TECHNICAL INSIGHTS

Is AS1428.1 approriate?

Howard Moutrie

ACAA Accredited Access Consultant, ACAA Accredited Fellow, Accessible Building Solutions

The articles featured in Technical Insights are to prompt thought and discussion to assist our members' questions and evaluate their understanding of the technical requirements of Australian Standards and other national/international source material. Technical Insights is intended to provide background information, a different viewpoint, a perspective from an individual with lived experience of disability or to prompt further discussion and/or research by you as an access professional.

I have been somewhat critical of Certifiers for being overly pedantic with the application of AS 1428.1. Certainly in NSW it has become ridiculous and I believe other states may be following suit. However, I have been softening to the plight of the Certifier. In NSW, at least, they are being reprimanded or having their certification cancelled for not applying statutory requirements to the letter – no common sense or objectivity is allowed. So when applying AS 1428.1 and it says something should have a particular dimension, they apply that, without any question even though we, as access consultants, may consider it not so critical. I am now thinking that the problem is not with the Certifier but perhaps with the Standards. I will explain.

AS 1428.1 provides requirements to allow people with a disability use public buildings. The requirements are primarily based on the spatial requirements of a person using an overly large, non-existent wheelchair, on the basis that if the space is suitable for this large wheelchair, then it will be suitable for smaller wheelchairs. Added to these spatial requirements are requirements to aid people with ambulant disabilities, with vision impairment and hearing impairment. The spatial requirements are based on research undertaken in the 1980s and as the subject wheelchair does not actually exist, a scale model of the wheelchair was made and moved by hand to obtain the required manoeuvring space. Then “error factors” were added to these minimum requirements to allow for people without perfect control. This is hardly definitive. Let’s look further.

I am sure you are familiar with David Caple’s research on the size of wheelchairs. However, prior to that, he, along with Daisy Veitch and Verna Blewett, conducted research on anthropometric data which was published as “Sizing Up Australia: How contemporary is the anthropometric data Australian designers use?” In that document it is stated that the data used in the accessibility Standards was vague and the authors of the research paper proposed “that some Standards, accepted in the marketplace as credible or being enforceable by law, may be flawed, inaccurate and potentially misleading”.

In the same paper, the authors say about AS 1428, “This standard seems to have been an acceptable base for design in the past. However, when scrutinised by the Human Rights and Equal Opportunities Commission (HREOC) it was found that the standard on one hand mandates compliance but on the other hand does not give enough raw anthropometric information to conclusively test specific access situations (see for example, HREOC 2000; HREOC 2004).” They further say “It highlights the plight of designers or certified ergonomists, who somehow have to bridge the gap between inadequate anthropometric data and the production of workable designs, workplaces or access to workplaces.”

Not only is Caple criticising the data but is understanding that the Standard is not intended to provide all solutions and that designers are required to provide suitable alternative designs. This follows the commentary in the AS 1428.1 Supplement where it says of AS 1428.1, “The illustrations should not be seen as the only means of providing suitably accessible facilities” and with respect to toilets “As long as adequate circulation space is provided there could be …. reasons for adopting one of a variety of other shapes in plan.”

So it is clear that the original intent of the Standard was to provide guidance to designers, not a solution. The preface to the Standard says the intention of the Standard is to provide a practical reference document for designers and it also says that “it is seen as necessary for the Standard to provide a range of data …. to allow flexibility in design..”

Has this been forgotten?

It would be particularly useful to have more recent anthropometric data, however, it is particularly difficult to get meaningful anthropometric data on which to base accessibility Standards. Firstly, there is such a wide range of disabilities which need to be addressed and then there is the problem of attracting people to participate in the research to make the data meaningful. So at this point in time we are reliant on AS 1428 to provide us with design requirements, based on this old data.

As noted before, the Supplement to AS 1428.1-1988 says that “the illustrations in the Standard should not be seen as the only means of providing suitably accessible facilities”. For those of you who have provided alternative solutions to those required by AS 1428, it is clear that other counties have different requirements and design outcomes. In fact, in many ways Australia is the odd one out, though that is not to say we are wrong. The issues we are currently facing occur when the flexibility originally envisaged is ignored and the documented Standard deemed to be the only solution.

It is my view that the Standard needs to allow more flexibility, particularly relating to normal building tolerance.

The following are some particular examples:

1. Turning area. AS 1428.1 requires a space 2070 x 1540mm, whereas the ISO requires 2000 x 1500mm, US ADA Standard 1500mm dia, UK is also 1500mm dia

2. Toilet layout. The ISO Standard and most other countries have a layout where the basin is close to the toilet pan so that it can be used while on the toilet. Allowing one to wash your hands while on the pan rather than transferring to your chair and moving to the basin, before you can wash. There seems to be a hygiene issue here which we may not be addressing. Interestingly, the ISO Standard has a number of design options, one which reflects our requirement.

3. Toilet grabrails in Australia must (currently) be at a height of 800-810mm. The ISO Standard requires grabrails to be at a height of 200-300mm above the toilet seat (which would cover a range of 600-780mm above the floor. In the UK it is 680mm. Are the people in other parts of the world so different?

4. In the ISO Standard there is a much greater flexibility in seat height and toilet pan location.

5. The ISO Standard and other international Standards require a 300mm extension of a stair or ramp handrail past the bottom riser, where as we require a 1 tread extension on the angle plus the 300mm extension.

On the basis that the people being addressed under other standards are comparable to Australians there is clearly a disparity in the perceived requirements. So, when a certifier is enforcing what is in the Standard, is this strict enforcement valid. Clearly, in many cases it is not. On this basis, the lack of tolerance and narrow design parameters need to be reconsidered and AS 1428.1 rewritten so that it responds to the environment in which it is now being used. That is, it is not being used as a design guidance tool but as providing critical design parameters. It should only require narrow design parameters when these are warranted and allow more flexibility when the dimensions are not critical. Perhaps a preferred dimension or dimension range is provided and where this is not critical an alternative range provided. For example, based on the grabrail height, this could be given as 700 -830mm (800-830mm preferred). For the purpose of this example, I have ignored the disparity of the maximum height with overseas Standards.

I am also not advocating that overseas Standards are better than ours, just using them to highlight differences when perhaps there should be none. Ed Steinfeld, in 2005, prepared a report for the US Access Board on the anthropometry for wheeled devices. In this report he compared the requirements of various Standards including US, Canada, British and Australian. Of the Australian Standard he said “ Much of the Bails’ data was reported in an incomplete and disorganised manner….had very small samples …….many of the changes made to… Australian Standards can be questioned in the light of research findings.”

There are a number of technical issues which need to be addressed in future versions of AS 148.1, including visual indicators on glazing and luminance contrast. I think all aspects of the Standard should be examined and where possible update the requirements to the latest technology and equipment, and respond to the environment it is now used by providing more flexibility where appropriate. In my opinion, Standards Australia have a duty to ensure that the information in the Standards is up to date and usable. This is particularly where the Standard is referenced in the BCA or other legislation.