Working with Canadian AHJs, Building Codes & the Value of Early Stakeholder Alignment w/ Crosscheck Modular Consulting

Permitting can turn “faster with modular” into “stuck in review” long before the first module leaves the plant. Sam Taylor, founder of Crosscheck Modular Consulting in Ontario, explains what actually slows modular projects down and what teams can do differently on their next build. If you’ve ever wondered why approvals feel unpredictable from one town to the next, this conversation puts real structure around the problem. 

Sam walks through the modular approvals process in Ontario, where building permits are submitted to local authorities having jurisdiction and shaped by local bylaws as much as code. She explains why early engagement with building officials matters so much, especially in smaller communities that may not see modular often, and how proactive communication can reduce redesigns, clarify inspections, and keep projects moving. Additionally, she also compares province-to-province realities, from Alberta’s deeper familiarity with modular to BC’s Step Code energy efficiency requirements.

Transcript

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Welcome And Guest Introduction

SPEAKER_01 0:00

Hello and welcome to Inside Modular, the podcast of commercial modular construction, brought to you by the Modular Building Institute. Welcome everyone. My name is John McMullen. I'm the marketing director here at MBI. Today I'm joined by Sam Taylor, founder of CrossCheck Modular Consulting in Ontario. Sam is here to talk about modular project reviews and approvals and what project stakeholders can do to get projects built more easily. Sam, welcome.

SPEAKER_00 0:29

Thanks, John. Thanks so much for having me. I'm excited to chat with you today.

SPEAKER_01 0:33

It is my pleasure. Tell me about yourself, Sam. What drew you to the modular side of the building industry and what made you decide to launch cross-check modular consulting?

SPEAKER_00 0:43

My background's in architectural technology. And for the past nine years, I've been working for an engineering and design firm who focuses on modular construction. And during my time at that company, the thing that I kept hearing more and more about is that we need to train more of our building officials and to no fault of their own, because modular is fairly new still, even though we've been doing it for years. But we need to share some of that knowledge on how modular buildings work so that our permits can be approved faster. So I saw an opportunity and uh am branching out to start Cross-Tech.

Sam’s Path Into Modular Consulting

SPEAKER_01 1:18

Well, you're very brave. Uh, congratulations on the new business. Um, tell me about your typical client and what issues are you tackling

Who Sam Helps And Why

SPEAKER_01 1:28

now?

SPEAKER_00 1:29

So there's actually a series of different people that I am working with and that I can support. Um, one of my focuses is actually on supporting people with the A277 standard here in Canada. So that's the standard that modular manufacturers have to build to in terms of quality assurance. It kind of acts as their building official in the manufacturing plant. So I can help those manufacturers or whoever needs assistance with A277 to prepare their quality documents or their tracking documents and help guide them through the process. Another client of mine would be maybe a manufacturer or developer who is looking for assistance in the permitting. So I can be their representative to submit building permits to the local authority and through that process help explain some of the differences between modular construction versus conventional construction and where some of the inspections would vary based on some of the work being done in the plan. Additionally, just help them with Canadian codes and design. So the thing that I've been doing for most of my career is design and code review. So I can help bring the right engineering team together and complete those code reviews on modular projects.

How Ontario Permits Really Work

SPEAKER_01 2:45

For listeners who don't really live in the world of approvals every day, what does the what does the modular approvals process in Ontario uh actually look like from you know from concept to occupancy? Where do teams get tripped up a lot of the time?

SPEAKER_00 3:01

Great question. And it's uh from people that I speak with, it's kind of unique here in Canada, I think. So we start in design and maybe maybe I'll start on the permitting process actually. So when you're submitting a building permit here in Canada, and most of our provinces are the same in that sense, if you're submitting a building permit here in Canada, rather than a provincial level, you're submitting to the local authority having jurisdiction, which means pretty well every city or town has their own authority that you have to approach and say, hey, I want to submit a building permit for the building that's going in your town. The tough part about that is that every single time you're going to a new authority, unless you're working within the same township. The good thing about that is that they know their area best. And so they do have local bylaws that you have to abide by and as well as the building code. So we have a national building code, and then we have a couple of provinces that have their own. Um, Ontario, Alberta, Quebec, and BC each have their own. So you kind of have to abide by that local bylaw as well, which is why you go to the local building official. The thing that I'm here to help with is to coordinate with each one of those different building officials to kind of guide it through. But to kind of go back to your question, the design process is very important to know where you're going early on. I always recommend engaging the building official as early as possible, especially on modular buildings in smaller townships who maybe are not as familiar with it. What you can do by approaching the building official early on with your design is to talk through it together. Like we're a team. We all want to add buildings to the communities that we're living and working in. Um, and then we can guide them through that process. Um, we can ask any questions. Maybe there's a variance that you want to go with. Maybe you're working with existing modular assets. And early engagement with that building official could potentially mean that they're willing to treat it like an existing building rather than a new building in their township. So communication is really key and early engagement with the local authority on your design process helps make it smoother and reduce changes throughout that design.

Province Differences That Affect Approval

SPEAKER_01 5:21

So have you noticed there being differences besides just township to township, uh province to province? Like when you compare Ontario to Alberta or BC, where do you see the biggest differences and how modular projects get reviewed and approved?

SPEAKER_00 5:37

Absolutely. So we have a couple of provinces who I would say are maybe more familiar with modular. So because of all the workforce housing that happened in Alberta in the oil fields, Alberta actually has, they're the only one that have a separate section in their building code for modular buildings, part 10. They tend to be more familiar with it, which helps. Typically, province to province, it's not so much about the local authority, but maybe the differences in the building code. So BC, for example, has step code, which is a higher efficiency, higher energy efficiency for buildings. So that's something that you have to factor into your design, where if you're trying to come up with a typical modular residential unit that you want to use across Canada, it's something that you have to factor into the design as well, that BC might have a little bit of a higher energy efficiency. So knowing your different provincial codes is important if you're trying to do a universal module who that's going to work across Canada, which is something that I am approached with quite a bit.

When Teams Must Align Early

SPEAKER_01 6:44

You spoke earlier about the importance of early coordination, which we we've heard a lot in this industry. And it's absolutely true. In your experience, at what point should the modular manufacturer, the architect, the engineer, and the local building official become aligned? And what happens when that happens too late?

SPEAKER_00 7:03

Good question. So the best approach for an efficient modular design is to engage a team that's familiar with modular construction from the very beginning. It's hard to take a fully completed concept plan that wasn't done with modular in mind and then convert it into modular. So it's really important to have the design team or at least one member. It doesn't have to be your whole team that's familiar with it, but at least one key member who's contributing to the concept design for be familiar with modular early on. Once you even start to have that concept design, really engaging the manufacturer to understand maybe the limitations within the manufacturing plant. Have the transportation team involved to understand, okay, how far are we shipping this? Do we have any transportation limitations that we have to factor into that design as well? Having early conversations to make sure that all of that is coordinated is going to make the design process as efficient as possible. And we all talk about modular being efficient and the time being one of the biggest contributors to why people want to go with modular construction. But what that means for the design team is that we need to have a lot of information up front because there's a lot of detail that goes into modular design to make it work as efficiently as it does. And so having those key stakeholders in the very beginning rather than contributing later when maybe construction has started, maybe the plant is already moving. It's too late at that point. So early coordination is key.

What Conventional Designers Often Miss

SPEAKER_01 8:35

Given your uh experience in design and engineering and all that goes into designing a building, what do architects and engineers who come in with a strong experience in conventional construction, uh, what do they often miss when they move into modular construction?

SPEAKER_00 8:54

Another great question. Um, I'm a huge advocate for training other designers and other members because I obviously we all want to promote modular as much as we can. But the more designers and engineers and architects who want to work in the modular field, the better, in my opinion. So some of the key things that are not always factored in is obviously we're working with a box. I shouldn't say obviously. I mean, panels, panels are there too, but most of the time we're working with a volumetric module. And so what we have to factor in, the big thing is that now you have two walls that are coming up to each other. So what used to be maybe just a six-inch wall is now a foot, like a full foot that is not factored into your design. So depending on how far along you are with that design, it is hard to make it modular. Are you already at the point where the foundation's in place? Um, and now your building is is either larger or you're taking space away from the inside. Another thing that we try and factor in is, you know, if you can, we try and group um plumbing into one module. And that's something that maybe in conventional construction, you still want to group things as much as you can, but it makes it a lot more efficient if you have a dry module and you're able to readjust some of those things. Chases are very important to be able to factor in as well. Uh, not having, like maybe having a plumbing wall in it rather than a marriage wall because you can't run some of those things on a mate wall like you normally would. So just a few, a few things to consider. But if you have a good modular designer or consultant on board, they can help flag some of those things

A277 Explained And Why It Matters

SPEAKER_00 10:32

early.

SPEAKER_01 10:32

Another thing you mentioned earlier in the interview was was A277, which is um what is A277? I'm not certainly as up on it as you are. I was wondering if you could give me a quick rundown of of how that standard is applied.

SPEAKER_00 10:46

So A277 is the it's can CSA A277. So it's a CSA standard that modular manufacturers use across Canada to ensure their quality assurance. So it's actually a standard that we do now have written into our building codes as a reference. Most building officials recognize this. And if your module shows up on site with an A277 label, then they have confidence that there's been a third-party inspection apart from the engineer that's been completed in the manufacturing plant to ensure quality assurance. So a couple of things to keep in mind about this standard is that it doesn't take over the responsibility of the engineer or the architect. So there still needs to be a qualified engineer, architect, or designer working on the drawings as well. And depends on the size and type of building, they will have to do inspections throughout the construction process in the plant as well, based on our building codes. So it doesn't take over for that. What it does is that a third-party inspection agency, so we have three up here, it's CSA, InterTech, or QAI, would come into the manufacturing plant at key points throughout the construction and do a random audit of the module construction that you're doing. So they're checking and inspecting the modules to see that you're following the engineered plans. They're tracking materials. So they want to make sure that your materials are Canadian approved materials based on our building code. They're tracking nonconformances and then just general conformance to the building code.

SPEAKER_01 12:20

Are there any misconceptions about what this standard or how it's applied and how how it should be applied versus you know how it definitely is not applied?

Common A277 Misconceptions

SPEAKER_01 12:29

Is there any confusion there that you've come across?

SPEAKER_00 12:32

For sure. I mean, uh one of the big ones is that if you're A277 certified, that you no longer need engineered drawings, you you're kind of your own governing body. And to an extent, you are your own governing body because once confidence is built with your certifying body, inspections move to quarterly inspections. And so as long as your quality assurance manager is maintaining the same level of quality, you are governing that yourself within the quarter. But you do still need to work from a qualified design package. And like I said, it doesn't, it depends on the building code. So, for example, if you're doing a 1200 square foot building, it could be a qualified designer in Ontario under a BCIN rather than an engineer. But depending on what the building code calls for, you do still need your engineer architect or qualified design drawings.

How To Avoid Delays And Train Officials

SPEAKER_01 13:27

Looking ahead, what advice would you give to a project team in Ontario or any other province that wants to avoid approval delays on its next project? What changes would you most like to see from regulators or or industry to make modular approvals more consistent across Canada?

SPEAKER_00 13:44

Good question. I think the best thing that us as a modular industry can do for building officials. And I and I believe there's opportunities coming out through the Canadian government to help with this as well. But I think it's training. I don't think it's fully on the building officials when it's something that's so rare that comes into their township to know the ins and outs of modular in detail. And I think the best thing that we can do is work as a team when you have a modular building in a township. Work with the building official to explain the processes that we know and work with every day and help provide more guidance on what it looks like to have a modular inspection done off-site and then come to site. Provide clarity as to what inspections are already being done off-site and by who. And that helps fill in the gaps of what work is being done on site and what the building official has to review. I think providing clarity on the process is something that is going to make the building permit more efficient.

Five-Year Wish List For Approvals

SPEAKER_01 14:50

Let's fast forward five years. What um what changes would you like to see in how Canada approves modular buildings?

SPEAKER_00 14:58

There are so many things I would like to see. Let me make a list. Um, I think a really important one for the modules that we have here in Canada is coming up with some type of universal standard for existing fleet. A lot of times when you have early engagement with building officials, they're open to treating existing modules as an existing building, even if it wasn't an existing building in your township. Um, what I would really love to see is some kind of written code that indicates that. And obviously, you still have to do an engineering review for the location that it's going to. So if you're moving something from Alberta to Ontario, you have to do a review for the local climate, like the snow loads, the thermal loads. You have to go through some of those things. But it would be really great to see something written in to our building code to treat existing modular fleet as existing buildings and have it universally recognized. That would probably be my biggest one.

Advice For New Modular Professionals

SPEAKER_01 15:58

Um, last question for you. Um, what advice would you give to younger professionals like you, uh, who are just getting into modular design? You've been in it for several years, but for for a new designer just discovering modular, where should they start?

SPEAKER_00 16:14

Well, obviously they should go to MBI first. Like you guys have such a wealth of knowledge to you share on your website and and you connect the right people together. It's it's really amazing the amount of people that I've been able to meet through MBI and through World of Modular. So that would obviously be my first recommendation, but modular is such a it's a small community, really, in the grand scheme of construction, but everybody is so supportive. It's fast paced. People are in it with the same goal. So even if you're at one of these conferences and you're sitting next to your direct competitor, you're there to help each other. Everybody's there to promote modular. So on it, I can I cannot recommend getting into the modular industry enough. If you like fast-paced and unique solutions and honestly, just a group of people who are all working towards the same direction, definitely started a career in Modular.

Wrap Up And Industry Events

SPEAKER_01 17:12

Thank you so much, Sam. Uh, I really appreciate your time today. You spoke of World of Modular just a second ago. It was great to see you last week in Las Vegas. Uh, and I hope I get to see you again soon.

SPEAKER_00 17:24

Thank you so much, John. WAM was amazing as it always is. You guys do an incredible job. And as a Canadian, I'm I'm very excited for how many Canadian events there were this year, too, to have a couple of socials and a couple of more opportunities to gather with Canadian members. So thank you so much for everything you guys do. And uh I'm sad I'm gonna miss the Toronto Expo that's coming up in June, but I'm very excited to see you guys again at the next event.

SPEAKER_01 17:54

Well, we are sad too. Um sorry you can't be there, but the Canadian industry is a huge part of our membership, a huge part of MBI. There's so much going on in Canada now, it's just mind boggling. Uh, hopefully we can stay in touch and do this again soon. Absolutely. Thank you so much, John. My name is John McMullen. This has been another episode of Inside Modular, the podcast of commercial modular construction. Until next time.