FM World June 2017 taster edition

I N F O R M I N G FA C I L I T I E S M A N A G E M E N T P R O F E S S I O N A L S

fm-world.co.uk / June 2017

TA ST E R E D I T I O N

FM AND DISABILITY AWARENESS :

ACCESS ALL AREAS Procuring an inclusive workplace demands better communication

GAP ADJUSTMENTS Compliance with the law on accessibility is being widely neglected

BE DISABILITY-SMART FM’s role in raising consciousness about inclusive design

F M WO R LD JUNE 2017

CONTENTS COM M UNI TY

2 2 PE R SPE C T IV E S The four most interesting and insightful opinions on FM this month

2 5 A BIT A BOU T YOU Doug McGarr: FM is not about chasing housekeepers around the building 26 THINK TA NK Election pledges that industry figures would like to see become policy

ANA LYS I S

7 WAST IN G AWAY Could better app technology cut the volume of food service waste in the UK? 10 GEN Z I N THE OFFICE BSRIA reports on Generation Z’s impact on working practices

KNOW LE DGE

35 RECEPTION CLASS ARTful’s five key pointers for FMs installing artwork in the workplace 36 RULES REWIRED Forthcoming regulations for energy efficiency of electrical installations

28 JU NE @ BIF M The people and projects currently informing BIFM activity 3 2 C A LL S TO AC T ION The events, surveys and discussions that deserve your attention

3 7 F U E L FOR T HOU G H T Regulatory procedures to eliminate the risks posed by fuel storage

12 TH E ‘ SI TT IN G DIS E AS E ’ A third of managers are ignoring the health risks of sedentary behaviour

3 9 IN T HE LOOP Making buildings fit for purpose for people with hearing loss

13 NEWS MAK E RS The stories proving most popular with FM World’s online visitors this month

4O HIGH R ISE Overseeing work at height: what FMs should do to assess competence

16 SAF ETY STR ATE GY Mike Bullock of Corps Monitoring talks about the changing world of security

44 OPE N OR C LOSED ?

What to consider when specifying a building’s smoke control system

FM World’s in-depth analysis section 48 ACCESS ALL AREAS Legislation may be in place to ensure against inaccessible buildings – but there remains a lack of communication around disability aware planning and procurement and a lack of forward thinking on the part of FM.

52 ALL INCLUSIVE Inclusive design is the responsibility of everyone who works in the built environment with facilities managers playing a particularly important role in helping raise consciousness about accessibility issues.

56 BUILDING INDEPENDENCE Compliance with the law on workplace accessibility includes a focus on usability and maintenance issues that goes way beyond the predictable issues of ramps, hand rails and signage.

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60 DISABILITY-SMART BIFM’s Good Practice Guide to Inclusive Access maps out how JU N E ’ S to ensure accessibility TO P I C improvements FM AND DISABILITY introduced to AWARENESS buildings do not decline progressively over timeWthrough W W. B I FaM .O RG .U K / F M WJ O I N lack of attention.

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F RO NT D E S K A N A LY S I S

SOUND BITES highlighting that it is estimated that the equivalent of one in six meals served in the UK food service industry is wasted.

One of the report’s recommendations was for the incoming government to require food businesses and retailers to separate food waste.

This should be done through a phased approach, applying first to businesses that produce more than 50kg of food waste a week, then applying to smaller food businesses that produce between 5kg and 50kg of food waste each week, it said.

Although household food waste in the UK makes up 70 per cent of the post-farm gate total, with hospitality and food service constituting 9 per cent, an argument remains that the catering sector should also make reductions for both ethical and financial reasons.

PHOTOGRAPHY: ALAMY, GETTY

Better technology

To that end, a report by the technology firm Omnico suggests that contract caterers can use technology to solve food waste problems on their sites.

In a survey it conducted as part of the report, Omnico interviewed 153 people in the contract catering and food services industry on their current use of technology and future ambitions to improve their customer engagement and revenue through new technology solutions.

It found that 54 per cent of respondents – senior figures in contract catering and food services – wish for technology to provide more accurate predictions of food and footfall to minimise food waste.

The survey focused on the attitudes towards technology in the sector. It also discovered that the contract catering sector broadly believes that a better use of technology would help to reduce queuing times and therefore improve footfall – such as through offering customers the ability

Sam Hurst, CEO of Grazing Catering “Our business model is based on flexibility and this applies across the board.

We actually supply each site with a tablet and a comprehensive wastage and stock ordering form to complete immediately after lunch service each day. This information is then fed back to our HQ and kitchen in real time so that we can constantly adjust production quantities and minimise wastage on a day-by-day basis.

“With real-time data flowing between each of our sites and our head office, we don’t have to wait until the end of each week or month to detect patterns after wastage has already occurred.”

Lin Dickens, marketing director, Bartlett Mitchell “We’ve actually developed a process to check our food waste every day via our intranet system.

For us, a strong waste strategy is just about doing what’s right for the environment but it actually makes business sense.

“Being able to drill down on areas of the menu we need to reduce waste is a key driver to keeping costs and waste to a minimum. We utilise technology alongside ‘Waste-ed’, our educational programmes which we run regularly.

“Our systems even show us where the waste goes – be it to landfill, anaerobic digestion or recycling some other way.

Technology enables us to get to know about it and measure it. After all, what gets measured gets monitored.” fm-world.co.uk

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to pay through a mobile app.

Nearly half (48 per cent) of respondents in the survey said they want to use technology to offer personalised discounts based on what the customer has previously bought – 41 per cent wish to offer a loyalty programme through a mobile app.

Seamless experience

Mel Taylor, chief executive at Omnico, said: “Caterers can now see they must give their diners a more allencompassing, technology-based experience that extends beyond the canteen or dining room doors and

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S U P P LY S I D E

BUSINESS NEWS

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CO M M E NTARY

TR A N S P ORT

WILL METRO MAYORS DELIVER ON SERVICES? G R A E M E D AV I E S newsdesk@fm-world.co.uk

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ntil recently the Triborough Partnership between the London boroughs of Westminster, Kensington & Chelsea and Hammersmith & Fulham was being held up as a beacon of how collaborative working and sharing of services could effectively deliver efficiencies.

But the doubt cast on the initiative after Hammersmith & Fulham was accused of preparing to go it alone raised questions over whether such a model can really work in this format.

For six years, the partnership had successfully amalgamated the delivery of adult social care, children’s services and public health under shared delivery units and was said to have saved more than £40 million.

But political changes at Hammersmith & Fulham led to a rift between the three authorities and, ultimately, the collapse of the partnership.

Many commentators say it was politics rather than performance that led to the initiative’s end. While service delivery was shared, ultimate ownership of the services remained divided between the three boroughs and hence, a hostage to political fortunes once political control changed.

So what are the prospects for similar partnerships being set up? Hope may lie in the latest round of devolution being handed down by central government to the metro mayors of major regional cities.

These figures are being promised more autonomy over a wider range of budgets.

Manchester’s mayor Andy Burnham will sit on a board that will control a £6 billion health and social care budget permed from 10 different unitary authorities. Could we see more collaborative working across old borough boundaries? Budgetary pressures are unlikely to ease on the public sector if the Conservatives prevail on 8 June.

It is impossible to know what a different political mix at the helm of the Triborough Partnership would have meant for the arrangement. The partnership appeared to have delivered on its prime aims to bring service provision in a complex area of London under a more efficient leadership and to produce savings. What such an arrangement clearly needs is considerable political will to make it happen in the first place and then to sustain it. Metro mayors may have the overarching political power to persuade local authorities to work together more closely. Maybe by shifting shared services into the hands of mayors, such initiatives will prosper.

“HOPE MAY LIE IN THE LATEST ROUND OF DEVOLUTION”

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Transport for London (TfL) has announced its intention to award five of six new contracts to manage TfL facilities, which it says will deliver savings of £34 million.

TfL intends to award the five contracts to Engie Services, Interserve Facilities Management, Lanes Group, and Vinci Construction UK. The deals, worth £320 million in total, will last for five years with the option to extend them for a further three. The suppliers will be responsible for the provision of services and the management of TfL facilities, including fire protection, mechanical and electrical facilities, such as power and water, buildings maintenance, and security and reception services.

A sixth contract, for cleaning, is expected to be awarded in the summer.

The savings have been made possible by consolidating 50 contracts into just six – part of TfL’s wider approach “to delivering the mayor’s ambitious plans for improved transport in the capital”. This includes becoming more efficient through the biggest-ever overhaul of the organisation and continuing to reduce operating costs.

The contracts include a commitment for all employees to be paid the London Living Wage as well as the creation of an additional 300 apprenticeship positions throughout the life of the six contracts.

TfL says it is “committed to making sure that it represents the city that it serves and increasing diversity within the transport industry encourage W W W. B Ito FM .O RG .U Kfurther / F M WJ O I N innovation”.

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GRAEME DAVIES writes for Investors Chronicle fm-world.co.uk

TFL parcels up 50 FM deals to save £34m

June 2017

V I E W P O I NT PERSPECTIVES

Have your say

Visit fm-world.co.uk for longer versions of these comment columns Get in touch by email – editorial@fm-world.co.uk Topical, inspirational, angry or amusing – we consider all relevant comment

PERSPECTIVES 1The problem

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with engineering apprenticeships

Being reasonably practicable on vehicle checks

ANDY OWEN is managing director of electric tug specialist MasterMover

ADAM GOMES is HSQE manager for Altius VA

he most pressing problem for the UK’s industrial sector in recent years has been the skills shortage, an issue that will again be at the centre of the public’s consciousness in light of the UK Government’s introduction of an apprenticeship levy in April.

While stability has been returning after the financial crash, the sector has continued to see the volume of skilled engineers entering the industry falling short of growing demand.

But according to the 2017 state of engineering report

by Engineering UK, support from the education system has led to a renewed interest in engineering among young people. Now, the government has put an apprenticeship levy in place to persuade larger engineering firms to employ more apprentices.

Herein lies the key problem with many of the current apprenticeship schemes. By introducing a levy to coerce businesses into offering apprenticeships, the government is taking the wrong steps to achieve the right goal. Businesses must make apprentices integral to their strategies rather than a financially motivated afterthought.

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and just ticking off all the rest. They felt that the pre-use checks were over the top and you wouldn’t carry them out on your own vehicle. They also said they were on a strict time limit for deliveries.

I suggested to the manager that they make the vehicle check monthly so enough time could be made to carry it out properly and that a user-friendly pre-use vehicle check was implemented along with staff training. The manager rejected my advice.

This seems to be a trend with companies whereby they do not heed information in the Health and Safety at Work Act 1974 about making health and safety ‘reasonably practicable’. This means balancing the level of risk against the measures needed to control the real risk in terms of money, time or trouble.

Institute monthly vehicle checks – pre-use vehicle checks, driver training, risk assessments, licensing use checks in place before any checks and a servicing/MoT member of staff used the van. schedule – to reduce risks.

I timed this procedure at 50 Try out procedures with minutes. I asked if this check staff to get their views and was carried out each time together come up with a the vehicle was used and was procedure that meets safety assured it was. and legal requirements.

I spot-checked the process tinyurl.com/FMW0617-safety on three occasions and found that staff were carrying out W W W. B Itinyurl.com/planner0617F M .O RG .U K / F M WJ O I N vehicle the main four or five points ast year saw several high-profile fatal vehicle road traffic incidents (RTIs) in the news, many involving commercial vehicles.

Such incidents highlighted concern for many companies on their policies for driving on company business and have led to what some would argue is excessive paperwork, especially for vehicle checks – the thinking being that this would prevent accidents and keep them within the law.

A client asked me to meet its transport manager to evaluate the ‘driving at work’ policy. I noticed that there were a large number of pre-

Organisations should take on apprentices each year across all departments from design engineering to finance, ensuring they are equipped with practical skills rather than just shadowing an engineer. This

“THE GOVERNMENT IS TAKING THE WRONG STEPS TO ACHIEVE THE RIGHT GOAL” makes it mutually beneficial, particularly for engineering apprentices, as the company gets extra work capacity and they gain valuable skills.

But an Institution of Engineering and Technology (IET) survey last year found that half of engineering firms believe typical recruits do not meet their expectations.

IET president Naomi Climer said: “It is more important than ever that we develop the next generation of home-grown engineering and technology talent.”

This cannot be accomplished unless businesses rethink apprenticeships to benefit both parties.

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“THEY FELT THAT THE PRE-USE CHECKS WERE OVER THE TOP”

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V I E W P O I NT

T H E T H I N K TA N K

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Join the Think Tank to have your opinion reflected here — editorial@fm-world.co.uk

GEN ERAL E LE C T IO N

WHAT MEASURES DOES FM NEED FROM THE NEXT GOVERNMENT? The nation will be heading to polling stations just as this edition of FM World hits the doormat. We asked what manifesto pledges would the FM industry like to see make it into actual policy? Here are the results JULIE KORTENS

JULIAN FRIS

Zero-hours contracts, raising the minimum wage and apprenticeships have been hot topics for years. But even though some might say that we shouldn’t focus on Brexit to the exclusion of all else, it has to be at the forefront of our thoughts.

We all know how dependent our industry is on a low-paid workforce comprised mainly of immigrants. People who have been here for years, working hard and forming invaluable parts of our teams deserve to have their rights guaranteed. I would extend this principle to all low-paid staff.

That is not to say that this is the only priority for FM. I think it would be great to assure people on zero-hours contracts that they will get a certain amount of work, and we certainly need to look at widening the apprenticeship levy.

These are all complex issues that will require time and effort to resolve. Then perhaps we can start looking at some of the other issues, such as implementing an annual review for the minimum wage and analysing the pay gaps between all people, not just ethnicities, though this can’t be the priority.

The new government will need to take a serious look at infrastructure within its public services, especially the NHS. The recent cyber attack that impacted many hospitals and healthcare establishments was a good example of where a lack of focus on infrastructure investment, IT in this case, can really have damaging consequences.

The NHS estate needs urgent attention and the new government needs to make this an absolute priority. Not only are the longterm commercial interests of the government at stake but, more importantly, patient care is on the brink of collapse in some areas.

Many buildings are in desperate need of maintenance and attention, and facilities will need to be improved and modernised to ensure the long-term sustainability of the estate.

Funding is just part of the solution. The NHS is fantastic and unique, but it is also very big and needs to be looked at from a macro perspective. There are too many competing priorities that make management and strategic planning very difficult. Given the backdrop of the economy – Brexit, labour issues – the government needs to make some bold and radical decisions about its future.

FM in this sector needs innovation and the consolidation of the marketplace does not help this. That’s why there needs to be greater consideration about how we can encourage movement and new players to enter the market.

JULIE KORTENS MD, Konnected People

JULIAN FRIS, director, Neller Davies

FOCUS ON LOW-PAID WORKERS

NHS NEEDS BOLD AND RADICAL ACTION

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K N OW H OW

GARY LEVERINGTON is technical services manager at Action on Hearing Loss

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leven million people in the UK have a form of hearing loss – one in six.

By 2035 this will have increased to 15.6 million (one in five). It is imperative for facilities managers to make buildings fit for occupiers and customers with hearing loss.

It is also a legal requirement – the Equality Act 2010 and Disability Discrimination Act in Northern Ireland protects people who are deaf or have hearing loss from discrimination. It also makes good business sense; without being properly equipped you could be excluding one in six of the population.

Action on Hearing Loss has been involved in the installation of assistive technology for over 20 years.

Fear of legal repercussions because of an accelerated need to change has often resulted in bad decisions being made. The challenges that these positive changes were identified to address have created additional issues to what some feel is enforced and ineffective legislation.

The public and bodies responsible for providing access to the public have told us about such contributing factors: Poorly installed assistive technology – the seemingly simple task of installing loops undertaken by enthusiasts with no formal training.

Lack of maintenance – most installed technology will be regularly maintained, however, loops are often low in priority.

Audio selection – Even the best technology will only be as effective as the audio input presented. Poor microphone selection or the expectation of both user and facilitator can wildly affect the capabilities of even the simplest system.

Now, driven by legislation

like the BS7594 and the EN60118-4:2006, a number of affiliated services have become key to improving user experience. Technology is changing and FMs must appreciate the importance of correctly installed systems.

The term ‘loop’ really refers to the delivery method, similar to radio systems, but it is often used to address all assistive technology available. ‘Loop’ can also refer to a number of different types of systems.

Counter loops – Small coverage systems designed for one-to-one conversations.

Installed systems are far superior to portable ones.

Perimeter loops – the most common type, which are very cost-effective. They are easier to retrofit and can provide support in meeting

(From the top) a perimeter loop, a single phased array, and a standard superloop

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TECHNICAL EXPL AINER

H E A R I N G LOOPS

IN THE LOOP

Under the Equality Act 2010 reasonable adjustments must be made to ensure those with a disability are considered in all public buildings – including the hard of hearing, says Gary Leverington of Action Hearing Loss rooms and training areas. being lifted to allow for the more They do, however, suffer from elaborate loop aerial. overspill (the magnetic ‘bleed’ These questions will help that loops create – bad for you to decide if a loop system confidentiality and systems in is the most appropriate answer. close proximity).

Did someone struggle to talk to your receptionist?

Single array – ideal when you can identify the position Is your environment free of of the hearing aid wearer, e.g. background noise? churches, lecture theatres How many people will or classrooms. They provide benefit from this system? greater coverage and quality Is the room used for but can suffer from ‘dead meetings, seminars or social spots’ (areas where the signal is events – and how large is it? lost) – not a problem if you can What is the level of predict where users will be. background noise from equipment such as air Phased array – the complete conditioning? solution providing excellent clarity and coverage. They Do you already offer some can also be designed to support, for example, a public minimise overspill and improve address or speaker system? confidentiality. Both the single Visit Action on Hearing Loss and phased array are more to find out more. difficult to retrofit and may W W W. B I F tinyurl.com/FMW0617-hearing M .O RG .U K / F M WJ O I N even require the floor finishing

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K N OW H OW EXPL AINER

COLIN LAWSON is head of sales, marketing and product development at Tamlite Lighting

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he lights are going out all over Europe. A wave of European Commission (EC) regulations – notably 245/2009, affecting fluorescent and other older lamp types – have sought to minimise the energy consumption of lighting for business and for home, and have led to a wave of public and private initiatives geared towards the replacement of legacy systems with high-efficiency, next-generation solutions.

April 2017 saw the introduction of the latest phase of EC rules intended to increase lighting efficiency, with the consequence that a significant number of older lamp types will no longer come on to the market.

So now is the time for facilities managers to think about next-generation lighting.

The third phase of the 245/2009 regulation was implemented in April.

As a result, it is no longer possible to place low-performing metal halide lamps with E27, E40 and PGZ12 caps (<405W) – or compact fluorescent lamps with two pins and an integral starter switch – on the market. These lamp types have historically been widespread in industrial and office applications.

With a few exceptions, companies are still allowed to stock and sell these lamps, but they can no longer be manufactured. It is estimated that there is somewhere in the region of two years’ worth of stock of both types out in the market, so there is certainly no need to panic about the availability of replacement fixtures just yet.

Rising maintenance costs

The laws of supply and demand mean that as no new such systems are being placed on the market, customers are set to see an increase in unit price for the older types.

Maintenance costs are also destined to rise as the replacement of these lamps becomes more problematic and requires more extensive sourcing efforts.

In a broader context, the impact of regulatory changes and the abundance of publicity about major corporations who have shifted towards high-efficiency – most commonly LED-based – lighting, means that the writing is surely on the wall for fluorescent lighting in most large-scale applications. Further initiatives at a Europe-wide or individual government level are pretty much guaranteed,

LI G H TI N G

OUT OF THE DARKNESS

With the phasing out of inefficient lamps, there’s never been a better time to investigate next-generation lighting, says Tamlite Lighting’s Colin Lawson

so those who have not moved away from old-style lamps may ultimately have no choice but to do so.

Consider overall upgrades

These changes may prompt facilities managers to carry out ‘spot’ replacements with LEDs as each older lamp type fails.

But spot replacements would result in the mixing of magnetic and electronic ballasts on the same switched circuit. This could cause damaging high-voltage peaks, so it is wise to replace all existing magnetic ballasts with electronic ones.

LED lighting is now overwhelmingly established as the light source of choice for those looking to both reduce energy and save money. On a fundamental level, the energy savings can be measured in

“LED LUMINAIRES COMMONLY OFFER A LIFETIME OF MORE THAN 30,000 HOURS” fm-world.co.uk

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high double-digit percentages. Based on a replacement of legacy lamp types with an equal number of LED replacements – figures indicate that reductions of 63 per cent (retail applications), 65 per cent (office) and 85 per cent (both industrial and domestic) are now achieved routinely.

LED luminaires commonly offer a lifetime of more than 30,000 hours, which even on the basis of 24/7 operation means that they can be up and running for at least three years – double the lifespan of some conventional lamp types. And the call for fewer replacements translates into reduced maintenance costs and interruptions to the normal working practices of a building.

All of this means that – rather than undertaking the shift away from older lamps in a piecemeal fashion – the smart move is to approach upgrades with a comprehensive strategy in place.

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ENABLING PRODUC TIVE ENVIRONMENTS FOR PEOPLE AND BUSINESS

FM’s

inclusivity mission

From design to delivery, facilities management’s role in ensuring no worker is cut out of the workplace picture

ACCESS ALL AREAS Clients, contractors and a failure to communicate

ABOVE AND BEYOND How do FMs operationalise inclusive facilities?

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Accessibility issues beyond W W W. B I F M .O RG .U K / F M WJ O I N base compliance

FAC I LITATE

D I S A B I L I T Y- C O M P E T E N T P R O C U R E M E N T

Despite legislation designed to prevent inaccessible buildings, the FM function could do better at procuring disability-smart solutions for end-users. Poor communication of disability awareness planning and procurement plays its part.

By Adam Leach

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sability and accessibility have risen in importance over recent times. As the digital sphere has expanded beyond desktops to encompass mobile applications covering almost every facet of modern life the usability of everything, from an app to order pizza to a terminal to purchase a ticket, has become a critical element of daily life.

But while the term and its importance is freely bandied about and understood in the ever-expanding range of digital spheres, its value as a factor in more traditional areas such as the built environment appears to lag.

Buildings stand, provide power, light and heat, and house the operations of a business, but are not in necessarily assessed on the grounds of their usability or accessibility to the same degree as more recent elements of life.

For many, this is not an issue. As long as a door can be pushed, a light switched, and a staircase ascended, a great many can go about their business. But for those with a disability or a chronic health condition, the wrong light can lead to serial migraines and the wrong door a barrier to entry.

As the frontline managers of the building and the contractors of the thirdparty service providers, both the facilities management and procurement functions hold key responsibilities in ensuring access and use for all. From the opening of doors to maintaining the disabled bathrooms, issues that can restrict access or inflame a staff memberâ&#x20AC;&#x2122;s condition are within their remit.

But as the Building Disability Forum (BDF) has found, both functions are failing to deliver fully on those demands. Its recent research found a series of failings relating to the contracts and communications carried out between clients and contractors on access and disability awareness. It found that 60 per cent of outsourcing agreements feature no element of disability, that 75 per cent of contracts are not reviewed to ensure that disability requirements are being met, and that 80 per cent of businesses do not discuss disability outside of formal processes.

Despite these, the BDF also found that facilities management is the main area of the business where positive outcomes on disability can be achieved. When asked which areas of a business had third parties delivering products or services that are helping to deliver good outcomes for disabled people, 93.8 per cent identified facilities management staff, with 81.3 per cent identifying them as having helped to deliver good outcomes.

Failing to open up access to all

Taken together, the findings paint a picture of a failure to deliver to standard, yet a capability to deliver positive outcomes. In essence, it is a lack of upfront planning and process that has created a structural flaw.

With a slew of regulatory measures having been implemented, the Disability Discrimination Act [DDA] 13 years ago, then replaced by the Equality Act in 2010, and Building Regulations in place, why is it that businesses and the functions within them have failed to deliver in this area?

It would appear that such regulatory measures are insufficient to assure accessibility in the modern day.

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FAC I LITATE

DISABILIT Y COMPLIANCE

Compliance with the law on workplace accessibility doesn’t begin and end with ramps and dedicated loos – there are usability and maintenance issues that go way beyond these that are being widely neglected, says Nick Martindale

BUILDING

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ccording to a recent report by the Equality and Human Rights Commission, fewer than half (47.6 per cent) of disabled adults are in employment compared with almost 80 per cent of non-disabled people, and that gap has increased in the past seven years.

The reasons for this are many and varied, but one issue is undoubtedly the accessibility of workplaces and the ease with which individuals are able to get in, around and out of their place of work.

For many years the requirement on employers – and facilities managers working within organisations or as service providers to them – was dictated by the Disability Discrimination Act 1995, which was later incorporated into the 2010 Equality Act. A key element of this, says Daniel Wilde, partner at Harding Evans LLP, is to facilitate access for disabled people, including making “reasonable adjustments” where needed. “That could be changing how things are done, changing a physical feature of a building, or providing an ancillary aid,” he says.

“There’s no obligation to make fundamental changes; if it would cost a small business owner £20 million then that obviously wouldn’t be reasonable because cost is a factor in a reasonable adjustment. But if it’s as simple as putting in a ramp, and there was the ability to do that, then that would be reasonable.”

INDEP

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