Access Insight - May 2019

APRIL / MAY 2019

2019 ACAA National Conference

REGISTER NOW

15th AUGUST

16th AUGUST

9.00 am - 5.00 pm CPD = 10 points/day $325+GST Early Bird Rates • Includes lunch, Trade Exhibition and Trade launch evening • Early bird rates valid to 1st July

9.00 am - 5.00 pm CPD = 10 points/day $325+GST Early Bird Rates • Includes lunch, Trade Exhibition and Trade launch evening • Early bird rates valid to 1st July

Design and assessment of NDIS Specialist Disability Accommodation (SDA)

NCC 2019 Accessibility Verification Methods DV2, DV3 and FV2.1 and Quantification

Presented by the Technical writers of the NDIS SDA Design Standard and includes Q&A session

Livable Housing Design

Presented by Chairperson of LHA

Presented by ABCB

A Metric to Assist Performance-Based Design

Presented by an ABCB Subject Matter Expert on Accessibility

Achieving inclusion through SDA

Update of Accessibility related standards - AS1428, AS2890 and AS1735 series

Designing for SDA Robust Housing

Presented by Standards Australia

Presented by SDA provider Summer Housing

Fire safety measures for people with disabilities

Presented by an Expert Fire Safety Engineer

Design for aged and dementia friendly access Sydney Opera House Accessibility management Accessibility in Museums Government supported home modification schemes

Human Centered Design in Access and Inclusion New NCC 2019 requirement for Accessible Adult Change facilities Access planning at Invictus Games Inclusion in External Environments Sensory design for Autism Spectrum Conditions

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

FROM THE PRESIDENT’S DESK

by Mark Relf AM

President of the Association of Consultants in Access Australia

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n this edition Access Insight tackles the sometimes thorny issue of exempting certain areas of a building using part D3.4 of the BCA or other concessionary clauses from the Access to Premises Standards.

Invariably, the exemption or concession is not a black and white decision and requires an expert opinion from an Access Consultant. On occasion the exemption may morph into the need for a performance solution and further evidence to justify why the exemption is valid.

From my perspective while the current provisions of D3.4 tend to align with the performance based nature of the NCC the topic is grossly undervalued within the Guide to the BCA and deserves much greater commentary. The Guide should adopt a more balanced human rights perspective about the abilities of people with disabilities and the removal of barriers, physical and attitudinal, especially as the NDIS continues to rollout across the country and more people with disability gain access to their communities. Supporting exemptions, dispensations, concessions and performance solutions must not be determined by the

chequebook but by evidence and knowing the “whys” that underpin the requirements and standards.

The articles presented in Access Insight provide useful guidance and experiences of our members and I’m sure others have useful advice in this area. If so drop us a line as I am sure we have not exhausted the topic in just a few articles.

NCC 2019 … IT’S HERE AND WHAT’S NEXT Well the Preview edition is now final and in force.

As previously noted NCC 2019, includes several important amendments related to access consulting: • Accessibility Verification Methods DV2, DV3 and FV2.1 • Adult change facilities I’m fairly confident in assuming no one has delved too far into using verification methods DV2, DV3, FV2.1 as yet. Especially given the open ended nature of DV2 and ambiguous parameters such as; a reference building, occupant profiles and

IN THIS ISSUE From the Vice President’s Desk.................2 ACAA State Networks...............................3 2019 Conference.....................................4 Exemptions and concessions....................8 To serve or not to serve..........................12 Interpreting Exemptions: A Rights-Based Perspective...........................................16 Disability (Access to Premises – Buildings) Standards 2010 Concessions.................20 Hot Apps...............................................22 Book Review..........................................24

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Address: 20 Maud Street, Geelong VIC 3220 Email: office@access.asn.au Phone: +61 3 5221 2820 Web: www.access.asn.au Editor: Farah Madon

vicepresident@access.asn.au April / May 2019 Issue Cover photo credit: iStock Please email the Editor if you would like to showcase your project on the Cover of the next Access Insight

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

ACAA MATTERS characteristics, appropriate modelling method and tool.

If you too are perplexed by DV2 don’t despair as the quantification of the verification methods is the next phase in the grand scheme towards the increased competent use of performance project (ICuP).

As we take the next step forward the ABCB is keen to work with ACAA and its members to assist in developing quantification processes and parameters to support DV2 and FV2.1.

This is an open invitation to members who would like to be part of the project to provide input into the quantification, modelling methods and evidence based data to support the verification methods. If you are interested please send me an email to marksrelf@gmail.com The second day of the ACAA Conference (16th of August) will have a number of speakers on this very topic and we look forward to seing you there.

AS 2890.5 OFF STREET PARKING The draft revision of this standard has been out for a while with public submissions closing on the 22nd May. The committee will review all comments in the next phase of drafting, which will lead to publication sometime later in 2019.

ACAA ACCESS 2019 CONFERENCE AND 2019 DISABILITY ACCESS INCLUSION AWARDS ACAA Access 2019 Conference planning continues. By popular request, we have extended the early bird registration dates to Monday 1st of July 2019. This will give some flexibility to attendees to register and pay for the conference on both sides of the financial year end.

The early bird registration fees are $325+GST per day of the conference (15th or the 16th of August).

We have received Abstracts for the ACAA 2019 Disability Access Inclusion Awards that will enable members to showcase their projects which have gone above and beyond the minimum regulatory requirements. Our judges for this Award will be John Deshon AM from QLD and Anita Harrop from WA. The A1 posters of the shortlisted projects will be displayed at the Conference.

I am also delighted to announce that the 2019 Access Inclusion awards will be presented at the Conference Dinner on the 15th of August 2019 by the new Disability Discrimination Commissioner Dr Ben Gauntlett.

Mark Relf AM

ACAA NSW Access Consultants Network

ACAA COMMITTEE OF MANAGEMENT CONTACT DETAILS

ACAA SA Access Consultants Network

PRESIDENT: Mr Mark Relf AM

Contact: ACAA NSW Chairperson

Robyn Thompson for details Contact: ACAA SA Chairperson

Grant Wooller for details

ACAA QLD Access Consultants Network

VICE PRESIDENT: Mrs Farah Madon

Contact: ACAA QLD Chairperson

Angela Chambers for details

SECRETARY: Mrs Anita Harrop

ACAA VIC Access Consultants Network

TREASURER: Mr Howard Moutrie

Contact: ACAA VIC Chairperson

Ms Maree Wyse for details

ACAA WA Access Consultants Network Contact: ACAA WA Chairperson

Anita Harrop for details

ORDINARY MEMBERS: Ms Jennifer Barling Ms Cathryn Grant Mr Bruce Bromley

April / May 2019

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2019 CONFERENCE

2019 ACAA Conference Program THURSDAY 15TH AUGUST: TOPICS (10 CPD POINTS)

FRIDAY 16TH AUGUST: TOPICS (10 CPD POINTS)

8.00am

REGISTRATION

8.00am

REGISTRATION

8.50am

Welcome and Conference Introduction

8.50am

Welcome and Conference Introduction

9.00am

Keynote Address 1: NDIS Specialist Disability Accommodation (SDA) program delivery

9.00am

Breaking through to Inclusion and Get Skilled Access

9.30am

Keynote Address 2: Specialist Disability Accommodation (SDA) Design Standard

9.30am

NCC 2019 Verification Methods and Quantification

10.00am

Achieving inclusion through SDA: A vision for the future

10.00am

Practitioner responses to Verification Methods

10.30am

MORNING TEA

10.30am

MORNING TEA

11.00am

Livable Housing Guidelines

11.00am

A Metric to Assist Performance-Based Design and Ensure Dignity and Equity

11.20am

Accessing the Home: Government-supported home modification schemes

11.20am

Applying Design Thinking to our Work as Access Consultants

11.40am

LHA, SDA and BCA access-navigating these with builders and certifier

11.40am

AON Risk Management for Access Consultants

12.00pm

Robust Housing design for SDA: what does it mean and how can it be achieved?

12.10pm

12.20pm

Posters Presentation

Human centred design in Access and Inclusion

12.30pm

LUNCH

12.30pm

LUNCH

1.30pm

Q & A Panel on Specialist Disability Accommodation (SDA) Design Guidelines

1.30pm

Standards Australia

1.50pm

Fire safety for people with disabilities

2.00pm

Accessible Adult Change Facilities

2.10pm

The Dos and DON’Ts of aged and dementia friendly access

2:20pm

Inclusion in External Environments

2.30pm

Parallel Parks and VR

2.40pm

AFTERNOON TEA

2.50pm

AFTERNOON TEA

3.10pm

Invictus Games

3.20pm

Technology enabling inclusion in the extreme

3.30pm

Access & Inclusion Assessment Toolkit 'The Human Factor'

3.40pm

Uber and the Future of Mobility

3.50pm

The sensory design features that influence participation (Autism Spectrum Conditions)

4:00pm

Hireup - the online platform revolutionising the Australian disability sector

4.10pm

Inclusive communities for people with communication difficulties

4.20pm

The Sydney Opera House and Accessible Programming

4.30pm

Ableism in the Built Environment - A work in progress

4.40pm

An Accessible Museum

4.50pm

CONFERENCE Closing

5.00pm

CONFERENCE Closing

*Subject to Change 4

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

2019 CONFERENCE

ACAA Conference Dinner and 2019 Access Inclusion Awards ACAA is delighted to announce that the new Disability Discrimination Commissioner will be attending the ACAA Conference dinner on the 15th of August 2019. Conference Dinner tickets are limited so book early: www.accessconference.com.au/register

Dr Ben Gauntlett Disability Discrimination Commissioner Ben Gauntlett commenced his term as Disability Discrimination Commissioner on May 7, 2019.

Ben is a quadriplegic following a schoolboy rugby union accident aged 16 in Perth, Western Australia. He has the experience of a person living with a disability and accessing care in Australia (Western Australia, Victoria and the Australian Capital Territory), the United Kingdom and the United States of America. He will be a participant in the National Disability Insurance Scheme.

Photo credit: Francis Burt Chambers

Prior to commencing as Disability Discrimination Commissioner, Ben worked as a barrister in Western Australia and Victoria with a broad ranging practice.

He has also worked as an associate to the Honourable Justice Kenneth Hayne AC at the High Court of Australia, as Counsel Assisting the Solicitor-General of the Commonwealth and taught law in Australia and the United Kingdom. Â Ben holds undergraduate degrees in Law (Hons) and Commerce from the University of Western Australia, and was awarded the Rhodes Scholarship for Western Australia in 2003. He also holds a Master of Laws from New York University and a D.Phil. in Law from the University of Oxford. Â In 2015, Ben completed the Perth to Rottnest swim in a team with three friends.

April / May 2019

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2019 CONFERENCE

2019 ACAA Trade Exhibition

14-16 August 2019 Crystal Palace Luna Park, Sydney Premium 3 x 2 sqm booth (2 sides - corner booth) $3,900 +GST Standard 3 x 2 sqm booth $3,500 +GST Standard 2 x 2 sqm booth $2,900 +GST

Download the Conference Tradebooth and other sponsorship options: https://www.access.asn.au/accessibility-communications/access-2019-trade-exhibition FOR FURTHER DETAILS CONTACT: Tannia Garces tgarces@intermedia.com.au 0476 386 813

OR

ACAA Vice-President Farah Madon vicepresident@access.asn.au

A big thank you to the following businesses who will be exhibiting their products at the Conference:

Australian Ramp & Access Solutions

ESP Australia RBA Group

Hearing Loop Australia

Britex

Active Mobility

Maxwood Technology 6

Para Mobility

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

Hearing Connections

2019 CONFERENCE

Conference Workshop (14 August 2019) DEVELOPING SUCCESSFUL PERFORMANCE SOLUTIONS FOR HERITAGE PLACES USING VERIFICATION METHODS

EARLY BIRD RATE OF $125 +GST VALID UNTIL 1ST JULY

COCKATOO ISLAND TOUR

• 10 CPD points awarded for attendance of workshop.

• Workshop will be a highlight of the Conference and is strictly limited to 56 participants. Book now to avoid disappointment https://www.accessconference.com.au/register/ DRAFT PROGRAM 11.30am - 12noon: Registration in the Success Room.

12noon - 12.45pm: Lunch in the Success Room with a 15 min pre-tour overview of the island’s 19th century history and adaptive reuse in the 20th and 21st centuries.

12.45pm - 2.15pm: 90 min guided tours in two groups with a maximum of 28 people in each group. Guided tours will include commentary on the conservation and heritage works on Cockatoo Island by tour guides, including the Harbour Trust’s Heritage Architect, Libby Bennett, covering the Industrial Precinct: Group A Lower Island guided tour for 90 mins (wheelchair accessible)

Group B Upper Island guided tour for 90 mins (no wheelchair access)

Group A Tasks:

Group B Tasks:

• The lower island group shall consider external access options to enter and gain enhance access within industrial precinct Buildings. Sub groups shall develop example concepts for several buildings and places.

• A sub group shall consider the effectiveness of the audio tour for people with vision impairment, including interpretive displays and what alternatives could improve the visitor experience.

• A sub group shall consider the effectiveness of the guided tour for people with hearing impairment and what alternatives could improve the visitor experience.

• The upper island group is to consider access options to facilitate equitable access to the upper island plateau by way of ramp or lift access and the convict precinct including Building No 2.

• External access to enter the Superintendents Cottage and Cottages 20, 21 and 23.

• A sub group shall consider the effectiveness of the audio tour for people with vision impairment, including interpretive displays and what alternatives could improve the visitor experience.

• A sub group shall consider the effectiveness of the guided tour for people with hearing impairment and what alternatives could improve the visitor experience.

2.15pm to 2.45pm: Afternoon Tea in the Success Room.

2.45pm to 3.45pm: Group photo presentations in the Success Room using AV projector.

3.45pm to 4.00pm: Depart the island.

April / May 2019

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FEATURED ARTICLE

Exemptions and concessions

by Paul Eltringham Stonehenge Consulting Pty Ltd

Paul has over 25 years experience in the building industry and is registered as a level 1 Building Surveyor in Victoria and Queensland and has worked on projects in all states of Australia as well as some in NZ and PNG. He is also a qualified Access Consultant and currently Secretary of the ACAA Victorian Access Consultant Network.

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art D3 of the NCC Building Code of Australia (Volume 1) outlines the Deemed to Satisfy requirements for ‘Access for People with a Disability’.

Although compliance with the BCA can also be achieved via an alternative approach such as a Performance Solution issued by an Access Consultant, there are concessions under Clause D3.3(f) and D3.4 BCA that the Building Surveyor/ Certifier can adopt without the need for a Performance Solution report.

NCC 2019 Building Code of Australia – Volume One (ie BCA 2019) allows an exemption for disabled access under Clause D3.4.

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THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

FEATURED ARTICLE Table D3.1 BCA lists the buildings and parts of buildings that require access for people with a disability. However, Clause D3.4 allows an exemption from this requirement to those buildings and parts if a particular area within the building falls into one of the following scenarios: a. An area where access would be inappropriate because of the particular purpose that the area is used. b. An area that would pose as a health or safety risk for a person with a disability. c. A path of travel providing access only to an area exempted by a) or b).

Note – ACT, SA and Tas have additional exemptions as noted in the relevant BCA State and Territory Appendices which include access exemptions to farm buildings and grain storage (SA) and common areas in certain low rise Class 2 buildings (Tas). The ACT Appendices are not listed in the BCA 2019. Refer to page 413 NCC 2019 Volume 1 for a reference to the ACT Legislation Register.

The Guide to the BCA lists some examples within a building that could be considered exempt from providing disabled access because of the nature

of the area or tasks undertaken. Although each should be taken on a case by case basis, it lists such areas as rigging lofts, waste containment areas, foundry floors, loading docks, fire look outs, Class 8 electricity network substations, plant and equipment rooms and other similar areas.

Clause D3.3 BCA also lists a fairly important concession available for disabled access. It states that a ramp complying with AS 1428.1 or passenger lift need not be provided to serve a storey or level other than the entrance storey in a class 5, 6, 7b or 8 building containing not more than 3 stories and with a floor area for each storey (excluding the entrance storey) of not more than 200m². However, even though access via a ramp or lift may not be required to some stories, all other accessible features required by the BCA (such as door circulation etc) are required.

Accessible sanitary facilities and accessible showers are not required though.

Clause D3.5 BCA lists which buildings need to provide carparking spaces for people with a disability. Class 2 buildings are not listed.

Therefore, if a multi residential Class 2 building has no other building classification (ie no Class

April / May 2019

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FEATURED ARTICLE 5 or 6) also within the building and there is no Town Planning condition requiring any accessible carparking spaces then none have to be provided in accordance with the BCA. There are also disabled access concessions available under the Disability (Access to Premises – Buildings) Standards 2010 that allow various access conditions to remain without any mandatory requirement to comply with the current Australian Standards in existing buildings.

These exceptions and concessions are outlined in Part 4 under the following headings: lessee concessions, lift concessions and toilet concessions.

PART 4.1 – UNJUSTIFIABLE HARDSHIP An application to an Access Panel or an application for a modification to the Building Appeals Board (ie Victoria) for a concession to the Premises Standard is another avenue where it can be demonstrated that the cost of upgrading a building to comply with the current access requirements would cause unjustifiable hardship. Normally this would require the applicant to provide evidence of the costs required to comply with the current requirements against the cost of work for the actual proposal. For example, if a $50,000 refurbishment was proposed and the Building Surveyor required a new lift to be provided so that access via the affected part complied, and the new lift cost was $200,000, there may be grounds for an application. Particularly so if the initial project would not be feasible due to the additional cost of the lift.

PART 4.3 - LESSEE CONCESSIONS Where an existing building is being modified or extended and triggers the requirement for a building approval, the Premises Standards will normally require an upgrade of the affected part of the building which requires a continuous accessible path of travel to be provided between the main entry of the building and the newly affected part of the building that triggered the requirement for the permit. Section 4.3 provides a limited concession from this requirement where a building is occupied by a number of different lessees. If an application for a building approval is made by one of the lessees for work on the area of the building that they lease, there is no 10

requirement on the lessee to provide a continuous accessible path of travel to the area of new work. For example a lessee of level 4 of a building would not have to upgrade the accessible path from the building entrance to the area of the works requiring a Building Approval (the affected part) as this would be too onerous. This concession recognises that the lessee generally has no control over those parts of the building that they do not lease such as the common areas of a building.

The lessee concession can also apply even where entry to the leased area does not involve use of any common area. An example of this may be when a shop is leased on the ground floor and the entry to the shop is directly off the street frontage. If the lessee of that shop was one of a number of lessees in that building (shop not on it’s own title) then even though the shop entry may open directly to the street, the shop would still be considered to be a lessee and gain the concession. Therefore the entry door to that shop would be eligible for the lessee concession. Note that if the shop is on it’s own separate title (even if joined to a row of shops) this concession would not apply.

However, even if the lessee concession applies and access via the main entry door is not compliant with the current requirements of AS 1428.1 (2009) such as door widths or circulation space being non compliant or a step is provided at the doorway, the lessee would still be vulnerable to a potential discrimination complaint and may need to rectify the issue.

PART 4.4 – LIFT CONCESSION Where an existing lift travels more than 12m and has a floor area not less than 1100 mm x 1400 mm ie if it complies with the access requirements of the BCA prior to 1st May 2011 when the Premises Standard was enforced then the lift size may remain without the requirement to be upgraded to comply with the current BCA floor area requirement of 1400 mm x 1600 mm. The concession recognises that rebuilding an existing lift shaft to house the larger lift floor dimensions would impose an unreasonable cost. However, the lift features such as Table E3.6b upgrades which include accessible lift controls etc must still be provided.

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

FEATURED ARTICLE PART 4.5 - TOILET CONCESSION The concession is available to allow existing accessible or ambulant sanitary facility to comply with AS 1428.1 (2001) in lieu of the current requirements of AS 1428.1 (2009) if the existing facility was built when AS 1428.1 (2001) was the relevant legislation (prior to 1 May 2010 when BCA 2011 and the Premises Standard were adopted and only if the sanitary facility actually complies with AS 1428.1 (2001). Strictly, if the existing sanitary facility was built prior to 1 May 2010 and does not comply with even AS 1428.1 (2001) for any reason then it should be upgraded to comply with the current requirements of AS 1428.1 (2009) unless a Performance Solution can be approved.

It should also be noted that in most cases existing toilets would not need to be upgraded anyway if they were not considered part of the new works unless a change of use (Change of Building Classification) was being carried out or else significant works were being carried out (generally > 50% of the existing building although this varies due to different specific State legisaltion).

The BCA and Premises Standard allows for innovative solutions to meet the Performance Requirements of the BCA and Access Code through the use of alternative approaches as long as the proposed solution satisfies the relevant Performance Requirements. A building certifier/ building surveyor would need to assess and approve the suitability of the proposed alternative solution (Performance Solution) before accepting it prior to issue of the Building Permit/Approval.

Exemptions (BCA) and concessions (Premises Standards) are options available to the design to recognise cases where it may be unreasonable to require full compliance with the current Deemed to Satisfy requirements of the BCA. It allows flexible approaches to particular building circumstances which is particularly important in relation to upgrades to existing buildings, including heritage buildings where strict compliance with the current Deemed to Satisfy provisions may not be possible or appropriate.

Where concessions are permitted under Part 4 Premises Standards, the designer has the option to ensure compliance is achieved under the current legislation (BCA 2019) or they can take advantage of the concessions.

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April / May 2019

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FEATURED ARTICLE

To serve or not to serve

by Aja Goddard Access Consultant, ACAA Accredited Member

Having previously worked in the disability, aged care and rehabilitation sectors, Aja now draws on this experience to inform her work as an access consultant and achieve building access solutions. Aja is an accredited member of ACAA and a registered assessor for LHA. She works at BCA Access Solutions, based in Newcastle, providing access advice on a range of projects across NSW and ACT.

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B

CA D3.4 exemptions seem to be a paradox at times. I certainly recognise the necessity of such exemptions and appreciate that there are particular situations where they should legitimately be applied, but too often it seems that these exemptions are sought as an easy excuse with the claim that people with a disability “can’t work here.”

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

FEATURED ARTICLE In some ways, a specific list of exempt areas would be useful so there could be no disagreement, but the flexibility afforded by not having such a list is beneficial in that it enables consideration of individual circumstances across a wider range of building uses. However, this potentially increases the instances of people mistakenly thinking they are entitled to and can justify such exemptions.

Some reasons given to me by building owners, occupants or designers seeking a BCA D3.4 exemption include a concern about liability where stairs are present on evacuation routes (ie preventing independent egress), use of perceived hazardous items in the area and the good old “we’ve never needed disability access before.” The most common reason I come across and perhaps the most loosely discernible is where physical duties are expected of staff, thereby precluding people with a disability from being employed, at the discretion of the employer.

In determining whether this can reasonably be considered to support an exemption, I ask for evidence in the format of position descriptions and/or a specific list of the physical duties expected by the different personnel employed.

Many employers have tried to present that there are absolutely no positions in which a person using a wheelchair could be employed, which in reality, is likely to be a stretch for the majority of workplaces. I also ask that consideration be given to the potential for any contractors, managers, information technology and human resources consultants to access the premises as their use of wheelchairs may be unpredictable and indeed possible.

On assessment of the information, it is with a sense of heavy responsibility that a judgement call is to be made on whether or not an exemption should be applied in a particular situation. Even when the evidence suggests I should support an exemption, I find myself wondering, “What if circumstances change in the future?” There is therefore some risk in making such decisions but I understand this type of assessment and exemption is yet to be tested in any legal capacity.

In this article, I particularly want to explore one situation where an exemption is typically sought: Service stations. I am told that all service station staff must be able to fulfil physical duties associated with fuel spills, restocking shelves and refrigerators, and attending to sales of larger items such as ice, gas bottles, fire wood and the like. Service station designs therefore tend to assume that staff areas need not be accessible.

Often, it would not take much to allow for accessibility with consideration to the potential for managers, contractors or consultants who may have a disability. Admittedly though, accessibility requires increased space when it is otherwise desirable to conserve space in staff areas of service stations by reducing door circulation spaces, doorway widths and turning spaces. These spaces do add up if there is a customer service area, office, lunch/staff room, cool rooms and stock storage areas so I can understand not wanting to provide such space throughout staff areas if it could be demonstrated that it is not necessary.

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FEATURED ARTICLE From the evidence I’ve seen, an exemption can be supported. This doesn’t stop me from second guessing it each and every time. I have not been made aware of any unforeseen circumstances requiring accessibility in staff areas, but perhaps none are willing to disclose if this occurs!

Nevertheless, I encourage service station operators to develop some strategies to minimise their risk of a complaint being made on the grounds of discrimination. I will admit that I have not seen anything formally progress beyond this recommendation as certifiers tend to accept my assessment and this permits the building to proceed with the exemption simply applied.

In addition to this, I am often asked whether an accessible staff toilet is required. In many smaller service stations, I have seen the proposal for one toilet in the building and it has been presented to me that this is not required to be available for use to patrons (as determined by the certifier).

However, it is proposed that it be located in a public area, rather than restricted to staff, appearing to be intended for patron use as is typical of service station operations.

My advice is that if the toilet will be restricted for staff use, it should be located in a staff area, and if it is publicly available, it should be accessible, despite how BCA requirements could be interpreted. This suggests an opportunity to appropriately restrict the use of a toilet to staff if that is the intent, while alternatively minimising the potential for discrimination where it could be a publicly available facility. Pleasingly, an accessible toilet has prevailed for all those I have been involved with.

Notwithstanding this, there remain other issues at service stations. The civil design in vehicular areas accounts for oil spills and the storage and refilling of fuel supplies with complex lumps and bumps around fuel pumps. Therefore, the paths of travel from the bowsers to the shop vary from AS 1428.1, having fluctuating gradients and crossfalls. In these situations, the safety elements are understood to be important and potentially comparable to the emergency egress provisions in the BCA which take precedence for life preservation purposes. However, it is rare that these directly contradict accessibility provisions, insisting upon features that compromise accessibility as seems to be the case for service

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stations where careful drainage solutions are necessary to ensure protection in the event of a fuel leak or spill.

Service station operators have put to me that people with a disability do not ordinarily refuel vehicles independently, but instead seek assistance from accompanying people or service station staff. It is anticipated that this results in a reduced need for a pedestrian with a disability to negotiate paths of travel between the bowsers and the shop. A more likely scenario would see the vehicle being parked in an accessible car park on the site following refuelling, and the accessible path of travel from such car parks to the shop being compliant. This maintains the safety and drainage protocols expected for service stations while enabling a person with a disability to access the shop and facilities without discrimination.

Despite this, I continue to question whether supporting a BCA D3.4 exemption as discussed for staff areas and for safety purposes, could effectively be facilitating discrimination? Could service station operators deny employment on the basis of the premises not being suitable?

In my opinion, if they can demonstrate how staff duties legitimately entail specific tasks of a manual handling nature, then the assessment at the time can justify the exemption. I acknowledge that this does not necessarily protect anyone from future changes in how a building is used, how duties of service station staff may vary or from legislation being altered. However, not all such instances can be predicted and I believe all that can reasonably be expected of such an assessment will be satisfied.

Therefore, I generally support a BCA D3.4 exemption being applied to staff areas of service stations and for external paths of travel between the bowsers and the shop, based on the evidence presented to me to date. In addition to this, I expect that access for people with a disability be provided in accordance with the BCA and AS 1428.1 between accessible car parking and the shop, and to and within all public areas of the building, including sanitary facilities, in order to provide suitable access, to the degree necessary.

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

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April / May 2019

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FEATURED ARTICLE

Interpreting Exemptions: A Rights-Based Perspective

by Mary Ann Jackson

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An Architect, Planner, and Access Consultant, Mary Ann’s passions revolve around accessibility in the built environment for people with disability. Other professional interests include built environment sustainability, disaster reconstruction and equitable housing provision and her innovative work has received local, national and international recognition. Mary Ann has also designed and delivered tertiary and professional courses, seminars, and workshops in design, technology, sustainability, and accessibility, as well as presenting at conferences and publishing peer-reviewed papers, internationally. Mary Ann holds degrees in Architecture and Applied Science (Built Environment), a Graduate Diploma in Urban Planning, a Master of Environment, and is currently undertaking a PhD focused on human rights based approaches to improving neighbourhood accessibility for people with disability.

THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

FEATURED ARTICLE

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stensibly, the Building Code of Australia (BCA) sets minimum building standards. As many readers will know, most subclauses within Volume One Part D3 Access for people with a disability Deemed-to-Satisfy (DtS) Provisions quantify (minimum) requirements. However BCA DtS clause D3.4 Exemptions1 is ‘qualitative’ thereby requiring interpretation.

This article explores this clause through the prism of human rights, people with disabilities’ employment status, and disability constructs.

DISABILITY CONSTRUCTS, EMPLOYMENT, AND HUMAN RIGHTS Lived experience of disability is heavily influenced by societies’ past and present positioning of disability. The ‘materialist landscape of the industrial era’ positioned people with disability as economically unviable needing no access to factories, workplaces, schools, and transport infrastructure23. Charity (Institutional) and Medical models of disability rendered people with disability virtually invisible; the medical model also conspiring to protect people with disability from risk through professionals’ gatekeeping45. In the 1980s the Social model of disability recognised that the built environment is disabling in itself. Commitment to anti-discrimination 1 Refer BCA 2019 Volume One for exact wording 2 West, Raelene. 2012. “What do We Mean by Support? The Receipt of Disability Services and Compensation for People with a Spinal Cord Injury (SCI) in Victoria.” University of Melbourne.

3 Jackson, Mary Ann. 2018. “Models of Disability and Human Rights: Informing the Improvement of Built Environment Accessibility for People with Disability at Neighborhood Scale?”

Laws 7 (10). doi: 10.3390/laws7010010.

4 Ibid 5 Maria Berghs, Karl Atkins, Hilary Graham, Chris Hatton, and Carol Thomas. 2016. “Implications for public health research of models and theories of disability: a scoping study and evidence synthesis.” Public Health Research 4 (8).

legislation in the 1990s produced the complaints-based Australian Disability Discrimination Act 1992 (DDA) and state-based legislation such as the Queensland Anti-discrimination Act 1991 and Victorian Equal Opportunity Act 1995.

The 2000s saw the Human Rights model of disability gathering momentum and the adoption of the United Nations Convention of the Rights of Persons with Disabilities (CRPD). The CRPD positions disability as both diverse and resulting from the ‘interaction between persons with impairments and attitudinal and environmental barriers that hinders their full and effective participation in society on an equal basis with others’6.

Under the CRPD, the federal DDA, and state-based Acts people with disability in Australia are not mere users of services, but have political, civil, cultural, and economic (particularly employment) rights.

However, in Australia, such rights are not reflected in people with disabilities’ employment status; overall labour force participation rate is approximately two-thirds that of people without disability, unemployment is almost double, underemployment is more likely, approximately one-third of DDA complaints relate to employment, and OECD ranking is in the bottom third.

Human rights-based approaches position people with disability as rights-holders and ascribe duty-bearer status to, for example, those with responsibility for, or control over7 the built environment. The Committee on the Rights of Persons with Disabilities believes that 6 United Nations, Convention on the Rights of Persons with Disabilities-Articles. 2006.

7 Under the Premises Standard, those who are ‘responsible for, or have control over’ buildings includes ‘building certifiers’, ‘building developers’, and ‘building managers’.

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FEATURED ARTICLE rights-based approaches are essential to improving both built environment accessibility legislative frameworks and built environment accessibility outcomes89. The continuing inaccessibility of the built environment can be explained, partly, by built environment duty-bearers generally lacking understanding of disability constructs, disability inclusion legislation, and people with disabilities’ rights.

Additionally many buildings were built long before current accessibility requirements were included in the BCA.

EVOLUTION OF BCA DTS CLAUSE D3.4 EXEMPTIONS Those with responsibility for, or control over, the built environment are generally more attuned to regulatory compliance than anti-discrimination and users’ rights. However, prior relevant DDA subordinate legislation, i.e., the Disability (Access to Premises – Buildings) Standards 2010 (Premises Standard), there was little connection between the DDA’s broad objectives and the BCA. Volume One of the first, prescriptive, edition of the national10 BCA, in 1988, contained Part D3 Access for People with Disabilities consisting of only four clauses. D3.3 Parts of buildings to be accessible stated, in part, that access for people with disabilities must be provided to areas normally used by the occupants, [but] excluding any plantroom, commercial kitchen, cleaners’ store room, maintenance accessway, rigging loft, or the like. D3.4 Concessions stated: It is not necessary to provide access for people with disabilities: a. to more than 30% of the public space in a restaurant, cafe, bar, function room, or the like, in a Class 6 or Class 9b building; or b. to a mezzanine floor or other space not regarded as a storey by definition; or 8 United Nations, Convention on the Rights of Persons with Disabilities 2014. Committee on the Rights of Persons with Disabilities (Comm CRPD). Eleventh session 31 March-11 April 2014.

9 United Nations, Convention on the Rights of Persons with Disabilities.

2016. Guidelines on periodic reporting to the Committee on the Rights of Persons with Disabilities, including under the simplified reporting procedure. Adopted by the Committe at its sixteenth session (15 August - 2 September 2016).

10 But, through defined processes, able to be varied at State and Territory level. State- and Territory-specific clauses are contained in the relevant Appendices.

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c. to more than 1 car parking space for each 100 spaces in a public carpark; or d. to any area if access would be inappropriate because of the particular purpose for which the area is used.

Under the new performance-based rationale, BCA 1996 contained ‘Deemed-to-Satisfy Provisions’ within the substantially expanded Part D3 Access for People with Disabilities. D3.3 Parts of buildings to be accessible retained the wording ‘excluding any plantroom, commercial kitchen, cleaners’ store room, maintenance accessway, rigging loft, or the like.’ Other than moving carparking requirements elsewhere, Clause D3.4 Concessions content also remained the same.

Therefore, even in the face of unfolding rights awareness, Australia’s building code deemed that people with disabilities’ exclusion from 70% of several types of everyday spaces was satisfactory.

In affirming connection between the DDA and BCA, the Premises Standard made such sentiments unacceptable. In an attempt to create more certainty around non-discriminatory building access Premises Standard wording initially canvassed not requiring access for people with disabilities to areas like: cleaners store rooms, commercial kitchens, staff serving areas in bars, foundry rooms, cool rooms, fire lookouts, lighthouses, rigging lofts, cooling towers, power plants, equipment or lift motor rooms, bunded areas, fire control areas, loading docks, access routes for maintenance, hazardous areas, waste containment areas, silos, grain bins, chemical stores, storage racks, and upper floors of warehouses used wholly for wholesale and/or logistic distribution purposes11.

Public consultation revealed substantial concerns about the consequent limitation of employment opportunities for people with disability resulting in final wording for Clause D3.4 Exemptions being: The following areas are not required to be accessible: a. an area where access would be inappropriate because of the particular purpose for which the area is used.

11 House of Representatives Standing Committee on Legal and Constitutional Affairs. 2009. Access All Areas Report of the Inquiry into Draft Disability (Access to Premises-Buildings) Standards. Canberra.

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FEATURED ARTICLE b. an area that would pose a health or safety risk for people with a disability. c. any path of travel providing access only to an area exempted by this clause.

In order to directly connect the BCA and the DDA, Part D3 Access for People with Disabilities of the BCA has subsequently been harmonised to the Premises Standard and the BCA 2019 Clause D3.4 Exemptions wording remains the same as the above. The BCA ACT Appendix counsels reference to relevant state-based legislation, Tasmania specifically exempts certain Class 2 (apartments) circumstances, and South Australia singles out farm buildings and bulk grain storage facilities. BCA DtS clause D3.4 Exemptions does not encompass ‘small area concessions’, lessee concessions, or unjustifiable hardship; the former being handled under BCA DtS clause D3.3 (f) and the latter two being the province of the Premises Standard.

GUIDANCE AVAILABLE TO BCA USERS REGARDING D3.4 Building designers are generally unaware of these histories and intricacies. Within BCA 2019 the Premises Standard and DDA are only specifically referenced in Tasmania’s Appendix and only mentioned as line items in Footnote: other legislation and policies affecting buildings.

The BCA is coy on referencing its own NCC 2019 Guide to Volume One (the Guide); the Guide states it has no legal weight. From a rights perspective guidance regarding D3.4 Exemptions awkwardly states the intent is to provide exemptions.

Interestingly the Guide only addresses inappropriate areas, ‘rigging lofts, waste containment areas, foundry floors, loading docks, fire lookouts, Class 8 electricity network substations12, plant and equipment rooms and other similar areas’, advising assessment on a case-by-case basis. However, no guidance on assessment criteria is provided. The Guide does say that greater access can be provided should designers desire, but neither refers designers to any relevant legislation or rights imperatives nor gives any guidance on interpreting ‘health or

safety risk’. The connection between the DDA, the Premises Standard, and the BCA is briefly explained at the start of the Guide’s Section D (p 116). Again though, from a rights perspective, the Section starts awkwardly by implying that ‘Compliance with Disability Discrimination Act 1992 (DDA)’ is a (difficult) issue. Under the next heading, ‘Objective’, the Guide does state that ‘One of the primary intentions of the DDA is to provide people with a disability with the same rights as the rest of the community.’ D3.4 Exemptions guidance (p 183) does not, however, suggest referring to the section start for further detail, leaving those looking specifically for exemptions direction unlikely to contemplate ‘rights’.

D3.4 Exemptions guidance in the (relatively obscure) ABCB’s NCC Volume One Disability Access Resource Kit aimed at educators doesn’t mention any relationship with other relevant (rights) legislation. The usual inappropriate area suspects of ‘rigging lofts, waste-containment areas, foundry floors, loading docks, fire lookouts, plant and equipment rooms and other similar areas’ are noted. Assessment on a case-by-case basis is advised and: Care needs be taken to ensure that any assessment of the need to utilise this exemption is not based on assumptions about the ability of people with disability or people with a particular type of disability to undertake work in those settings.

Much of the above guidance, however, provides little insight into why disability constructs or human rights or employment impacts matter.

Moving beyond ‘compliance’, both people with disabilities’ life experience and building utility would greatly benefit from designers having deeper understanding of disability as a normative aspect of human diversity and that people with disability have equal rights to wide-ranging employment opportunities.

12 A new entry on the usual suspects list. Commercial kitchens and bar service areas not mentioned.

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FEATURED ARTICLE

Disability (Access to Premises – Buildings) Standards 2010 Concessions

by Cathryn Grant and Sharlene Howland

Cathryn is a registered Occupational Therapist and ACAA Accredited Access Consultant. She has been working as a Access Consultant since 2007. Prior to this she worked with people with a diverse range of disabilities in community and rehabilitation settings. Cathryn has recently completed a Masters in Public Health, specialising in health and the built environment. This involved researching and writing a thesis on universal design and consultation with users.

Sharlene is a qualified access consultant, building inspector and architectural draftsperson, with experience in the field of allied health in an educational setting.

She specialises in working with architects, designers, engineers, government agencies and managers of buildings to ensure the requirements of disability access and universal design are incorporated into proposed developments.

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he Disability (Access to Premises – Buildings) Standards 2010 (herein referred to as DAPS) is a legislated instrument made under subsection 31 (1) of the Disability Discrimination Act 1992. DAPS came into operation on 1 May 2011, and applies to new buildings, or new portions of existing buildings where building approval was lodged on or after that date.

DAPS refers to the Access Code; which is more or less based on the provisions of the Building Code of Australia at the time. Within DAPS is a 20

section titled Part 4 Exceptions and Concessions, which covers (among others) the Section 4.3 Lesee Concession,4.4 Lift concession and 4.5 Toilet concession.

LESEE CONCESSION Section 4.3 provides the third concession which is available for lesees of a building the are doing works to their tenancy within a larger building that is owned by another party. The concession relives the tenant of any responsibility of upgrading the affected part. Such that if a tenant on the fifth level of a building does building works that requires a permit the DAPS requires that the path of travel to these works must be accessible ie: the affected part is triggered. However in a larger building own by one entity with different spaces rented by others the affected part which is likely to be common areas of the building and may include lifts cannot be the sole responsibility of the tenant doing works on level 5.

LIFT CONCESSION Section 4.4 relates to the concession for the floor dimensions for existing lifts, which Table E3.6(b) in the Access Code requires lifts travelling more than twelve metres to have a lift floor of no less than 1400mm by 1600mm. A lift travelling more than twelve metres with a minimum lift floor size of 1100mm by 1400mm does not have to meet the Access Code requirements under this concession.

Earlier access requirements (prior to 2011) for lifts in the BCA required minimum floor dimensions of 1100mm by 1400mm, and so there are existing buildings to which this concession will apply.

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FEATURED ARTICLE It is recognised that requiring a lift shaft to be enlarged to meet current lift car sizes could impose an unreasonable cost and be almost unbuildable. However, upgrading other features of the lift such as audible information, lift controls, and other fixtures and finishes are not affected by the concession and must be provided.

TOILET CONCESSION

How would you feel if you were left behind?

The toilet concession in section 4.5 provides for existing unisex accessible toilets and existing cubicles suitable for use by people with ambulant disabilities undergoing new work not to comply with AS 1428.1-2009 requirements, as referenced by the current Access Code. However, the existing facilities must comply with the circulation and fit out requirements of AS1428.1-2001.

If an existing unisex accessible toilet does not meet AS 1428.1-2001 requirements, subject to the defence of unjustifiable hardship, the unisex accessible toilet is required to be upgraded to AS1428.1-2009 standard.

p: 1300 669 730 w: EvacuLife.com.au

In another example, if an existing unisex accessible toilet undergoing new work achieves the circulation space requirements of AS1428.1-2001, but a backrest at the pan is not installed, there is a requirement to install the backrest to comply with AS 1428.1-2009.

It’s all about access & freedom Para Mobility specialises in the design, manufacture and distribution of disability equipment. Our key products include: • • •

Changing Places Bathrooms Powered Change Table Manual & Mobile Change Tables

The above concessions in DAPS allow for existing buildings undergoing permitted refurbishment that were compliant at the time of construction to be maintained if they meet the immediate past Australian Standard for access for people with disabilities. These concessions recognise the structural and cost constraints of upgrading existing buildings whilst aiming to provide reasonable levels of access to the built environment.

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Generally, upgrading a unisex accessible toilet does not trigger an upgrade of the existing gendered facilities to provide ambulant cubicles, unless they are subject to the new work as well. However, upgrading both gendered and unisex facilities at the same time provides more equitable access for people with varied disabilities.

M O BIL

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18/07/2017 11:00 am

HOT APPS

May 2019 HOT APPS

By Jen Barling

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n this section, we feature apps that are Access Industry related. If you have an app that is useful for Access Consultants, please let the Editor know so that it can be included in the next issue of Access Insight.

AIRA Aira is a service that instantly connects people with low-vision or who are blind to trained, remotely-located agents through a smart phone or smart glasses.

By using a smartphone camera (or Aira’s proprietary smart glasses) a live video stream is sent to an Aira agent who can see and hear the environment. Agents also have access to web-based data, including maps, location tracking, search engines, text-based messaging and even rideshare integration, to provide blind and low-vision users with a seamless and positive experience.

Aira can be used for an array of activities including: • • • • •

Getting a coffee Navigating a site Locating the lift Interpreting presentation slides Operating office equipment

• • • •

Locating a stadium seat Choosing an outfit Selecting menu items Helping kids with their homework

Find out more at https://aira.io/australia

ANNOUNCING… Inaugural Australian Access Awards for Digital Campaigns or Resources The Centre for Accessibility are launching the inaugural Australian Access Awards, an annual event celebrating organisations that have successfully implemented accessibility in their digital campaigns or resources. Anyone within Australia can nominate a website or app for an Award in the appropriate category. The role of The Centre for Accessibility is to empower the accessibility movement and encourage organisations to implement digital access when designing online resources.

Call for submissions: Thursday 16 May 2019

Global Accessibility Awareness Day Nominations close: Friday 30 August 2019 Finalists announced: Monday 21 October 2019 Winners announced: Tuesday 3 December 2019

International Disability Day Find out more at https://www.accessibility.org.au/awards/

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THE MAGAZINE FOR THE ASSOCIATION OF CONSULTANTS IN ACCESS AUSTRALIA

Australia’s only Type A inspection body accredited by the National Association of Testing Authorities, Australia (NATA) for slip resistance & recognised globally through the ILAC mutual recognition agreement to AS ISO/IEC 17020 for the inspection and conformity of slip resistance and luminance contrast testing.

02 9621 3706

www.SafeEnvironments.com.au

April / May 2019

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BOOK REVIEW

TRAVEL WITHOUT LIMITS

CLICK HERE TO DOWNLOAD

Founders and executive editors: Julie Jones & Janeece Keller Published by: Bound Round Pty Ltd Reviewed by: Cathryn Grant

AIM: The aim of this magazine is to share information about travelling for people of all abilities and needs.

SUMMARY: Travel is a wonderful opportunity to challenge and broaden our minds and travel magazines are there to whet our appetite and assist in planning our next journey. Travel without Limits magazine certainly provides a feast for your eyes with a range of travel experiences from around the world with the unique angle of promoting accessible travel. This issue covers a range of stories from clothing, employing a team of carers for overseas travel, travelling with a family member with autism, beach access, adaptive skiing, applying for a passport and travelling with medications. It has a good mix articles for children and adult travellers. There are a number of advertisements for accessible travel products and accommodation some promoting accessible options. Travel without Limits is a travel agency for people of all abilities and needs and now in

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addition to their website they use this magazine to promote travel to people of all abilities. Whilst readers of the magazine (and website) should be discerning, as some of the articles promote specific products or brands, overall this magazine is a good read and provides some practical advice for getting out there.

TAKE HOME MESSAGE: Very informative, practical travel ideas for people of all abilities and needs.

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our new CORPORATE SPONSOR category!

Association of Consultants in Access Australia

CORPORATE SPONSORS

The annual fee for BRONZE Corporate Sponsor is $1,100. Sponsorship is is suitable for businesses that provide: • Products that relate to accessible built environments and support the objectives of ACAA. • Disability access-related consultancy services (provided that the business employs at least ONE financial ACAA Accredited level member).

BRONZE ‘Corporate Sponsor’ Package includes the following: Use of ‘ACAA Bronze Sponsor’ logo on your website and advertising material (for financial members).

Early release of ACAA Conference Trade booths and other Sponsorship packages at 10% discount for the next ACAA National Conference to be held at Luna Park Sydney in August 2019.

Free listing as a ‘Corporate Sponsor’ on ACAA website

¼ A4 page advertisement in six issues of Access Insight magazine (approx. value of $1,500); OR 2 x ¼ A4 page advertisements and 1 page ‘Advertorial’ in Access Insight magazine (approx value of $1,500 based on current Access Insight advertising rates).

Free admission to attend any two ACAA State Network seminars / meetings for two people (approx. value $200)

For details, contact Farah Madon: vicepresident@access.asn.au

APPLY NOW

April / May 2019

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ADVERTISING OPPORTUNITIES

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The content of this magazine is for information purposes only and opinions expressed in articles are those of its author and not ACAA. ACAA assumes no liability or responsibility for any inaccurate or incomplete information, nor for any actions taken in reliance thereon. Advertised products and services that appear in this magazine have been provided by such organisations without verification by ACAA. ACAA does not guarantee, support nor endorses any product or service mentioned in this magazine, nor does it warrant any assertions made by the manufacturers of such products or services. Users of are recommended to obtain independent information and to perform independent research before using the information acquired from this magazine.

In this magazine, you will find links to other websites. ACAA cannot be held liable for the content of these websites nor for the way in which these websites handle your (personal) data. For information in this regard, read the privacy policy, disclaimer, copyright notices, general terms & conditions, if available, of any website you visit. No part of the magazine may be reproduced without the prior written consent of the ACAA Committee of Management.

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