OFA provides comments to the Ministry of Municipal Affairs and Housing regarding proposed changes to Ontario’s Building Code (OBC) – Phase 3 Fall 2022 Consultation.
OFA is supportive of consistent applications of Building Code requirements across jurisdictions, however, OFA is concerned with the OBC consultation process and outcomes to date.
Firstly, the consultation documents are unclear as to which changes to the OBC outlined in the first two phases of the consultation have been adopted or carried into Phase 3. It is challenging to provide comprehensive feedback to the proposed changes in Phase 3 when it is unclear how they will be interpreted in the context of earlier proposed changes.
Secondly, efforts to consult with the agricultural community and the engineering expertise at OMAFRA should have been done early and often to ensure that implications for buildings on farms were clearly identified, analyzed and consulted on.
Thirdly, OFA is concerned that while proposed changes to the OBC are meant to clarify and streamline development by harmonizing requirements with the NBC, some proposed changes to the OBC as drafted are more restrictive than the National Building Code.
Finally, OFA is also concerned that the proposed changes will be misconstrued and adversely applied to farm worker housing.
OFA recommends that MMAH work closely with agricultural stakeholders to ensure OBC changes are not detrimental to agricultural businesses with farm worker housing.