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What? The AMA's Built Environment Standard won't include buildings

Nov 26, 2018

Person in a wheelchair at the bottom of steps

Manitobans with disabilities continue to face pervasive barriers to full accessibility in housing, offices, factories, entertainment venues and commercial buildings throughout the province. These barriers prevent them from exercising their human rights to live, work and recreate as full citizens. Significant limitations in The Manitoba Building Code, for example, result in costly and preventable barriers being perpetuated and newly created every day in built environments across the province. And the Building Code does little if anything to remove existing barriers because it applies, for the most part, to new construction and major renovations.

BFM has been trying to work constructively with government officials over the last two years to ensure that our province’s disability communities are meaningfully consulted on the efforts needed to address the current inaccessibility of our built environment.

We have become increasingly concerned that such consultations at the provincial level aimed at addressing barriers in buildings will be limited or entirely unavailable. Indeed, we've been informed that the pending Accessible Built Environment standard will not even consider buildings. Rather, this standard will focus on areas outside the Building code such as sidewalks, pathways and parks.


This seems to defy logic and common sense. It also seems to directly contradict the letter of the landmark Accessibility for Manitobans Act (AMA). The purpose of the Act is vividly clear. 


2(1) The purpose of this Act is to achieve accessibility by preventing and removing barriers that disable people with respect to

(a) employment;

(b) accommodation;

(c) the built environment, including

    (i) facilities, buildings, structures and premises, and

    (ii) public transportation and transportation infrastructure;

(d) the delivery and receipt of goods, services and information; and

(e) a prescribed activity or undertaking.  

As this clause 2(1)(c)(i) abundantly evident, the purpose of the AMA, as passed by a unanimous vote of the Legislature in December 2013, specifically includes preventing and removing barriers related to “facilities, buildings, structures and premises”.

The government’s intention, as we understand it, is for accessibility of buildings to be covered under revisions to The Manitoba Building Code. This is the approach that has been used, for the most part, under Ontario’s 2005 Accessibility for Ontarians Act (AODA) despite major criticism from many of that province’s disability advocates. Notably, past processes that the government has used to revise the Manitoba Building Code have not provided for meaningful and timely input by our diverse disability communities and has not included broad public consultations.

In efforts to be constructive, BFM has stressed the critical importance of government:

  • Providing clear and timely information to our disability communities on plans to address accessibility barriers in the built environment both inside and outside of buildings.
  • Ensuring close and ongoing coordination in communication, consultative and development processes related to work on the Accessible Built Environment Standard and to The Manitoba Building Code.
  • Ensuring that Manitobans with disabilities have timely and meaningful opportunity to contribute to the development of the Standard and revisions to the Code.

Progress of these discussions have been significantly hampered by the need to promote collaboration across two departments (The Department of Families is responsible for the AMA while the Department of Growth, Enterprise and Trade is responsible for the Code).

Accordingly, we have become very concerned by two recent developments.

  • A September 13, 2018 letter sent on behalf of the Minister responsible for the AMA referring to the Accessible Built Environment Standard as the “Accessible Public Spaces Standards”. This not only represents a renaming of one of the five initial standards but the letter now also suggests that more than one standard will be developed to address built environment barriers.
  • An August 2018 email message from the Deputies of Families and Growth, Enterprise and Trade advising us that we should focus on “work at the federal level to ensure that issues related to [building] accessibility that are paramount to your organization are addressed at the beginning of the code development process and that codes are designed in a manner that benefits all Canadians.”  

These developments lead us to believe that our provincial government still has no clear and effective plan, five years into the AMA implementation, to address the pervasive physical barriers that face Manitobans with disabilities every day. 

We are raising these concerns because the timely removal and prevention of barriers in buildings is so very critical to meeting the AMA's promise of achieving major progress toward full accessibility by 2023.

We are also raising now it because, as far as we know, final decisions are yet to made. So there still is time for the Province to reconsider what seems to be incompletely thought out plans. 

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