Can Disability Access Consultants issue Certificates of Compliance?

As access consultants, we get involved at all stages of building projects, from concept or schematic designs right through to inspections of the completed works. We work across Australia and more recently overseas, but this discussion is specific to the building regulatory system in Victoria.

Access-Consultants-and-Certificates-of-ComplianceFrom time to time we get asked to provide ‘Certificates of Compliance’ for building designs or recently completed building works. When this occurs, our response to this request is always the same – we’re unable to issue them. We can however provide reports that determine if compliance is achieved within the proposed works, or the completed works.

This request is very common when we prepare ‘Alternative Solutions’ to support designs that vary from the prescriptive ‘Deemed-to-Satisfy’ provisions of the Building Code of Australia (or BCA, part of the National Construction Code) and Premises Standards (under the Disability Discrimination Act).

Brothels: Weighing Disability Access, Dignity, and Safety

Introduction

Disabled Access in Brothels ProstitutesAccessibility is becoming an important concern in all sorts of public places. From stadiums to hospitals to museums, more businesses and organisations than ever before are getting with the times by making their facilities accessible for all people.

Accessibility measures are even being taken in some unexpected industries. One of these is the sex industry.

That’s right: businesses that provide sex in exchange for money, or brothels, are now thinking about how they can make their facilities more accessible for those with disabilities.

Obviously, the unique nature of these businesses means there are specific physical challenges that must be met in order for accessibility requirements to be fulfilled. To get a better sense of how it is possible to make brothels accessible for those with disabilities, it is necessary to first understand why this requirement has entered the public discussion over the past few years.

How many disabled car parks do I need

Or more politically correct “How many accessible car parking spaces do I need”

Double accessible car paring space AS2890.6One of the most common questions we get in our office is how many accessible car parking spaces do I need to provide for my building?

The following table hopefully will assist.

Demand Action Now – Accessible toilets at events and festivals

We want compliant accessible toilets at events and festivals

We discussed in an earlier blog post the issues faced by people with disability with the current range of (non) accessible toilets being provided at events. Accessible Toilets at Events & Festivals

It is not acceptable that people with a disability are not provided with suitable amenities at events and festivals. It is both undignified and discriminatory.

It’s time to start lobbying the toilet rental and hire companies that their current offerings are unsatisfactory and it is time for immediate change.

Event Disabled Toilet Photo 08

New Changing Places at the MCG Melbourne Cricket Ground

Equal Access are proud to have been involved with the design and documentation of the new Changing Places facility at the Melbourne Cricket Ground.

The facility was opened on the 26th February 2015 and is located off Gate 3 and services 37 wheelchair seating spaces nearby.

We would especially like to thank William Coomaraswamy, Capital Works Project Manager at the Melbourne Cricket Club for the opportunity to consult on this project.

Builder: Rodney Clarke, ONE68 Pty Ltd.

MCG Changing Places Plan

A Free National Construction Code for 2015

The National Construction Code (incorporating the Building Code of Australia)

The National Construction Code 2015 (incorporating the Building Code of Australia) Book Covers

The National Construction Code (NCC) is an initiative of the Council of Australian Governments (COAG), which has been developed to incorporate all on-site construction requirements into a single code. The NCC introduced in May 2011 comprises the three parts: the Building Code of Australia (BCA), Volume One and Two; and the Plumbing Code of Australia (PCA) as Volume Three.

All three volumes are performance-based documents allowing options to achieve compliance, including compliance with the Deemed-to-Satisfy Provisions, the flexibility of developing Alternative Solutions based on existing or new innovations, efficiencies or other benefits, or a combination of both.

I’ve just leased a new tenancy but I don’t have wheelchair access!

OK, so you’ve started a new business and done all your due diligence beforehand, right?

New building lease, what about access for people with disability disabledBut the last thing people think about before they start to plan their move into the new premises is access for people with disability. Under Commonwealth and State or Territory legislation, if the work triggers a building permit or building approval – then you need to think about this. If you don’t, it could get very expensive or litigious.

We regularly get calls from business owners who’ve leased a tenancy within a building, or an entire building, and had drawings prepared for their new fit-out, only to be told by the building surveyor / building certifier that they need a new ramp into the building from the street, or a new passenger lift within the building (if so, say goodbye to the project budget you planned for straight away). The quote below is all too common:

“I’ve just leased a new tenancy but I don’t have wheelchair access!”

 

Handrail Termination to Ramps & Stairs

There are several options available for the terminations of handrails to ramps and stairs as referenced in Australian Standard AS1428.1 (2009) – Design for access and mobility, Part 1: General requirements for access – New building work- Design for access and mobility.

Handrail terminations to stairs and rampsThe inclusion of these extensions is referenced from both the current version of the Building Code of Australia and the Disability (Access to Premises – Buildings) Standards 2010 (Premises Standards)

Handrail compliance is important, as it ensures the safety of everyone who’s using the stair or ramp especially those with an ambulant or vision impairment.

The requirements for handrail extensions were one point of concern, as the requirements posed a danger to those who were unfamiliar with the stair railing locations. This was especially true for those who were traveling on a transverse path.

The AS1428.1-2009 remedies this by including a provision for handrail extension ends to be setback either from the property boundary or a transverse path of travel. These provisions reduce the risk of injury, while ensuring that the railing is both accessible and practical.

Ambulant Toilets and Lightweight Toilet Partitions

Since the introduction of the premises standard we have included within our desktop assessments the following.

“Confirm proposed toilet partition can withstand a 1100N force as required by AS1428.1”

We have recently seen a number of projects when this issue as raised has not been addressed prior to ordering toilet partitions. Any deflection in the toilet partition will mean to ambulant toilet will be non compliant.

What does AS1428.1 say?

16.2 Grabrails
Grabrails shall be installed in accordance with Clause 17 and Figure 53(A).

17 GRABRAILS
Grabrails shall comply with the following:
(c) The fastenings and the materials and construction of grabrails shall be able to withstand a force of 1100 N applied at any position and in any direction without deformation or loosening or rotation of the fastenings or fittings.

Whilst 17(c) does not nominate partitions we would consider a partition that flexes on which a grabrails is installed also is not fit for purpose.

Tactile Ground Surface Indicators TGSIs Specifications & Compliance?

The endless complexities of the Standards continue.

Luminance Contrast Testing of Tactile Ground Surface Indicators to Kerb RampsI thought I’d post this after having discussions with numerous people regarding equipment and equations. Most people are getting this wrong. Please note that the Standard defines two (2) ways to calculate luminance contrast (Building elements – TGSI’s use the same equation) – most people are just using the Bowman-Sapolinski equation for building elements other than TGSI’s. This equation is ONLY usable for luminous reflectance values and should not be used with luminance values. Luminance values need to use the equation in B5.3 (e) of 1428.1 – 2009. Note that if TGSI’s are being tested then the Bowman-Sapolinski equation is used – another interesting contradiction between these two standards.

And now a little about equipment – if you’re looking at buying some equipment to test contrasts – do yourself a favour and buy a Photometer. In most cases, you will be testing in an on-site setting and this will be fine – note that if your testing TGSI’s then there is a set up that needs to be done. The biggest issue is the laboratory tests.

You cannot use the colorluminator, NCS or similar or any spectrophotometer. The reason for this is geometry.

The Standards state for laboratory tests the instrument must be

A tristimulus colorimeter or spectrophotometer with a diffuse illumination/normal viewing (d/o) geometry is used with CIE Standard Illuminant D65. The instrument has to be capable of measuring absolute CIE for Yxy to be calculated. The measured luminous reflectance is defined by the tristimulus value Y. The chromaticity coordinates x and y provide an indication of the colour.

The important thing to note is the (d/0) – this means a diffuse illumination (spherical dome illumination) with the receptor (measuring point) at 0 degrees.

Most of the equipment that people are using (Tristimulus Colorimeters – including the colorluminator) has a geometry of 45/0. This geometry does not meet the Standards and illuminates from 45degrees and measures from 0degrees. Even more so – there is NO spectrophotometer that has (d/0) – what IS available is diffuse illumination 6-8degree. It is also EXTREMELY important to understand specular component included or excluded. I.E. glossy surfaces will measure differently.

Another big question is – Who’s going to tell the CSIRO that their Gardner Gmbh colour Guide doesn’t meet the Standards??? It’s a spectrophotometer with 45/0.

Does the ME64 committee or Standards Australia actually understand what they are including in the standards and the liability & risks these irregularities will cause for specifiers, certifiers etc should an issue in the future go to court?

One more quick equation issue for you to think about. If you have a Dulux LRV value of 50 what is the required LRV’s to achieve the 30% – most people answer by saying 30% difference from the 50. If you review the table B1 you’ll notice that the lighter possible surface is actually 80% difference and the darker 50% difference. We must be careful with these equations.


 

Who is now prepared to sign off TGSI installations? As a practice, we currently will not support the use of Stainless Steel Tactile Ground Surface Indicators. We have also sought to get some guidance from the Victorian Building Commission.