The Building Code plays an important role in determining what types of housing builders can construct economically. Planning and zoning reforms alone will not increase housing supply if Building Code requirements make new housing impractical or prohibitively expensive.

As the province conducts a line-by-line review of the Ontario Building Code, TRREB has submitted a written submission to members of the Building Code Short-Term Advisory Body, providing detailed feedback and solutions to make the Code clearer, more practical, and more supportive of housing construction.

TRREB Recommendations

1. Establish an Annual Building Code Review Process: Ontario should establish an annual review process between consolidated Building Code editions to reflect a more continuous approach to Code development similar to the national review approach. It should allow the province to consider emerging technologies, new construction practices, recurring interpretation issues, national Code changes, and proven reforms from other jurisdictions without waiting for the next complete Code edition.
   
2. Permit Single-Stair Residential Buildings Up to Six Storeys: TRREB’s latest report, Removing Roadblocks: Tackling Municipal Barriers to Housing Supply and Affordability in Ontario, advocates for allowing single-stair egress for buildings up to six storeys by establishing clear safety standards, including sprinklers and floorplate limits, and aligning Building Code reform with provincial missing-middle housing policies. British Columbia provides a relevant Canadian precedent. We are not recommending lower safety standards, but Ontario should adopt a modern, risk-based approach that reflects advances in sprinklers, materials, fire detection, compartmentation, and firefighting practices.
   
3. Permit Elevators Within Qualifying Exit Enclosures: To make better use of a small building footprint, TRREB recommends permitting an elevator within an exit where the building is no more than three storeys high, has sprinklers, and the elevator doors open only into the exit. This reform could make it easier to provide barrier-free access in small apartment buildings, reduce unnecessary circulation space, and improve the coordination of the stair and elevator within a constrained floorplate.
   
4. Modernize Elevator Size and Speed Requirements for Small Apartment Buildings: We encourage allowing the option of a faster passenger elevator that meets applicable barrier-free dimensions for residential buildings that are not more than four storeys in height and 600 square metres in building area. This would not eliminate stretcher-sized elevators where building height, size, occupancy, or emergency-service requirements warrants them. It would provide a proportionate option for small buildings where a faster passenger elevator could improve accessibility without imposing the spatial requirements of an elevator that serves a substantially larger building.

Our recommendations on the Ontario Building Code would help make missing-middle and small mid-rise housing more feasible, improve accessibility and design flexibility, and reduce unnecessary regulatory burden without compromising the Code’s core public-interest objectives.

Read TRREB’s recommendations here.