Advancing Accessibility Standards Research

Grants and Contributions Program

Project #: 17319989

Clearing Our Path: Evidence-based guidelines on accessibility in the built environment for people living with sight loss

Introduction – About CNIB

Founded in 1918, CNIB is a non-profit organization driven to change what it is to be blind today. We deliver innovative programs and powerful advocacy that empower people impacted by blindness to live their dreams and tear down barriers to inclusion.

Contents

Introduction – About CNIB

Background

Project overview

Objectives

How did we meet the objectives?

Challenges

Hearing from people with disabilities

The “Clearing Our Path” Summit

Hearing from other stakeholders

Hearing from professionals

Presentations

Parallel studies

“Clearing Our Path” at a glance

About “Clearing Our Path” – Version 2.0

What we learned

What we heard

Americans with Disabilities Act (ADA)

The Architectural Barriers Act (ABA)

Federal Highway Administration (FHWA)

Conclusions

Appendix A – Summit agenda

Appendix B Cited standards

Appendix C CNIB presentations

Background

Navigating public spaces safely, independently and with dignity is crucial for inclusivity in Canada. This principle is enshrined in various domestic and international laws.

Under Canada’s Human Rights Act, denying individuals access to goods, services, or facilities based on discrimination is prohibited. Each province and territory have its own human rights legislation and seven provinces have enacted accessibility laws specifically addressing public spaces.

Accessibility legislation across Canada, including the Accessible Canada Act of 2019, aims to remove barriers in the built environment for people with disabilities through infrastructure standards.

Canada ratified the United Nations Convention on the Rights of Persons with Disabilities in 2010, preceding provincial acts in Ontario, Accessibility for Ontarians with Disabilities Act (AODA), and Quebec, Quebec’s e-20.1 Act. Articles within the Committee on the Rights of Persons with Disabilities (CRPD) stress the obligation of states to ensure all public spaces are accessible. Several articles within the CRPD speak specifically to the obligation set out for states to ensure that public spaces can be accessed by everyone. And, both Ontario’s and Quebec’s legislation cite accessibility to public spaces specifically in the legislation. [1]

CNIB’s “Clearing Our Path” project, spanning four years, involved research and consultation with Canadians of various abilities and government stakeholders. Originally published in 1999, these guidelines evolved and are now available online in both official languages, supported by ESDC funding.

“Clearing Our Path” aims to fill a void by providing comprehensive accessibility guidelines for architects, property managers, and planners. Despite the availability of newer standards, it remains a vital resource.

The guidelines are designed to be accessible to Canadians with sight loss, including those on municipal accessibility committees.

The “Clearing Our Path” website continues to attract over 5,000 monthly visitors, underscoring its relevance. CNIB welcomes feedback at advocacy@cnib.ca to further improve the guidelines.

Project overview

Objectives

1. Advance existing accessibility guidelines in the built environment for Canadians who are blind or partially sighted
2. Validate the most relevant and updated evidence-based research within disability studies, architecture, design studies, emerging accessible, adaptive equipment and other academic research with global benchmarking
3. Ensure that accessibility guidelines and recommendations continue to be the best available solutions for people with sight loss and further, that they do not create additional barriers for other people with disabilities
4. Ensure that the lived experience of people who are blind and partially sighted is identified, analyzed and complements the research
5. Consult the lived experience of individuals with other sensory, mobility and cognitive disabilities to identify areas where the research may cause further barriers and identify strategies to mitigate these barriers
6. Provide a final report to Accessibility Standards Canada with recommendations on future standards in the built environment, with a focus on individuals who are blind or partially sighted

How did we meet the objectives?

1. Advance existing accessibility guidelines in the built environment for Canadians who are blind or partially sighted.

At the start of this project in 2020, CNIB recognized established domestic and international standards aimed at reducing barriers for Canadians with sight loss. These standards, developed through consensus, have been in place since the early 1990s and as recently as 2023. They include:

• ISO 21542 Second edition-2021-06
• ISO 23599 Second edition 2019-01
  Assistive products for blind and vision-impaired persons — Tactile walking surface indicators (TWSI)
• CSA 651 2018
• Section 3.8.3 – National Building Code of Canada 2020
• Transportation Association of Canada (various publications) including the following:

• Geometric Design Guides for Canadian Roads – 2017
• Canadian Roundabout Design Guide (2017)
• Manual of Uniform Traffic Control Devices for Canada, Sixth Edition (2021)
• Guidelines for Understanding, Use and Implementation of Accessible Pedestrian Signals (2008)
• The Manual of Uniform Traffic Control Devices for Canada, Sixth Edition

Each standard will be detailed in Appendix B of this report. Please note that only the CSA-2023 standard and the 2020 National Building Code are freely available. The other standards are copyrighted by their respective publishers. It’s also important to note that the National Building Code is not compatible with screen readers.

In addition to these Canadian and international publications, CNIB has been actively monitoring developments in accessibility through the U.S. Federal Highway Administration (FHWA) and the U.S. Architectural Barriers Act.

CNIB is pleased to inform Accessibility Standards Canada that these sources closely align with CNIB’s existing guidelines published in “Clearing our Path.” Later in this report, we will highlight the differences between CNIB’s guidelines and those provided in the comparative standards. Please be aware that due to variations between Canadian and U.S. regulations, the review of American regulations serves only as informative reference.

2. Validate the most relevant and updated evidence-based research within disability studies, architecture, design studies, emerging accessible, adaptive equipment and other academic research with global benchmarking.

CNIB enlisted Professor Robert S. Wall Emerson, PhD, a prominent expert in blindness studies from the University of Western Michigan, early in the project. With over 142 peer-reviewed articles, his research primarily addresses orientation and mobility skills for individuals who are blind. He has focused extensively on wayfinding challenges and the impacts of autonomous vehicles on those with sight loss. Additionally, Professor Emerson has examined the implications of silent electric vehicles. CNIB tasked him with reviewing their guidelines and suggesting updates as needed. CNIB was pleased to learn that after two updates, in 2009 and 2016, the guidelines remained relevant and were consistent with both published international standards and best practices.[2] Professor Emerson’s research took place from June through October in 2021.

3. Ensure that accessibility guidelines and recommendations continue to be the best available solutions for people with sight loss and further, that they do not create additional barriers for other people with disabilities.

Accessibility in the built environment presents a multifaceted challenge. People with disabilities defy easy categorization, making it impractical to devise universally applicable guidelines. The CNIB’s approach involves engaging in meaningful dialogues with Canadians of diverse abilities. Our aim is to grasp the potential obstacles posed by accommodations like tactile warning surface indicators (TWSI) while emphasizing their critical role for individuals with sight loss.

For instance, the advent of cut curbs in the late 20th century aimed to ease mobility for those using wheelchairs, strollers, or other wheeled devices, but inadvertently disoriented individuals with sight loss at crosswalks. This led to the creation of TWSIs, specifically truncated domes, originating in Japan to aid blind navigation within communities.

Over the past three decades, media reports have occasionally cited TWSIs as imposing unnecessary barriers on pedestrians with mobility impairments. CNIB contends that with proper installation and upkeep, such barriers are minimal, albeit with exceptions. When weighing safety against inconvenience, CNIB stresses that accommodations should not compromise the safety of individuals with sight loss in the built environment.

Design professionals frequently seek guidance on accommodating diverse needs, but CNIB underscores the complexity of a one-size-fits-all solution. Understanding the breadth of human experiences is crucial before embarking on public space designs. CNIB advocates close collaboration with disability community representatives, such as municipal accessibility advisory committees, to fully comprehend challenges and opportunities.

By fostering inclusive consultations, design professionals can develop public spaces that cater to the broadest spectrum of individuals effectively.

4. Ensure that the lived experience of people who are blind and partially sighted is identified, analyzed and complements the research

An integral component of this project was to establish an advisory committee with representation from persons living with cognitive challenges, persons living with mobility challenges and those who are Deaf. Honorariums were offered to The Neil Squire Society, Independent Living Canada and Deaf and Hard of Hearing Alberta for their participation and input. In addition, Neil Squire Society and Independent Living Canada participated on the project advisory committee and were active participants in the 2022 Summit.

5. Consult the lived experience of individuals with other sensory, mobility and cognitive disabilities to identify areas where the research may cause further barriers and identify strategies to mitigate these barriers

Through CNIB’s ongoing discussions with Canadians living with disabilities, including those mentioned above, the concept of the “disability dividend” has been consistently realized. For instance, CNIB recommends that paths of travel be at least 1.8 meters wide to ensure safe passage for pedestrians walking in opposite directions. This width not only accommodates those traveling with a sighted guide or guide dog but also enhances overall convenience.

For individuals using ASL/LSQ to communicate, a path width of at least 1.5 meters is preferred, allowing them to maintain conversations while walking side by side. SignAble Vi5ion Inc. has made several other recommendations, such as ensuring customer service counters provide text messaging as an alternative to voice communication, and considering the use of colors that facilitate ASL/LSQ understanding. Additionally, they suggested:

• Providing information on the prevalence of Usher syndrome, a condition affecting people who are deafblind
• Recognizing the use of hearing ear service dogs
• Addressing design needs and using color to facilitate effective communication
• Meeting conversational needs in various settings like meetings and classrooms
• Considering acoustics to improve accessibility

These recommendations cover several sections of “Clearing Our Path” and will be integrated more extensively as CNIB updates its guidelines.

6. Provide a final report to Accessibility Standards Canada with recommendations on future standards in the built environment, with a focus on individuals who are blind or partially sighted

This report, along with the accompanying appendices, fulfills the requirements of objective six. CNIB intends to share a condensed version of this report on the “Clearing the Path” website, a platform that garners approximately 5,000 monthly visitors. This summary aims to provide accessible insights from the report to a wide audience, thereby contributing to greater awareness and understanding of the findings outlined herein.

Challenges

There were several challenges which required CNIB to pivot in order to achieve the project deliverables. The original plan set out in CNIB’s proposal was to gather stakeholders for a 2-day in-person gathering. This gathering was to bring together persons living with disabilities, municipal/provincial government stakeholders and design professionals. Similar gatherings have taken place in prior years which have proven productive.

Due to the pandemic, February of 2022 was not an ideal time to invite stakeholders to travel and gather.

However, with every challenge comes an opportunity. CNIB needed to find a way to engage with Canadians living with sight loss and other disabilities and stakeholders from across Canada. The solution, which was successfully implemented, was to host a 2-day virtual conference consisting of keynote addresses and 17 breakout discussions. Participation exceeded expectations and the resulting conversations have proven beneficial in opening doors for those with sight loss.

Another objective set out by CNIB in its proposal to Accessibility Standards Canada was to establish an advisory committee representative of groups/individuals living with perceptual, physical and hearing disabilities. CNIB identified three organizations before the project launched to provide feedback instrumental in updating the guidelines published on “Clearing Our Path”.

Two of the three organizations identified were able to review the guidelines and provide extremely helpful suggestions. The organization with perspective of persons living with hearing loss or those who are Deaf was unable to continue their engagement.

Fortunately, through the ongoing engagement facilitated through this project CNIB was able to obtain vital input from the perspective of persons who are Deaf.

Hearing from people with disabilities

The lived experience of Canadians with sight loss is a fundamental principle which underpins all of CNIB’s initiatives. Consistent with the Accessible Canada Act’s principle of “Nothing Without Us…” CNIB’s proposal was to hear from and learn of the lived experience of Canadians with sight loss and other disabilities.

The “Clearing Our Path” Summit

On February 7 – 8, 2022, the Summit took place from 12:00 PM to 6:00 PM AST. These times were intentionally picked in order that participation from all of Canada’s five time zones would be possible. CNIB’s outgoing Chief Executive Officer, John Rafferty, provided opening remarks and welcomed attendees. The agenda included keynote addresses from Chris Downy, an architect who is blind and is practicing in San Francisco, a panel discussion featuring accessibility leaders from across Canada and a presentation from the PEACH Unit of Dalhousie Universities school of planning.[3]

Over the 2-day Summit, 17 break out discussions were held, each facilitated by a person with a disability or other stakeholder. Appendix (A) provides a detailed synopsis of participants at the virtual Summit.

Hearing from other stakeholders

Of the more than 450 people who attended the virtual Summit, almost half were people with disabilities. The remainder of participants consisted of municipal/provincial governments, traffic engineers, accessibility consultants and other advocacy groups from across Canada. The Summit was promoted starting in November 2021 using CNIB’s numerous social media properties. The Summit was also promoted using a banner message which would appear each time someone visited the “Clearing Our Path” website.

CNIB also received promotional assistance from various professional associations by sharing information on the Summit with their memberships.

Hearing from professionals

At each of the 17 breakout sessions, CNIB was pleased to see many attendees were professionals working in accessible design. For many, their roles included providing recommendations to property managers and municipal governments regarding accessibility considerations. A recurring theme throughout the Summit was the lack of training for professionals responsible for designing or maintaining public spaces, particularly in accessibility.

Outside the specific accessibility standards mentioned earlier and detailed in appendices at the end of this report, detailed accessibility requirements are typically minimal or entirely absent. Barriers persist in deploying and constructing public spaces, both indoors and outdoors.

A resounding theme that CNIB continues to hear is that neither the “Clearing Our Path” guidelines nor existing standards go far enough. CNIB has been asked on numerous occasions, including various conferences funded by ASC, to provide more detailed and precise guidelines. While we appreciate validation of our expertise in accessibility for people with sight loss, CNIB believes guidelines and standards have limitations. Designers and other experts must rely on their domain expertise. Existing Canadian and international standards represent the minimum requirements for achieving accessibility and usability in public spaces for Canadians with disabilities. However, throughout the two-day Summit, the consistent message was that CNIB’s guidelines could be more extensive, offering illustrative examples for better implementation of accessibility.

As CNIB continues to update the guidelines on “Clearing Our Path,” we will leverage the capabilities of the existing technology provided by the content management system underlying the website.

Presentations

Throughout this project and specifically following the February 2022 Summit, CNIB has actively engaged with numerous stakeholder groups. In-person and virtual presentations have been delivered at conferences across Canada including the following:

• RHFA – Accessibility Professionals Network 2023 and 2024 AGM – Vancouver
• Royal Architectural Institute of Canada (RAIC) 2023 AGM – Calgary
• Association of Architectural Technologists of Ontario – Guelph
• The Buildings Show 2023 – Toronto
• Transportation Association of Canada (TAC) 2022 and 2023 AGM – Edmonton and Ottawa
• TAC active transportation committee April 2023 – virtual presentation
• Canadian Urban Transportation Association (CUTA) – 2023 and 2024 AGM – Montreal and Halifax
• Ontario Traffic Council 2024 Active Transportation Summit – Toronto

In addition to these in-person conferences and presentations, CNIB continues to both actively engage and support numerous accessibility advisory committees across Canada. Volunteers and staff are regularly asked to comment on initiatives regarding accessibility relying heavily on existing guidelines published on “Clearing Our Path”. Many of CNIB’s advocacy leads located in offices across Canada are both active participants in local initiatives regarding the built environment; and are themselves persons living with sight loss. Equally important, is that these colleagues support members of the sight loss community in their own individual advocacy initiatives.

A small sampling of these initiatives include:

• Engagement with public transit providers in Thompson, Manitoba
• Discussions with various municipalities in British Columbia discussing accessible pedestrian signals and other outdoor challenges faced by residents living with sight loss
• The City of Ottawa consulted on:
  • The introduction of a new tactile delineator to separate cycle and pedestrian traffic on the Mackenzie-King Bridge
  • Protected Intersections Design Guide – 2022-2023
  • OC Transpo – Electric busses – Spring 2022
  • Lansdowne Park (currently in the planning phase)
  • The new public library main branch (currently under construction)
  • The new Ottawa Hospital complex at Dow’s Lake
• Township of North Glengarry Main Street accessibility plan February 2023
• The City of Kingston – Access for All – accessibility home renovations – Winter 2024
• The City of Guelph – discussions with the accessibility advisory committee regarding the installation of accessible pedestrian signals
• The City of Hamilton – installation of tactile warning surface indicators
• The City of Edmonton – consultation on the use of continuous radius intersections
• Halifax Regional Municipality – various consultations on outdoor spaces including outdoor patios and traffic structures

Parallel studies

Throughout the life of this project, CNIB has not learned of research similar to that funded by Accessibility Standards Canada. Our research as cited earlier has included both domestic and international assessments. The conclusions which CNIB has drawn are as follows:

• The body of knowledge regarding accessibility best practices and standards as these pertain to people living with sight loss remains relatively stable. Little guidance outside of promotional materials exists concerning the multitude of innovative or digital indoor and outdoor navigation solutions.
• Some jurisdictions such as the U.S. Access Board closely parallel Canadian standards such as CSA’s body of work but, very much are in line with CNIB’s “Clearing Our Path” guidelines.
• CNIB understands international jurisdictions such as Japan, the United Kingdom do have their own best practices but, based on research these tend not to deviate far from existing standards such as the ISO documents cited above.
• While the number of existing standards on accessible public spaces as they pertain to people living with sight loss are perhaps nominal, their effectiveness can be better assessed by examining how various governing bodies choose to follow them. As is the case in Canada, the National Building Code morphs as Canadian jurisdictions implement the prescriptive requirements. This cascading effect permeates to provincial codes then municipalities develop their own guidelines which are adhered to at a municipal level. There is no reason to suspect that other Canadian jurisdictions adopt accessibility standards or perhaps even their own building codes differently.
• CNIB is pleased to learn that Accessibility Standards Canada has begun discussions to consolidate accessibility standards amongst Canada’s disparate jurisdictions. However, given that the Accessible Canada Act, under which Accessibility Standards Canada receives its mandate, has little if any influence over provincial and municipal standards as they pertain to the built environment.

“Clearing Our Path” at a glance

In June 2022 CNIB migrated the “Clearing Our Path” website from a static flat file PHP system to a WordPress content management system which was intentionally selected due to the ease with which content can be updated.

Moving forward, CNIB will be adding multi-media content which will illustrate the guidelines set out on the website. It is hoped that this will enable CNIB to effectively share emerging best practices as they pertain to accessibility for people living with sight loss and to equally unpublish those guidelines which may no longer be relevant.

About “Clearing Our Path” – Version 2.0

Version 2.0 provides a brief overview of why CNIB first published the guidelines in 1999 and an equally brief historical overview of accessibility legislation in Canada. The site also references the Rick Hansen Foundation’s accessibility certification research on the cost of making public spaces accessible.

Blindness basics

Provides a brief narrative as to the prevalence of sight loss in Canada. This section includes additional information on:

• Common Eye Conditions
• Mobility
• Wayfinding
• Reading and Writing

Design needs

This section of “Clearing Our Path” is where CNIB’s guidelines first appear. The website outlines various guidelines and best practices which speak specifically to accessibility requirements for people living with sight loss. The sections linked to from this page speak to both interior and exterior environments and how these public spaces can be made accessible for the target population.

Emergency and safety

This section speaks to the minimum requirements necessary to ensure that a visitor or resident can safely exit a facility in the event of an emergency. This section also discusses the need for life safety plans to be made available in alternate formats, a practice which is unfortunately rarely followed.

Resources

This section of the website contains links to resources sited throughout the 337 pages.  

What we learned

A key objective of this project was to undertake an exhaustive review of best practices and existing guidelines/standards as they pertain to people with sight loss. As has been mentioned earlier, Professor Wall Emmerson’s research which took place in the summer of 2021 found that overall, CNIB’s guidelines closely mirrored best practices and existing international standards. CNIB has completed two prior updates to our guidelines and a subsequent refresh when these were made available online: the first in 2009 and in 2016.

In the ensuing four years over which this project has operated, several Canadian jurisdictions have either published draft standards regarding public spaces or will be doing so shortly. These jurisdictions include:

• Nova Scotia Accessibility Directorate and
• Accessibility Standards Canada.

Manitoba, Ontario, British Columbia have likewise existing standards related to accessible public spaces which have either been published or are in various stages of consultation.

CNIB suspects that when the above standards are published that many common themes will exist across these documents. CNIB would suggest that as Accessibility Standards Canada continues its work on developing standards applicable to the federal government and federally regulated entities that close attention be paid to the provincial standards. Both those which have or will be published shortly.

What we heard

An integral piece of this project was to bring together voices from Canadians living with disabilities and, especially those living with sight loss. We are pleased to share that our expectations were surpassed.

Earlier in this report, we provided a brief overview of the February 2022 virtual Summit hosted by CNIB. The Summit ran over two days with participation in the 17 breakout discussions ranging from 15 participants to more than 100. The registration process invited attendees to self-identify and to request any accessibility accommodations.

The requests received through the online registration form included availability to ASL interpreters, an accessible meeting platform and the provision of materials both in advance and in accessible formats. To meet these requests, CNIB engaged several sign language interpreters all of whom were well versed in providing ASL support online. The interpreters were made available upon request for breakout discussion attendees elected to participate in. All breakout discussion facilitators received training prior to the Summit on spotlighting ASL interpreters.

All pre-reading materials were provided in Microsoft Word and linked to each of the breakout discussion groups. These resources remained available online for several months following the Summit. The pre-reading materials were extracted from the then current version of “Clearing Our Path” as well as several new resources identified early on. It was felt that while the “Clearing Our Path” website is fully accessible, the ability to lead focussed discussions in each of the breakouts would be easier if the contents were not left to individual preference or navigation styles. CNIB is please to share that this formula worked exceptionally well in that all attendees had a common frame of reference from which to begin the discussions.

Finally, at each of the three keynote addresses, CNIB ensured that ASL services were also provided. The panel discussion held on day two of the Summit provided an opportunity for attendees to engage with the three panelists and again, the availability of ASL services proved to be successful.

In 2023, a detailed synopsis of what was shared at the Summit was made available. The report, entitled “What We Heard” can be found at the preceding link. Upon review of this report, several themes appeared. First, is that despite the many guidelines and standards which exist on accessibility of public places, barriers persist. A timely reference given the state of the pandemic was on return-to-work practices. For example, “Hot Desks” or “hotelling” where employees do not have assigned desks but simply arrive and select the first available spot from which to work. Several attendees cited that when an employee requires assistive technology such as a closed-circuit TV reader the flexible nature of office spaces would often find them designated away from their colleagues. While well beyond the scope of this report, this speaks clearly to employment practices that do or should not isolate employees with disabilities.

Several comments were also made regarding the lack of detail available on the “Clearing Our Path” resource. We have briefly alluded to this earlier citing questions posed by design professionals as to how problems should be addressed. Other comments shared with CNIB following the Summit were that the guidelines perhaps were not as universal as they could be. CNIB appreciates all the comments shared at the Summit. While it is not within CNIB’s mandate to provide prescriptive guidelines, we will ensure that future updates to these provide additional clarity and where available multi-media illustrations demonstrating how the guidelines should be implemented.

From these and other comments from various stakeholders CNIB can only conclude that both education and additional partnerships are an essential component if future standards and guidelines are to have meaningful impact on the lives of Canadians living with disabilities. 

Also, as stated earlier, numerous design professionals expressed concern as to the level of education they received on accessibility accommodations. CNIB was somewhat disappointed to hear this given that for at least the past 10 plus years, conversations on accessibility to public spaces have been difficult to ignore. Recognizing that much more is needed, CNIB would encourage Accessibility Standards Canada and all accessibility standards setting bodies to seriously consider outreach to academic and professional groups as a core activity to encourage changes to the planning and engineering curriculum.

Americans with Disabilities Act (ADA)

The Americans with Disabilities Act has been in place for almost 35 years. It was passed into law in 1990. While well beyond the scope of this report, a brief history of American legislation and its corresponding standards as they relate to the built environment is informative.

The ADA encompasses numerous areas including employment, transportation and telecommunications, all of which are beyond the scope of this project.

The Architectural Barriers Act (ABA)

The Architectural Barriers Act was first introduced in 1982. It has undergone several iterations the most recent of which was in 2014. As with the Accessible Canada Act the U.S. regulations speak only to facilities operated or serving federal government departments, crown corporations and federally regulated entities. Unlike the Accessible Canada Act, the U.S. regulations specifically state that regulations apply to any initiative which receives federal funding. The ACA on the other hand is not so direct but does provide limited guidance on procurement. The applicability to private sector or state/municipal governments is beyond the scope of this report.

Unlike Canadian standards on accessibility including the National Building Code of Canada and parallel accessibility standards being developed or published across Canada, the ABA’s reach is considerably more extensive. Chapter 10 of the ABA speaks to recreational facilities in considerable detail. Subjects within chapter 10 include:

• Recreational facilities
• Amusement rides
• Recreational boating facilities
• Exercise machines and equipment
• Fishing piers and platforms
• Golf facilities
• Miniature golf facilities
• Play areas*
• Swimming pools, wading pools and spas
• Shooting facilities with firing positions
• Outdoor constructed features
• Parking spaces within camping units and picnic units and pull-up spaces at dump stations
• Tent pads and tent platforms
• Camp shelters
• Viewing areas
• Outdoor recreation access roots
• Trails
• Beach access routes*

* Play areas – neither the NBC or CSA’s current standards speak to the items indicated above. However, CNIB’s guidelines, do provide some guidance to facility operators as to how these spaces can be made accessible to patrons living with sight loss.

* Beach access routes – in the fall of 2023, Nova Scotia’s draft standard on the built environment did provide some guidance regarding the provision of accessible routes on beaches. Unfortunately, these draft guidelines spoke only to the provision of ground surfaces navigable by visitors using mobility devices. CNIB is not aware of any comparable guidelines that would accommodate visitors with sight loss or those with other perceptual disabilities.

Federal Highway Administration (FHWA)

Accessibility, to public outdoor spaces including sidewalks, intersections and trails, is prescribed under the Federal Highway Administration (FHWA). There is some intersectionality between the ABA sited above and FHWA’s guidance on accessibility to public spaces. Much of the guidance contained in FHWA’s resources speak primarily to vehicle infrastructure; however, there is considerable guidance on the navigability and use of streets and sidewalks by people living with disabilities.

Jurisdiction over roads and sidewalks and the necessary accommodations to ensure these facilities are accessible rests exclusively with provincial/territorial governments in Canada. The guidance which Canadian transportation infrastructure designers rely on is published either by the Transportation Association of Canada, (TAC) or the Canadian Institute of Traffic Engineers (CITI). As with the National Building Code of Canada referenced above, each Canadian jurisdiction interprets the TAC or CITI guidelines based on regional characteristics.

While comprehensive and highly effective with regards to the efficient movement of vehicles, their guidelines tend to be comparatively silent when it comes to the accessibility challenges faced by pedestrians living with sight loss. CNIB is pleased to share that transportation professionals both domestically and in the U.S. are receptive to guidance on how accessibility could be improved.

It is our view that due both to the complex regulatory environment which exists in the U.S. and Canada’s jurisdictional landscape that little would be gained by reviewing the FHWA guidance/standards in detail. At the same time, because many of the consulting firms active within Canada are multi-national it is reasonable to assume that the body of knowledge present in the U.S. will flow efficiently to Canada.

Conclusions

In conclusion, the inevitability of a growing number of Canadians living with sight loss underscores the critical need for enhanced accessibility in the built environment. Addressing key questions regarding the true meaning of accessibility, its intended beneficiaries, and the means of achieving it are paramount. While existing standards provide a foundational starting point, their universal applicability remains questionable due to their consensus-based origins. CNIB advocates for a future where evidence-driven research informs robust standards that reflect evolving demographics and technological advancements.

It is incumbent upon governments, city planners, and engineers,  to tangibly commit to accessibility, moving beyond mere adherence to standards to actively dismantling barriers. The societal costs of exclusion are profound, affecting individuals with disabilities and society at large. Canada’s progress in fostering a barrier-free society hinges on aligning future standards with the needs and voices of those they aim to benefit, guided by rigorous research and inclusive dialogue.

In closing, CNIB extends gratitude to Accessibility Standards Canada for facilitating a platform where over 450 stakeholders, including Canadians with disabilities, could voice their perspectives. Acknowledging room for enhancement, CNIB remains dedicated to refining guidelines to ensure accessibility initiatives, such as “Clearing Our Path,” continue to evolve and empower inclusivity across the nation.

Appendix A – Summit Agenda

The Summit was conducted virtually on February 7 and 8, 2022. CNIB’s outgoing Chief Executive Officer, John Rafferty, opened the event, welcoming attendees and expressing gratitude to the volunteer facilitators who contributed significantly to its success.

The first keynote address was delivered by Professor Mikiko Terashima from the PEACH unit of Dalhousie University’s School of Planning. Her presentation focused on the positive impact of accessible spaces on community health and the wellbeing of all citizens.

Day 2 commenced with a presentation by Chris Downey, a blind architect practicing in San Francisco for many years.

Also on day 2, a panel discussion featured Gerard (Gerry) Post, David Lepofsky, and David Kron, each renowned for their leadership in advancing accessibility legislation in Nova Scotia, Ontario, and Manitoba, respectively.

Session Title	Number of Attendees
101: Interior Spaces: Amenities, Washrooms, Meeting Rooms	105
102: Indoor Navigation	62
103 Emergency Preparedness Evacuation Plans	37
104 Exterior Design Elements: Bike Lanes, Parking Lots, EV Charging Stations	137
105 Paths of Travel Including Patios and Service Zones	63
106 Public Transit: Buses and Trains	43
201 Innovations in Accessibility: Dispatch Destination Elevators, Indoor Beacons and Other Digital Wayfinding Techniques	74
202  Roundabouts, Traffic Circles and Traffic Calming	69
203 Shared Spaces Micro Mobility Devices Including E-Scooters and Delivery Robots	34
204 Multi-use Trails	66
205 Construction Sites, Maintenance Considerations and Service Zones	37
206 Intersection Design, APS, Pedestrian Waiting Area Where Vehicles Have a Right-Turn Lane, Cut Curbs and TWSI Usage	76
301 The Importance of Lighting, Acoustics and Colour Contrast in Interior Spaces	65
302 Communication Systems, Directories, Service Counters, Virtual Agents – AIRA Be My Eye	44
303 Community Parks, How To Make Community Parks More Accessible For People Who Are Visually Impaired	45
304 First and Last Mile: How Can Cities Fix the First and Last Mile Problem?	47
305 Shared Streets and Walkability Making Shared Streets More Accessible For The Blind	108

Appendix B Cited Standards

This report references several standards that inform CNIB’s research. Except for CSA-B651 2023, all of these standards are copyrighted by their respective authors. It is important to note that many of the publishing bodies from which CNIB obtained these standards have significant accessibility issues with their online stores. For example, the Australian Standard on Wayfinding and the European Built Environment Standard could not be acquired, preventing CNIB from reviewing these informative documents.

Due to copyright restrictions, CNIB can only provide information that is freely available online. Sharing more could be considered an infringement of copyright or trademarks.

While we cannot reproduce the copyrighted standards, we will highlight any significant differences between these standards and CNIB’s guidelines. Only those differences that represent substantial variances in measurements or suggested content will be addressed.

ISO 21542:2021

Building construction — Accessibility and usability of the built environment

Scope

This document specifies a range of requirements and recommendations for the elements of construction, building assemblies, components, fittings and products that relate to the design and constructional aspects of usability and accessibility of buildings, for example, access to buildings, circulation within buildings, egress from buildings during normal conditions and evacuation in the event of a fire.

CNIB Comments

5.4.7 Glare and shadows for determination of uncomfortable glare levels caused by light sources, the unified glare rating (UGR) shall be applied.

The method outlined in the ISO standard acknowledges that people perceive things differently; however, it does not address the needs of individuals with sight loss. Until further research is available, CNIB recommends that standards offer guidelines for task-based lighting levels. Ideally, the measurement tools or formulas used by lighting designers should yield consistent results.

5.7 Acoustics – ‘The acoustic environment in a building should be suitable for its users, and the parameters of noise and reverberation are among the most important issues that should be considered. Noise transmitted from outside of a room can make an audible message difficult to perceive, and long reverberation times in the room itself can transform sounds and voices into noise that blurs the primary signal.’

This section of the ISO guide offers significantly more detail than CNIB’s current guidelines. We strongly recommend considering the recommendations outlined in this section when developing future standards. Acoustics have long been a barrier for everyone, regardless of ability, particularly in public spaces like restaurants, which often feature large, open areas with hard surfaces that do not support good ambient sound.

CNIB will strive to incorporate this section of the ISO standard into our ongoing updates to the “Clearing Our Path” guidelines, where feasible.

8.5.5.4 Mirror or mirrored wall within the elevator car – ‘Where a person using a wheelchair cannot turn around, a mirror or a mirrored wall shall be installed to enable the person to observe obstacles behind when moving backwards out of the car. If a glass mirror is used, it shall be made of safety glass.

If any wall of the car is substantially mirrored or covered with a reflective surface, measures shall be taken to avoid creating optical confusion (for example by means of decorated glass, or a minimum vertical distance of 300mm between the floor and the bottom edge of the mirror).’

CNIB’s guidelines on elevators specifically exclude this standard. Unfortunately, this highlights how accommodations for one group—such as wheelchair users and individuals who are blind—can inadvertently create challenges for others. While the rationale in the ISO standard is well-founded, incorporating mirrored surfaces in an elevator can lead to confusion for those with low vision.

9.2.7 Card and vending machines

Vending machines, or self-service kiosks, have become widespread since the publication of this ISO standard. While these devices can be made accessible, it ultimately depends on the provider’s choice. CNIB highlights examples such as those found on the TransLink SkyTrain network, at most Canadian airports, and at Canadian Border Services crossings as models for future standard development. Although the CSA has recently updated its self-service kiosk standard, the examples mentioned often do not comply with CSA B652, which is unfortunate.

11 Fire safety and evacuation – ‘Reliable protection of people with disabilities is achieved by equitable fire prevention and fire safety measures, building user/occupant practices, independent fire evacuation procedures and, when necessary, assisted evacuation and firefighter rescue.

Alternative, intuitive, clear, unobstructed, safe and accessible evacuation routes, both horizontal and vertical, away from the scene of a fire shall be available to all building users.

In all situations, independent emergency evacuation by persons with disabilities is preferred over situations where assistance by others is required.’

Section 11 of the ISO standard offers comprehensive recommendations for fire and emergency exits to date. CNIB strongly urges that these provisions be carefully reviewed in the development of future standards. While this report cannot reference every provision in Section 11 of the ISO standard, it highlights its significance.

As noted earlier, the Canadian National Building Code/Fire Code includes comprehensive standards on fire protection. However, the document’s format poses challenges for users of assistive technology, making it difficult to navigate effectively.

Annex E (informative) – ‘Methods for the determination of the luminance contrast E.1 General determination of the luminance contrast In this document, the Michelson formula and the Weber formula are used for determining luminance contrast values. The Michelson contrast algorithm is most frequently used when it comes to calculating luminance contrasts of building elements. On the other hand, the Weber contrast formula is the most frequently used method for calculating contrast values for small elements such as symbols that are mounted on a larger surface.’

In summary, the methods outlined in Annex A of this ISO standard are likely precise and would hold up under laboratory validation. However, both this standard and the CSA B651 2023 standard seem to lack an analysis of how luminance calculated using these formulas is perceived by individuals who are blind or have low vision. CNIB believes that, regardless of the calculation method used, the effectiveness of any formula must be evaluated under conditions that take into considerations the lived experience of people with varying eye conditions.

ISO 23599 Second Edition 2019-01

Notable Changes

ISO 23599 Second Edition (2019-01) introduces the Sapolinski formula as an additional method for calculating Light Reflectance Value (LRV), increasing the total number of approaches to three. The other methods include the Michelson contrast and Weber contrast formulas. Further research is needed to assess which of these formulas, when evaluated with lived experience of differing sight loss conditions, is the most effective.

The applications for determining LRV are extensive, but at a minimum, appropriate LRV levels are crucial for wayfinding and tactile walking surface indicator (TWSI) installations, among other uses.

CNIB Comments

‘This document provides product specifications for tactile walking surface indicators (TWSIs) and recommendations for their installation to assist in the safe and independent mobility of blind or vision-impaired persons.

This document specifies two types of TWSIs: attention patterns and guiding patterns. Both types can be used indoors and outdoors throughout the built environment where there are insufficient cues for wayfinding, or at specific hazards.’

Notably, ISO recommends that TWSIs be placed at both the top and bottom of stairs, escalators, and moving sidewalks, which contrasts with the guidelines set by CNIB and CSA. In indoor environments, TWSIs at the bottom of stairs may be unnecessary, as individuals with sight loss can often detect ascending stairs through echolocation or residual vision. However, in outdoor spaces, identifying ascending stairs can be more challenging.

Further research is needed to assess whether TWSI installations following the ISO standard would enhance accessibility. Additionally, typical installations of escalators and moving sidewalks often include metal plates that may serve a similar function to TWSIs. Further investigation would be beneficial in exploring this aspect.

CSA 651 2018

Accessible Design for the Built Environment

Scope
‘This Standard specifies technical requirements on how to make buildings and the exterior built environment accessible and safely usable by persons with physical, sensory or cognitive disabilities.’

Note: CSA B651-2023 was released mid 2023 and is freely available from the CSA website.

CNIB Comments

4.2 Luminance (colour) contrast

This section of the latest CSA publication introduces the Michelson contrast formula, which assesses the adequacy of color contrast between objects. CNIB notes that, while this method can effectively measure contrast and light reflectance values, research has primarily involved subjects with normal or corrected vision. Although the Michelson contrast measure can provide precise scientific data, CNIB’s findings suggest it may not be particularly useful for ensuring that visitors to public spaces do not face additional barriers due to inadequate lighting or contrast. For recommended formulas for measuring LRV between TWSIs and adjacent surfaces, please refer to the ISO guidelines above.

4.4.4 Tactile Warning Surfaces

This section of CSA B651 has been expanded for greater clarity on the application and use of tactile attention surfaces. The updated standards should be integrated into any new or emerging guidelines. Additionally, CNIB will incorporate these revised standards into “Clearing Our Path”.

5.6.4.7 Audible indication

In a recent comment submitted to CSA, CNIB recommended that audible announcements be provided on moving sidewalks. At that time, this suggestion was rejected. CNIB advocates for audible warnings on moving walkways to assist pedestrians who may not perceive the end of the walkway, allowing them to prepare to disembark. Citing the earlier-mentioned disability dividend, anyone using a moving sidewalk who may be temporarily distracted could refocus on navigating the walkway. Furthermore, this recommendation aligns with the ISO standard referenced above.

5.7 Emergency Provisions

B651 2023 does not address alarms for individuals who are Deafblind. CNIB’s guidelines recommend the inclusion of vibrating devices, as those who are Deafblind may not perceive flashing lights. Additionally, individuals who are solely Deaf may not notice a flashing light if their back is turned or if they are asleep.

8.3.6.3 Level medians and islands within a pedestrian crossing

The 2023 edition of CSA standards suggests that no tactile warning surface indicators should be provided if a pedestrian island intersects an intersection and the island is less than 2,400 mm long and level with the road surface. However, “Clearing Our Path” disagrees, recommending that tactile warning surface indicators be placed at both entry and exit points. CNIB asserts that whenever a pedestrian is about to enter a vehicular roadway, they must be notified in an accessible manner. Currently, tactile warning surface indicators are the recommended solution.

National Building Code of Canada – Section 3.8.3

CNIB Comments

The National Building Code of Canada – Section 3.8.3 is extremely challenging to view due to the inaccessibility of the document when using assistive technology. While addressing accessibility within the Government of Canada is beyond the scope of this project, CNIB believes that significant progress is still needed in information communication technology.

CNIB cautions anyone using assistive technology to access this Standard to proceed with care, as the document’s size causes it to render very slowly, if at all.

Geometric Design Guide for Canadian Roads

Scope

‘TAC’s Geometric Design Guide for Canadian Roads has been a fundamental road design reference for decades. It has contributed to the development of regional, provincial and national road and highway systems by helping planners and designers meet the needs of road users with safety and consistency.’

CNIB Comments

CNIB is pleased to see that more of TAC’s publications address accessibility and frequently refer designers to “Clearing Our Path.”

Canadian Roundabout Design Guide (2017)

Scope

‘The Canadian Roundabout Design Guide (CRDG) provides information and guidance related to the planning, design, construction, operation, maintenance and safety of roundabouts in Canada.’

CNIB Comments

Roundabouts and traffic circles effectively achieve their design objectives, including improving the efficient movement of vehicles, reducing serious collisions, and decreasing greenhouse gas emissions. However, individuals with sight loss face challenges when encountering a roundabout, as they lack orientation cues. If a roundabout is functioning as intended, a steady flow of traffic eliminates any audible signals that would indicate to a pedestrian with sight loss that traffic has stopped, and it is safe to cross.

CNIB’s guidelines reference research from the National Cooperative Highway Research Program (NCHRP) Report 674, which addresses crossing solutions at roundabouts and channelized turn lanes for pedestrians with sight loss. One recommended solution is to equip each leg of a crossing with a pedestrian-activated Accessible Pedestrian Signal (APS), requiring vehicles to come to a stop. Unfortunately, there is considerable resistance from the traffic planning and design community to implement this. Feedback from traffic practitioners in both Canada and the United States indicates that adding an APS at each leg of a traffic circle could be counterproductive.

While municipalities and provinces may not be bound by future standards authored by ASC, this information could be beneficial for government procurement practices.

Guidelines for Understanding, Use and Implementation of Accessible Pedestrian Signals (2008)

Scope

‘This publication on accessible pedestrian signals (APS) contains guidelines that were prepared in response to:

• the evolving needs of people with vision loss;
• technological advances in the accessible pedestrian signals industry; and
• the need to address the high degree of variability amongst APS installations in Canada.

The publication’s objective is to act as a set of stand-alone national guidelines for the understanding, use and implementation of APS in Canada and to expand upon the APS provisions within the Manual of Uniform Traffic Control Devices for Canada.’

CNIB Comments

Traffic signals have evolved significantly since these guidelines were first published in 2008. Smart cities are beginning to incorporate road sensor units into their traffic control infrastructure, and connected autonomous vehicles are set to appear on Canadian streets soon. Additionally, there is a growing number of mobile apps that claim to enhance the interaction between individuals with sight loss and traffic control signals.

However, CNIB suggests that ASC consider developing guidelines and/or standards to assess the effectiveness of these digital solutions. Emerging technologies, including mobile apps and those facilitating connected and autonomous vehicles, offer opportunities for improved mobility, but this potential can only be realized if the necessary data architecture supports open access. CNIB is optimistic that, with the increasing prevalence of open data models, this goal can be achieved.

“Manual of Uniform Traffic Control Devices for Canada

Scope

‘The Manual of Uniform Traffic Control Devices for Canada, Sixth Edition (MUTCDC) guides the use of road signs, traffic signals, pavement markings and other devices that inform travellers about road regulations, hazards and temporary conditions. It helps Canada’s federal, provincial, territorial and municipal governments to apply traffic control devices in a consistent and harmonized manner, which is an important factor in road safety.’

CNIB Comments

The MUTCDC offers substantial guidance on accessibility for road safety practitioners, including detailed information on accessible pedestrian signals and road markings regarding contrast and visibility. While this technical resource aims to assist in designing safe and efficient Canadian streets, it also encourages practitioners to consult with road users when developing or updating infrastructure.

Although much of the relevant content in the MUTCDC and other TAC publications falls outside the mandate of Accessibility Standards Canada, CNIB believes these resources could be valuable in developing future standards for outdoor public spaces.

Appendix C CNIB Presentations

Earlier in this report CNIB provided a summary of the presentations delivered over the past two years. The following expands on these providing additional details and subjects discussed.

RHFA – Accessibility Professionals Network 2023 and 2024 AGM	Vancouver, British Columbia March 2023	“Navigation within indoor public spaces without the aid of wayfinding accommodations” This presentation illustrated the experience of a person who is blind attempting to find a shop within a typical Canadian shopping centre. With the aid of a GoPro camera, the real and unedited challenges faced by someone with sight loss in navigating a busy, noisy and large open area were highlighted. Many solutions do exist to mitigate some of these challenges but these are rare. Several Canadian airports and several other venues have introduced either fixed beacon navigation systems or have subscribed to virtual agent assistance.
Royal Architectural Institute of Canada (RAIC) 2023 AGM	Toronto, Ontario May 2023	The goal was to network with and build awareness amongst architects and designers on the importance of accessible and inclusive built-environments for people living with sight loss. CNIB provided remarks suggesting that much more can and should be done to improve accessibility for people living with sight loss. The exhibitor hall primarily had building materials vendors and suppliers. CNIB’s representative spoke with each exhibitor about the importance of considering accessibility in their products and materials, whenever applicable, in anticipation of increasing demand from architects for materials that support accessibility. Finally, during networking events, CNIB met with many architects to convey the need for a holistic approach to accessibility that considers the needs of all communities. Although attending the event was a useful awareness and education building activity, it was determined that a more impactful next step will be to seek a speaking opportunity at the next conference.
Association of Architectural Technologists of Ontario	Hamilton, Ontario Spring 2023	CNIB was invited by this group to present from the lived experience of someone with sight loss. A CNIB staff person, who has been losing his sight over the past few years shared his experience in navigating residential spaces. His challenges are typical of those who share his story in that residential spaces simply lack basic accessibility accommodations. It was disappointing that his current residential building was only a few years old and barriers persist for him which include: Inaccessible call buttons Poor wayfinding to access building amenities Amenities including laundry facilities that lack any accommodations for people who are blind Inadequate lighting to properly assist anyone with less than “normal vision”
The Buildings Show 2023	Toronto, Ontario Fall 2023	CNIB attended this event for the second time in the past five years. Our first engagement well before this project came about was in 2018. CNIB had and continues to work with an emerging technology leveraging virtual reality to assist people who recently have begun to lose their sight. At our first presentation, a demonstration using virtual reality was provided. Participants were invited to wear VR glasses which simulated the leading eye conditions and then asked to navigate a virtual setting. Those participants who chose to try the simulation were astounded to learn how challenging navigating a flight of steps can be, if those steps are poorly equipped. Our presentation in the fall of 2023 took a more conventional approach where CNIB presented as an exhibitor at the Buildings Show trade floor. Conference delegates engaged readily with CNIB staffing a booth and numerous conversations were held.
Transportation Association of Canada (TAC) 2022 and 2023 AGM	Edmonton, 2022 Ottawa, 2023	2022 The use of accessible pedestrian signals by pedestrians living with sight loss. This was the second time in five years that CNIB delivered this same presentation. The first, was in St. Johns Newfoundland and Labrador in 2017 and then again in Edmonton in 2022. The audience, all of whom have some degree of familiarity with the guidelines developed by TAC in 2008 were invited to observe as pedestrians with various degrees of sight loss navigated intersections around Canada. The guidelines were presented and then illustrations of how, when built differently can impact people who rely on APS to know when a walk signal has changed. 2023 In 2023, CNIB was, once again invited to present to the active transportation committee as part of the 2023 AGM. A panel discussion was organized with CNIB, Accessibility Simplified and SignAble Vi5ion Inc. discussed what accessible transportation meant to each of the panelists. All panelists were persons with lived experience, someone who has been blind from birth, someone who has acquired a mobility disability and a person who has been Deaf for many years.
Active Transportation Committee (Virtual presentation)	April 2023	Construction mitigation CNIB presented the real lived experience of a pedestrian who is blind attempting to navigate city streets amongst the disruptions of ongoing and prolonged construction. With the aid of a practicum student, a CNIB staff ventured out onto Halifax streets wearing a GoPro camera. Several construction sites were featured where barriers either were non-existent or job sites were not barricaded. The importance of properly trained workers was reinforced. If encountered, while heavy equipment is operating, anyone living with sight loss would quickly become disoriented. This presentation was to illustrate CNIB’s guidelines on construction sight mitigation found on clearing our path.
Canadian Urban Transportation Association (CUTA)	2023 and 2024 AGM – Montreal and Halifax	This was CNIB’s first time attending any CUTA event. Given the importance that public transit plays in the lives of Canadians living with sight loss, CNIB—with support from Accessibility Standards Canada—was able to engage with transit operators from across Canada. Our message to operators was, firstly to ensure that electric buses are equipped with an appropriate acoustic vehicle alerting system (AVAS) and that consultations with persons living with sight loss or other disabilities continue as a best practice.
Ontario Traffic Council 2024 Active Transportation Summit	Toronto, Ontario, 2024	At this one day gathering of municipal engineers and consultants, CNIB delivered a presentation discussing the following accessibility issues: How members of the sight loss community leverage accessible pedestrian signals Barriers created when construction sites fail to implement appropriate safety practices to ensure that vulnerable road users do not end up in harm’s way The findings of recently published CNIB research which spoke to the challenges created at island bus stops

[1] Quebec’s legislation differs drastically from that of the other provinces likely due to the timing of the legislation. The Quebec legislation takes a holistic view to people with disabilities and mentions specifically expectations of government, public/private organizations to ensure they do not create barriers.

[2] The first edition of “Clearing Our Path” was published in 1998, updated in 2009 and then again in 2016 when the guidelines became available online.

[3] To learn more about the PEACH Unit visit their website at:

Planning for Equity, Accessibility, and Community Health