Replace the Term "Visually Impaired Persons" with "People with Low or No Vision"
Description:
This proposed change replaces the terms "visually impaired persons" and "people with vision loss" with "people with low or no vision" in Parts 3 and 9.
Related Code Change Request(s):
CCR 1528
Related Proposed Change(s):
PCF 1342, PCF 1778
Problem
The terminology used in the National Building Code of Canada (NBC) to refer to “visually impaired persons” and “people with vision loss” is outdated and should be replaced with “people with low or no vision” (note that the other National Model Codes do not use this terminology).
A common terminology should be used to update the language in the requirements and explanatory Notes in the NBC that refer to people who are blind or have low vision to reflect the currently accepted wording. This would facilitate a consistent interpretation of the Code requirements.
Justification
Replacing “visually impaired persons” and “people with vision loss” with “people with low or no vision” in the NBC is editorial in nature and will affect the clarity and understanding of the Code’s provisions but not their meaning, intent or application.
This proposed change also harmonizes the terminology about vision that is used in the NBC with the terminology used in other standards and guidelines. Using a single terminology simplifies the interpretation of the applicable requirements and thus improves the safety of people travelling in corridors, ramps or stairs, and in other building areas. The intent of the proposed change is to focus on the functional aspects of vision and the related need for building code requirements (e.g., the need for tactile information and increased lighting) without using terminology that is associated with a person’s identity or vision level, or with the reason for or permanence of a person’s condition (e.g., disability, temporary injury or misplaced eyewear).
Although the National Model Codes aim to promote the use of consistent language, people’s experiences and terminology preferences around vision are subjective and varied.
PROPOSED CHANGE
[3.3.1.8.] 3.3.1.8.Headroom and Protruding Objects
[1] 2)Except as permitted by Sentence (3) and except for paths of travel in service rooms and dwelling units, protruding building elements located within 1 980 mm of the floor shall not project more than 100 mm horizontally into paths of travel in a manner that would create a hazard. (See Note A-3.3.1.8.(2) and (3)PROPOSED CHANGE A-3.3.1.8.(2) and (3).)
Note A-3.3.1.8.(2) and (3)Protruding Building Elements in Paths of Travel.
The term “protruding building elements” refers to elements regulated by this Code that are permanently affixed to the building and protrude into the path of travel.
The sweep of a cane used by people with low or no visionwith vision loss normally detects protruding building elements that are within 680 mm of the floor. Any protruding element above this height would not normally be detected and can, therefore, create a hazard if it projects more than 100 mm into the path of travel.
[3.8.3.15.] 3.8.3.15.Water-Closet Stalls and Urinals for Persons with Limited Mobility
[3.8.3.16.] 3.8.3.16.Lavatories and Mirrors
[3.8.3.17.] 3.8.3.17.Showers
[3.8.3.18.] 3.8.3.18.Accessible Bathtubs
[3.8.3.19.] 3.8.3.19.Assistive Listening Systems
[3.8.3.20.] 3.8.3.20.Counters
[3.8.3.21.] 3.8.3.21.Telephones
[3.8.3.22.] 3.8.3.22.Spaces in Seating Area
Note A-3.8.Barrier-Free Design Principles.
This Section contains minimum requirements for the design of buildings that accommodate people with diverse abilities, across their lifespan, including, but not limited to, people who use wheelchairs or other assistive mobility devices (e.g., walking aids, canes, crutches, braces, prosthetics), people with personal care providers, people with low or no vision, people with low or no hearing (see PCF 1778) with hearing or vision loss, and people with service animals, so they can access and use buildings.
Examples of basic accessibility requirements of the Code are as follows:
a clear floor space of at least 800 mm by 1 350 mm,
a 1 000 mm clear width allowing a 90° turn,
a 2 100 mm diameter clear floor space allowing a 180° turn in one motion, and
a 1 700 mm diameter clear floor space allowing a 180° turn in multiple motions.
Note A-3.8.2.3.Access to Rooms and Facilities.
If barrier-free access is required into suites or rooms in Subsection 3.8.2., it is intended that access be provided, with some exceptions identified in Sentence 3.8.2.3.(2), throughout each room or suite. Some examples of where barrier-free access is required are as follows:
within each suite (subject to Clauses 3.8.2.3.(2)(k)and (l)),
within rooms or areas that serve the public or are designated for use by visitors, including areas in assembly occupancies with fixed seats, display areas and merchandising departments,
within rooms or areas for student use in assembly occupancies,
within general work areas, including office areas,
within general use or general service areas, including shared laundry areas in residential occupancies, recreational areas, cafeterias, lounge rooms, lunch rooms and infirmaries,
within sleeping rooms in hospitals and nursing homes with treatment,
(if installed), into at least one passenger elevator or elevating device conforming to Articles 3.5.2.1.and 3.8.3.7.,
into washrooms described in Sentences 3.8.2.8.(1)to (4),
to any facility required by this Section to be designed to accommodate persons with physical disabilities,
onto every balcony provided in conformance with Clause 3.3.1.7.(1)(c), and
to service counters used by the general public (examples include ticket counters, refreshment stands, drinking fountains, cafeteria counters, checkout counters and bank service counters).
The permission to waive a barrier-free path of travel for wheelchair access to certain specified areas of a building is not intended to waive accessibility requirements for persons whose physical disabilities do not require special provision for access to raised or sunken levels. PersonsPeople with visuallow or no vision and people with low or no hearing (see PCF 1778)disabilities thatwho do not require the use of a wheelchair can be expected to move throughout a building.
Seating booths and banquettes in restaurants and bars are considered furniture, which is beyond the scope of the Code. However, various types of seating should be considered to ensure the availability of barrier-free options.
The concept of wheelchair accessibility does not extend to building service facilities, nor to all floor levels within a storey, e.g., mezzanines not served by an elevator. Mezzanines that are accessible by an elevator are therefore not excluded.
Note A-3.8.2.10.(4)Directional Signage.
The NBC requires that directional signs be provided in a number of situations. Although they are only required to provide visual information, tactile directional signs should also be provided where practicable.
In some buildings, it may be necessary to supplement signs that provide visual and tactile information with visual displays, such as information displays and electronic interactive displays (e.g., wayfinding, exhibits and self-serve points-of-sale). Visual displays are common in motion picture theatres, law courts, exhibition halls, passenger stations/depots, museums, conference facilities, shops, stores and markets.
Wherever practicable, visual displays should be designed so that they are accessible to all people. In order to be accessible to people with low or no vision, visually displayed information should also be audibly communicated, either electronically or orally. Where touch screens are installed, an alternative means of accessing the information should be provided, for example by providing tactile buttons on an interactive display or by ensuring an attendant is always available to assist customers or visitors. Visual displays should also be accessible to people who use mobility devices. The degree of operability should accommodate people using a wide range of mobility devices (e.g., wheelchairs, scooters, walkers, canes) and people with a wide range of arm and hand mobility. Approach side, mounting height above the finished floor, amount of knee space, types of controls and the ability to reach them are particularly important considerations.
Note A-3.8.3.2.(3)Surfaces in a Barrier-free Path of Travel.
Floor finishes, including walk-off mats and carpet, should be selected, installed and securely fixed to provide a firm and stable surface so that people, including those who use mobility aids, can easily travel over them without tripping or expending undue energy. Other than very high-density, short-pile carpeting, most carpeting does not meet these criteria.
Furthermore, where the path of travel is exposed to intense light conditions, such as daylight or directional lighting, a low-glare or matte floor surface should be selected, as glare from floor surfaces can influence the perception of all users' perception, particularly those with low or no vision loss. For the same reasons, heavily patterned flooring should also be avoided.
Note A-3.8.3.5.(1)(b)Ramp Slopes.
Ramps with a slope of more than 1 in 16 can be very difficult for persons with physical disabilities with upper body mobility to manage. Even though they pose less of a problem for persons in motorized wheelchairs, these ramps can be unsafe to descend, especially in cold climates. Although Article 3.8.3.5. permits slopes on ramps as great as 1 in 12 for distances of up to 9 m, slopes of 1 in 20 are safer and less strenuous. When limited space is available, as may be the case during renovations, ramps with a slope of up to 1 in 12 should be restricted to lengths not exceeding 3 m whenever possible. A strip contrasting in colour and texture should be used at the top and bottom of ramps to warn personspeople with low or no vision.
The phrase “uniform slope along its length” is intended to mean that the slope remains constant along the length of individual ramp segments.
Note A-3.8.3.6.(6) and (7)Doors with Power Operators.
Doors equipped with a power operator actuated by a pressure plate identified with the International Symbol of Access or, where security is required, by a key, card or radio transmitter, and that can otherwise be opened manually, meet the intent of the requirement. The location of these actuating devices should ensure that a wheelchair will not interfere with the operation of the door once it is actuated. Swinging doors equipped with power operators which are actuated automatically and open into passing pedestrian traffic should be provided with a guard or other device designed to prevent pedestrians from stepping in the swing area of the door. These guards or devices should be detectable by people with low or no visionblind persons. For example, inverted U-shaped guards should have an additional rail at a height not more than 680 mm so that it is detectable by the long cane. These doors should also have a device (mat or other sensor) on the swing side to prevent the door from opening if someone is standing in the swing area.
Handrails are required to be installed so as not to obstruct pedestrian travel. To achieve this end, the rail should not extend so far into a hallway as to reduce the clear width of the hallway to less than the required width. Where the stair terminates in a room or other space, likely paths of travel through that room or space should be assessed to ensure that any projection of the handrail beyond the end of the stair will not interfere with pedestrian travel. As extensions of handrails beyond the first and last riser are not required in dwelling units (see Sentence 9.8.7.3.(2)) and as occupants of dwellings are generally familiar with their surroundings, the design of dwellings would not generally be affected by this requirement.
Handrails are also required to terminate in a manner that will not create a safety hazard to people with low or no vision blind orvisually impaired persons, children whose head may be at the same height as the end of the rail, or personspeople wearing loose clothing or carrying items that might catch on the end of the rail. One approach to reducing potential hazards is returning the handrail to a wall, floor or post. Again, within dwelling units, where occupants are generally familiar with their surroundings, returning the handrail to a wall, floor or post may not be necessary. For example, where the handrail is fastened to a wall and does not project past the wall into a hallway or other space, a reasonable degree of safety is assumed to be provided; other alternatives may provide an equivalent level of protection.
[9.8.7.3.] 9.8.7.3.Termination of Handrails
[1] 2)Except for stairs and ramps serving only one dwelling unit or a house with a secondary suite including their common spaces, at least one handrail at the sides of a stair or ramp shall extend horizontally not less than 300 mm beyond the top and bottom of each flight or ramp. (See Note A-9.8.7.3.(2)PROPOSED CHANGE A-9.8.7.3.(2).)
Note A-9.8.7.3.(2)Handrail Extensions.
As noted in Note A-9.8.7.2.PROPOSED CHANGE A-9.8.7.2., the guidance and support provided by handrails is particularly important at the beginning and end of ramps and flights of stairs and at changes in direction. The extended handrail provides guidance and allows users to steady themselves upon entering or leaving a ramp or flight of stairs. Such extensions are particularly useful to visually impaired personspeople with low or no vision, and personspeople with physical disabilities or who are encumbered in their use of the stairs or ramp.
[9.9.5.3.] 9.9.5.3.Obstructions in Public Corridors
[1] 1)Except as permitted in Sentence (2), obstructions located within 1 980 mm of the floor shall not project horizontally more than 100 mm into exit passageways, corridors used by the public or public corridors in a manner that would create a hazard for peoplevisually impaired persons travelling adjacent to walls.
Impact analysis
This proposed change is editorial and does not affect building costs. The proposed change will support the consistent application of the Code requirements, facilitate understanding and interpretation of the Code provisions, and update the terminology to what is commonly used in the industry.
Enforcement implications
The revision of terminology is an editorial change that supports the consistent application of the Code requirements by building officials and designers.
Who is affected
Building officials, owners and designers would use a common terminology that supports the consistent application of accessibility requirements and reflects more modern and accepted terminology.
OBJECTIVE-BASED ANALYSIS OF NEW OR CHANGED PROVISIONS
[3.3.1.8.] 3.3.1.8. ([1] 2)[F30,F73-OS3.1]
[3.8.1.1.] 3.8.1.1. ([1] 1)no attributions
[3.8.1.1.] 3.8.1.1. ([2] 2)no attributions
[3.8.2.1.] 3.8.2.1. ([1] 1)no attributions
[3.8.2.2.] 3.8.2.2. ([1] 1)[F73-OA1]
[3.8.2.2.] 3.8.2.2. ([2] 2)no attributions
[3.8.2.2.] 3.8.2.2. ([3] 3)no attributions
[3.8.2.2.] 3.8.2.2. ([4] 4)[F73-OA1]
[3.8.2.3.] 3.8.2.3. ([1] 1)[F73-OA1]
[3.8.2.3.] 3.8.2.3. ([2] 2)no attributions
[3.8.2.3.] 3.8.2.3. ([3] 3)[F74-OA2]
[3.8.2.3.] 3.8.2.3. ([4] 4)[F74-OA2]
[3.8.2.3.] 3.8.2.3. ([5] 5)[F74-OA2]
[3.8.2.3.] 3.8.2.3. ([5] 5)[F10-OS3.7]Applies to portion of Code text: “... each row of seats served by two aisles shall have one adaptable seat conforming to Subsection 3.8.3. located adjacent to one of the aisles.”
[3.8.3.12.] 3.8.3.12. ([1] 1)([h] h)[F30-OS3.1]Applies to portion of Code text: “… be equipped with a coat hook … projecting not more than 50 mm from the wall …”
[3.8.3.12.] 3.8.3.12. ([1] 1)no attributions
[3.8.3.13.] 3.8.3.13. ([1] 1)[F74-OA2]
[3.8.3.13.] 3.8.3.13. ([1] 1)([b] b)[F10-OS3.7]
[3.8.3.13.] 3.8.3.13. ([1] 1)([c] c)
[3.8.3.13.] 3.8.3.13. ([1] 1)([d] d)
[3.8.3.13.] 3.8.3.13. ([1] 1)([f] f)
[3.8.3.13.] 3.8.3.13. ([1] 1)([g] g)[F30-OS3.1]Applies to the requirement for a coat hook.
[3.8.3.13.] 3.8.3.13. ([1] 1)([i] i)[F74-OA2]Applies to the requirement for a shelf.
[3.8.3.22.] 3.8.3.22. ([1] 1)[F30-OS3.1]Applies to portion of Code text: “… level … level and have removable seats, …”
[3.8.3.22.] 3.8.3.22. ([1] 1)([d] d)[F10-OS3.7]Applies to portion of Code text: “… without infringing on egress from any row of seating or any aisle requirements …”
[3.8.3.22.] 3.8.3.22. ([2] 2)[F74-OA2]
[3.8.3.22.] 3.8.3.22. ([2] 2)[F30-OS3.1]Applies to portion of Code text: “… level, ...”
[3.8.3.22.] 3.8.3.22. ([3] 3)([a] a)[F10-OS3.7]Applies to portion of Code text: “… without infringing on egress from any row of seating or any aisle requirements …”