Welcome

Home Contact Information Bedroom Bathing Toilets (doc m) Showers Grab Rails Kitchens Out & About

Building regulations Part M: review of access and facilities for disabled people

Background to the executive summary
In May 2000 the Department invited views on the provisions that Part M of the Building Regulations makes for disabled people in buildings other than dwellings, and how they might be improved. We were interested in feedback particularly from disabled people on the operation of the current Part M. The responses, which are summarised in the attached report, will be used to assist in developing detailed proposals for revising Part M as it applies to buildings other than dwellings.

The Department will need to weigh the various views expressed in the report and cannot undertake that particular views or recommendations will be adopted, but there will be a further opportunity to comment, probably towards the end of this or early next year, on any proposed changes before they come into effect.

The executive summary

Introduction

Study aims
The study was undertaken for DETR between January 2000 and January 2001 by The Camden Consultancy, a grouping of independent consultants in the construction field. The overall aim of this study was to gather ideas to form the basis of a revised Part M through an initial consultation which would identify:

• aspects of the existing guidance that should be clarified;
• ways in which Part M could be extended to existing buildings;
• appropriate building features for which guidance should be included;
• and, where possible, quantify potential benefits, practical problems or regulatory burdens.

The study was also to consider the provisions of Part T of the Scottish Building Regulations and Part R of the Northern Ireland Building Regulations.

Outline of study method
The study used postal surveys and six seminars to gather ideas from building regulation users and disabled users of buildings (together with their organisations and companions). Two types of postal survey were used: 784 copies of one were sent to organisations and a few individuals known to have an interest in Part M of the regulations. 433 copies of the other was sent in response to requests, mainly to disabled people and groups representing disabled people. Different versions of the questionnaires were prepared for Scotland and Northern Ireland. A total of 408 responses (33.25 per cent) were received.

The questionnaire responses, and the 6,642 written comments, together with records of issues raised by the 161 people who attended the seminars, provide the data which were analysed to report the study findings. Conclusions were then drawn from these findings.

This summary deals briefly with the issues and findings and gives a short version of the conclusion drawn in italics at the end of each section.

General issues
Regulation of disabled access and facilities: 89 per cent of those who responded to the question thought that Part M (T&R) had been helpful and few thought that it should not continue in some form. Many respondents wanted close co-ordination with the Disability Discrimination Act. Others wanted better co-ordination with guidance on Planning, Fire safety and Staircases.

There were many suggestions for additions and improvements to Part M (T&R) which was often seen as being out of touch with current thinking. Most respondents, particularly disabled people and
their representatives, have very high expectations of the revision. Even the organisations that will design or have to pay for additional provisions are prepared for change. It is widely accepted that
from 2004 onward the DDA will bring in a new approach to meeting the needs of disabled people in buildings used by the public.

A revision of the Regulations in the next 2 years in parallel with BS 8300 (the revision of BS 5810) and the DDA code for the 2004 provisions will be timely and generally welcomed.

The requirement

Criticism of the requirement focused on two aspects: the word 'reasonable' and the way 'disabled people' is interpreted.

It was felt by many disabled people that requiring only 'reasonable' provision allowed developers and designers to .get away with less than a minimum standard of provision. Other words such as 'adequate', 'optimum' or 'best practice' were suggested. In Scotland the word 'adequate' is used rather than reasonable but the same criticism was levelled at 'adequate' by Scottish respondents.

There is a need for flexibility in these requirements, particularly if they are applied to existing buildings. 'Reasonable' has a recognised meaning in terms of building control and allows flexibility. Use of another word would not be a significant improvement.

Interpreting disabled people in terms of specific disabilities was not liked and there were strong objections to a question that suggested extending the requirement to other specified disabilities. It was said that the 'medical' rather than the 'social' model of disability had been adopted and that in future the Regulations should deal with the social model and concentrate on the barriers that buildings present rather than on the impairments of building users. It was pointed out that the
provisions in Part M benefited many able bodied building users as well as disabled people.

The requirement should be revised to deal with standards of access and convenient use. The interpretation of disabled people should be based on the DDA definition.

Existing buildings
Change of use: 82 per cent of respondents wanted Part M ( R) applied to changes of use, 15 per cent did not express an opinion and only 3 per cent did not want Part M applied. In Scotland Part Talready applied to change of use, so the question was not asked.

The difficulty here is that change of use in Part M is principally related to fire safety and use by the public is only recognised in 'public buildings' whereas the DDA will apply wherever goods and services are offered to the public. Respondents wanted to see a rationalisation of the planning and the building regulation changes of use or at least some redefinition of categories as in Scotland. However, any change in categories is a general issue for the Regulations and outside the scope of this study. Applying just Part M to all changes of use where the DDA would apply would considerably increase the load on building control.

Part M should apply to changes of use and its application should be taken into account when any new use categories are considered.

Material alterations: 77 per cent of respondents wanted Part M (R) applied to material alterations, 14 per cent did not express an opinion and 9 per cent did not want Part M applied. In Scotland Part T already applied to alterations, so the question was not asked.

A strict application of all minimum standards for all material changes of use does not make sense. Where floors are never likely to be accessible to wheelchairs there is no need to eliminate steps, widen doorways and provide accessible facilities but in many instances applying minimum standards to material alterations would be sensible and would greatly increase accessibility of the existing building stock. There are also cases where it would be sensible to widen doorways and leave space for facilities where, for instance, a passenger lift might be added later.

Part M should apply to material alteration work but a distinction should be made between floors that are accessible to wheelchairs, floors that could be made accessible and floors that are never
likely to be accessible.

Extensions: 64 per cent of respondents wanted Part M (T&R) applied to extensions with no entrance at ground floor level, 23 per cent did not express an opinion and 13 per cent did not want Part M applied. If the suggested application of Part M to material alterations is adopted there is no reason why a distinction should be made between extensions and material alterations.

Part M should apply to all extensions as if they were material alterations.

Reasonable application of minimum standards: From the comments on many questionnaires and from the seminars it is clear that judging what minimum standards it is 'reasonable' to require is a
key issue. Some respondents wanted the minimum standards to apply by prescription to all work covered by the Building Regulations many others suggested limiting requirements by building size, by use or by storey etc.

A clearer definition of what is reasonable and the involvement of disabled people themselves in advising on the reasonable application of standards to particular circumstances would be welcomed. Such a definition and consultation could apply to new construction as well as existing buildings. Many local authorities, particularly in Scotland do consult access groups on significant applications.

The meaning of 'reasonable' as applied to Part M should be spelt out either within the guidance or in instructions to local authorities and approved inspectors. Local authorities considering refusal
or relaxation should take account of criteria based on:
• use,
• consistency,
• practicality,
• best practice,
• proportionality with size and cost,
• effective reduction of barriers,
• safety,
• reversibility in historic buildings,
• provision for extension of accessibility in the future,
• value of innovation.

Local authorities and approved inspectors should be urged to consult local or national access organisations on significant applications and could be obliged to consult them in certain circumstances e.g. where no level access, passenger lift or accessible toilet is proposed.

Clarification of existing guidance

Respondents were asked about the relationship of Part M to other documents and about differences of interpretation of the Part M provisions.

• 35 per cent of respondents were aware of problems or confusion between Part M and other legislation (in particular the DDA, Planning legislation and fire safety requirements).
• 31 per cent of differences of interpretation of Part M (in particular ramps).
• 20 per cent found problems with the overlap between the ADs (in particular B and K).
• 20 per cent thought that disabled people's interests could be better served by controls or guidance not related to the Building Regulations (in particular the DDA and the revision of BS 5810).

There is a need to co-ordinate the guidance in DDA codes, A.Ds. B and K and BS 8300.
Explanatory cross references in Part M and in the other documents would be helpful.

Issues external to the building

Respondents to the questionnaire for organisations were asked for comments and suggested modifications to the provisions of Section 1 of Part M.

• 46 per cent wanted to see changes in guidance on principal entrance doors,
• 40 per cent on approach to the building,
• 33 per cent on revolving doors,
• 29 per cent on handrails,
• 28 per cent on entrance lobbies and
• 25 per cent on hazards on access routes.

The main issues suggested as requiring improved guidance included:

• Tactile paving (at top and foot of ramps and not to conflict with wheelchair use)
• Ramps (level access preferred, 1 in 12 too steep, passing places on long ramps)
• Handrails (contrasting colour)
• Entrance doors (to be wider and wherever possible to be automatic)
• Revolving doors (to be avoided)
• Lobbies (larger and to have transitional lighting)
• Hazards on access routes (bollards and street furniture to be better positioned).

New guidance was called for on:
• Paved surfaces (not cobbles or gravel)
• Parking and setting down places (level parking and setting down to be provided)
• Signage (to identify the building and its entrance)
• Automatic doors ( use when possible better guidance on operation and controls)
• Opening force to operate doors (limit to be stated)
• Ironmongery (guidance needed on easily operated door furniture)
• Reception spaces (guidance needed on layout, lighting and seating).

All the above issues should be considered for inclusion in a revised Part M.

Applicants could be required to state what measures they have taken to meet performance requirements, e.g. for parking and setting down, signage, door operation.

Circulation within the building

Respondents to the questionnaire for organisations were asked for comments and suggested modifications to the provisions of Section 2 of Part M.

• 46 per cent wanted to see changes in guidance on doors,
• 39 per cent on passenger lifts,
• 34 per cent on wheelchair stairlifts,
• 33 per cent on corridors,
• 27 per cent on platform lifts
• 26 per cent on internal stairs.

The issues suggested as requiring improved guidance included:
• Doors widths (including width of double door leaves
• Glazing in doors (dividing bars, height and width, correlation with standards)
• Corridor widths (including space to pass and manoeuvre)
• Obstructions (in corridors)
• Lobby dimensions (for different configurations)
• Passenger lift dimensions (larger lifts)
• Passenger lift controls (tactile buttons, position of controls, voice announcements)
• Stairlifts (uses, cntrols, dimensions)
• Platform lifts (uses, controls, dimensions)
• Tactile surfaces (top and bottom of stairs and ramps and in corridors)
• Internal stair dimensions
• Marking of stair nosings
• Stair handrails (tactile indicators).

New guidance was called for on:
• The weight of doors (force required to operate)
• Ironmongery (handles etc)
• Automatic doors (controls, warning of closing, entrapment of visually impaired persons)
• Colour contrast (of handles, of door and surrounding wall and in corridors, lift controls, handrails)
• Lighting (in corridors and on stairs)
• Signage (for accessible exits, facilities, and wayfinding)
• Sliding doors (operation, space requirements)
• Lifts for emergency evacuation (use, suitable phones)
• Floor surfaces (soft carpets, slippery surfaces, ribbed stair treads).

Most the above issues should be considered for inclusion in a revised Part M.

Applicants could be required to state what measures they have taken to meet performance requirements, e.g. for colour contrast, lighting and signage.

Facilities in buildings

Several questions were asked about issues in Parts 3,4 and 5 of Part M and the equivalents in Scotland and N. Ireland. (The percentages here relate to the questionnaire that went to organisations
unless otherwise stated.)

• Wheelchair accessible toilets: 51 per cent wanted changes in guidance.
• Ambulant user's toilets: 30 per cent wanted changes in guidance (47 per cent of respondents to the
questionnaire for individuals said Yes when asked whether they would like to see other provisions included for either type of toilet) (e.g. more provision and close conformity with revised standards in
BS 8300)
• Changing facilities: 34 per cent wanted changes in guidance (e.g. specific requirement for more building types)
• Aids to communication: 38 per cent wanted changes in guidance (e.g. suiting systems to spaces)
• Spectator seating: 41 per cent wanted changes in guidance (e.g. more choice of seating ).

These provisions should be reviewed in the light of comments and the revision of BS 3800.

Performance standards and guidance should be considered for bathrooms,, rest areas, seating, switches and controls.

Application to different building types

39 per cent of the respondents to the questionnaire that went to organisations wanted changes in guidance on restaurants and bars (e.g. more floor area accessible). 42 per cent wanted changes in
guidance on hotel and motel bedrooms (e.g. more provision and choice of location).

Respondents were asked to suggest other buildings to which the provisions in Part M should apply.
Travel interchanges, hospitals, clinics, health centres, churches and crematoria were suggested, and elsewhere schools, open auditoria, small spectator events and visitors centres were mentioned.

The hotel and restaurant provisions should be reviewed in the light of comments and the revision of BS 8300.

Widening the application of the regulation could increase accessibility and the coordination for the DDA and Building regulations but may only be feasible when the application of other Parts of the Regulations is also widened.

Scotland and Northern Ireland

Scotland
Some of the conclusions of this study do not apply to Scotland because the regulations have now been dispersed throughout the Scottish Standards and Deemed to Satisfy (dts) Provisions. This
change has been accepted by the majority of Scottish respondents. The regulations already apply to existing buildings in Scotland. However the definition of disability and the dts guidance from
Disability Scotland (which is less detailed than Part M ) are now seen by some Scottish respondents to be out of date. Additions to the dts references could be considered.

The dispersed regulations should be retained.

The definition of disability should be reconsidered.

The deemed to satisfy document from Disability Scotland needs to be revised and expanded.

Northern Ireland
The Northern Ireland Regulations and the Technical Booklet for Part R are much closer to Part M than the Scottish Regulations. The conclusions of this executive summary could apply equally to
part R. However different terminology, the illustrations of application to existing buildings and anti-discrimination legislation will all have to be taken into account.

The conclusions for Part M should be rephrased to suit Northern Ireland and applied to Part R.

Benefits and costs
Many respondents pointed out that the benefits of the Part M provisions would be shared by other building users; in some cases (e.g. passenger lifts) by virtually all users of upper and lower floors
and in others by a particular categories of user (e.g. mothers with small children). The benefits should increase the efficiency and postpone the obsolescence of the building stock with an added value being reflected in increased rents.

Some of the measures suggested for inclusion (e.g. colour contrast, floor surfaces) would have virtually no cost implication. However the measures that provide access for wheelchair users to buildings are costly, particularly level parking, level access, passenger lifts and accessible toilets.
Lifts and automatic doors have the added penalty of high maintenance costs. Extending these provisions to all non-domestic refurbishment projects will have major cost implications - but also major benefits.

There will be additional work for building control, particularly if more consultation with access groups etc is involved (although consultation on significant developments is already routine in many areas). The cost of training staff, checking plans and extending inspections will need to be covered by building control fees.

The linking of the DDA Codes to the Building Regulations should also be taken into account.
Bringing new provisions into Part M (T & R) will mean that they can also be required wherever the DDA applies, whether or not building work is being carried out (e.g. handrails on both sides of existing stairs, wheelchair accessible controls in existing lifts). These items may not come under building control but could apply because they would be a requirement of the regulations if a new stair or lift was being installed. Costs brought in by this route will be hard to estimate.

For a true picture of benefits and costs, the benefits to all building users and the costs of extra work under the DDA should be taken into account.

Form of publication

Form of publication: Respondents were asked whether the guidance in Part M (R) should be dispersed to other related sections as has been done in the fifth amendment to the Scottish Regulations. Opinion was divided but the majority favoured a single booklet and more cross
referencing to other sections - some saying that the time was not yet right for dispersal and that it would be easier to promote the necessary awareness of any new provisions with a single booklet.
Those in favour of dispersal felt that a single booklet gave the wrong message by treating disabled people as a distinct group. Complete dispersal of Part M provisions would not be easy as there is no
natural home in the current Regulations for such issues as hotel bedrooms and spectator seating.

The benefits of a single booklet for the forthcoming revision outweigh those of dispersal but in the longer term dispersal should be foreseen. Part M could have separate sections on 'access' and
'facilities'. The 'access' section could then be integrated with Part K in a later revision.

Other issues

Increasing awareness
There are several issues affecting disabled people that should be considered and acted on when designing buildings but where guidance on minimum standards does not seem entirely appropriate.
Communication systems and signage are examples. In both these areas Building Control will find it difficult to ensure that appropriate measures are adopted. In both cases there are several options and
small differences in the use, size or furnishing of spaces will tip the balance in the choice of system.
Building control need to ensure that applicants are aware of the issues and have followed best practice advice. Building control should be able to ask for an applicant's statement saying how such issues were to be dealt with. If the response was not satisfactory, Building control could ask for fuller details and seek advice on responses from experts and disabled people's organisations.
Training for designers at both student and practitioner level is essential and should be a principal objective of access groups and organisations representing disabled people with incentives for
training and execution of projects.

For new buildings, changes of use and extensive alterations applicants should be asked for statements on the provision of appropriate measures for communication systems, signage, colour
contrast, lighting, rest areas and seating.

Performance criteria and reference to advice on best current practice for these and other issues should be included in the AD for Part M.

Enforcement
In response to several questions there were comments on the lack of effective enforcement of Part M. The issue was also discussed at seminars where the related issues of 'disabled access in the
design process' and of 'pre-application consultation' were raised.

The recommendations in this report that extend the provisions of Part M will increase the problems of enforcement. Final decisions on several aspects of disabled access are commonly made at a late
stage in design and even towards the end of the construction process. It is difficult to control such things as ironmongery, lighting, colour contrast and the surface of external paths through the plans
approval system. If designer were to submit statements on how they intended to meet the guidance at plans submission stage, besides alerting the designers it might be easier to pick up omissions
during inspections and to have them put right if the original intentions had not been followed.

Designer's statements on appropriate measures should be used to make enforcement more effective (see under 'increasing awareness')

Management
The importance of management was emphasised by several respondents and at the seminars. For some provisions to be fully effective staff need to be trained and management procedures adopted.
The relationship between building regulation provisions and management is an issue that goes beyond Part M and applies to B, F, L, etc. In each case there is information available to the
designer which needs to be passed on to the people responsible for cleaning, maintenance repair and refurbishment.