Making code changes

Question 1:

How does a person propose a code change? What is involved, and do you need to be an “expert” to do this?

Answer to question 1:

Suggestions for changes to Codes Canada publications are welcome from anyone at any time. A specific Code Change Request form is available online to formulate and submit a request. It is not necessary to be an “expert”. Anyone submitting a Code Change Request should ensure that it is clear and focuses on technical issues that are generic or widespread. The request should include:

  • the existing Code requirement, if applicable
  • the reasons for the change or addition
  • the proposed revision or new requirement
  • supporting documentation, including cost/benefit data
  • the enforcement implications, and
  • the related Code objectives.

Requests that do not satisfy these criteria will be returned to proponents for additional information. For more information, see Guidelines for requesting changes.

Question 2:

When a code change is being considered, what information and factors are taken into account? What factors are not considered? Why?

Answer to question 2:

In looking at each proposal, the Canadian Commission on Building and Fire Codes (CCBFC) seeks answers to the following questions:

  • What is the problem that the proposed change seeks to address?
  • 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?

Factors not taken into account include aesthetics, comfort, workmanship, maintenance and life-cycle costs, and anything that cannot be related to a specific objective, is not enforceable, or is above minimum requirements. Some characteristics of a building that could be perceived as having a bearing on Code objectives, such as psychological health or protection from vandalism, are also not addressed.

Question 3:

I understand that I can provide input to the CCBFC, but my building code is managed by my province. Can I also discuss code issues with my provincial government? If so, who do I talk to?

Answer to question 3:

Yes. The CCBFC is responsible for developing and updating Codes Canada publications but it is the provinces and territories that have jurisdiction over construction. Most provinces and territories adopt these model codes, sometimes amending and/or supplementing them to suit regional needs before publishing them as provincial codes. To talk with someone in your local jurisdiction about code issues, visit the provincial or territorial ministries page for the relevant contact information.

Question 4:

Can the code development process respond quickly to emerging issues, or must everything wait until the end of each five-year cycle? Does it take long to make changes to the Codes?

Answer to question 4:

Emerging issues are dealt with through the regular code development cycle. It may take a few months, or several years, to develop and secure approval for a proposal that is then adopted in the next edition of the Codes, depending on the complexity or scope of the matter. If it is an emergency issue that affects life safety or has a major impact on industry, the CCBFC responds immediately and issues an interim change.

Question 5:

What is the “consensus-based decision-making process” that is used to update and produce the Codes and how does it work? Why is it important?

Answer to question 5:

Consensus is the substantial agreement of members and includes the resolution of all significant concerns and technical disagreements. It implies much more than the concept of a simple majority, but it does not necessarily imply unanimity. Consensus requires that all opinions be considered and weighed and that any statement of committee agreement should be reached only after full and fair discussion of the issues involved. When consensus on a proposed change has not been achieved, additional development is undertaken, or the proposed change is rejected and the proponent of the requested change is informed. Committee decisions are based on this principle, whenever possible.

Question 6:

Why do the Codes only set minimum standards of health and safety? What is meant by “minimum requirements”?

Answer to question 6:

In a world of limited resources and competitive markets, it is important that building infrastructure be provided in a cost-effective manner. On the other hand, regulators need building codes that establish realistic minimum acceptable standards to ensure safety and meet other objectives such as health, accessibility, building protection, and energy efficiency.

The national model Codes are not best practice guides. By specifying particular minimum solutions acceptable to society at the time, they establish a level playing field that everyone can build to, cost-effectively. Many owners, designers and builders seek to achieve a higher standard than specified in the Codes, which is perfectly legitimate. By identifying the base line, the Codes provide a starting point that has broad agreement.

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