Proposed Change 1957

The ability to access controls and receptacles (e.g., light switches) in the dwelling is essential for people to live independently. However, as people age, disabilities become more common, and Canadians over the age of 65 are nearly twice as likely to be disabled compared to those who are 20–64 years old [1].

Consequently, controls that were once accessible when a person moved into a dwelling may no longer be accessible as the person's health status evolves. This situation can create problems for persons with disabilities related to balance and mobility (particularly those who use wheelchairs or scooters while seated, as well as those at a higher risk of falls while reaching up or bending down) as they may not be able to reach controls in the dwelling that have been installed too high or too low. Persons who use mobility aids (including walkers and rollators) also experience difficulty in reaching controls when the controls are located in the inside corners of a room and the mobility aid is blocked by the adjacent wall.

When renovating a dwelling unit, repositioning certain controls for accessibility is possible. However, repositioning hard-wired controls, such as light switches, is expensive and labour intensive relative to installing the controls in accessible locations when the dwelling is first built.

This proposed change introduces new requirements for the design and installation of controls in dwelling units so that they can be more easily reached by persons with disabilities related to balance and mobility. Specifically, this proposed change constrains the installation location of certain types of controls (e.g., light switches, electrical outlets and regularly operated components of security systems) in a dwelling unit to be within a height range of 400 mm to 1 200 mm above the finished floor or ground surface. Moreover, where controls are to be installed in inside corners of a room, this proposed change would require them to be located at least 300 mm from the inside corner.

Approximately 10% of Canadians report having a disability related to mobility [1], while 1% of Canadians who live in the community regularly use wheelchairs or scooters [2]. Restricting the height range of the installation location of certain types of controls would also benefit many older adults and persons with disabilities related to balance who do not use wheelchairs or scooters by reducing the need to reach extensively to access controls located in high positions or to squat, stoop or crouch to access controls located in low positions. These are activities that increase the risk of balance loss and subsequent fall or injury in older adults and persons with disabilities related to balance [3–6]. Similarly, placing restrictions on the location of controls in the inside corners of the room would make it easier for persons who use mobility aids, such as walkers or rollators (in addition to wheelchairs or scooters), to reach the controls while also using their mobility aid. By constraining the installation location of controls in dwelling units, this proposed change would limit the probability that persons with disabilities related to balance and mobility cannot safely access the building's facilities.

This proposed change complements the existing requirements in the National Building Code of Canada (NBC) for the accessible design of controls in most units in multi-unit residential buildings, as outlined in Section 3.8. of Division B. The current requirements in the NBC differ from this proposed change in that they address dexterity and focus on all controls, whereas this proposed change strictly addresses height and proximity to an inside corner for a limited range of controls. As such, this proposed change would generally affect houses and other dwelling units that do not need to comply with Section 3.8.

By focusing on specific controls that are frequently used by occupants and are expensive to relocate once installed relative to the initial installation cost, this proposed change is expected to address critical controls used in a dwelling unit while simplifying enforcement and Code compliance. This proposed change also maintains flexibility in the design of controls that are typically installed in an accessible location (e.g., door hardware and faucets) unless occupants choose to install them elsewhere.

Impact on accessibility

Being able to access controls (e.g., light switches and electrical outlets) profoundly affects one's independence while living in a dwelling unit.

This proposed change is expected to improve accessibility by facilitating the reaching of controls from a seated or standing position. Approximately 10% of Canadians over 15 years old have a disability related to mobility [1], with 1% of community-dwelling Canadians being regular users of wheelchairs and scooters [2]. While the proposed height range was originally established to facilitate persons reaching from a seated position, the proposed change would also improve the safety of persons accessing controls while standing and reduce the need for stooping, squatting or crouching to reach low positions—all of which are activities that are associated with balance loss and potential falls, even in older adults without disabilities related to balance [3–6]. Similarly, the proposed requirements for the location of controls in inside corners (i.e., at least 300 mm from the inside corner) are expected to improve the safety of persons accessing controls while using a mobility aid (e.g., walkers, rollators, wheelchairs, scooters). By requiring that controls be installed in an accessible location irrespective of wheelchair or scooter use, this proposed change would make it easier for occupants to access these controls throughout the dwelling.

Impact on financial costs

This proposed change is not expected to increase the costs of building new dwelling units, as the change would only affect the mounting location of the controls. However, implementing the proposed change to the installation height and location ranges of controls is expected to reduce the need for individuals to modify the location of controls to make them more reachable from a wheelchair or a standing position after the dwelling unit has been built. This proposed change should result in cost and time savings related to complex adjustments, such as changing the location of hard-wired electrical outlets and light switches. Designers and builders would need to be aware of the change and apply it in practice.

Impact on the provinces and territories

The impact of this proposed change would differ across provinces and territories based on (a) the type of dwelling unit, where existing requirements for the accessible design of controls in dwelling units currently apply; and (b) the specific technical components of these requirements.

This proposed change is mostly a relaxation of the adaptability requirements for controls in the Nova Scotia Building Code, Article 3.8.4.6., which apply to the design and construction of all dwelling units, including houses. Specifically, the Nova Scotia Building Code already addresses dexterity requirements (which impact the geometry and operating force of controls) and defines "controls" much more broadly. On the other hand, the Nova Scotia Building Code does not address the position of controls with respect to inside corners, whereas this proposed change does.

In the Quebec Construction Code, all dwelling units not exempt from the accessibility requirements in Section 3.8. (i.e., dwelling units in multi-unit residential buildings [MURBs]) would have to comply with this proposed change. The one key difference is that this proposed change would apply throughout the dwelling unit, whereas the current requirements in Quebec only apply to controls that are within or are adjacent to the barrier-free path of travel. The NBC proposes a broader application to address the needs of persons with mobility disabilities who do not use wheelchairs in the home, in addition to those who do.

Other provinces and territories have similar requirements for the location of controls in their provisions for accessible dwelling units, which typically apply to a percentage of units in MURBs but do not apply to houses.

Finally, the NBC 2020 requires that all buildings (including dwelling units) that are not subject to the exemptions outlined in Section 3.8. (e.g., houses) comply with the requirements for controls stated in Article 3.8.3.8. (which prescribes a height range for installation, clearance requirements around the controls to allow a wheelchair to approach and turn, and requirements to allow a person with a disability related to dexterity to operate the controls using low force and a closed fist). Thus, this proposed change would mostly affect houses; however, the requirements are relaxed compared to those for MURBs.

References

[1] Statistics Canada. (2017). “New data on disability in Canada 2017.”  https://www150.statcan.gc.ca/n1/en/pub/11-627-m/11-627-m2018035-eng.pdf?st=v5UqujRh

[2] Smith, E., Giesbrecht, E., Mortenson, W., and Miller, W. (2016). Prevalence of wheelchair and scooter use among community-dwelling Canadians. Physical Therapy, 96, 1135–1142.

[3] Glinka, M. N., Weaver, T. B., and Laing, A. C. (2015). Age-related differences in movement strategies and postural control during stooping and crouching tasks. Human Movement Science, 44, 246–257.

[4] Hernandez, M. E., Ashton-Miller, J. A., and Alexander, N. B. (2013). Age-related differences in maintenance of balance during forward reach to the floor. Journals of Gerontology Series A: Biomedical Sciences and Medical Sciences, 68(8), 960–967.

[5] Huang, M. H., and Brown, S. H. (2013). Age differences in the control of postural stability during reaching tasks. Gait & Posture, 38(4), 837–842.

[6] Nasarwanji, M. F., Paquet, V. L., and Steinfeld, E. (2012). Age differences in postural strategies for low forward reach. In M. M. Soares and F. Rebelo (Eds.), Advances in Usability Evaluation–Part I: pp. 97–118. CRC Press, Boca Raton, FL.

This proposed change could be enforced using existing Code enforcement methods for accessible controls in Part 3 buildings, including the use of a measuring tape to measure installation height.

Authorities having jurisdiction would need to be made aware of this proposed change and its distinction from existing requirements for accessible controls in Article 3.8.3.8. (which apply to a broader range of controls and also address dexterity).

Designers, builders, engineers and homeowners would need to be aware of this proposed change and select controls to comply with the proposed requirements.

Manufacturers would need to be aware of the expanded requirements for accessible controls in Canada.

Authorities having jurisdiction would need to be aware of this proposed change when evaluating building compliance.