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Approved Protocol for Addressing New Objectives in Model National Codes

The review of a request for a new objective for the national codes must proceed in a disciplined manner, proceeding from a broad overview of the request and an examination of the public policy concerns underlying the proposal. This leads to a more detailed examination of the options for action. If a decision is made to proceed with the development of an objective, detailed work then proceeds on code requirements, etc.

Each step in the process follows logically from the previous step and leads to a decision on whether to proceed further. Once it is clear that the development of an objective is an appropriate approach a work plan may be developed which may allow for sequential work on functional statements and code requirements.

It is intended that the steps and the element within each step need not be completed sequentially. The development of code requirements by the standing committees could start while the objective and functional statements are being developed by the Joint Task Group.

Timeframes for each step have been provided as guidelines and indicators of the amount of level of details and effort required for each step.

Step 1 Request for change to the code’s objectives

This request may come from any person or organization. The request must be accompanied by a rationale for action.

Step 2 Executive Committee initial consideration of request (2-4 months)

  1. Assess if there a general agreement that there is an public policy concern that can be addressed by a new objective by:
    1. Obtain preliminary comments from PTPACC
    2. Seek comments from other appropriate regulatory agencies and key stakeholders
    3. Determine if the proposal addresses a matter which is within the mandate of model codes
  2. Executive Committee determines whether or not to request permission from the CCBFC to move forward to more detailed work on the issue
  3. Seek approval of the CCBFC to add this task to the Executive Committee work plan
    or advise the CCBFC of the request and the EC’s recommendation not to address the request.

If appropriate, the CCBFC communicates:

  • that a request has been received by the CCBFC
  • that the CCBFC has expressed an interest in pursuing the request
  • an invitation to participate.

Step 3 Executive Committee’s analysis of the request with input from PTPACC, appropriate regulatory agencies and key stakeholders (6-8 months) to determine the appropriateness of a new objective in the codes.

  1. Develop policy goals and measurable outcomes. These could include societal benefit, uniformity of approach, leadership, etc
  2. Identify and examine available instruments or mix of instruments to determine if a building regulatory response is appropriate
  3. Develop options for action demonstrating how each option will address the policy goals
  4. Conduct impact analysis of each option by:
    1. Examine legal and enforcement implications
    2. Assess the effectiveness, and efficiency
  5. Assess timelines for implementation of the various options
  6. Executive Committee determine whether or not to request permission to move forward and form a joint task group to address the request
  7. If requesting to move forward, the Executive Committee draft a terms of reference (ToR) for the Joint Task Group, which addresses the elements captured in Step 4.
  8. Seek approval of the CCBFC to form a joint task group (ToR)
    or advise the CCBFC of the EC’s recommendation not to address the request.

Communicate CCBFC’s decision to approve the formation of a Joint Task Group to draft objectives and functional statements or not to pursue.

Step 4. Formation JTG CCBFC/PTPACC to scope the objective code development work (3-4 months)

  1. The task group will review the inventory of existing provincial requirements
  2. Determine boundaries for technical development, which include:
    1. Draft objectives and functional statements
    2. Determine which code(s) this objective applies to
    3. Design (e.g. NBC, NPC) vs. operation (e.g. NFC)
    4. Application, for example
      1. All buildings vs. some buildings vs. parts of buildings
      2. All uses vs. some uses
  3. Joint Task group reports its recommendation to the CCBFC and PTPACC
  4. CCBFC decision point to send for public review if decision to move forward.

Communicate CCBFC’s decision to move forward (public review) and develop the technical requirements or not to pursue.

Step 5. Public Review if decision of step #4 is to move forward (6-9 months)

  1. Comments reviewed and addressed by JTG
  2. JTG makes recommendation to CCBFC
  3. CCBFC Decision based on the public review comments and recommendations from the JTG.

Communicate CCBFC’s decision to move forward and develop the technical requirements or not to pursue.

Step 6. Technical requirements developed following the CCBFC’s Code development documented in Part 3 of the Policies and Procedure with the following additional elements:

  1. Executive Committee ensure coordination between the JTG and the SC(s) with respect to Refining of Objectives and functional statements (Division A) as well as the technical requirements
  2. Executive Committee review of Division A proposed changes (PCFs) and approval for public review
  3. Public review of technical requirements received by standing committees and refined objectives and functional statements received by Executive Committee.
  4. Standing committee and EC review and address comments from Public Review and make recommendation to the CCBFC.