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Consultations

Proposed Amendments to Guidance under the Building (Scotland) Regulations 2004

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�SDEF Consultation Response

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SDEF

The Scottish Disability Equality Forum works for social inclusion in Scotland through the removal of barriers and the promotion of equal access for people affected by disability.

It is a membership organisation, representing individuals with any type of impairment, disability organisations and groups who share its values. It aims to ensure the voices of people affected by disability are heard and heeded.

SDEF promotes access in its widest sense: access to the built and natural environment and access to the same opportunities as are enjoyed by other people in our community. It takes a broad definition of access, within which it focuses on access to the environment and access to information and mechanisms promoting two-way communications. It campaigns to improve access in these areas and seeks to become a free source of high quality information on them.

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General points �

The consultation/ proposed changes are not necessarily about disabled people but rather about access for all.

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The working group should include representation of disabled people. There should be more/better consultation/involvement to discover what needs of disabled people are. Disabled people don’t carry their own hoists, need bigger beds, more space, grab rails and sometimes have to pay for alterations.

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�Disabled people should be involved at every stage.

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The Disability Discrimination Act has raised the profile regarding accessibility of buildings, however, there is a general need to promote inclusive design. Building standards cannot achieve this alone so there is a need to work with planners.

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National standards for housing should be addressed.

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Education in building standards is an issue. SDEF members would like to see inclusive environmental access and design as part of architects’� training. Those designing and/or fitting facilities for disabled people should be able to demonstrate a qualification in this area or several years experience.

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British Standards are often cited as the method of best practice. However, it is felt that the Standards are a minimum that do not adequately meet the needs of disabled people and that builders/planners are doing the least they can rather than aiming for the best solutions.

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If the building regulations are not descriptive there will always be someone who will try and shortcut the system and we will end up with sub standard facilities.� This is something that must be avoided at all costs.

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Manoevering space does not meet needs nor take into account sometimes necessary presence of carers.

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Sensory impairment is often neglected. There are issues with lighting, glass panels that reflect muffled sounds. These are not covered by the consultation.

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Although building standards stop at property boundaries there is an argument for a joined up approach of inclusive design including highways, for example, placing of A boards.

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Car parking in new buildings - there should be provision for angled^�hatched parking bays. This is a health and safety issue. However, this issue is not covered by the guidance.

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The �proposal for space down the side of the bed is inadequate for wheelchair user. The minimum standard should be changed to reflect this. 3.11.2 that covers enhanced apartments is still too small

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There are concerns that new building structures cannot bear the installation of roof/track hoists.

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Lifts that can be used in emergencies are not covered in the guidance. Unclear whether this is covered by European guidance.

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Hotel bedrooms - there should be hoist facilities in disabled bedrooms. Many have baths that are inaccessible to disabled people. There is an issue with pull chords, which should be accessible to people lying on the floor, and should run round the perimeter of the room.

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Emergency egress� - little thought given to escape. Often the emphasis is on access rather than egress presenting disabled people with extra problems and increasing risk of harm in the event of an emergency.

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ANNEX C

SPECIFIC PROPOSALS ON WHICH COMMENT IS REQUESTED

Standards and guidance within Sections 3 (Environment) and 4 (Safety) that relate to the access to, and usability of, buildings have been revised, substantially rewritten and reorganised. Although many clauses are still recognisable from the 2005 edition of the Technical Handbooks, there are significant changes to both standards and to the prescription offered within guidance. Consultees are invited to respond on any aspect of the proposals but Scottish Ministers would welcome comments specifically on the following issues:

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ISSUES RELEVANT TO DOMESTIC BUILDINGS

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1. ACCESSIBLE SANITARY ACCOMMODATION

Standard 3.11. One of the keystones to providing accessible homes is provision of accessible sanitary accommodation in clause 3.12.2. Proposals are for both WC, washbasin and bath or shower on the principal entrance storey that can be used by almost all occupants of a dwelling, with the option of a future provision for an accessible bathing facility is offered in houses only.

Do you agree with this principal and/or have any comments over suggested provision?� YES

This will increase the accessibility of dwellings and should begin to address the shortfall of residential accommodation.
Why “almost all”?
If accessible homes were provided with lift access to all floors then these facilities could be sited elsewhere.
�There have been comments on the position of the colostomy shelf in accessible toilets. This is not covered by building standards but is something that requires further investigation.

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COMPLEMENTARY STEPS - Standard 4.1 (Access to buildings)

Standard 4.1. Recognising the difficulties a gradient may present to many ambulant people with mobility impairment, clause 4.1.3 recommends the provision of a complementary stepped route wherever a ramped route has a rise in excess of 300mm, on any accessible route serving more than a single dwelling.

Do you agree that this is a practical response to this issue? YES

It is pleasing that consideration given to those who are ambulant disabled in addition to wheelchair users
�The height could be dropped to 150mm

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3. ACCESSIBLE ENTRANCES (GENERAL)

Standard 4.1. Clause 4.1.8 makes recommendations that protection from the elements should be provided to people entering a common entrance to a domestic buildings.

Should building standards contain prescription on this issue and, if so, do you have any views on where it should apply? YES�

Protection from the elements should be provided in all areas immaterial whether the entry gives access to flats or housing and is an issue where there is an intercom system.

4. CORRIDOR WIDTHS IN COMMON AREAS

Standard 4.2. To ensure there is sufficient space within common areas, clause 4.2.1 recommends a single corridor width of 1.2m throughout, regardless of whether lift access is provided to a storey. This is intended to recognize that a minimum width is necessary for general amenity of occupants and not just where there is access for wheelchair users.

Do you agree with this principal and/or have any comments over suggested provision? NO

Where a lift accesses a corridor in a new build that corridor should be widened to a width of 1.8m at that point, .12m is not wide enough. There are reservations over the turning circle for wheelchair users.

5. PROVISION FOR FUTURE ACCESS BETWEEN STOREYS IN A DWELLING

Standard 4.2. Clause 4.2.7 makes recommendations that provisions are made for future installation of both stairlift and ‘through-floor’ powered lifting platform, with the opening for the latter being constructed in a suitable location to simplify adaptation.

Do you agree that both these provisions are required? Comments on both options would be welcomed. YES

These provisions as houses will greatly improve access for all disabled people.� Stairlifts should not be the only means of traveling between floors as they are not suitable for wheelchair users. Everyone should be able to access all parts of the building wherever possible.
�There is a cautionary note that unrealistic costs are not passed on to the buyer because of this provision.� While all new buildings must be fully accessible we must not run the risk of further pricing first time buyers out of the market.

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6. SOCKET OUTLETS

Standard 4.6. Clause 4.6.4 gives some additional guidance on the distribution of socket outlets throughout a dwelling

Do you consider this an adequate minimum provision for the way homes are used today? If not, what provision would you consider more representative?� YES

Disabled people should be able to access plugs and sockets. There is room for greater provision, for example, �eight sockets in each room, including and especially bedrooms, with a minimum of 10 + cooker socket in the kitchen.

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�7. ELECTRICAL FITTINGS AND CONTROLS

Standard 4.8. Whilst electrical fittings in buildings are generally installed to accepted conventions for ease of use, suggestions have been made that this could be further regularised, to ensure ease of use, by inclusion within the building regulations.

Is there a need for the location and height of electrical fittings and controls be included within guidance and, if so, to what extent? YES�

There is such a variance of positions and heights of sockets and light fittings applied by tradesmen it is imperative that the height of sockets and switches is determined within building regulations and is not left to chance.

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ISSUES RELEVANT TO NON-DOMESTIC BUILDINGS

8. ACCESSIBLE TOILETS

Standard 3.12. Recognising the limitations of space within small premises, the present provisions where a toilet accessible to wheelchair users need not be provided are retained for certain buildings containing not more than 20 people.

Do you agree that such a limitation should remain? If not, can you offer support for any change? NO�

This limitation must be lifted at all costs; not doing so will be blatant discrimination against disabled people and give a glaring get-out for Architects, Designers and Tradesmen alike. Why should disabled people be unable to go to a small caf� or restaurant because they can’t use the toilet?� Disabled people are entitled to the same level of service and access to facilities as �the non-disabled. The provision of accessible toilets is a key issue for disabled people as they may have more needs than others. Within this there is an issue over the guidance on handrail height and locks, which are felt to be inadequate. There is also a question over the provision of changing facilities in general, with disabled people’s needs continuing to be unmet.

In not removing this limitation the SBSA will be guilty of inducing discrimination against 20.31% of the population of Scotland.

Would the situation change as a result of a temporary increase in the buildings users? For example, where a caf� places seating and tables on a pavement area raising the number of people to well over 20

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9. COMPLEMENTARY STEPS - Standard 4.1 (Access to buildings)

Standard 4.1. Recognising the difficulties a gradient may present to many ambulant people with a mobility impairment, clause 4.1.3 recommends the provision of a complementary stepped route wherever a ramped route has a rise in excess of 300mm.

Do you agree that this is a practical response to this issue? YES

This �is a good practical solution that will ensure the best possible choice for all, disabled and non disabled people alike, with very little extra costs.

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10. ACCESSIBLE ENTRANCES (GENERAL)

Standard 4.1. Clause 4.1.7 recommends a single minimum width of 800mm for entry into a building. Should consideration be given to an increased width under certain circumstances, for example, based upon the scale of entrance or number of people using a building, to better accommodate the needs of people using a building?

Should this be considered and, if so, do you have any views on the level of provision that should be sought? YES

Doors of 800mm clear width is much to restrictive to many disabled people, wheelchair users and ambulant disabled, alike.

Door width that will accommodate the standardised size of 926mm door (a recognised standard in the building trade) would ensure that no disabled person was excluded from buildings.

Should this be considered and, if so, do you have any views on the level of provision that should be sought?

Doors of 800mm clear width is much to restrictive to many disabled people, wheelchair users and ambulant disabled, alike.

�Door width that will accommodate the standardised size of 926mm door (a recognised standard in the building trade) would ensure that no disabled person was excluded from buildings.

There may be the odd exception, however, if the refurbishment of an existing building did not allow for the widening of the door because of structural or severe financial constraints that may occur in the likes of a historically listed building.

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11. ACCESSIBLE ENTRANCES (GENERAL)

Standard 4.1. Clause 4.1.8 makes recommendations that protection from the elements should be provided to people entering a building, to any accessible entrance where there is any barrier other than an unlocked door. This would apply externally large number of non-domestic buildings. �

Should building standards contain prescription on this issue and, if so, do you have any views on the extent of application? YES

�It should be up to the Architect or Designer to suggest a suitable solutions as what is suitable for one building or situation may not be suitable for another.
�Such shelter or protection should be large/wide enough to accommodate a wheelchair user.

12. ACCESSIBILITY WITHIN AND BETWEEN STOREYS

Standard 4.2. Clause 4.2.1 removes the previous guidance permitting storeys below a certain size to be provided with stair access only and seeks that all storeys are accessible.

Is the guidance given on small areas within a storey where this need not apply considered an appropriate level of exception? If not, what suggestions would you offer? YES

With the exception of turning circle dimensions for wheelchairs the answer is yes. This is an important step towards achieving inclusion.� Buildings should be accessible for all and where there are multiple storeys, lift access provided.

13. VISION PANELS TO DOORS

Standard 4.2. Clause 4.2.5 makes recommendations for vision panels in doors across corridors to assist in preventing collisions.

Should a similar or reduced provision be made to other doors within buildings, where privacy is not an issue? YES

For health and safety reasons this would be an improvement and should contain the prescribed two glazed vision panels for those who use wheelchairs and those who do not or do not have a disabling impairment.

14. ELECTRICAL FITTINGS AND CONTROLS

Standard 4.8. Whilst electrical fittings in buildings are generally installed to accepted conventions for ease of use, suggestions have been made that this could be further regularised, to ensure ease of use, by inclusion within the building regulations.

Is there a need for the location and height of electrical fittings and controls be included within guidance and, if so, to what extent? YES

�The building regulations be descriptive as far as heights are concerned.� However, in a non domestic environment it has been suggested that 50% of all sockets should be at a height that could be utilised above desk height to accommodate modern technology and ease of use of such.� Otherwise all sockets should be at a height to 500mm from floor to centre level and all light switches at a height of between 1000 and 1100mm from floor to centre level.

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