Code change requests should include:
- the existing code requirement, if applicable,
- the reasons for the change or addition,
- your proposed revision or new requirement,
- supporting documentation, including any information on costs and benefits,
- enforcement implications, and
- the related code objectives.
Some examples of common changes include:
- accommodating new construction techniques and systems,
- clarifying requirements,
- updating references to standards, and
- proposing expansion of scope or objective.
Suggestions for changes to the National Model Codes are welcome from anyone at any time. Individuals and organizations interested in submitting a code change request should consider the following points:
Consideration by code development committees: To bring about a change in one of the National Model Codes, sufficient information must be provided that allows the CBHCC and its code development committees to consider whether a suggested change warrants a change to the code. Code development committees are made up of volunteers chosen for their expertise to represent various perspectives of the construction industry in Canada.
Clarity: Code change requests should identify the perceived shortcomings of the existing model code, and existing code provisions that would be affected by the change. New wording should be suggested to address these shortcomings. Proponents of code change requests that lack clarity may be contacted for further clarification.
Focus on generic/widespread issues: The Codes do not reference proprietary building products. Rather, they establish the criteria that building materials, products and assemblies must meet. Innovative proprietary products that are not yet covered by referenced standards or that do not fall within the parameters specified in the Codes are not necessarily excluded from use; they can be accepted by local authorities based on the compliance provisions in the Codes regarding alternative solutions (equivalents). Similarly, unique situations are best addressed by local authorities.
Focus on technical issues: With few exceptions, the National Model Codes are technical in nature and do not address administrative issues, such as what professional qualifications are required to perform certain functions or whether certification by a particular agency of products’ compliance with standards is necessary. Such administrative provisions are the purview of regulating authorities having jurisdiction. Code change requests should therefore address technical issues, which in the National Building Code of Canada (NBC), National Fire Code of Canada (NFC), National Energy Code of Canada for Buildings (NECB) and National Plumbing Code of Canada (NPC) are typically covered in Division B of these documents.
Objectives and functional statements: The NBC, NFC, NECB and NPC are objective-based codes. This means that the objectives and functional statements that each code provision addresses are clearly stated. It follows that an objective-based code will only contain provisions that are related to achieving at least one of its stated objectives and functional statements.
The objectives and functional statements of the NBC, NFC, NECB and NPC are determined by the CBHCC. The objectives and functional statements are listed in Parts 2 and 3 of Division A of each code. Persons submitting a code change request to the NBC, NFC, NECB or NPC should ensure that the requested change is linked to at least one of the code’s stated objectives and functional statements. Any requested changes to the existing objectives and functional statements should be well supported and clearly identify the need to change the scope of the Codes.
Supporting documentation: Code change requests should be accompanied by enough documentation to make the case that a change is needed, and that the requested change is the optimal change. This documentation can include information such as research and testing results, statistics, and case studies.
Impact analysis: Information on the likely benefits and costs associated with the change’s implementation should be provided since proposed code changes include an impact assessment.
Proponents of code change requests should also bear in mind the availability of suitable means to verify compliance. Code changes may not be possible where there are no existing tools that can be used to evaluate whether a design or construction conforms to the provision. Code change requests should therefore include information on conformity verification and enforcement implications, including available resources.
Timing: Although suggestions for changes to the National Model Codes are welcome from anyone at any time, the Codes are generally revised and published on a five year cycle; therefore there may be a period of time between the submission of a code change request, consideration of the code change request, and the publication of a proposed change, if applicable. Code development is generally substantially completed two years prior to publication in order to allow time for further iterations stemming from public review comments.
Persons with an interest in the contents of the National Model Codes can maintain an awareness of code development progress by participating in public reviews and by volunteering on a code development committee. Observers can also attend meetings of code development committees, task groups, and the Advisory Council on Harmonized Construction Codes, as well as public meetings of the CBHCC.
Code change request status: Code change requests can be submitted by anyone with an interest in improving the Codes. Code change requests are entered into a database where they are given a unique identification number for tracking purposes.
Proponents can follow the status of their requests by using the code change request tracking database.
Privacy notice and consent: In order to submit a request for a change to National Model Codes, personal information such as name, affiliation and email address will be required. The information submitted as part of the code change request, together with the proponent’s personal information, may also be included in meeting agendas and the appendices of meeting minutes for completeness of records. Except as required by confidentiality requirements, meeting minutes are available to the public.
Personal information is collected as it may be necessary to contact a proponent if a code change request is incomplete or missing essential information, or if clarification is needed. The purpose of the collection is to ensure that the code development work is unbiased, based on consensus, and that the source of the request is clearly identified.
The collection and use of personal information are in accordance with the federal Privacy Act. The Privacy Act states that persons have the right to access their personal information. Contact the CBHCC to report inaccurate information or to withdraw your request after submission.
By clicking on the “I agree” button below, you are confirming that you have read this notice and are in agreement with the collection and use of your information as stated above.
If you do not agree to the above terms and conditions, click “I decline”, in which case you will not be able to proceed to the code change request form.