Canadian Association of the Deaf – Association des Sourds du Canada (CAD-ASC)
Modernizing Canada’s Building and Fire Codes to Protect Deaf, Deaf-Blind, Hard of Hearing, and Deaf & Disabled (DDBHHD+) People

THE ISSUE

Canada’s current building and fire safety frameworks do not consistently require accessible emergency alerting for people who cannot rely on audible alarms. While some provisions for visual alarms exist in certain jurisdictions and building types, national standards and the National Building Code of Canada (NBC) and National Fire Code (NFC) do not mandate universal inclusion of visual or vibrating alerts across residential and public environments.

This inconsistency creates an unequal and unsafe emergency notification system for Deaf, deafened, Deaf-Blind, Hard of Hearing, and Deaf & disabled (DDDBHHD+) individuals. Without mandatory accessible alerts, people who cannot hear alarms remain at substantially greater risk during fires and life-threatening emergencies.

OUR POSITION

The Canadian Association of the Deaf – Association des Sourds du Canada (CAD-ASC) calls for modernizing both federal and provincial codes and standards to ensure emergency alerts are inclusive, multimodal, and accessible to all Canadians.

We advocate for:

A national requirement that all emergency alerting systems include audio, visual, and vibrating notification options, appropriate to the occupancy and risk level of the space.

This approach recognizes the diverse communication and sensory needs of DDDBHHD+ Canadians and reflects current accessibility, human rights, and safety principles.

Although some provinces—such as Ontario—have implemented requirements for visual alarms in certain multi-unit residential buildings, the absence of consistent national requirements leaves millions of Canadians unprotected. The federal code framework must set a clear foundation that provinces and territories can adopt and expand.

BACKGROUND

1. Inconsistent Protection Across Canada

  • The NBC and NFC emphasize audible fire alarm signaling, but do not consistently require visual or vibrating alerts in most residential settings.
  • Some visual alarm requirements exist—for example, in buildings primarily intended for people with hearing loss—but these provisions are limited and not universally applied.
  • Provinces and territories vary significantly:
    – Ontario, for example, introduced requirements for visual fire alarms in certain multi-unit residential buildings in 2015.
    – Other jurisdictions have minimal or no comparable requirements.

2. Standards Gaps

  • The Canadian smoke alarm standard (CAN/ULC-S531) focuses on audible single-station alarms and does not require integrated visual or vibrating features.
  • Visual (strobe) devices are covered separately under CAN/ULC-S526, but this standard is not uniformly referenced in federal or provincial codes for residential environments.
  • This division between audible-only and visual-only standards results in fragmented protection.

3. Human Rights and Accessibility Obligations

Canada is committed to upholding the UN Convention on the Rights of Persons with Disabilities (CRPD) and the Accessible Canada Act (ACA). Ensuring the safety of DDDBHHD+ individuals during emergencies is not only a building-code issue—it is a matter of human rights, equality, and dignity.

Emergency alert systems that rely solely on sound disproportionately endanger those who cannot hear and undermine federal and provincial accessibility mandates.

OUR RECOMMENDATIONS

CAD-ASC urges the federal government, the Canadian Board for Harmonized Construction Codes, and provincial/territorial governments to adopt the following changes:

1. Modernize Definitions in National and Provincial Codes

Revise definitions of “alarm signal,” “alert signal,” and related terms in the NBC, NFC, and provincial building/fire codes to explicitly include:

  • Audible alarm signals
  • Visual alarm signals (e.g., strobes)
  • Vibrating or tactile alerts (where appropriate, especially in sleeping areas)

This ensures all future code provisions recognize multimodal emergency notification.

2. Mandate Multimodal Alerts in New Construction

Require audio + visual alarms—and, where appropriate, vibrating alerting devices—in:

  • All new multi-unit residential buildings
  • All new public buildings and facilities
  • Any building intended to serve or accommodate people who may not receive audible alerts
  • Sleeping areas where occupants may disconnect hearing devices overnight

3. Create a Federal Standard for Residential Accessibility

Working with ULC Standards, revise CAN/ULC-S531 or create a complementary standard to ensure:

  • Residential smoke alarms incorporate visual and/or vibrating capability, or
  • Integrated systems require interconnected strobe/vibration devices meeting CAN/ULC-S526.

This closes the technical gap between audible-only and visual alarm standards.

4. Support Provincial and Territorial Adoption

Encourage provinces and territories to:

  • Adopt the revised federal definitions and requirements
  • Introduce requirements for visual/vibrating alarms during major renovations or alterations
  • Provide phased compliance timelines to support industry readiness and affordability

Ontario’s 2015 model demonstrates that phased implementation is practical and effective but financial support is needed to modify homes not equipped with life-saving equipment at the present time.

RATIONALE

1. Equity and Human Rights

All Canadians deserve equal access to emergency warnings. Providing only audible signals places DDDBHHD+ individuals at disproportionate risk, contradicting Canada’s accessibility and human rights commitments.

2. Technical Feasibility

Modern visual and vibrating alarm technologies are widely available, reliable, and already incorporated in many safety standards.

3. Cost Effectiveness

Requiring multimodal alerts during construction or renovation is significantly less expensive than retrofitting. Even modest investments dramatically reduce liability and improve life safety outcomes.

4. National Consistency

A harmonized national approach prevents the patchwork model that currently leaves safety dependent on provincial boundaries.

CONCLUSION

Canada’s emergency alerting framework must evolve to reflect the needs and rights of DDDBHHD+ people. Ensuring all alarms include audible, visual, and vibrating notification options is essential to equitable safety—and it is achievable with current technologies and code mechanisms.

By updating national and provincial codes and standards, Canada can prevent avoidable tragedies, strengthen compliance with accessibility obligations, and ensure that no person is left unaware during life-threatening emergencies.

This change is overdue, reasonable, and vital. CAD-ASC calls on federal and provincial authorities to act now.

APPROVED: December 8, 2024

FOR FURTHER INFORMATION CONTACT:

The Canadian Association of the Deaf – Association des Sourds du Canada

606 – 251 Bank Street, Ottawa, ON K2P 1X3
(613) 518-2944 (VRS)
Info@cad-asc.ca
www.cad-asc.ca