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Emergency Egress for Occupants with Disability Regulatory Impact Statement

31/10/2014

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The Australian Building Codes Board (ABCB) has undertaken an Egress for All Occupants project since 2011. This was in response to the work preceding the release of the Disability (Access to Premises – Buildings) Standards 2010 and the concern expressed across a number of forums with regard to the provision of equitable and dignified egress for people with disabilities within the built environment.

Multiple areas of concern arise regarding various diagnoses and conditions and the ability to respond to the alarms and warnings currently provided within buildings in Australia, as well as being able to consequently evacuate safely. These especially prescient given the conditions which may arise within a building when evacuation is deemed necessary.

In May 2013, the Building Code of Australia (BCA) was amended to include some additional provisions in light of some of the shortfalls identified. These included a new Performance Requirement (DP7) intended to facilitate the use of lifts to evacuate occupants from buildings in addition to traditional exits. ‘Deemed to satisfy’ provisions had not been included to facilitate this change, however the possibility of developing suitable ‘alternative solutions’ arise and encourages diverse inputs from Fire and Structural Engineers, Architects and Designers, Certifiers as well as Access Consultants.

A number of ‘deemed to satisfy’ provisions were also included at the time attending to items such as the removal of thresholds at exit doors, the provision of a suitable handrail to stair and ramp exits serving accessible areas, suitable door furniture to exit doors, as well as the provision of tactile and Braille signage to identify exit doors.

Following on from this ABCB recently formulated five further proposed amendments to the BCA with a view to further enhancing emergency egress for people with disability. These are documented in a recently published Regulatory Impacts Statement (RIS) and include:

·        The provision of visual alarms where automatic smoke detection and alarm systems are required within the accessible parts of buildings;

·        The provision of tactile alarms (vibrating pillow alarms) to be provided in all bedrooms of Class 1b buildings (boarding house, hostel, etc.) and all sole occupancy units within Class 3 buildings (hotel, motel, residential part of a school, etc.);

·        The co-location of fire isolated exits with lifts;

·        The provision of accessible egress paths to and from an exit;

·        Enhancing the accessibility of fire isolated exits by providing additional features such as an additional handrail, tactile ground surface indicators to stairs and ramps, reducing door operating forces, and providing contrasting finishes between doors and their surrounding surfaces.

Class 1a (private dwellings) and 10 (non-habitable buildings e.g. garage) buildings have been excluded from the scope of the RIS and corresponding analysis.

The published RIS goes on to review the cost impact of implementing these measures with figures attached to the number of buildings which are anticipated to be affected as well as amounts against each class of building and the total cost anticipated for each proposal. Discussion regarding the sensitivity, possible error and discount rates applied is also included.

In analysing the benefits of the proposals, a high level of effectiveness is suggested with referenced reports regarding the effectiveness of vibrating alarms for example at 85% for sleeping occupants and the effectiveness of visual alarms to those awake at 80%-90%.

In discussing the monetary value of benefits in applying these proposals however, much effort was afforded to describing the difficulties in monetising ‘dignity’ and the benefit it may represent. Direct and indirect benefits such as potential increases in employment, participation in education, reduced carer costs, reductions in the need for people to live in supported forms of accommodation, reduction in community based services supporting people with disabilities, reduction of injuries as a result of falls within buildings, increased participation in tourism, greater housing and accommodation options; and of course a whole host of other possibilities unfortunately gain no mention at all.

At the time of writing this article the closing date for comment was fast approaching, however the RIS and the accompanying report detailing proposed amendment costs are available at the ABCB website. Hopefully the weight of submissions gained provide some balance to the analysis put forward in the RIS.

George Xinos
Functional Access Solutions

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