Lift Standards

by Mark Relf and Eric Martin ACAA representatives on the ME-004 Lift committee

As an observer of lift standards, the past 8 years have been similar to watching a train wreck in super slow motion waiting to happen. At last the first two trains have run off the accessibility tracks.

Let us explain: in 2013 the Australian lift industry realised the first step in the globalization of lift standards by removing Australian Standard lift standards from the Building Code of Australia with modifications to table E3.6 by inserting a performance based descriptor to replace the referenced standards.

• Stairway platform lift replaced the reference to AS 1735.7

• Inclined lift replaced the reference to AS 1735.8

• Low rise platform lift replaced the reference to AS 1735.14

• Low-rise, low-speed constant pressure lift replaced the reference to AS 1735.15

• Small sized, low-speed automatic lift replaced the reference to AS 1735.16

To the casual observer these changes seemed innocuous but belied what lay ahead as globalization meant adopting overseas standards regardless of the consistency with the requirements of the Australian Standards.

In 2020 AS 1735.12 (1999) as we knew it was updated by adopting the European standard EN 81-70:2018 to become AS 1735.12:2020 Lifts, escalators and moving walks Part 12: Facilities for persons with disabilities (EN 81-70:2018, MOD). From an Australian perspective the important aspect is the “MOD” in the title, that refers to Appendices ZZ and ZA, which are normative modifications for Australian requirements.

Like many European (EN CEN) and International (ISO) standards it is common for countries to adopt a national variation to suit local requirements, which is similar to state and territory variations to the National Construction Code (NCC).

It should also be noted that the NCC and DDA Standards do not automatically reference the 2020 update of AS 1735.12. Importantly, Appendix ZZ Variations, paragraph 0.2 includes:

e) for Australian legal requirements, see the Disability (Access to Premises - Buildings) Standards 2010.

A review of AS 1735.12:2020 will read as a confusing arrangement for Australia as the assumptions include several statements like;

National building regulations will not conflict with the provisions of this standard.

Somewhat more confusing is the preface which includes;

This European Standard shall be given the status of a national standard, either by publication of an identical text or by endorsement, at the latest by November 2018, and conflicting national standards shall be withdrawn at the latest by May 2020.

Ironically, neither the NCC or DDA Standards have reacted to this requirement, albeit this section is titled European Preface and is just a preface and Australia is not a listed country. It

is anyone's guess where we may be if a trade agreement is struck between Australia and the European Union.

A technical review of the main body of AS 1735.12:2020 provides further confusion for Australian readers on matters such as;

• Lift types where table 3 lists five different types.

• Door size

• Handrail requirements.

• Wheelchair classes A, B, C and no recognition of A80 and A90 occupied wheelchairs.

• Control panels which includes numerous references to ISO 4190.

• Extra large control devices, which is explained in Annex B.

• An induction loop in the lift car in accordance with EN 60118-4:2015.

• Touch screen devices for destination control systems.

Thankfully appendix ZZ and the NCC resolve many of these issues. However, it is an ambiguous and clumsy manner to prepare a standard for potential referencing in the NCC and DDA Premises Standard. However, appendices ZZ and ZA do not resolve all of the accessibility issues as the Standards Australia lift committee has been more focussed on adopting EN 81-70 than making progressive enhancements to make lifts more accessible to people with disabilities, in particular people with vision impairment.

For people with vision impairment, luminance contrast of lift controls including touch screen controls remains problematic. Character outlines of numbers and control buttons is still a hairline 0.72mm to 1.8mm which are barely visible to people with ordinary vision and not visible at all to people with low vision.

While Annex C of AS 1735.12: 2020 does contain requirements for touch screens on destination control lifts, there are a myriad of exceptions and additions from ordinary collective control lifts that make the task for access consultants and the end user even more difficult to determine compliance and usability.

It is evident that touch screen accessibility for people with vision impairment shall remain inaccessible for some time before the lift industry is inclined to bother resolving the issue.

Similarly, the standard fails to provide test methodology for insitu testing of luminance contrast of control panels, except for the suggestion in clause 5.1.2 and table 2 that a black and white photo be taken and then compared to a LRV scale to determine whether there is at least 30 points difference is achieved at a 45 degree angle or perpendicular viewing point as applicable. Obviously, this type of testing methodology is far removed from Australian practices.

To add further dilemma for access consultants a note to clause 5.1.2 suggests that measuring shiny and reflective surfaces, that we often experience in lift cars, can reduce luminance contrast using this LRV method and we should be guided by ISO 21542: 2011, B.7.2. If you’re not confused by now then pick up your 2011, not 2020 or 2021, and a copy of ISO 21542 which articulates a host of alternative test methods and calculus. Some may consider this type of choice as convenient and appropriate in a world of performance solutions where prescription is infinitely evasive.

ACAA proposals to conduct a survey with people with vision impairment regarding lift car controls was loudly rejected by the lift industry in favour of a European study which was meant to conclude by the end of 2020, but alas no report yet and maybe another Covid 19 casualty.

Surprisingly, appendix ZA for Australia, is devoted to wayfinding and includes a reference to AS 1428.4.2. Largely, the ZA appendix deals with identification rather than wayfinding with a tactile alpha identifier for lift cars A, B, C, etc and numeric identifier of floor levels on the frame of lift doors using numbering of floor levels -1 for B1, 0 for ground, 1, 2, 3 and / or G for ground, B for basement, C for concourse, M for mezzanine and so on.

In summary, it is difficult to determine any real improvement in adopting this standard and it appears that enhancement of clause 3.6 and inclusion of a specification E3.6 in the NCC and DDA Premises Standards can deliver greater benefits for end users, regulators and designers.

The next chapter of interest for access consultants is the latest revision of AS1735.15 [2021] which adopts EN 81-41: 2010 MOD, an eleven year aged out of date standard, with the ridiculously long title of; Lifts, escalators and moving walks Part 15: Safety rules for the construction and installation of lifts – Special lift for the transport of persons and goods – Vertical lifting platforms intended for use by persons with impaired mobility (EN 81-41: 2010 MOD).

Ironically, even this long title does not match the NCC definition in table E3.6 of Low-rise, low-speed constant pressure lift and it is not referenced in the DRAFT NCC 2022. Furthermore the Australian appendix ZZ makes no reference to the NCC or Disability (Access to Premises - Buildings) Standards 2010. Therefore, it could be argued that the only way to utilize the contents of AS 1735.15 [2021] is within a performance solution.

Again, the MOD in the title implies variations in Appendix ZZ for Australia. However, on this occasion the variations do not include any real accessibility matters which is mainly due to a ‘direct adoption’ of an EN standard, under rules and agreements between Australia and European body, cannot be altered and simultaneously permitted a combined public comment and ballot process. Interestingly, the public comments submitted by ACAA were immediately ignored and the majority of the lift committee voted YES in the combined public comment and ballot process.

The glaring standouts of interest and concern for access are:

• The standard articulates compliance will accommodate type A and B wheelchairs but not type C. There is no mention or recognition of A80 and A90 occupied wheelchairs.

• Table 2 suggests 900 X 1400mm lift platforms for through cars and 1100 X 1400mm where the doors / gates are adjacent.

• Control devices – Table 8 and clause 5.5.15.12 require hold and run constant pressure at 2-5 Newtons in a height range of 900-1200mm (preferably 1100mm) and 400mm minimum distance to a corner.

• Control buttons shall be visually different from the background and have a colour contrast not luminance contrast. Other aspects of tactile requirements are specified.

• Clause 5.8.2 permits 800mm clear opening width for lift doors/gates and an opening force of no more than 40 Newtons.

• There is no requirement for level landings at lift doors/gates and no latchside clearances as previously required by AS1735.15.

• Clause 5.8.4.6 permits a 10mm sill threshold height at the lift door/gate with a gap of up to 20mm. Sill threshold heights up to 50mm permit a 1:4 gradient, up to 75mm a 1:6 gradient, up to 100mm a 1:8 gradient and over 100mm with no apparent upper limit requires a 1:12 gradient ramps.

• Threshold sill ramps require 900mm width with no mention of kerb guards or handrails.

• Clause 7.3.1.5 specifies an International Symbol of Access that is different to AS1428.1.

Clearly, this standard needs to be considered with extreme caution with a significant risk of DDA complaints. The departures from the previous version and the norms of AS1428.1 are of considerable concern for access consultants and individualised lift specification should be prepared to remove the high risk elements.

During the public consultation phase of NCC 2022 and the DDA Premises Standard, ACAA did submit a number of changes to Table E3.6 (b) in an endeavour to bridge the gap between an Australian Standard lacking in equitable access and the overall objectives of the DDA and NCC. ACAA’s submission to the ABCB an Premises Standards review recommended the following additions:

Lifts that provide manually operated doors and gates must provide:

• Doorway landing circulation spaces complying with AS1428.1; and

• Landing areas with a slope complying with AS1428.1;

• Sills that exceed 10mm or more in height difference to the landing must provide a 1:8 gradient threshold ramp with a maximum length of 280 mm; and

• D-handles complying with AS1428.1; and

• Force to open the door or gate must not exceed 20 Newtons.

• Retractable protection screen under the lift car to avoid headroom hazards where the lift is un-enclosed.

Lift and landing control buttons that require continuous pressure must provide:

• Control buttons in a height range of 900 mm to 1100 mm above the lift floor and 500 mm minimum distance from the corner of the lift or platform; and

• Luminance contrast complying with AS1735.12; and

• The force to operate the control buttons shall not exceed 5 Newtons.

In the recent Ryan Vs Sunshine Coast Hospital and Health Service matter we have a salient reminder that compliance with deficient Australian Standards and regulations, either by deemed to satisfy or performance assessment, is not a defense against DDA complaints.

This standard is clearly a reduction in accessibility and should never be referenced by the NCC or Premises Standards.