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.
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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.
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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.
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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.
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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.
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18.2 Laundry areas
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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7.4 Limits
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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.
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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.
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9.1 Definitions
Heading number portion
9.1
Submission ID
65355
Submitted by
sweiner