences across several relevant and intersecting domains: 1. Standards development; 2. Owning and operating a business that runs multiple childcare centres in the city of Kingston (including one that is specifically designed and marketed at inclusive to children with disabilities, which also employs staff with disabilities); 3. Parent of a neurodivergent child; 4. Parent with a disability.
Heading text
6. Introduction
Heading number portion
6.
Submission ID
65444
Submitted by
sweiner
Submitted on
Fri, 05/29/2026 - 13:59
Consent to contact
Yes

Individual 65457's submission

CAN-ASC-4.1 Accessible Procurement
Feedback items
Item id
1779994451901_333
Heading id
s10
What kind of suggestion are you making?
General comments on the overall standard or a section such as things that are missing
What should we change?
To the Accessible Procurement Resource Centre (APRC) Suggested feedback re Draft Standard for Accessible Procurement Thank you for the opportunity to provide feedback on the draft standard for accessible procurement. At the Document Imaging Solutions Centre (DISC) of PSPC, we have had the pleasure of working with our procurement colleagues in the development of the National Master Standing Offer (NMSO) for digitization services currently available to the federal government and to other public sector organizations in Canada under the Canadian Collaborative Procurement Initiative (CCPI). We are very pleased that our expertise when combined with that of Procurement Branch helps other organizations achieve their digitization and data enrichment objectives in a cost-effective and technically correct manner, meeting all required Government of Canada standards. Related to accessibility, DISC will complete an Accessibility Digitization project under the Innovative Solutions Canada (ISC) program by October 2027 that will be invaluable in meeting the objectives set out in the standard for Accessible Procurement and the Government of Canada obligations under the Accessible Canada Act 2019. The area of focus is the Information Management section. The project is developing a software solution with the support of the Innovative Research Solutions Division-Challenges (SI). The software solution will meet the change statement posted on the ISC website; https://ised-isde.canada.ca/site/innovative-solutions-canada/en/turning-pixels-data-imaging-accessibility which seeks to fully automate the remediation of static file formats like PDF into dynamic file formats like HTML5 and ePub3 so that accessibility tools like JAWS (Job Access With Speech) which is an example of a screen reader that converts on-screen text, menus, and controls into synthesized speech or Braille. It empowers individuals who are blind or have low vision to navigate computers, browse websites, and operate applications independently. The software solution has cleared Phase 1 and we are at milestone 4 of 12 in Phase 2 of the prototype development using a multi-model AI architecture to remediate high volume of information management assets with high quality and low cost. We would like to suggest that the standard recognize the importance of remediation of static information management assets and partner with DISC for solutions when vendors submit materials in a static file format and/or public servant employees require materials in accessible formats to be able to do their job within Procurement Branch.
What should we change it to?
x
Why should we change it?
x
Heading text
11. Procurement information, websites, and applications
Heading number portion
11.
Submission ID
65457
Submitted by
bruce.covington@pwgsc.gc.ca
Submitted on
Thu, 05/28/2026 - 14:54
Consent to contact
Yes

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Date modified:
2026-08-02

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