Guideline for Requesting Changes to the Building Code
Request a Code Change
Ontario’s Building Code improves with each edition thanks to the contributions of building officials, designers, builders, contractors, product manufacturers, researchers, building owners and the public. Typical changes accommodate new materials, systems and building design, clarify requirements, or update references to standards.
The Building Code is a regulation made under the Building Code Act, 1992. Given the joint Federal/Provincial/Territorial Code development process, changes developed by the Canadian Commission on Building and Fire Codes (CCBFC) for the model National Building Code (mNBC) and the model National Plumbing Code (mNPC) are considered for inclusion in Ontario’s Building Code. Suggestions for changes to the Building Code made by members of the public may also be considered. Potential changes to the Building Code are generally developed following a public consultation process and review by a Building Code technical committee.
Suggestions to improve the Building Code may be submitted to the Building and Development Branch of the Ministry of Municipal Affairs and Housing. The following points should be considered in developing a request for a Building Code change:
Clarity
Code change requests should clearly identify the specific change being proposed, current Code provisions that would be affected by the change, and the rationale for proposing the change. Proposed language for new Code provisions is helpful.
Supporting Documentation
Code change requests should be accompanied by sufficient documentation to support the need for the change. Documentation may include research, testing results, statistics, case studies, etc.
Cost/Benefit Analysis
Code change requests should include information on implementation costs and the benefits likely to be achieved.
Assessment of Conformance
Code change requests may not be viable if there are no practical means of assessing conformance with the proposed new requirement. Requests should consider whether there are existing tools or models that can be used to assess the conformance of designs or construction with the requirements of the proposed Code change.
Requests also need to consider whether the implementation of Code changes would have implications for enforcement bodies.
Timing
Although requests for changes to the 2012 Building Code can be made at any time, it is likely that most changes will be considered for inclusion in the next edition the Building Code. However, “interim” Code changes to the 2012 Code are possible.
Objectives
The objectives of the Building Code’s requirements (“acceptable solutions”) are set out in Division A. Code change requests should link proposed changes to at least one of the Code’s stated objectives. The addition of a provision that cannot be linked to one of the currently stated objectives would require the addition of new objectives.
Focus on Generic/Widespread Issues
The Building Code’s standards are of general application and it is therefore impractical for the Building Code to deal with specific products or with situations that arise only rarely.
However, innovative products that are not yet covered by standards or mentioned in the Codes are not necessarily excluded from use. Current administrative procedures to enable the use of innovative products are listed in Division C, and include Alternative Solutions, the Building Code Commission, the Building Materials Evaluation Commission and Minister’s Rulings.
Code Change Request Form
The attached form should accompany requested changes, although its use is not mandatory provided the criteria stated above are considered. Where the form does not provide sufficient space for the information you wish to include, you are encouraged to attach additional pages as necessary. Additional electronic copies of the Building Code change request form may be obtained from the Building Code website at: www.ontario.ca/buildingcode.
Building Code Development Process
Ontario’s Building Code is based on the model National Building Code (mNBC) but includes some differences from the mNBC that are determined by Ontario-specific priorities such as high standards for energy efficiency and greenhouse gas reduction, additional sections to deal with specific building types and elements such as public pools and spas and rapid transit stations and Part 11 to address renovations to existing buildings.
New editions of Ontario’s Building Code generally follow the cycle of the mNBC and may include technical and editorial changes throughout the Code. Proposed changes are typically posted on the Ministry of Municipal Affairs and Housing web site for public consultation. Comments received through that public consultation process are considered by Technical Advisory Committees, including designers, builders, regulators and other expert Code users, before final recommendations are submitted to the Provincial Government for approval.
The Building Code may be amended at any time and each edition of the Code may be amended several times during the life of that edition. However, the Code is not amended each time an individual Code Change Request is submitted to the Ministry.
All Code Change Requests are logged on receipt and may be considered as part of a general amendment package once sufficient proposals are received. Other amendments may address changes related to specific topics such as sprinkler requirements or barrier-free design.