Carpet pile height is a particularly interesting area, and one that has been subject to a little confusion.
Australian Standard AS1428.1-2009 is referenced under both the Disability (Access to Premises – Buildings) Standards 2010 (Premises Standards) and the current Building Code of Australia (BCA). Carpet pile height is covered under Clause 7.4.1(a) of AS1428.1-2009, which requires carpet pile height or pile thickness not to exceed 6 mm and the carpet backing thickness not to exceed 4 mm. These dimensions are also reflected in Figure 8 of AS1428.1.
But, Clause D3.3(g) of the BCA states that Clause 7.4.1(a) of AS1428.1-2009 does not apply and states that ‘the pile height or pile thickness shall not exceed 11 mm and the carpet backing shall not exceed 4 mm’ . Also, Clause D3.3(h) of the BCA states that the carpet pile height or carpet pile thickness and the carpet backing thickness shown in Figure 8 of AS1428.1 are to be replaced with
11 mm and 4 mm respectively to be consistent with Clause D3.3(g).
The inconsistency between the Premises Standards and the BCA presents a dilemma for carpet selection – carpet with a 11 mm pile height or pile thickness will satisfy the BCA, but currently represents a non-compliance under the Premises Standards.
We are however aware of a proposed amendment to the Premises Standards that will align the 11 mm maximum pile height between the BCA and the Premises Standards. This was tabled with the Senate in late 2010, but at the time of writing this blog, the amendment has yet to be adopted. The proposed amendment (amongst other items) states that ‘industry research suggests there is little difference between the rolling resistance of 6 mm and 11 mm carpet’. For further information, refer to the link below:
http://www.comlaw.gov.au/Details/F2010L02539/Explanatory%20Statement/Text
Where there is inconsistency between Commonwealth law (Premises Standards) and State law (BCA, as reference under each State’s or Territory’s building regulations), Commonwealth law takes precedence. Therefore, at the moment, we still recommend compliance with the Premises Standard – carpet pile height or pile thickness not to exceed 6 mm and the thickness of carpet backing not to exceed 4 mm. Also, as compliance with the Premises Standards provides immunity against a compliant under the Disability Discrimination Act 1992 (DDA), this further emphasises the importance of satisfying the Premises Standards, whereas compliance with the BCA’s carpet provisions could be subject to complaint under Section 23 of the DDA (Access to premises).
It is important to verify that the carpet provisions under the Premises Standards are met when specifying carpet for any new building or alterations to existing buildings.
If you do require any further clarification of this blog please contact our office.
Equal Access Pty Ltd is one of Australia’s leading accredited disability access consultants and can also assist with questions regarding general building access requirements. We are registered with the Association of Consultants in Access Australia Inc. (ACAA) and provide a specialist consulting service throughout Australia to enhance the built environment and to provide ‘equal access’ for members of the community with a disability.
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