Guidelines for requesting changes
Suggestions for changes to Codes Canada publications are welcome from anyone at any time. However, anyone thinking of submitting a Code Change Request should bear the following points in mind.
Consideration by code committees
To bring about a change in one of the Codes Canada publications, you must provide sufficient information to allow the Canadian Commission on Building and Fire Codes (CCBFC) and its standing committees (Code committees) to determine that your suggested change is needed and that it is technically correct. These Code committees are made up of volunteers chosen for their expertise to represent all facets of the construction industry from all regions of Canada.
The Code committees expect proponents to make very clear what specific change they would like to see. Code Change Requests should identify the shortcomings of the existing Codes Canada publication, and existing Code provisions that would be affected by the change. New wording should be suggested to address these shortcomings. It is recognized that not all those interested in improving the Codes can be experts in Code writing, and NRC Codes Canada staff will suggest improvements to the proposed wording, if necessary. Nevertheless, if specific wording is used, it will help to make the proponent’s intentions clear. Code Change Requests that lack clarity may be returned to the proponents for clarification, thus prolonging the time required for the Code committees to deal with the requests.
Focus on generic/widespread issues
It is not an appropriate role for Codes Canada publications to deal with specific products or with situations that arise only rarely. Code Change Requests should therefore address generic or widespread issues. Innovative products that are not yet covered by standards or mentioned 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). Services, such as the NRC Canadian Construction Materials Centre, are available to assist authorities in evaluating such innovative products. Similarly, unique situations are best dealt with by local authorities rather than swelling the Codes with requirements that are seldom applied.
Focus on technical issues
With few exceptions, Codes Canada publications are strictly technical in nature and do not deal with 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. The provincial and territorial agencies, which adopt Codes Canada publications, have instructed the CCBFC to avoid addressing administrative issues in the Codes because to do so could create conflicts with related provincial and territorial legislation and regulations. As a result, most administrative provisions in the National Building Code of Canada (NBC), National Fire Code of Canada (NFC) and National Plumbing Code of Canada (NPC) have been grouped in Division C of these documents. Code Change Requests should therefore address technical issues, which in the NBC, NFC and NPC are typically covered in Division B of these documents.
Objectives and functional statements
The NBC, NFC and NPC are objective-based codes. This means that the objectives and functional statements each Code provision attempts to address 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 and NPC have been determined by the CCBFC, in consultation with the provinces and territories. 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 or NPC should ensure that the requested change is linked to at least one of the Code’s stated objectives and functional statements.
Adding a provision that cannot be linked to one of the currently stated objectives or functional statements would require adding at least one new objective or functional statement. Although this is not out of the question, the CCBFC would consider such an expansion of the scope of the Code in question only after consultation with the provinces and territories.
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 right change. This documentation can include research and testing results, statistics, case studies and so forth.
One aspect to include in the documentation supporting your Code Change Request is information on the benefits likely to be achieved and the costs of implementing it.
Proponents of Code Change Requests should also bear in mind the availability of suitable means to verify compliance. This problem can arise when requested changes are written such that there are no existing tools or models that can be used to evaluate whether or not a design or construction actually conforms to the provision. A related issue is the implications of Code Change Requests for the existing building, fire or plumbing code enforcement infrastructure. Therefore, a Code Change Request should include information on conformity verification and enforcement implications, including available resources.
Where the requested change has major cost or enforcement implications, the Code committees may ask that a detailed impact analysis be provided.
Although suggestions for changes to Codes Canada publications are welcome from anyone at any time, the Codes are revised and published according to a schedule and there may be a delay between the submission of a Code Change Request and its publication in the relevant Code, even if the request has clear sailing through the Code committee and public review processes.
Persons with an active interest in the contents of Codes Canada publications should maintain an awareness of the various Code cycle stages.
Code Change Requests should provide sufficient information to Code committees to demonstrate that there is a problem with certain existing requirements or an omission in those requirements, that a change is needed, and that the requested change is the right change.
Each request should answer the following questions:
- What is the problem?
- What is the proposed solution and how does it address the problem?
- Which of the stated objectives and functional statements of the Code will the proposed solution assist in achieving?
- What are the cost/benefit implications?
- What are the enforcement implications?
Requests should be clearly stated and should address generic or widespread technical issues and avoid administrative issues.
The CCBFC has instructed Codes Canada staff to return requests that do not satisfy these criteria to their proponents. Codes Canada staff are available to help proponents prepare suitable submissions, but the responsibility is on the proponent to satisfy these criteria.
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