About code change requests

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 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.

Clarity

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.

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 right change. This documentation can include research and testing results, statistics, case studies and so forth.

Impact analysis

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.

Timing

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.

Summary

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.

Process for developing Codes Canada publications

Codes Canada publications are continuously evolving to accommodate new technologies, materials, construction practices, research, social policy, and the changing needs of Canadian society. Globalization and free trade, for example, have led to the harmonization of some North American standards and the increased use of international standards.

Development of code content is a consensus-based process that relies on the voluntary contributions of standing committee and task group members, and the public. A common process —from the initial proposing and consideration of code change requests to the publication of approved changes— is followed for all codes. An important feature of the code development and maintenance process is the extent of public involvement.

Proposed changes

Submission

Code change requests can be submitted to Codes Canada by regulatory officials, design and safety professionals, manufacturers and suppliers, contractors, building managers or owners, consumers, and other public and private sector stakeholders— in fact, by anyone with an interest in the codes. CCBFC standing committee members and NRC staff may also propose changes.

Work plan

Each code change request is reviewed by the appropriate standing committee. After this initial review the standing committee determines if it wishes to work on it and to include it in its work plan for CCBFC approval and priority setting. Work plan approval and priority setting by the CCBFC ensures that code development work focuses on issues of importance to the provinces and territories as well as to stakeholders.

Review

Once authorized by the CCBFC the appropriate standing committee undertakes a detailed review of the code change request. If the proposed change is complex and requires significant analysis, a task group may be established to study it and make recommendations. When a change has implications for a part of a code that is the responsibility of other committees, all affected committees review the change. For example, a proposed change to NBC Part 9, Housing and Small Buildings, may need to be reviewed by the committees responsible for Parts 3, 4, or 6, and may also lead to a corresponding change in one of those parts.

A standing committee may reject a proposal, amend the wording, defer it pending receipt of more information or research, or approve the proposed change.

Pre-public review

The provinces and territories have the opportunity to review draft proposed changes. If any of them has serious policy or administrative concerns about the inclusion of a certain proposed change for public review, the proposed change can be withdrawn or deferred for further discussion prior to public review.

Public review

All proposed changes approved by the standing committees are made available for public review annually, in the fall, for two months. Additional public review periods may be called, when necessary, at other times of the year. This allows those most affected by a proposed change to provide feedback and increases the range of expertise available on any subject. Provinces and territories are invited to coordinate their public review activities with the national public review periods.

The Internet is the primary format for distribution of public review information and receipt of comments. The availability of the public review documents is announced in Construction Innovation (NRC Construction’s newsletter) and on the Public Review page of Codes Canada’s web site.

Post-public review

Following the public review period, the standing committees review the submitted comments. A proposed change moves forward only once all comments have been taken into consideration. Some proposed changes may be deferred, withdrawn or revised at this point. The provinces and territories then review the final version of the proposed changes from a policy perspective and identify their concerns before the changes are submitted to the CCBFC for final approval.