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TABLE OF CONTENTS
INTRODUCTION ............................................................................................................... 3
EXECUTIVE SUMMARY ..................................................................................................... 4
BACKGROUND TO THE NCC .............................................................................................. 6
Building Regulations ............................................................................................... 6
The Australian Building Codes Board .................................................................. 6
The National Construction Code ........................................................................... 7
BACKGROUND TO ACCESS AND EGRESS FOR PEOPLE WITH DISABILITY........................... 11
The Disability Discrimination Act 1992 ............................................................... 11
Disability Egress .................................................................................................... 14
EGRESS AMENDMENTS & PROPOSALS ........................................................................... 19
D-t-S Amendments to BCA 2013 .......................................................................... 19
Proposed D-t-S Amendments for NCC 2015 ...................................................... 20
Proposals for Active Systems.............................................................................. 21
Proposals for Passive Systems ........................................................................... 26
Table 1. Summary of the intent of Proposed Changes to Achieve the
Objectives of Proposals 3 & 4. ............................................................................. 32
FUTURE PROPOSALS ...................................................................................................... 40
Considerations on a Future Model for Refuges ................................................ 42
OPPORTUNITIES FOR INVOLVEMENT ............................................................................. 45
Timeframes for Amendments ............................................................................... 45
APPENDIX A BCA 2013 CLASSIFICATIONS ....................................................... 46
APPENDIX B BUILDING EVACUATION ............................................................... 48
Strategies ................................................................................................................ 48
APPENDIX C D3 BUILDING ACCESS REQUIREMENTS.................................... 50
EXECUTIVE SUMMARY
INTRODUCTION
EXECUTIVE SUMMARY
EXECUTIVE SUMMARY
The Australian Government's Disability Discrimination Act 1992 (DDA) has been
in effect since March 1993. The DDA prohibits discrimination against people with
disability or their associates in a range of areas including transport, education,
employment, accommodation and premises used by the public.
The DDA is complaints-based (as opposed to compliance-based) legislation. It
does not include legislative or regulatory guidance as to the specific steps that
must be taken to ensure compliance with the general duties in relation to access
to premises.
Concern with the lack of certainty regarding practical compliance obligations
under the DDA led to amendments to Section 31 of the DDA, which came into
effect in April 2000, to allow the Australian Governments Attorney-General to
formulate Disability Standards in relation to access to premises.
With this change in 2000 came the need to review the BCA access provisions.
The need for change also stemmed from:
recognition that the technical requirements of the BCA were not considered to
meet the intent and objectives of the DDA; and
the potential for inconsistencies between two legislative requirements
regulating access for people with disability to buildings, being the DDA and
through State and Territory building law, the BCA.
The Australian Building Codes Board (ABCB) was requested by the Australian
Government to develop proposals for a revised BCA, to enable it to form the
basis of draft Premises Standards. Once the Premises Standards had been
formulated, the BCA would be amended so that the technical details of each
document mirror each other. Therefore, compliance with State and Territory
building law and the access provisions of the BCA would mean compliance with
the Premises Standards and the DDA.
Prior to the development of the Premises Standards, the ABCB undertook work
towards a national approach to access to buildings for people with disability
through a discussion paper and technical proposal RD097/01. These proposals
included some egress provisions in the form of enhanced emergency notification
and accessible evacuation refuge areas as a means of providing protection from
the effects of fire. Comments received in response to these initial egress
proposals were polarised with some suggesting refuges were less preferable and
equitable than alternatives such as suitably designed lifts. While lifts were seen
as a desirable solution for emergency egress needs, it was acknowledged that
solutions were either not currently available or were under-developed.
4
EXECUTIVE SUMMARY
In 2000, the ABCB established the Building Access Policy Committee (BAPC) to
recommend changes to the BCA, to consult widely with industry and the
community and to provide advice to the ABCB on access-related issues.
Through the BAPC and its Technical Working Group, draft Premises Standards
were developed, and recognising the need for technical solutions for egress, the
BAPC recommended that the ABCB continue research in the area of egress for
all occupants.
Research commissioned by the ABCB in 2005 on optimal strategies for the
evacuation of people with disability highlighted the difficulties faced by people
with mobility impairment when using stairs. This research also highlighted that
any Deemed-to-Satisfy (D-t-S) Provisions were likely to be very complex
considering the numerous building, system and configuration scenarios.
The Access to Premises Standards were launched in 2010 and central to
matters not covered by the Standards was emergency egress for people with
disability. In recognition of the needs of people with disability and the complexity
of potential solutions, the ABCB were tasked with the identification of D-t-S
provisions as soon as possible.
The ABCB adopted a strategy to include amendments to D-t-S Provisions
incrementally, and the development of a non-regulatory handbook for lifts used in
evacuation. This was in recognition of the limitations of the BCA in applying
management practices, the finalisation of the Premises Standards and little
international progress towards solutions involving lifts in emergencies. In
accordance with this incremental strategy, changes proposed in this Directions
Report build upon improvements to the accessibility of egress paths which were
included in National Construction Code (NCC) 2013 Volume One. The future
regulatory proposals outlined in this report are intended to be included in NCC
2015 and include:
Each State and Territory has building control legislation including Building Acts and
Regulations that reference the NCC.
While State and Territory governments may include minor variations to the NCC in
their legislation and different criteria or triggers for how they apply it to existing
buildings, essentially the NCC applies to:
the proposals would generate benefits to society greater than the costs (that is,
net benefits);
the competitive effects of the regulation have been considered and the regulation
is no more restrictive than necessary in the public interest.
adapted to be used. As the purpose of buildings varies, the BCA applies different
requirements for different classes of buildings.
BCA Deemed-to-Satisfy Provisions
The Deemed-to-Satisfy (D-t-S) Provisions provide solutions that are common
prescriptive methods of meeting the Performance Requirements. As Performance
Requirements are applied generally and in some cases limited in their application
(e.g. to particular classifications) so are the D-t-S Provisions, which may be general,
specific or exclusive as triggered by the characteristics of the building and the
number and characteristics of the occupants. Therefore these factors influence the
scope of the D-t-S fire safety systems that are to be installed. A fire safety system
means one or any combination of the methods used in a building to
warn people of an emergency; or
provide for safe evacuation; or
restrict the spread of fire; or
extinguish a fire,
and includes both active and passive systems. 1
The Guide to BCA Volume One lists some examples of active and passive fire
safety systems as follows:
Passive systems
Active systems
BCA Classifications
The BCA classification system broadly categorises buildings into 20 building classes
and sub-classes (see Appendix A) and uses this as a means of minimising occupant
1
Australian Building Codes Board, Building Code of Australia Volume One (2013), A1.1 pg. 27
risk associated with a buildings use. It has been described as the gateway to the
BCA and classes are often used as a means to differentiate which Performance
Requirements and D-t-S Provisions apply to the design and construction of a
building.
BCA Structure
BCA Volume One is divided into Sections and Parts that contain both the mandatory
Performance Requirements, Verification Methods for assessing Alternative
Solutions, D-t-S Provisions and in some cases Specifications. While these are
interrelated, each Part has a particular focus and is prefaced by Objectives,
Functional Statements and mandatory Performance Requirements.
The Sections of the BCA that contain the majority of requirements relating to fire
safety systems and occupant egress are:
Below is a brief description of the role these Sections play in providing safety from
fire.
Section C Fire Resistance
The requirements of Section C relate primarily to the passive fire resistance of a
building structure and prescribe maximum fire compartment sizes and the protection
of openings. These elements are crucial in providing the necessary level of
separation to prevent the spread of fire, contain its effects and in turn reduce
occupants exposure, while maximising the time and opportunity for evacuation in an
emergency.
9
10
International Declarations such as the 1975 Declaration on the Rights of People with
a Disability, to which Australia was a signatory, was symbolic of a growing
international awareness of rights of people with a disability. This also served to
underpin need for federal legislation to replace a patchwork of State and Territory
Discrimination Acts and also improve coverage to include federal government
employees. 2
The DDA which was introduced in 1992, has been in effect since 1993 and is
complaints based legislation, whereby individual complaints are the main means of
effecting a change. The DDA could be seen as reactive in nature, but also aims to
influence community attitudes and behaviour through its objectives and the setting
of a series of standards, including:
to ensure that as far as practicable, persons with a disability have the same
rights before the law as the rest of the community; and
to promote recognition and acceptance within the community of the principle that
persons with disabilities have the same fundamental rights as the rest of the
community.
Concern with the lack of certainty regarding practical compliance obligations under
the DDA led to amendments to Section 31 of the DDA, which came into effect in
April 2000, to allow the Australian Governments Attorney-General to formulate
Disability Standards in relation to access to premises.
With this change in 2000 came the need to review the BCA access provisions. The
need for change also stemmed from:
recognition that the technical requirements of the BCA were not considered to
meet the intent and objectives of the DDA; and
11
The ABCB was requested by the Australian Government to develop proposals for a
revised BCA, to enable it to form the basis of draft Premises Standards. In 2000, the
ABCB established the BAPC to recommend changes to the BCA, to consult widely
with industry and the community and to provide advice to the ABCB on accessrelated issues.
The BAPC consisted of representatives of key stakeholders including the AttorneyGenerals Department, the Human Rights and Equal Opportunity Commission,
disability groups and industry.
Disability (Access to Premises - Building) Standards
Through the BAPC and its Technical Working Group, draft Premises Standards
were developed with wide stakeholder input. A negotiated set of proposals were
produced for public comment in 2004. The documents underwent a period of
extensive public consultation and were finally considered by the House of
Representatives Standing Committee on Legal and Constitutional Affairs (HRSC).
The HRSC sought submissions to allow it to consider, and report on, the
appropriateness and effectiveness of the draft Premises Standards in:
A series of public hearings were conducted by the HRSC where evidence was heard
from people with disability, advocates, representatives of government agencies,
business and industry and this resulted in a report titled Access All Areas (2009).
The report contained 19 recommendations relating to the scope of the Premises
Standards, possible concessions and exemptions and where these should apply,
clarification of specific provisions, matters still to be addressed and their
implementation and review.
Significantly, the report recommended:
that the Premises Standards be introduced without delay. Any issues
which cannot be finalised without causing delay should be considered at a
later date. 3
This recommendation acknowledged that there were matters that would not be
finalised in time for inclusion in the Premises Standards. These matters are
discussed in more detail in Chapter 6 of the Access all Areas report.
12
Central to those matters not covered by the draft Premises Standards was egress
for people with disability. The HRSC heard submissions from people with disability
on the inadequacy of existing emergency egress requirements which impinged on
their dignity and their ability to work safely. 4
The HRSC concluded that the BCA requirements for emergency egress fall short
of ensuring the safety and dignity of people with a disability. These deficiencies must
be rectified as soon as possible. 5
Specific matters that were considered by the HRSC included fire stairs, lifts, visual
and other alerts and places of rescue assistance. These are discussed in Section 6
of the Access all Areas report, which recommends:
Recommendation 16
The Committee recommends that the Australian Building Codes Board
undertake further research to identify deemed-to-satisfy Provisions for
emergency egress for people with a disability with a view to making changes
to the Building Code as soon as possible.
The Australian Government, in response to the report, accepted many of the
recommendations either in full or in principle, and undertook to deal with other
HRSC recommendations as far as possible without causing delay in order to bring
the Premises Standards to fruition. The Premises Standards were launched on 15
March 2010.
4
5
13
Disability Egress
Prior to the development of the Premises Standards, the ABCB undertook work
towards a national approach to access to buildings for people with disability. An
ABCB Discussion Paper and Regulation Document RD97/01 titled Provisions for
People With Disabilities were released in 1998 to consult on proposals for changes
to the BCA.
RD097/01 proposed provisions to enhance both access and egress for people with
disability, but significantly proposals for egress were limited to emergency
notification and accessible evacuation refuge areas. It recognised that occupants
who were unable to use exit stairways required assistance to evacuate and
proposed provisions requiring places of refuge utilising lift lobbies or toilet blocks.
These were designed specifically to provide separation from the effects of fire and
smoke and intended to be used temporarily while occupants awaited assistance to
evacuate.
Feedback received on the Discussion Paper and RD97/01 revealed polarised views
on the refuge proposals. Some viewed the move to provide these areas as a
positive step, and others suggested that this approach was less equitable than
alternatives such as suitably designed lifts. A number of assumptions were also
challenged through the subsequent Regulation Impact Statement, which concluded
that the provision of emergency evacuation would not significantly contribute to
participation in socioeconomic activities such as employment, recreation, tourism
and education.
Despite attempts to address egress through the Premises Standards, the BAPC
acknowledged that solutions were either not currently available or were underdeveloped. It requested the ABCB to review international research and if necessary,
undertake additional research in the area of egress for all occupants.
Research
In order to progress this objective, a three stage research program was proposed:
Stage One: To develop context and alternatives;
Stage Two: To consider and refine preferred options; and
Stage Three: To develop D-t-S Provisions.
Research was undertaken as part of Stage One to analyse the various egress
strategies available for occupants with disability in a building, which took into
consideration aspects of occupant warning, path identification and egress. While the
research discussed the need for amendments to also cater for people with hearing
and vision impairments, the main findings of this study related to the barriers to
emergency egress for people with a mobility disability, in particular the inability to
independently manoeuvre when using stairs.
14
The research noted that the practicality of alternatives diminished in tall buildings
and examined the potential for people with disability to either independently, or with
assistance from fire wardens or assistants, use a fire-isolated stair. It was
acknowledged that this approach and other similar strategies failed to address the
dignity and equity issues the DDA seeks to influence.
The research suggested a more accessible and dignified option would be to provide
evacuation lifts that are specifically designed to operate under fire conditions.
However, the research acknowledged that evacuation lifts were more expensive to
install, support and maintain as well as requiring more resources to operate
effectively during an emergency. In addition, they had not been fully tried and tested
at that time. 6 Noteworthy disadvantages of a solution incorporating a lift or liftrefuge strategy were listed as:
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities, 2004 Prepared for the
Australian Building Codes Board.
7
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004 Prepared for the
Australian Building Codes Board - 7.2.1
15
Recent Developments
Further to the recommendations of the HRSC, the ABCB convened an Emergency
Egress Forum in 2011 to seek opinions on proposals to improve egress for all
occupants. The Forum was attended by representatives from industry, government
and the disability sector. This Forum and advice from the Commonwealth Attorney
Generals Department supported changes to the BCA being undertaken
progressively, rather than waiting until research and analysis on all aspects had
been completed. This incremental approach is considered to be consistent with the
Australian Governments response to the HRSC Recommendation 16 to make
changes to the BCA as soon as possible.
In examining international approaches, the ABCB found that little had been achieved
in the development of prescriptive egress solutions. The International Building Code
(IBC 2009), a model code used in the USA, had introduced requirements that, under
specified conditions, allowed the use of lifts for evacuation in large buildings (over
128 m in height) in lieu of an additional exit stairway. However, the UK had adopted
a risk management approach and provided guidance on the design, management
and use of lifts through a British Standard BS 9999 that supported the notion that life
safety is reliant on effective management and trained personnel (BS 9999 p.3).
Strategy
While there had been some developments internationally, it appeared there was a
reluctance to mandate the use of lifts for egress, and awaiting developments was no
longer considered a sustainable approach. Therefore, the ABCB has adopted a
strategy that includes amendments to D-t-S Provisions being considered
incrementally, and the development of a non-regulatory handbook for lifts used in
evacuation. A non-mandatory handbook is also considered more able to address
building management procedures, roles and responsibilities and building specific
considerations, which are unsuitable for inclusion in the BCA.
Use of Lifts
The BCA has specific exemptions for certain small buildings from the need to install
a passenger lift. 8 However, in taller buildings where access is required to a level
other than an entry level, passenger lifts are often seen as the most practical means
of entering and exiting a building under normal conditions.
Conventionally designed lifts are considered unsuitable for use as a means of
evacuation to reach a point of safety in the event of a fire (a key objective of the
BCA). A number of factors may affect the operation of lifts and their controls
including, but not limited to the effects of fire (heat/smoke/flame) and fire fighter use
8
Australian Building Codes Board, Building Code of Australia (BCA) Volume One (2013), D3.3 (f) p.222
16
during fire response operations. Lifts may also be unavailable for use due to
decommissioning for maintenance, or the waiting times for a lift may be
unacceptably long when used for simultaneous evacuation.
Therefore, the BCA requires the installation of signs warning occupants not to use
lifts in the event of a fire. This is consistent with a long established policy both in
Australia and internationally. This also applies to what the BCA terms an
emergency lift which is for use by emergency services personnel.
Building emergency evacuation practices and emergency plans also reflect this
practice through training or direction from wardens. This has also conditioned
occupants to opt for means of egress other than lifts such as fire stairways or
horizontal exits (see appendix B) in an emergency.
The ABCB recognises that potential technical solutions using lifts for evacuation are
complex, reliant on building management practices and their suitability may be
influenced by human behavioural factors. However, lifts offer obvious accessibility
advantages over other options for people with disability.
Performance Requirement DP7
In 2013, Performance Requirement DP7 was included in the BCA to ensure
appropriate consideration is given to an Alternative Solution that involves using a lift
for evacuation. DP7 states:
Where a lift is intended to be used in addition to the required exits to assist
occupants to evacuate a building safely, the type, number, location and fire-isolation
must be appropriate to
(a) the travel distance to the lift; and
(b) the number, mobility and other characteristics of occupants; and
(c) the function or use of the building; and
(d) the number of storeys connected by the lift; and
(e) the fire safety system installed in the building; and
(f) the waiting time, travel time and capacity of the lift; and
(g) the reliability and availability of the lift; and
(h) the emergency procedures for the building.
DP7 lists those issues that must be considered when using a lift for evacuation in
addition to the existing required exits (used for egress) as a means of assisting in
the evacuation of all building occupants. As buildings get higher, the occupants
needing assistance will not only be people with disability but people with a health
17
condition or temporary injury, pregnancy, who are obese or who are managing small
children.
DP7 (a) to (c) require similar consideration to that required by DP4, but are
additional specific requirements where a lift is proposed to assist in evacuation.
The intent of DP7 (e) to (h) is to ensure a high level of safety and engineering
reliability in a solution that includes a lift. DP7 also requires that appropriate
consideration be given to a lifts interaction with other fire safety systems of the
building, and building evacuation procedures under evacuation conditions.
An ABCB handbook Lifts Used During Evacuation has been developed to aid
designers and regulators when developing or assessing an Alternative Solution
using lifts as a means of egress. Matters that need to be addressed to achieve
compliance with DP7 include:
18
As the first stage of amendments to enhance the egress provisions for all
occupants, the ABCB undertook development and consultation on changes that
were considered to be logical first steps in improving the accessibility of building
exits, for inclusion in BCA 2013.
D2.21 Door handles in the path of travel to an exit
19
20
PROPOSAL ONE
The Problem
The BCA, through referenced technical standards, includes provisions for
arrangement and control of automatic smoke detection and alarm systems or
occupant warning systems. These rely on audial signals produced by sounders or
21
PROPOSAL ONE
amplified sound systems which are required to be 10 decibels (dB) higher than
ambient noise levels and not less than 65dB(A). 10 The use of other warning signals
such as visual and tactile signals is not mandatory except where the specific
installation requires background noise greater than 95dB(A) to be overcome. For
occupants with a hearing impairment, these audial cues may be inappropriate or
insufficient.
Objectives of the Proposal
The proposed changes are intended to assist those with a hearing impairment to
receive adequate warning at the same time as other occupants. The proposal would
apply in buildings required to be accessible which require alarm systems and
intercom systems. The arrangement of these systems in common areas (not soleoccupancy units) would be broadly consistent with the requirements of the Disability
Standards for Accessible Public Transport.
Proposed BCA Wording
Note: To illustrate proposed changes, where new text is proposed for inclusion in
the BCA underline blue is used. Where text is proposed for removal from the BCA
red text with a line struck through (strikethrough) is used.
EP4.3
To warn occupants of an emergency and assist evacuation of a building, an
sound alarm system and intercom system for emergency purposes must be
provided, to the degree necessary, appropriate to
(a) the floor areas of the building; and
(b) the function or use of the buildings; and
(c) the height of the building.
Specification E2.2a Smoke Detection and Alarm Warning System
3. Smoke Alarm System
(a) A smoke alarm system must
(i)
consist of smoke alarms complying with AS 3786; and
(ii)
be powered from the consumers mains source; and
(iii)
In a Class 3 sole-occupancy unit required to be accessible, the alarm
system must also provide visual and tactile warning to building
occupants in accordance with AS 1603.17.
6. Building occupant warning system
10
SAI Global, AS 1670.1 : Fire Detection Warning Control and Intercom systems Design, Installation and
Commissioning (2004), Clause 3.22 p.27.
22
PROPOSAL ONE
23
PROPOSAL ONE
http://www.wadeaf.org.au/media/docs/Providing_accessible_services_brochure2006.pdf
Australian Deafness Forum, Draft Disability (Access to Premises Building) Standards (2008).
13
Australian Deafness Forum, Position Statement on ACCESSIBLE ACCOMMODATION, reviewed 15
October 2012.
14
Australian Deafness Forum, Position Statement on COMMUNICATIONS AND INFORMATION ACCESS IN
THE BUILT ENVIRONMENT, reviewed 15 October 2012.
12
24
PROPOSAL ONE
Figure 2 Example of a lithium battery powered visual and vibrating alarm. Picture Courtesy of the Deaf Society of NSW
25
PROPOSAL TWO
more than two consecutive storeys (a third may be permitted under specified
conditions) in a Class 3, 5, 6, 7, 8 and 9 building; or
2 consecutive storeys in a Class 2 building.
PROPOSAL TWO
15
Department for Communities and Local Government Eland House (London), The adequacy of refuges,
escape stairs and management procedures (2008), p.15
27
PROPOSAL TWO
Lincoln Scott, Using Lifts for Evacuation of People with Disabilities (2003), prepared for the Victorian
Building Commission.
17
NFPA, Life safety code provisions and its impact on emergency egress behaviour of people during fires
(2008).
28
PROPOSAL TWO
For example, the UK building regulations provide for the location of the lift shaft
within the enclosure of a protected stairway for the purposes of fire separation from
the remainder of the storey 18. Guidance on the use of evacuation lifts and refuge
areas is also provided through BS 9999 : 2008 Annex G (superseding BS 5588-8 :
1999). This standard provides options, details and figures for location of lifts and
refuges. While not mandatory, the standard suggests where evacuation lifts are
provided, that they be associated with a refuge and located close to a protected
stairway.
In specified instances, the USA International Building Code requires at least one
accessible means of egress be in the form of an elevator that is designed to ensure
emergency operation and be directly accessible from either a refuge or a horizontal
exit. Where refuges are utilised, these need to provide access to an elevator or an
accessible stairway. However, in order for a stairway to be considered accessible,
the stairway needs to incorporate a refuge or be accessible from a refuge.
Therefore, efficiencies may dictate that refuges are designed to adjoin, or be
accessible from stairways that also provide access to an elevator.
While international regulations consider the location of refuges associated with an
exit, refuges are not associated with this proposal and are explored as a potential
future regulatory proposal in this report.
This proposal tests the role and importance of intuitive building design in the location
of a place of safety forming part of the every-day building circulation space. It has
been suggested, in proposing enhancements to building egress requirements, it is
easier to design a building with evacuation lifts in the normal circulation paths19.
However, the proposal is considered an effective means of providing a suitable exit,
or place of relative safety (suitably designed lift, refuge or accessible exit
stairway/ramp or horizontal exit) which can be located through wayfinding.
18
UK Building Regulations, Approved Document B Volume Two Buildings Other than Dwelling Houses
(2010), Clause 5.42.
19
W Bretherton, Everybody Out Emergency Evacuation for Persons with a Disability (2003) p. 62.
29
PROPOSAL THREE
paths of travel to an exit do not require turning spaces and circulation space at
doorways to allow their use by occupants in a wheelchair
luminance contrast of doors and doorframes with adjacent walls may not be
sufficient to enable an occupant with vision impairment to identify an exit
exit door controls may impede the egress of occupants with gripping impairments.
PROPOSAL THREE
The BCA requires a minimum exit width for a path of travel to a required exit
(excluding doorways) of 1 m. Additional exit width is required in certain
circumstances due to the use of the building and the number and characteristics of
occupants. This dimension is consistent with the minimum required for accessibility.
However, accessways require additional circulation space at doorways and at
changes in direction greater than 60 degrees, luminance contrast between doors and
doorframes and adjacent walls and limitations on opening forces.
Turning Spaces
A corridor serving an exit is not required to accommodate room for wheelchairs to
turn. Consequently, occupants in wheelchairs may be forced to retrace their journey
in reverse when faced with an obstruction potentially delaying their own egress or
that of others.
Objectives of the proposal
The objective of the amendments is to improve the accessibility of exits and paths of
travel to exits to places of safety for all occupants. Specific changes to the BCA text
have not been developed for these proposals. Instead, Table 1 below contains a
summary of the intent of proposed changes to egress elements for Proposals 3 and
4.
31
PROPOSAL THREE
Table 1. Summary of the Intent of Proposed Changes to Achieve the Objectives of Proposals 3 & 4.
Egress element
No additional requirements
No additional requirements
No additional requirements
No additional requirements
D2.15(c)
Fire-isolated stairway
Fire-isolated ramp
Fire-isolated passageway
No additional requirements
D1.7(b)(B)
PROPOSAL THREE
Discussion
Turning Spaces on Paths of Travel to an Exit
The BCA requires passing and turning spaces at 20 m intervals on those parts of an
accessway where a direct line of sight is not available; or within 2m of the end of an
accessway, where it is not possible to continue along the path. This requirement
recognises that it is not appropriate to require a person in a wheelchair to reverse
over long distances.
Despite long unbroken corridors being relatively uncommon in designs, the ABCB
Access RIS assessed the provision of passing and turning spaces in buildings for
accessibility as being a proposal which would have a moderate impact. 20 This was
due to the range of buildings that the requirements would apply. It might be
assumed that the effect of requiring the installation of these spaces for access would
have diminished to a large extent the number of potential instances where these
would be required for egress purposes.
Accessways
Designing a path of travel to an exit as an accessway requires compliance with AS
1428.1 requirements for door opening forces, circulation space at doorways,
luminance contrast of doors and restrictions on the use of steps in paths of travel.
The requirement is intended to prevent features which might impede the egress of
occupants with disability in paths of travel from areas required to be accessible, and
upon discharging from an exit, on the route to open space. An increase in initial
construction costs is anticipated for this proposal associated with:
the additional materials required for an accessible ramp, or a step ramp in lieu of
providing a landing served by steps; and
increases in door widths, circulation space.;
However, the degree costs will be increased will depend on the number of exits in a
building, and the slope of the site. It is important to note that most buildings will
require at least one accessible entrance to be provided, so for these entrances
(exits) there will be no associated cost increases. Impacts would be limited to fireisolated passageways, fire-isolated ramps used as required exits and the route from
required exits which do not discharge directly to open space.
Doors and Circulation Space
The increases in widths at doorways and circulation spaces in order to provide
access for people with disability would have captured some doorways in the path of
20
Australian Building Codes Board, Final Regulation Impact Statement for Decision (RIS2009-05) Proposal to
Formulate Disability (Access to Premises Buildings) Standards and Amend the Access Provisions of the
Building Code of Australia ( RIS 2008-02 as amended) pg33.
33
PROPOSAL THREE
travel to exits. However, an area not likely captured by changes for access would be
the entrance and exit doors serving a fire-isolated exit and would be subject to the
circulation requirements, luminance contrast and door controls requirements of
AS1428.1 to allow the exit to be identified and used by occupants with disability. The
ABCB Access RIS (pg. 133), attributed an additional $100 as a cost of compliance
with the door widths and $1,250 allowance for an additional 1m2 average circulation
space.
34
PROPOSAL FOUR
opaque risers;
two accessible handrails; and
tactile ground surface indicators.
Ramps are required to have similar accessible features with the addition of kerb
rails. The standard also places limitations on gradients and intervals for landings to
assist in their use by a greater number of occupants including those with vision
impairment.
However, there is the potential that some occupants will still be unable to use an
accessible stairway for egress in a manner which is considered safe, equitable and
dignified. This issue is considered separately as a future regulatory proposal in this
report.
In considering the draft Premises Standards, the HRSC recommended exemptions
for fire-isolated stairs be reconsidered and narrowed. Apart from improving the
general access to buildings, the effect of installing these features on fire-isolated
stairways or ramps was recognised by the HRSC as improving the overall safety of
these exits for ambulant people who are blind or have vision impairment. 21
Changes to BCA 2013 require the size, configuration and location of handrails
associated with a ramp or required exit stairway, from an area required to be
accessible, to comply with clause 12 of AS 1428.1. However, these requirements do
not require handrails to be provided on both sides of a stairway, or include other
accessible features such as handrail extensions and returns.
Objectives of Proposal Four
The objective of the proposal is to improve the accessibility of fire-isolated stairs or
ramps for use by occupants with a mobility impairment, a gripping impairment or
vision impairment. (Note: Table 1 contains a summary of the intent of proposed
changes to achieve the objectives of Proposals 3 and 4)
21
35
PROPOSAL FOUR
(vi)
(ii)
(iii)
(h)
(j) clause 12(d) of AS 1428.1 does not apply to a second handrail in a Class 9b
primary school required by D2.17(a)(iii)(B).
Discussion
By removing exemptions in D3.3 for fire-isolated stairs and ramps as well as
reference to Clause 12 of AS 1428.1, the changes would require all features of AS
1428.1 for stairways and ramps used in exits. These measures while small in
nature, together are considered essential to providing the necessary sensory
information to enable an occupant with a vision, mobility or dexterity impairment to
use a ramp or stairway in an emergency.
Stairs
This proposal would result in the following changes to the requirements for stairs in
areas required to be accessible:
The major costs associated with this proposal relate to the increased set-backs to
avoid the enhanced features encroaching on the transverse path of travel. This
36
PROPOSAL FOUR
potentially affects a buildings lettable area (the proportion of the usable floor area
available for lease) which excludes the lift and stair cores. A commercial buildings
lettable area may influence the value of its lease.
Costs associated with potential changes would however, be building specific and
depend upon the options used to achieve compliance.
Open risers present a particular difficulty for occupants with vision impairment when
negotiating a stairway. The presence of light behind a stairway with an open riser
can reduce the visibility of a stair and the gap between treads poses a hazard for
those using mobility aids, or with prosthesis. Off-form concrete stairs as typically
used in high rise construction are an example of those which would generally meet
the proposed requirement. That is, the vertical element of the stair is solid and not
prone to entrapment although this is considered achievable with most commonly
used stair materials.
While the main benefit in respect of opaque risers is to users ascending a stair, the
direction of travel in an emergency will depend on the occupants location relative to
the place of safety and the fire safety strategy adopted, i.e. some egress routes
involve ascending rather than descending stairs.
Handrails
The proposals would result in the following changes to handrails in areas required to
be accessible:
There are numerous benefits in providing handrails in stairs. Where designed for
access they are used as a disruptive anchor in the event of a fall. They also
provide an important visual cue to a change in level and stability and confidence
when using a stair.
37
PROPOSAL FOUR
The primary function of a fire-isolated exit stairway or ramp is to provide a means for
escape by descent in an emergency (depending on strategy; see Appendix B).
Recent research cited studies in the UK and US that found approximately two-thirds
of stair accidents were found to have occurred during stair descent. Furthermore,
descent accidents were likely to result in more severe injuries than falls which
occurred on stair ascent 22.
The BCA does not require the installation of two handrails unless the width of the
stairway or ramp is greater than 2m. Therefore current BCA requirements assume
occupants have use of either hand. The inclusion of two suitably designed handrails
on stairways and ramps is a measure intended to assist those occupants with
mobility or vision impairment or where an occupant only has the use of one hand, in
negotiating a stair.
It is noted that aside from the cost of the handrail itself, the main cost associated
with the proposal to provide an additional handrail is the additional width required for
the stairway core or ramp, potentially at the expense of the lettable area.
Ramps
The proposals would result in the following changes to ramps in an area required to
be accessible:
22
38
Monash University Accident Research Centre, The relationship between slips, trips and falls and the design
and construction of buildings 2008, funded by the ABCB p.22.
PROPOSAL FOUR
TGSIs
The installation of TGSIs on landings at stairways and ramps used as exits will
assist vision impaired occupants in independently exiting a building. TGSIs are
required where a hazard is present, such as at the commencement of a stairway.
They are intended to be interpreted by a person with a vision impairment either
under the foot, by the tip of a seeing cane or by their visual contrast. Their location
and dimensions is intended to provide a tactile cue to a vision impaired occupant to
their location and impending interaction with a stair or ramp. The consistent
application of TGSIs will provide predictability for these occupants when moving in
the built environment. 23
The installation of TGSIs would be required at the top and bottom of stairways and
ramps on landings greater than 3 metres not bounded on both sides by a handrail.
Typically this would be where doorways penetrate a fire-isolated stairway or ramp.
The top surface of a TGSI and the bottom of a door leaf have the potential to
overlap leading some to suggest a TGSI will obstruct the operation of a door.
However, a typical clearance between a door leaf and a threshold of 10mm would
provide a residual clearance for free operation over TGSIs. Furthermore, the
favourable difference in level due to the absence of floor finishes in fire-isolated
exits, suggests design solutions will overcome the need for an increase in landing
size. Therefore, current landing dimensions are considered unchanged, and costs
are assumed to stem from the supply and installation of TGSIs only.
23 Blind Citizens Australia Submission to House of Representatives Legal and Constitutional Affairs
Committee Inquiry into Draft Disability (Access to Premises Buildings) Standards (March 2009), p. 15.
39
FUTURE PROPOSALS
FUTURE PROPOSALS
Places of Refuge
Unlike proposals 1-4 which, subject to feedback and impact assessment, are
proposed for consideration in NCC 2015, places of refuge are not intended for
consideration in 2015. Feedback on this report will instead inform the
development of any future changes.
Questions 5 to 7 of the report specifically address opinions on the use of places
of refuge in egress.
Discussion
The use of spaces in buildings to provide protection to occupants from the effects
of fire is not a new concept and is recognised in the use of horizontal exits and
compartmentation (e.g. in health-care buildings). Internationally, places of refuge
may be used as a solution to provide occupants with disability with a place of
relative safety in an emergency.
Refuges are spaces which are fire and smoke separated from the remainder of a
building in a similar manner to a fire-isolated stairway. However, other
considerations such as signage, minimum sizes, means of communication, and
access for assistance are cited by research and embodied in codes
internationally as essential features of refuges.
The ABCB developed proposals for egress to assist people with disability in
Regulation Document RD97/01(circa 1997). The proposals focus was limited to
visual alarms and places of refuge as a means for meeting obligations expressed
under the DDA. RD97/01 contained detailed proposals for places of refuge
defined as a place which offers protection from a fire hazard for people with
disabilities while awaiting assistance to evacuate.
RD97/01 explained that the intention was to provide spaces where a continuously
accessible path of travel was not available, or make use of existing spaces (e.g.
lift lobbies or toilet blocks) as temporary places of refuge form which rescue
personnel can later evacuate occupants. Proposed provisions applied the
requirements to buildings other than Class 2, Class 4 parts or Class 9a buildings
and proposed all exits be accessible or supplemented by a place of refuge.
Requirements developed as part of this work applied restrictions to the following
elements to assist with egress
40
fire and smoke separation utilising smoke proof walls where sprinklers were
provided, or providing a level of protection equivalent to a fire-isolated stair or
ramp and in other cases a minimum fire resistance level for walls and
ceilings;
FUTURE PROPOSALS
24
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004, Prepared for the
Australian Building Codes Board - 4.2
25
Warrington Fire Research, Emergency Evacuation for Occupants with Disabilities 2004, Prepared for the
Australian Building Codes Board - 4.7
41
FUTURE PROPOSALS
FUTURE PROPOSALS
their design is the fire and smoke protection of assembly areas such as lift
lobbies to serve the lifts. Concessions from providing places of refuge, where a
suitably designed lift lobby is provided, may also be appropriate.
User Acceptance
Central to further consideration of the inclusion of a place of refuge will be
accounting for user perceptions of how equitable the option is compared to other
options such as lifts. A suggested common view is that for occupants with
mobility impairments, a reliance on trained assistance to egress via a stairway is
less dignified and equitable than exiting via a lift. This is despite both alternatives
requiring the assistance of trained personnel and a period of assembly (in a
protected area) while awaiting assistance. While perceptions are individual, it
should be recognised that the BCA proposals are designed to provide safe,
equitable and dignified egress solutions for all occupants in an emergency.
A more complex debate when discussing the merits of the use of refuges in
association with strategies to protect-in-place or evacuate using suitably
designed lifts is highlighted by Bretherton 2003. His thesis Everybody Out points
to research indicating that refuges, unlike traditional evacuation, requires
occupants (perceptively at least) to remain in the proximity of the initial danger
from fire 26. Therefore the success of refuge areas is likely to ultimately hinge on
the willingness of the occupants to use these areas as a safe place 27.
Regardless of the strategy adopted, research argues that the success of
emergency evacuation for people with disability is dependent upon the familiarity
of the occupants with evacuation procedures. Consultation with users of places of
refuge in the United Kingdom revealed concerns over their use and the
procedures which support them 28, highlighting the importance of supporting
systems to any solution.
Building Emergency Management
Building management obligations require administrative practices and procedures
to be in place in order to respond as needed for coordinated and orderly
management of evacuation for all occupants. However, it is possible that an over
reliance on assistance by trained personnel may perversely entrench inequity in
egress routes.
In proposing requirements for either protect in place or everybody out (full
evacuation), Bretherton (2003) recognises the importance of building specific
26
W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.44.
W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.59.
28
Department for Communities and Local Government Eland House (London), The adequacy of refuges,
escape stairs and management procedures (2008), p. 3.
27
43
FUTURE PROPOSALS
Management
Procedures
- Emergency procedures
- Risk minimisation
- Training
Fire and
Life Safety
Built Structure
and
Systems
including Community
and Utility Services
Emergency drills
Maintenance
Familiarity
Organisation
structure
Egress/Circulation
Compartmentation
Suppression systems
Detection systems
Alarm systems
Occupant
Behavioural
Systems
Figure 5 Essential Elements of Fire Safety - Taken From Feasibility of Using Lifts for Emergency Egress Lincolne Scott, 2000
29
W. Bretherton, Everybody out Emergency Evacuation for Persons with a Disability (2003), p.144.
44
Early 2014:
Mid
2014:
Late 2014:
May
2015:
(ii)
which are not located above or below another dwelling or another Class of
building other than a private garage.
Class 2:
Class 3:
(a)
(b)
(c)
(d)
(e)
(f)
Class 4:
Class 5:
Class 6:
a shop or other building for the sale of goods by retail or the supply
of services direct to the public, including
46
(a)
(b)
(c)
(d)
Class 7:
a building which is
Class 9:
(a) Class 9a a health-care building, including those parts of the building set
aside as a laboratory; or
(b) Class 9b an assembly building, including a trade workshop, laboratory or
the like in a primary or secondary school, but excluding any
other parts of the building that are of another Class; or
(c) Class 9c an aged care building.
Class 10:
(a) Class 10a a non-habitable building being a private garage, carport, shed,
or the like; or
(b) Class 10b a structure being a fence, mast, antenna, retaining or freestanding wall, swimming pool, or the like; or
(c) Class 10c a private bushfire shelter
47
Strategies
An evacuation strategy to manage the evacuation of building occupants is a
critical component of an overarching emergency management plan to meet the
above obligations. Such strategies are integral in the effective management of
buildings during emergencies, and as such are developed specifically for the
particular characteristics of the building, the types of emergency, the fire safety
systems installed in the building, and reflect the level of coordination involvement
of trained personnel such as fire wardens. The various strategies are discussed
briefly below.
Personal Emergency Evacuation Plans
Personal Emergency Evacuation Plans (PEEPs) and to some extent the
assistance of trained personnel or other occupants in an emergency, are borne
from a practical recognition that building occupant warning systems and egress
routes may prevent people with hearing, vision or mobility impairment evacuating
independently.
PEEPs are recognised as a necessary and effective measure to assist people
with a disability respond to an emergency. PEEPs are highly individual and
designed to cater to the needs person and the specific characteristics of the
building. Australian Standard AS 3745: 2010 Planning for Emergencies in
Facilities suggests the development of PEEPs be considered during the
development of emergency procedures, in consultation with occupants with
disability from the facility.
Full or Staged (Phased)
Australian Standard AS 3745: 2010 Planning for Emergencies in Facilities
advises that full evacuation would normally be carried out in response to a
potentially catastrophic, life threatening situation or where the building cannot
function due to a severe services malfunction. As implied by this description, this
would involve simultaneous or phased evacuation of all building occupants
typically utilising fire-isolated stairways.
48
49
Deemed-to-Satisfy Provisions
Where a Building Solution is proposed to comply with the Deemed-to-Satisfy Provisions,
Performance Requirements DP1 to DP6, DP8 and DP9 are satisfied by complying with
(i)
(ii)
(iv)
(b)
(ii)
(iii)
(iv)
D3.1
Buildings and parts of buildings must be accessible as required by Table D3.1, unless
exempted by D3.4.
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY
Class of building
Access requirements
Class 1b
(a) Dwellings located on one allotment(1) and used
for short-term holiday accommodation,
consisting of
(i)
50
4 to 10 dwellings
To and within
1 dwelling
(ii) 11 to 40 dwellings
2 dwellings
(iii) 41 to 60 dwellings
3 dwellings
(iv) 61 to 80 dwellings
4 dwellings
5 dwellings
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued
Class of building
Access requirements
To and within
1 bedroom and associated sanitary
facilities; and
not less than 1 of each type of room or
space for use in common by the residents
or guests, including a cooking facility,
sauna, gymnasium, swimming pool,
laundry, games room, eating area, or the
like; and
(b)
51
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued
Class of building
Access requirements
Class 3
Common areas
(b)
to and within rooms or spaces for
use in common by the residents,
located on the levels served by the lift or
ramp.
Sole-occupancy units
Not more than 2 required accessible soleoccupancy units may be located adjacent to
each other.
Where more than 2 accessible soleoccupancy units are required, they must be
representative of the range of rooms
available.
52
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued
Class of building
Access requirements
To and within
1 to 10 sole-occupancy units
11 to 40 sole-occupancy units
41 to 60 sole-occupancy units
61 to 80 sole-occupancy units
Class 5
Class 6
Class 7a
Class 7b
Class 8
Class 9a
Class 9b
Schools and early childhood centres
53
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued
Class of building
Access requirements
Class 9c
Common areas
(b)
Where more than 2 accessible soleoccupancy units are required, they must
be representative of the range of rooms
available.
To and within
1 to 10 sole-occupancy units
11 to 40 sole-occupancy units
41 to 60 sole-occupancy units
61 to 80 sole-occupancy units
54
Table D3.1 REQUIREMENTS FOR ACCESS FOR PEOPLE WITH A DISABILITY continued
Class of building
Access requirements
Class 10a
Non-habitable building located in an accessible
area intended for use by the public and containing
a sanitary facility, change room facility or shelter
Class 10b
Swimming pool
55
(b)
(c)