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ARCHIVED - Treasury Board Real Property Accessibility Policy

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1. Effective date

This document contains the policy as revised June 30, 1998. It replaces the version dated November 15, 1993.

2. Policy objective

To ensure that persons with disabilities can gain access to, and use, federal real property.

Note: For interpretation of this policy in the Province of Quebec, "real property" means "immovable" within the meaning of civil law of the Province of Quebec and includes the rights of a lessee in respect of such an immovable.

3. Policy statement

It is government policy to ensure barrier-free access to, and use of, real property it owns or leases.

4. Application

This policy applies to all departments within the meaning of section 2 of the Financial Administration Act, unless specific acts or regulations override it.


(a) All departments should be aware that the Canadian Human Rights Act prohibits discrimination in the provision of goods, services, facilities, and accommodation.

(b) The Treasury Board Human Resources Management group of policies provides information on the provision of services to employees with disabilities.

5. Policy requirements

(a) Custodian departments must provide barrier-free access to, and use of, real property they administer using the technical standards and implementation requirements in the Appendix.

(b) Certain elements of real property may be exempted from the full-accessibility requirements in accordance with the provisions of the Appendix. Custodian departments must identify those real properties within their custody that are to be made accessible and those that are to be partially or fully exempted.

(c) Departments must take steps to provide appropriate access and use where this policy does not satisfy a special need of a federal employee with a disability, does not deal satisfactorily with access in particular properties, or adversely affects certain employees.

(d) Wherever practicable, persons with disabilities must be offered the same level of access to, and use of, federal real property as persons without disabilities.

(e) All departments must take temporary action to meet the requirements of persons with disabilities while planning and implementing permanent adjustments.

(f) Tenant departments must ensure

(i) that the lease, in the case of a private-sector landlord, or occupancy agreement in the case of a federal custodian landlord, clearly states that the landlord must adhere to the accessibility requirements of this policy; and

(ii) that their tenant operations, as well as fit-up parameters requested by them, do not negate the efforts of the custodian or landlord in providing accessibility in accordance with this policy.

(g) In leasing out federal real property to a tenant who is located on or in the same property as a government service and serving either the same employees or the same users as the government service offered in that property, custodian departments must require, in the lease agreement, that the tenant adhere to this policy. For existing leases, departments must make every effort to ensure that tenants adhere to this policy.

(h) Annual reports are to be submitted to the Real Property and Materiel Policy Directorate, Treasury Board of Canada Secretariat, and should reflect changes made to accessibility plans and implementation progress. Accessibility improvements completed to real property in the preceding year should also be described.

6. Responsibilities

(a) Custodian departments have primary responsibility for ensuring that the real property they administer is accessible to persons with disabilities and for planning appropriate capital and maintenance programs to ensure implementation of the accessibility policy.

(b) Public Works and Government Services Canada (PWGSC) provides technical support; architectural and engineering support and services; and guidance on best practices as they apply to accessibility for persons with disabilities on an optional, cost-recoverable basis. PWGSC maintains a technical library for the benefit of the federal government and other interested parties.

(c) The Treasury Board of Canada Secretariat

(i) consults with representatives of tenant and custodian departments and other interested parties, especially persons or groups concerned with accessibility issues regarding this policy; and

(ii) prepares reports for the Treasury Board that provide an overview of the progress made as measured against departmental plans.

7. Monitoring

The Secretariat will determine how effective this policy is, find out how it is applied in departments, and decide whether it needs to be revised. It will do this through ongoing contact with departments, consulting with the Treasury Board Advisory Committee on Real Property, and noting audits and reviews conducted by departments or the Auditor General of Canada. The Treasury Board Guide to Monitoring Real Property Management provides information so that departments can monitor and assess policy implementation.

8. References

8.1 Authority

This policy is issued pursuant to the Financial Administration Act, subsections 7(1), 9(1.1), and 9(2), and the Federal Real Property and Federal Immovables Act, subsection 16(4).

8.2 Treasury Board publications

Treasury Board Guide to Monitoring Real Property Management

Treasury Board Real Property Glossary

9. Enquiries

Please direct enquiries about this policy to your departmental headquarters. For interpretation of this policy, departmental headquarters should contact:

Real Property and Materiel Policy Directorate
Treasury Board of Canada Secretariat
L'Esplanade Laurier
140 O'Connor Street
Ottawa ON K1A 0G5
Telephone: (613) 941-7173
Facsimile: (613) 957-2405


Appendix - Barrier-free Design: Implementation Requirements

1. Technical standard

The technical standard to be applied in implementing the requirements within Crown-owned or Crown-leased real property, referred to in the policy as the "technical standard," is found in the publication entitled Barrier-free Design Standard (CAN/CSA-B651-M95 or subsequent editions).

2. Minor variations

In applying the technical standard or the detailed implementation requirements to existing owned or leased real property, custodian departments may allow minor variations from the standard or implementation requirements. Such variations must be consistent with the general intent of this policy but must not affect the general accessibility of a specific property.

3. Supplemental standards

Custodian departments, when developing standards that either supplement or are a substitute for the technical standard, must consult on these with technical experts at both the developmental and final stages. These changes should be described in the department's annual accessibility report to the Treasury Board of Canada Secretariat.

4. Scheduling

Federal real property must be made accessible in the following sequence:

(i) sites (or locations) where the public or employees in large numbers require access;

(ii) other Crown-owned real property;

(iii) other Crown-leased real property.

5. Implementation requirements for new construction


This section refers to all Crown-owned and lease-purchase real property. The decision to make a building or other facility accessible should be based on occupancy requirements as well as the type of property and its expected use during its life.

5.1.1 If parking spaces are provided for employees or visitors, accessible spaces must be provided in conformance with municipal by-laws and the following table. If these parking spaces are reserved for government employees only, then the accessible parking spaces may be assigned on a temporary basis to employees in general. These spaces must be relinquished, however, should employees with disabilities require them:

Parking spaces

Total parking

Minimum No. of
accessible spaces

up to 25


















more than 500

2% of total

The accessible parking spaces may be distributed among distinct parking areas but must be within a reasonable and safe proximity of the federal facility.

5.1.2 Where applicable, accessibility must include routes from accessible parking areas, local public transit stops, and all drop-off areas to main entrances.

5.1.3 Where applicable, access to, and use of, the following must be provided:

(i) entrances to the real property. Frequently used points of access to the property must be equipped with a power door operator. Where access or egress to the facility is through doors in series (in a vestibule-like arrangement), at least one complete set of doors allowing access through the vestibule area must be so equipped;

(ii) passenger elevators;

(iii) public areas (including, but not limited to, cafeterias, lounges, recreation areas, eating areas, patios, libraries, and walkways);

(iv) federal work areas (including, but not limited to, offices, on-floor storage areas, meeting and training rooms, computer rooms, and spaces for business machines);

(v) interior doors and corridors;

(vi) washrooms;

(vii) public telephones. When banks of public telephones are provided, there must be at least one public telephone per bank accessible to persons in wheelchairs and one public telephone per bank accessible to persons with hearing impairments. All direct-line telephones and at least one charge-a-call telephone, when provided, must be similarly accessible;

(viii) one accessible water cooler or drinking fountain in each location where a water cooler or drinking fountain is provided; and

(ix) emergency egress from all accessible areas.

5.1.4 Where applicable, emergency egress must be accessible by means of an area of refuge, a horizontal exit, or an accessible route to the exterior.

5.1.5 Where applicable, detectable warnings must be provided at the top of all stairs except exit stairs in a separate stairwell.

5.1.6 Tactile signage must be used for washrooms, emergency egress, elevators, stairwells, and doors off main corridors.

5.1.7 Accessible seating spaces must be provided within auditoriums, theatres, and other general assembly areas in conformance with the National Building Code of Canada.

5.1.8 Classrooms, auditoriums, meeting rooms, and theatres with an area of more than 100 square metres must be equipped with an assistive listening system encompassing the entire seating area.

5.1.9 Fit-up parameters must not detract from the efforts of the custodian department or landlord to provide accessibility in accordance with this policy.

5.1.10 All new residential units must either conform to the technical standard or be designed to be easily adaptable when employees or their immediate dependents require accessibility.

6. Exemptions for new construction

6.1 Custodian departments are solely responsible for establishing internal procedures for identifying and approving any exemption in accordance with this section. As part of this procedure, custodian departments should consult users as well as experts in addressing accessibility issues. When evaluating the factors for exemptions, custodian departments should consider that restrictions for one disability do not automatically apply to all disabilities. Exemptions should be considered on an individual basis. A justified exemption from one type of accessibility requirement does not mean that exemption from other accessibility requirements will be granted.

6.2 Various new buildings or structures, due to their specialized design function or requirements, may be candidates for a reduced level of accessibility or can be completely exempted from barrier-free design requirements. Such facilities include, but are not limited to, the following: naturally inaccessible facilities in remote locations, unattended monitoring stations, facilities that are designed and constructed to accommodate able-bodied personnel (i.e. where being able-bodied is a specific part of the job requirement), and facilities where operational requirements preclude reasonable access by persons with disabilities. If the specialized design or operational requirement that justified the exemption changes, then the custodian department must reassess the facility against the policy to ensure that the exemption is still justified.

6.3 In some cases, access need not be provided to certain parts of a facility, such as boiler rooms, roofs, elevator pits, elevator penthouses, mechanical rooms, electrical vaults, piping or equipment catwalks, or areas of hazardous occupancy (as defined by the National Building Code of Canada and the National Fire Code of Canada ) unless the intended use requires public access or the job requirements are such that a person with a disability could meet these requirements.

7. Existing Crown-owned real property


The decision to make Crown-owned real property accessible should be based on occupancy requirements as well as the type of property and its use during its life expectancy.

7.1 All existing Crown-owned real property must meet the following requirements:

(i) all the requirements in sections 5.1.1 and 5.1.2;

(ii) all the requirements in section 5.1.3 with the following differences:

  • In the case of entrances to the property, the door for at least one entrance from the outdoors at sidewalk level or from a ramp leading from a sidewalk must be equipped with a power door operator, where appropriate. Wherever possible, this door must be the main entrance to the facility. Where access or egress to the facility is through a series of doors in a vestibule-like arrangement, at least one complete set of doors allowing access through the vestibule area must be so equipped.
  • In the case of washrooms, there must be at least one accessible men's washroom and one accessible women's washroom or one accessible individual washroom for each occupied floor where washrooms are provided.

(iii) all requirements in section 5.1.4. In existing real property, however, suitable operational procedures can be used where accessible egress facilities are impractical; and

(iv) all requirements in sections 5.1.5 to 5.1.9.

7.2 Generally, existing Crown-owned residential units need not be accessible. Custodian departments must be prepared, however, to make units accessible when required by employees or their immediate dependents.

8. Exemptions for existing Crown-owned real property

8.1 No barrier-free access is required to the second storey of a two-storey building if the area of the second storey is less than 600 rentable square metres and there is full access to government services and employment opportunities on the ground floor. The same provisions apply to single-storey buildings where the basement is used as an operational second floor.

8.2 The exemptions listed for new construction apply.

8.3 Real property that the government will permanently vacate, or that will be removed from the federal inventory within 12 months, may be exempted completely. Custodian departments must be prepared, however, to take temporary action in the interim in cases where people with disabilities are employed or served.

8.4 Custodian departments must adapt existing residential units when employees or their immediate dependents require accessibility.

9. Heritage facilities

The requirements for heritage facilities are the same as those for other Crown-owned facilities except where these requirements will significantly reduce the heritage quality of the facility. Some deviation from the standard is permitted provided a local or regional committee consisting of experts in accessibility issues and the Federal Heritage Building Review Office, which represents federal heritage considerations, have agreed to the accessibility requirements and the following requirements are met:

(i) access must be provided to at least one main level in the facility;

(ii) there must be full access to government services and employment opportunities;

(iii) where washroom facilities are provided in an inaccessible location, equivalent facilities that are accessible must also be provided; and

(iv) for inaccessible exhibitions, another version of the exhibition, such as a video display, must be provided in an accessible area.

10. Leased real property


In this section, "leased" means space leased to the federal government, not space owned by the federal government and leased to the private sector. The decision to require a leased property to be rendered accessible should be based on occupancy requirements as well as the type of property and its use during the lease term.

10.1 Where applicable and subject to the following, all leased space must be rendered accessible in accordance with sections 7 and 8, relating to existing Crown-owned real property.

10.2 Where custodian departments are expressly permitted to exercise discretion or flexibility in applying the technical standard or the implementation requirements, it must be exercised in such a way so as not to nullify the general intent of this policy or the general accessibility of the specific property. Custodian departments are also required to take whatever temporary action is necessary in cases where persons with disabilities are employed or served.

10.3 For existing leases where:

(i) people with disabilities are employed or served; and

(ii) the landlord does not agree to alter the facility or to have the facility altered in accordance with the requirement, even at the Crown's expense;

departments should take whatever alternative or temporary action the landlord will permit and vacate the premises at the end of the lease term.

10.4 For all new lease tender calls or exercised lease options with terms of more than two years, access to and use of facilities must be in accordance with article 10.1. When the requirement would unduly restrict the competitive process, or when such facilities are not readily available on the market, custodian departments may

(i) exercise minor discretion in applying the technical standard or the detailed implementation requirements, based on building configuration; or

(ii) consider bidders who agree to make the leased space conform with article 10.1 within one year of the lease being signed. Based on building configuration, minor deviations may be acceptable.

10.5 For non-renewable new leases and lease options for temporary space having a duration of less than two years, custodian departments may exercise an increased level of flexibility in applying the requirements, based on the building configuration.

10.6 Generally, leased residential units need not be accessible. Custodian departments must be prepared, however, to lease accessible premises or render the existing premises accessible when required by employees or their immediate dependents.

11. Enquiries

(a) Technical enquiries about making federal facilities accessible should be directed to PWGSC:

Standards and Codes Architect
Buildings Directorate
Architectural and Engineering Services
Public Works and Government Services Canada
Place du Portage, Phase III, Level 1
11 Laurier Street
Hull QC K1A 0S5
Telephone: (819) 956-7888
Facsimile: (819) 956-2720

(b) Enquiries about disability policy and co-ordination issues, the Federal Task Force on Disability Issues, and non-government organizations contacts for disability issues should be directed to Human Resources Development Canada:

Office for Disability Issues
Human Resources Investment Branch
Human Resources Development Canada
Suite 100, 25 Eddy Street
Hull QC K1A 0M5
Telephone 1-800-O-Canada or 1-800-622-6232
TTY/TDD: 1-800-465-7735
Facsimile: (819) 953-4797 or (819) 997-2073

(c) Enquiries about the Barrier-free Design Standard referenced in this Appendix should be directed to either the nearest Canadian Standards Association regional office or to the head office.

Head Office:

Standards Sales and Customer Service
Canadian Standards Association
178 Rexdale Boulevard
Etobicoke ON M9W 1R3
Telephone: (416) 747-4044 or 1-800-463-6727
Facsimile: (416) 747-2475
Web site: 

Regional Offices:

Canadian Standards Association
Pacific Office
3799 Commerce Parkway
Richmond BC C6V 2N9
Telephone: (604) 244-6652
Facsimile: (604) 244-6508

Canadian Standards Association
Western Office
1709-94th Street
Edmonton AB T6N 1E6
Telephone: (403) 490-2007
Facsimile: (403) 435-0998

Canadian Standards Association
Eastern Office
865 Ellingham Street
Pointe-Claire QC H9R 5E8
Telephone: (514) 428-2418
Facsimile: (514) 694-5001