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)
- Assess if there a general agreement that there is an public policy
concern that can be addressed by a new objective by:
- Obtain preliminary comments from PTPACC
- Seek comments from other appropriate regulatory agencies
and key stakeholders
- Determine if the proposal addresses a matter which is
within the mandate of model codes
- Executive Committee determines whether or not to request permission from
the CCBFC to move forward to more detailed work on the issue
- 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.
- Develop policy goals and measurable outcomes. These could include
societal benefit, uniformity of approach, leadership, etc
- Identify and examine available instruments or mix of instruments to
determine if a building regulatory response is appropriate
- Develop options for action demonstrating how each option will address
the policy goals
- Conduct impact analysis of each option by:
- Examine legal and enforcement implications
- Assess the effectiveness, and efficiency
- Assess timelines for implementation of the various options
- Executive Committee determine whether or not to request permission to
move forward and form a joint task group to address the request
- 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.
- 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)
- The task group will review the inventory of existing provincial
requirements
- Determine boundaries for technical development, which include:
- Draft objectives and functional statements
- Determine which code(s) this objective applies to
- Design (e.g. NBC, NPC) vs. operation (e.g. NFC)
- Application, for example
- All buildings vs. some buildings vs. parts of buildings
- All uses vs. some uses
- Joint Task group reports its recommendation to the CCBFC and PTPACC
- 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)
- Comments reviewed and addressed by JTG
- JTG makes recommendation to CCBFC
- 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:
- 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
- Executive Committee review of Division A proposed changes (PCFs) and
approval for public review
- Public review of technical requirements received by standing committees
and refined objectives and functional statements received by Executive
Committee.
- Standing committee and EC review and address comments from Public Review
and make recommendation to the CCBFC.