The Canadian Commission on Building and Fires Codes (CCBFC) is responsible for the development and content of the National Model Code documents. These documents are developed through the transparent National Model Codes development system. The system is based on achieving broad consensus, which gives those affected the opportunity to participate in the Code development process and have their views considered.
The CCBFC recognizes the authority of provincial and territorial governments to establish their own laws and regulations. Working in partnership with regulatory authorities, Code users and the public, the CCBFC:
- promotes uniform adoption and understanding of the National Model Codes
- responds to the needs and priorities of the adopting authorities
- facilitates the resolution of issues
- responds to technological change and innovation
- establishes and implements policies, procedures, and priorities for the National Model Codes
- advises the National Research Council of Canada (NRC) on the need for Code-related research
- acts as the focal point for issues related to the National Model Codes
The CCBFC sets Code development priorities based largely on the advice of its partners, the Provincial/Territorial Policy Advisory Committee on Codes (PTPACC) and the NRC.
Once priorities are set, the CCBFC implements a work plan management and monitoring approach by approving individual tasks at the request of the standing committees. The CCBFC formally approves its priorities and a plan for each five-year Code cycle. This approved plan informs standing committees, provides focus and orientation to partners and stakeholders, and offers sufficient detail to allow ongoing monitoring of resources available and necessary adjustment.
The input for the process comes from a variety of sources, such as standing committees, individual provinces or territories, advice from the PTPACC, CCBFC future-sensing activities, or external requests for Code development projects on specific subjects.
Process for setting priorities
The priority-setting process has three major phases:
- collection phase
- selection phase, and
- approval and monitoring phase
The process of determining priorities for a new Code cycle ideally spans the time between the end of the old Code cycle (new standing committee members) and the beginning of the new Code cycle (new CCBFC members).
In the collection phase, the CCBFC’s Executive Committee engages in a discussion of high-level priorities and areas of focus with the PTPACC and the NRC. These discussions are informed by priorities collected from committees, partners, stakeholders, and other sources (including standing committees, provinces and territories, the PTPACC, the NRC, other government departments, and major industry stakeholders). The potential for external funding of Code development projects is also considered.
The CCBFC Task Group on Priorities evaluates the input from the various sources based on identified assessment criteria and tools. The task group may suggest areas of focus and/or specific Code cycle initiatives. The task group is responsible for recommending draft CCBFC priorities to the Executive Committee. The task group’s assessment also includes a consideration of the capacity of the system.
The Executive Committee reviews and—if necessary—revises the task group recommendations. The draft CCBFC priorities are then forwarded to the PTPACC for advice and to the NRC for review with regards to resource allocation, deliverables and timelines.
Approval and monitoring phase
The finalized draft priorities are then provided to the CCBFC for approval along with a plan for the Code cycle.
The standing committees are then tasked with carrying out the technical work related to the CCBFC priorities within the respective timelines. The CCBFC, the PTPACC and the Executive Committee work on policy priorities, and the NRC works on systemic priorities.
The Executive Committee monitors the set of CCBFC priorities and timelines and reviews the progress. Ongoing considerations of capacity will take place with feedback from the standing committee chairs and the NRC. Because of the dynamic nature of Code development and the need to be responsive to emerging issues, it is likely that some priorities will be adjusted in their scope or timeline. A review of priorities takes place at the Executive Committee as needed, but not less than annually.
Where priorities are revised, it is important to provide the standing committee chairs with an opportunity to provide feedback on the impact of these revisions.
The following questions may be used to determine the urgency, importance or significance of proposed priorities and may serve as weighting factors when selecting priorities.
Does the proposed Code development priority …
- deliver critical safety or health updates to Codes?
- contribute to reducing technical variations between the National Model Codes and provincial/territorial codes?
- contribute to the simplification of the regulatory environment?
- contribute to enabling the use of innovative products or technologies?
- need to be completed within the Code cycle?
- fall within the objectives and scope of the Codes?
- reflect an identified provincial/territorial interest to alter the scope or objectives?
- contribute to an identified subject of focus for the new Code cycle?
Types of priorities
Dividing the proposed priorities into three categories (technical, policy and systemic) may facilitate the selection of priorities for the CCBFC Task Group on Priorities. At a minimum, these categories will assist in providing some guidance as to the approach and responsibility for undertaking the priorities. Each category may need specific assessment criteria or weighting factors.
Tasks categorized as a technical priority are generally completed by standing committees or task groups with the assistance of NRC technical advisors. These priorities are issues falling within the scope of the current Codes and that respond to changes in building technology, design and construction or the updating of guides and commentaries.
Tasks falling under policy priorities are generally completed by joint CCBFC/PTPACC task groups or by the Executive Committee with assistance from the Secretary and Deputy Chair of the CCBFC, with input from provinces and territories and the PTPACC, and with the support of standing committees and their respective technical advisors. These priorities typically represent expansions of the scope of the Codes, introductions of new objectives for the Codes, or other changes that may have significant impacts. Before a change is made to a Code, an analysis of the potential impacts of the change is undertaken.
Tasks falling under systemic priorities would typically be completed by NRC staff. With few exceptions, such as the move towards objective-based Codes, these priorities typically address the format or structure of the Code documents or improvements or clarifications of the process; they require limited or moderate standing committee or provincial/territorial involvement.
When evaluating priorities, it is important to consider the total resource capacity needed to complete the work and to recognize that the final mix of Code changes will reflect maintenance, urgent issues and strategic issues.
The total capacity can be used to divide and limit each type of priority, such as:
- fundamental code maintenance priorities
- urgent and/or critical code development priorities
- strategic priority subjects of focus and initiatives
A review of the proportion of fundamental, urgent and strategic tasks over the last two Code cycles can provide a benchmark for this assessment.
Fundamental Code maintenance is a priority throughout the Code cycle and should constitute a small portion of the capacity. Some examples include:
- clarifications (substantial editorial changes and reorganization of content)
- reducing technical variations between provincial/territorial codes and the National Model Codes
- keeping referenced documents/standards up to date
- introducing new technologies
- keeping data up to date
- removing obsolete requirements
Urgent and/or critical Code development priorities are issues where resolution is required in this Code cycle. Some examples of situations leading to urgent changes could include:
- safety, health or accessibility issues with extensive, widespread and significant impact
- several provinces or territories are already aware/affected and wish to act
- a potentially hazardous situation has arisen
- an economic hardship can be remedied that is caused by an unwarranted restriction of appropriate use of materials, appliances, systems, equipment, methods of design, construction procedures, industrial processes, or methods of operation of facilities
While maintaining Code provisions and promptly addressing urgent issues are paramount for Code development, strategic priority subjects of focus and initiatives typically constitute the majority of CCBFC priorities. This outcome is desirable when there is strong consensus on the need to make significant progress on policy goals, emerging issues, areas where delay may impact unduly on health and safety, etc.
Progress in these priority areas, which in some cases may be supported with external funding, is essential for the Code development system to maintain its support and leadership role.