I understand there's some variation. I'd refer you again to the Council of Canadian Academies' study, because I believe there is a useful summary there that compares the jurisdictions. I understand there is variation, and in particular in some jurisdictions it may not be as specific as the British Columbia statute you mentioned. It may be more a matter of how the case law has evolved and is implemented by common law.
Again, I would commend to you the CCA study, because I think that provides your answer.