In this post, our guest writer Jon Cumberlidge gives a comprehensive overview of the Equality Act. John is the Director and Principal Building & Fire Consultant of C3 Design Approvals Ltd, a corporate Approved Inspector and industry leading experts in Building Regulation compliance. For more information please visit www.c3designapprovals.co.uk
Inclusive Buildings – Part M
It’s a pleasure to have been asked to pen this guest blog for Rap Interiors. The aim is to highlight some of the issues surrounding inclusivity in the built environment including a brief overview of the legislative background and some of the key technical standards to be met for building regulation compliance.
First off, I’m going to say something controversial … there is no such thing as a DDA compliant toilet, or a DDA compliant handrail or a DDA whatever for that sake! I still hear these statements regularly from designers and contractors. The reason I say there is no such thing as a DDA compliant (insert generic building item here) is that the DDA (Disability Discrimination Act), has now been subsumed into the Equality Act. The Act is a legislative frame work, it does not contain detailed design advice on how a building feature, such as an accessible toilet should be laid out. There are however detailed design guides such as Approved Document M or BS 8300 that should be followed, but these are to show compliance with building regulations which in turn can help with compliance with the Equality Act.
What is the Equality Act?
The Equality Act is an important piece of UK legislation that provides legal protection to persons from discrimination within the workplace and wider society. Coming into force in 2010 it replaced a multitude of seperate pieces of legislation, including the Disability Discrimination Act (DDA), bringing these together under a single harmonised piece of legislation.
The Equality Act covers a broad range of what it terms, ‘Protected Characteristics’. These include age, gender, race and sexual orientation and disability.
The Equality Act also provides a legal definition of disability and places a duty on service providers and employers to ensure that they do not discriminate against a person with a disability.
This duty not to discriminate extends to making reasonable adjustments. This essentially means that where a person who has a disability is put at a disadvantage over someone who does not have a disability there is a duty to make changes to remove the disadvantage. This includes making physical alterations to buildings, such as installing a ramp to provide step free access for example.
What is the Social Model?
Disability can encompass a huge spectrum of conditions with varying severity; from restricted mobility (everything from requiring use of a wheelchair to arthritis affecting dexterity and grip of the hands) to sensory impairments such as sight and hearing restrictions through to cognitive conditions.
Whilst the Equality Act provides a legal definition of disability it is important to be aware that there are two principle models for disability; the medical and social. It is the second of these, the social model that is of particular interest to those who design, build or have responsibility for managing buildings. The social model focuses on the fact that it can be the attitudes of society and physical attributes of the built environment that restrict or exclude disabled persons. A good example of this is to consider a building that has steps leading to its main entrance, this is an obstacle that restricts access for a mobility impaired person. However, if the building was designed without the need to negotiate the steps there is no barrier and therefore there is no ‘disability’.
Building Regulations – Part M
For those carrying out building work, whether constructing a new building or making alterations to an existing one, there is a legal requirement to comply with the Building Regulations.
Part M of the Building Regulations covers access and use of buildings and is a set of functional requirements, this means that it sets down a broad performance requirement to be achieved but does not necessarily dictate how to comply. Fortunately, there is detailed guidance available in the form of Approved Document M and BS 8300.
It’s important to note that it may not always be necessary or practical to follow the guidance of the Approved Document to the letter. In these cases, an Access Strategy may be of assistance in justifying how the requirement can be met in another way, this could include management strategies.
Approved Document M
Approved Document M is a guidance document that provides practical ways including detailed specifications that if followed can be regarded as satisfying the building regulations.
In 2015 Approved Document M for use in England was split into two separate documents, Volume 1 covering new dwellings (houses and flats) and Volume 2 covering buildings other than dwellings.
The separation of guidance documents in 2015 was driven by the Housing Standards review, which sought to streamline guidance and standards for new housing. Part M Volume1 now contains ‘Optional Requirements’ similar to the Lifetime Homes standard that can be imposed on development under the Planning process. There are essentially three categories of dwellings, 1: Visitable, 2: Accessible and Adaptable and 3: Wheelchair User dwellings.
Below we will look at some of the technical aspects for buildings other than dwellings including offices, shops, public buildings etc.
Access to the building
The aim is to provide suitable access from the boundary of the site of parking spaces to the entrance of the building. Some of the key features to consider in doing this are:
Level pathways at least 1.5 meters wide with passing places. A maximum gradient of 1:60 or less than 1:20 if landings are provided for every 500 mm of rise. No more than a 1:40 cross fall.
Crossing places provided to roads with drop kerbs and visually contrasting tactile blister paving.
Car Parking if provided should be suitable for disabled users. Consideration should be given to the height of any ticket machine. Parking bays should an activity space 1200mm to the side and rear to assist with transfer to and from the vehicle and manoeuvre around the vehicle. Spaces should be near to entrances and have level access to footpaths.
Ramps should be provided where gradients exceed 1:20. Maximum lengths and gradients apply. Don’t forget that the ramp surface should provide a visual contrast.
Steps should be provided in addition to ramps. These should have a rise and going which is easy to negotiate (rise 150-170mm, going 280-425mm) with visually contrasting nosings and corduroy paving provided as a warning of a change in level at the top and bottom of the flight(s).
Handrails are a safety feature as well as aiding and giving reassurance to users of ramps and stairs. It’s important that handrails are of the correct diameter and height. In cold weather external handrails can be uncomfortable to use or worse for people with Raynaud’s, therefore the recommendation for handrails to not be ‘cold to touch’. Handrails should terminate in a way to minimise the risk catching clothing, this is usually achieved by turning the end of the handrail down by 90 degrees.
Access into the building
Main entrance referred to as principle entrance in Approved Document M should be easily identifiable within the building’s façade. In public buildings this should be a minimum of 1 meter wide.
Signage to an alternative accessible entrance should be provided where it is not possible to make the principle entrance comply.
Level access threshold from a landing of at least 1500 x 1500mm clear of any door swing.
Door entry systems should be suitable for all users including those with a hearing impairment or who cannot speak. Consideration of video as well as audio capability.
Weather protection is considered to non-powered manual entrance doors.
Power assisted doors are preferred however manual doors maybe acceptable if carefully designed to minimise obstruction to users. In practice this can be difficult to achieve when a self-closing device needs to hold the door shut on a windy day but also be light enough to open. An opening force of 30N for the initial pull and then 22.5N from 30 – 60 degrees should be achieved.
Entrance matting provided to help remove moisture from feet and wheelchairs. This should ideally be recessed so that it sits flush with the floor British Standard BS 7953 recommends a minimum length of 2.1 meters.
Reception areas are often the first point of contact and therefore an important space. Receptions should be easily identifiable, desk should have a clear manoeuvring space in front and be suitable for both standing and seated users being provided a low-level section with knee recess. An induction loop system should be provided to assist people with hearing impairments.
The aim is to provide suitably sized spaces and facilities to allow all users to freely and independently move throughout the building. Some of the key features to consider in achieving this are:
Lobbies should be sized so that doors swings do not interfere with use. Spatial arrangements are provided in Diagram 10 of Approved Document M with the principle aim to maintain a space of 1570mm which should be suitable for an occupied wheelchair and a companion pushing, or a large scooter. Care should be taken to avoid confusing reflections from the extensive use of glazing.
Door widths should be sized in accordance with Table 2. The width of the door is an effective clear width, this is a measurement of the free space between door, including any projections (such as a door handle) and the frame. Door widths relate to the size and direction of access corridor. Generally, 800 mm wide is sufficient with 825mm being required where access is a right angle and the corridor is at least 1200 wide. Don’t forget the 300mm return between the leading edge of the door and wall (diagram 9)
Corridors should be a minimum of 1200mm wide with passing places at least 1800mm long provided. If corridors are at least 1800mm wide no passing places are required.
Visual contrast should be provided between floors and wall, door furniture and doors and door frames and walls. This helps users appreciate the size and shape of the space they in as well as recognise where doorways are located even if doors are open.
Staircases within the building need to provide key features to make them easier to use. Features such as a minimum width of 1200mm, easy rise and going, visually contrasting nosings etc. all help in this respect. As a result of a Government drive to reduce and simply guidance detailed design recommendations for internal staircases and ramps is now contained within Approved Document K.
Lifts or in certain cases lifting platforms are the preferred method of providing vertical circulation. Lifts must be sized accommodate the appropriate number of persons considering wheelchair users and companions. Visually contrasting and tactile buttons, auditable floor indication assist people with sight impairments should be provided. Floors of lift cars should not be dark in colour and ideally contrast with the floor of the landings. Call buttons should be a minimum of 500 mm from any return wall.
The aim is for all users to be able to access, use and participate in events such as lectures or entertainment within the building. This section also covers refreshments facilities and sleeping accommodation.
Audience and spectator facilities are split into three key categories lecture/conference, entertainment such as cinemas and theatres and sports facilities. There needs to be a minimum number of wheelchair accessible spaces provided and these need to provide a choice of locations and range of views. Good sight lines and induction loops can assist people with hearing impairments. Space for guide dogs should be considered as well as access to stages and lecterns.
Refreshment facilities should be designed for independent use by all as well as companions of people with a disability. Low level counters at a maximum of 850 mm from floor level should be provided for wheelchair users and a higher section for standing patrons. Self service areas such as beverage rooms should allow independent use with undercounter knee recess’ and 1500 x 1500 turning zone.
Sleeping accommodation needs to be provided in suitable number and be convenient for all people to use. There are two key sets of requirements, firstly for wheelchair accessible bedrooms and secondly for all bedrooms.
All bedrooms should be provided with window controls between 800 – 1000 mm above the floor and be easy to operate. Doors to built-in wardrobes should be capable of opening 180 degrees. Visual warning to the fire alarm and embossed door numbers to assist people with sight and hearing impairments respectively.
Wheelchair accessible bedrooms should be provided with a frequency of 1 per every 20 bedrooms. Key dimensions to allow movement and access to the bed, wardrobe, balcony or windows and wheelchair access bathroom should be provided. An emergency assistance pull chord should also be present.
Switches, sockets and pull chords should be designed to be easy to operate, visible, and at a height that makes them easy to use.
Toilet and Washing Facilities
All toilet accommodation should have certain features to in order to makes them easier to use but also be safe. Features such as visual indication of the fire alarm can aid those with hearing impairments, taps should be easy to use for persons with limited dexterity and comply with requirements to ensure water is not too hot. Another often overlooked consideration is that all WC compartment doors should be capable of being unlocked form outside and open outwards to assist in emergency, such as the occupant collapsing behind the door. People should generally not need to travel more than 100 meters to reach a toilet or 40 meters in the case of accessible facilities.
Wheelchair accessible WCs are usually unisex facilities. They have key dimensions and contain accessories such as support handrails, to make them easy to use. Doors should open outwards and the minimum size for the room should be 1.5 x 2.2 meters; unless they are the only facility in the building in which case, they should be enlarged in width to 2 meters so that they can contain an additional sink at standing height. Often a user will wash their hands before adjusting their clothing therefore the relationship between the WC pan, handrails, the sink, soap dispenser etc are all critical.
Ambulant disabled WCs are generally provided within separate sex toilet facilities. These are slightly larger (at least 80mm) than a standard cubicle, have an outward opening door and be provided with horizontal grab rails. Where 4 or more WCs are provided then an enlarged ambulant (1200 mm wide), in addition to the standard provision should be considered.
Washing facilities are covered in their various forms, from rooms combine both accessible WC and shower to bathrooms. Key dimensions, safety features such as grabrails, emergency assistance pull chords and drop-down seats within showers should all be considered.
An emergency assistance pull chord with indication outside the room and at a staffed location should be provided.
As operators, managers, designers or constructors of buildings we have a duty to ensure the built environment does not create unnecessary barriers. Good design and expert advice taken early on in any project can help achieve this aim, creating buildings that are safe, sustainable and inclusive and welcoming for all.
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