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Journal of the Ontario Building Officials Association, August 58, pp. 31-32, 2003-08-01
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What happens to your comments about proposed technical changes to building and fire codes
Archer, J. W.
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What happens to your comments about proposed technical changes to building codes?
Archer, J.
NRCC-46635
A version of this document is published in / Une version de ce document se trouve dans : Journal of the Ontario Building Officials Association, no. 58, Aug. 2003, pp. 31-32
2 July 2003
What Happens to your Comments about Proposed Technical Changes to Building Codes?
John Archer Secretary
Canadian Commission on Building and Fire Codes
This article explains how comments made in response to proposed technical changes are handled in the codes process.
The coordinated national consultation on proposed technical changes to the national and provincial/territorial codes has just been completed. You may be wondering what happens to comments that you and others have made during the consultation.
The code development process depends on this consultation process to identify issues that the standing committees of the Canadian Commission on Building and Fire Codes
(CCBFC) may have overlooked in developing the proposed changes. All comments submitted, whether pertaining to a national model code, or to a provincial/territorial code, are being assembled into one comprehensive database at the Canadian Codes Centre at the National Research Council’s Institute for Research in Construction. This data entry will be completed by the end of July 2003.
Copies of the database will be shared by all of the provincial/territorial authorities, to give them an overview of the national response. Although some provinces have proposed technical changes unique to their jurisdiction, most differences are variants of what is proposed for the national model codes.
The review of the comments on proposed technical changes to the national model codes is done by the CCBFC standing committees. The standing committees have strict rules governing how comments are analyzed and dealt with. A key principle is that no substantive revision to a proposed technical change, or a new technical change, can be introduced at this stage of the process.
Here are the rules:
1. All proposed changes for which no comments have been received are considered to have “passed” the public review process and are automatically recommended to the CCBFC for adoption.
2. All proposed changes for which only positive or supporting comments have been received are also considered to have passed the public review process and are automatically recommended for adoption.
3. Where a commenter suggests that a proposed technical change be extended in some way – wider scope of application, more demanding a requirement, for example – these comments are treated as if they are new proposals for technical changes to the codes and are referred to the next code cycle for action.
4. Where a commenter supports a proposed technical change, but has pointed out opportunities to clarify the wording, the standing committees will consider these suggestions.
5. Where a commenter supports a proposed change, but has suggested technical
modifications that would improve its effectiveness, the standing committee will consider them and if found to be acceptable, agree to their incorporation provided that they would not likely result in substantial adverse reaction from code users and stakeholders. Any proposed technical change that is modified in this way must be “flagged” for the attention of the CCBFC and a justification provided.
6. Where a proposed change has received a negative response, the standing committees evaluate the reasons provided. If they are persuasive on technical grounds, the standing committee may withdraw the proposed change for further study during the next code cycle, or withdraw the proposed change completely.
7. Where a proposed change has received a negative response, but no reason is provided, the comment is not considered.
The public consultation process is not a “voting” process. Although hundreds of comments may be sent in as part of a “letter writing campaign,” either for or against a proposed technical change, the standing committees focus on the technical issues and only recommend changes to the codes where they agree that the technical change will accomplish what is intended.
During the fall of 2003, all of the national model code standing committees will meet to consider the comments received. The meetings are open to the public, with dates and
locations posted on the CCBFC website (www.nationalcodes.ca).
When the standing committees have completed their work, a report to the CCBFC is prepared, presenting the results of the public consultation and resulting recommendations for changes to the national model codes. The results and recommendations are also sent to the provincial and territorial jurisdictions for review. This information assists the provinces and territories in their own process for determining province/territory-specific technical changes to their codes. It is also an opportunity for a province or territory to inform the CCBFC of a concern it may have with what a standing committee is recommending.
Because of the large number of proposed changes that usually pass the public
consultation process and the standing committees’ evaluation, it would not be possible for the CCBFC to vote on and approve each one individually at its meeting. The CCBFC, rather, deals with exceptions. The first step is to ballot the CCBFC on the standing committees’ recommendations. Where a CCBFC member has raised questions or voted negatively on a proposed change, an effort is made to resolve his or her concerns at the CCBFC meeting. At the end of the meeting, a formal motion to approve the new content for the model codes is made.
2 July 2003
one year for editing, verification, and printing of the three codes in English and French. The new objective-based model national codes are expected to be available during the 2nd quarter of 2005.
