|
Consultations
Proposed Amendments to Guidance under the Building (Scotland)
Regulations 2004
�
�SDEF
Consultation Response
� |
<back>
|
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.
�
General points �
- The consultation/ proposed
changes are not necessarily about disabled people but rather about
access for all.
�
- 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.
�
�
- 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.
�
- National standards for
housing should be addressed.
�
- 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.
�
- 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.
�
-
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.
�
- Manoevering space does not
meet needs nor take into account sometimes necessary presence of carers.
�
- Sensory impairment is often
neglected. There are issues with lighting, glass panels that reflect
muffled sounds. These are not covered by the consultation.
�
- 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.
�
- 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.
�
- 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
�
- There are concerns that new
building structures cannot bear the installation of roof/track hoists.
�
- Lifts that can be used in
emergencies are not covered in the guidance. Unclear whether this is
covered by European guidance.
�
- 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.
�
- 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.
��
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:
�
ISSUES RELEVANT TO DOMESTIC
BUILDINGS
� |
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.
� |
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
� |
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�
|
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.
� |
6. SOCKET OUTLETS
Standard 4.6. Clause 4.6.4
gives some additional guidance on the distribution of socket outlets
throughout a dwelling
-
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.
� |
�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.
� |
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.
- 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
� |
|
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
� |
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
- 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.
� |
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
|
|
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
|
|
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.
� |
� |
<back>
|
|