How could the current…

How could the current examination design, content and/or delivery be improved?

-Stop using scenario questions that anchor the information to the first question this forces exam takers to scroll up and down to refresh on info when the time is already limited. Provide 3 1/2 hours for the exam. Try and stick to the items covered in the prep course, the remainder of the knowledge could be gathered with further learning for CPD credits via courses or other training.

Are the current training offerings meeting your needs?

- The pre-exam courses are good but further in depth training is still needed such as Part 3 classification & construction, this course goes into more detail of how the code works flush out how requirements work together, rather than just reading from the code book.

Do you see a role for the administrative authority in the delivery of training for building code professionals?

- Yes the AA could work with groups like the OBOA, OAA, PEO, OACETT and other associations to create and deliver more in depth training on specific topics such as Exposed building face details, Install of fire rated closures, Fire service mains & sprinkler systems, Fire alarms etc.

What factors could contribute to the low take-up of the current internship programs?

- lack of knowledge of that it exists and lack of time for people to mentor interns.

What role could an administrative authority play in internship programs?

- Start conversations with municipalities about the benefits of the program at the council level.

Would implementing a provisional licence framework help with municipal recruitment challenges and what should be considered?

- This could help, but the person should have passed the legal exam under the building exams to be granted a PL, the code already provides for as per the notes to table 3.5.2.1 Div C.

Are there other ways to help building code enforcement bodies attract and retain experienced building professionals?

- Audit municipal staffing levels or provide a metric in the building code act based on population or building permit fees whichever is higher for mandated staffing levels, many municipalities ignore low staffing levels and don't address them until problems arise or staff leaves due to being over worked,
if this was addressed maybe more entry level jobs could be created. As for retention pay between municipalities can differ drastically for a comparable building department thus causing high turn over.

Do you think the use of a Prime Consultant, under certain circumstances, would support a more streamlined building permit application process?

- Yes the PC could be very helpful on larger buildings to organize one central point to address the permit process, ensure field reports are documented and provided to building officials, address inspection deficiencies or ensure when further details for the project are required they are addressed by the proper design professional.

Do you think the use of Certified Professionals, under certain circumstances, would support a more streamlined building permit application process?

- No. The CP appear to be a helpful tool but how will liability be decided if something goes wrong when the building department is only partially engaged with part of the project, also Elliot Lake provided a window into how even seasoned professional can have poor judgment. The optics of the builder picking a CP is also not a good one.

If the ministry decides to move forward and allow the use of such professionals, what do you think needs to be considered in implementing this change?

-How will liability be decided in the courts, the municipality will still be the last player standing after other go bankrupt.

If you are a registered building code professional, what are the key issues you face with the current QuARTS system?

- Navigation and user interface.

What registration functionality would you find helpful that is not currently available in QuARTS?

- Better searching or provide an app and allow designers to provide a scalable code to bring up qualifications and other info such as proof of insurance etc.

As a member of the public, what information would you like to see made publicly available on the registry to help you make an informed decision on hiring a qualified building code professional?

- Provide examples of buildings that the designer is qualified to design. if the designer is only qualified in house provide examples of projects they could design, show that people are qualified in the legal exam.

How many activities or hours of CPD do you feel is reasonable to require of building code professionals?

- 80 over 4 years, this would be 20 per year based on 1 hour = to 1 CPD.

What is the right mix of formal and informal CPD activities that building code professionals should be required to complete (e.g., courses, training, examinations, reading professional/technical journals or documents, volunteering in the sector, attending relevant conferences, etc.)?

- Based on my above notes 20 informal such as reading or volunteering or other non building related but job related items & 60 formal such as courses, association meetings with guest technical speakers or conferences.

What is a reasonable timeframe for completing CPD requirements to ensure knowledge is maintained (e.g., annually, at every new Building Code cycle which is usually 5-7 years, other)?

- 4 years as my notes above, special considerations would also need to be thought of for such items as paternal leave, medical leaves, over seas work just as we have seen with officials working in NZ etc, When a code change is completed formal training on the updates should be required for the areas of qualification for the building official or designer for CPD, this could be one large course that could cover many subjects or broken down so training is completed on similar Parts from the code such as Part 3 and 9 being once training course, exams should not be needed for this as professionals already have the qualifications but are only being provided new code requirements.

Are there already mechanisms, materials, or offerings that would give building code professionals options on how they could meet their CPD requirements?

- Yes the OBOA, OAA, PEO & OACETT all have training or track CPD credits.

What types of compliance measures should be put in place to ensure building code professionals are meeting the requirements of their registration?

- If BCP such as designers or building officials do not comply with the yearly fee or CPD a public list should be published of who is not currently meeting the minimum requirements for qualifications to notify the public.

What types of accountability mechanisms do you think might be appropriate if a body enforcing the building code (i.e., municipality, Conservation Authorities, Boards of Health) is found not to be meeting its responsibilities under the Building Code Act, 1992?

- Audit the body and find out why and force the body to address the issues.

Do you see any challenges with requiring all building code professionals to adhere to a code of conduct?

- Building officials already have a COC, but designers are mostly small business, that being said it could be made part of the requirements to practice under a BCIN and is issues are brought forward an investigation should be conducted by the AA.

What should be considered when increasing the number of available enforcement tools and using an escalating enforcement model?

- Proper training again this could be an in depth training course for building officials on how to handle interacting with the public and when to escalate to orders or charges. Ensure fine are set via the BCA and not by the municipalities

Under what circumstances do you think it would be appropriate for financial penalties to be used as a means of encouraging compliance with registration requirements?

- If building officials or designers are found to be not working in good faith example sharing BCIN numbers, designing outside of qualifications etc. financial penalties should only be enforced under strict serious situations.

How could these penalties be set so that they are fair?

- Based on the severity of the offence.

What types of orders do you think administrative penalties could be used for? What do you think the province should consider in developing an administrative penalty framework?

- Any order under the code depending on the severity of the offence. Provide escalating guidance of when AP should be enforced, if someone is building a shed without a permit the first step should be to try and gain compliance by providing a business card or notice to contact the building department, if that is ignored place an order, if not complied with then AP should be placed. The same could not be said for say a house being built/renovated without a permit, in this case the order should be placed and the AP should be charged as this could carry more liability for the municipality.

Are there enforcement tools that would help principal authorities ensure compliance with technical requirements of the building code?

- Allow municipalities to seek restraining orders on habitual offenders who contravene the BCA & OBC.

Would it be beneficial for municipalities to have the ability to transfer some or all of their building service delivery to the administrative authority?

- Yes this could help or provide a network for support for smaller municipalities can hire or seek out building officials that are qualified in areas that the building official serving that area are not qualified in. Another way would be to create a central unit that could be drawn from to preform this function under the AA.

What kind of framework should the province consider for dealing with building code compliance and enforcement in unincorporated areas?

-If we had centralized building departments set up almost like the OPP we could provide support to UC areas to address unsafe building.

Would you support the issuance of technical bulletins and/or code interpretations? Please explain.

-Yes, these could be used to ensure explanation of material or clarifications and help foster consistent enforcement of the code.

If additional resources and guides to help with code interpretation were created, what types of resources (e.g., type of content, format, etc.) would be most useful?

- Technical content and illustrated details in a downloadable PDF documents, printed copies when requested.

Would the addition of more visual guidance materials for specific building code issues be helpful?

- Yes, bring back the illustrated guide even if it's only in PDF.

As a member of the public, what resources and tools would you need to assist you with understanding code requirements for your small or personal construction projects (e.g., minor renovations, decks, sheds etc.)?

- Provide helpful handouts with easy to use pre-set details for smaller projects such as decks, sheds, garages, finished basements or accessory apartments in a house.

If you would use an electronic version of the Code, on what type of electronic device would you most frequently view/use it on? (e.g., laptop/desktop, mobile device)

- On all devices. The electronic version should be fully searchable or searchable to only parts of the code, clickable links or provide pop ups when a sentences notes another part of the code or the appendix notes if provided.

In addition to digital versions of the Ontario Building Code Compendium, what other digital guides, resources or tools would you find most useful?

- Illustrated guide, further guides on but not limited to Insulation, HAVC, Plumbing, Septic systems, Public pools and spas, Tents, Secondary unit in a house etc.

How could the potential increase in municipal reporting burden be mitigated?

- Legislate a electronic system that all municipal building departments are required to use.

Do you think it would be beneficial if the administrative authority conducted research on behalf of the sector?

Yes.

Is the proposed funding model a reasonable approach to delivering improved services to the sector?

Yes.

Are there impacts in implementing such a fee model that the government should consider?

- This could pass more costs on to the public from the construction industry.

If we want better service levels the building departments of Ontario need to stop being used as the catch all for other code related and non code departments or enforcement agencies. We need to provide better more enhanced training and guides to help both the public and municipal authorities navigate the code.

If we want to provide even across the board permit application acceptance the government should look into developing a made in Ontario software program for electronic reporting, electronic permit upload, plans review, inspection, enforcement etc. This way no matter the size of the municipality your permit application process would be the same and allow for easy transfer of plans review to other departments in Ontario if support was required.

In closing any changes made from this consultation should not add more burden to municipal departments or staff.