The History Of ‘Accessible’ Homes in the UK and the Role of Approved Document M

by Rachel Whymark - Positive Access and Sustainable Solutions (PASS) Building Consultants

Rachel’s passion and advocacy for a more accessible (and sustainable) building environment began as a trainee building certifier in the UK 33 years ago. Specialising in interpretation of legislation, particularly of Part M (Access to and use of buildings), Part L (Conservation of fuel and power) and Part B (Fire safety) of the UK building regulations. She went on to be part of the specialist building control team at the National House Building Council, judged the RIBA housing design awards, and worked as a project manager for the Movement for Innovation’s Housing Forum. Rachel is an Associate member of the ACAA based in Cairns.

When I emigrated to Australia 16 years ago, one of the first things I did was go and visit some display homes here in the tropics. Construction methods are very different here, as are the developments themselves and I was fascinated at how different the model of housing is here compared to the UK. Here I saw lots of single storey homes on large blocks (in Cairns at the time standard lots sizes were typically 800m2). In the UK, where space is at premium, having an entire estate of hundreds of detached single storey detached homes is just not possible.

However, whilst I was impressed with the size of blocks, and the beautiful homes built on them, I was pretty shocked to see single skin blockwork homes, full of air-conditioning, with little or no insulation, no eaves overhang, no regard for overall energy efficiency, and with absolutely no accessible features built in.

Why was I so surprised? Because in the UK (as with many other countries), lifetime homes have been the norm for decades, as have homes with a focus on energy efficiency. Let’s put it this way, I completed a thesis on the UK’s two established Energy Rating systems nearly 30 years ago. In Australia, energy ratings have only been nationally mandated in the Australian Building Codes since 2003 (which was a woefully pathetic 4 stars). I am STILL waiting for the codes to introduce anything meaningful for Class 1a buildings in terms of ANY mandatory accessibility provision.

So, whilst there are many aspects of Australian construction methods which I prefer in new homes, energy efficiency and accessibility are certainly not among them. The unwillingness to embrace the very many short and long term benefits of building homes which meet high standards in these two areas has baffled me as I sit in my 9 star energy rated home typing this article, which only cost $268,000 to build (so excuse me, it does NOT have to be cost prohibitive), costs peanuts to run, and which will adapt to suit my needs over time without me having to resort to moving and building something more suitable.

I built my home nearly 10 years ago and incorporated the very sound principles of Approved Document M of the UK Building Regulations at that time, which is the standard applicable to all new homes built in the UK.

Slightly wider doors, level thresholds, no steps (though there are exemptions for steep sites), higher GPO’s, reinforced walls to bathrooms and hobless shower, WC door opening outwards. It was seen as radical here 10 years ago, and took out several awards including HIA House of the Year in our region against multi-million dollar homes. For me it was about showing what is easily achievable with some forethought on a pretty tight budget and about changing the perception of what a more accessible and sustainable home might look like (i.e. just like any other home in the street).

APPROVED DOCUMENT M – WHAT IS IT?

In the UK, The Building Act 1984 is the primary enabling legislation under which the Building Regulations are made. It empowers the Secretary of State to make regulations for the purposes of ‘securing the health, safety, welfare and convenience of persons in or about buildings and of others who may be affected by buildings or matters connected with buildings’. The Building Regulations are statutory instruments that are the equivalent of our National Construction Codes (NCC). These regulations cover all aspects of construction for all building types in terms of compliance. The latest building regulations were released in 2010.

Supporting these Regulations are Approved Documents. These cover everything from Part A - Structure to Part R – Physical Infrastructure for high speed electronic communications networks. Each area having its own approved document and which are often broken down in to sections. Each one relates back to the over-riding requirement of the Building Regulations. It sounds complicated, but in reality, they work extremely well and are easy to read and interpret. Approved documents give practical guidance on how to meet the requirements of the Building Regulations. Part M, is the Approved Document which covers ‘access to and use of buildings’.

There are also British Standards (equivalent to our Australian Standards), but more reliance is placed on the approved documents for compliant solutions in most cases. British Standards might be referred to in unusual circumstances or particularly complicated situations, equivalent to providing a performance solution, but not called anything formal until 2004 (when access statements were introduced).

APPROVED DOCUMENT M TIMELINE

1992 – The Building Regulations 1991 Approved Document M (Access and Facilities for disabled people) is introduced. It does not apply to new dwellings at this point.

1999 – The revised edition now includes provisions for new dwellings: ‘Reasonable provision shall be made for disabled people to gain access to and to use the building’. Yes, builders struggled with this and Building Control Officers (building certifiers) all over the country had to educate them on the implications and how to incorporate the new requirements.

2004 – Name change and an overhaul! Now called Access to and use of buildings. Main changes are that it draws on the guidance of British Standard (BS) 8300:2001 ‘Design of buildings and their approaches to meet the needs of disabled people – Code of Practice’. They no longer refer to ‘disabled people’ as they are wanting to focus on inclusivity. Section 4 is added, which covers audience and spectator facilities, refreshment facilities, sleeping accommodation and switches, outlets and controls. Sanitary accommodation in buildings other than dwellings moves to Section 5. Additional guidance on educational establishments and purpose-built student accommodation is added. Also, an explanation on the relationship between Part M and the Disability Discrimination Act 1995 has been updated to reflect changes since the 1999 version was published. Access statements are introduced. These identify the philosophy and approach to inclusive design adopted by the project in terms of how they intend to meet the requirement if differing from the guidance in Part M (oh hello performance solution, there you are!).

2010 Amendments – Incorporates text amendments as a result of the new Building Regulations 2010.

2013 Amendments – Refers to Approved Document 7 ‘Materials and workmanship’. References the Equality Act 2010 and the Equalities Act 2010 (Disability) Regulations 2010. Guidance on stairs and ramps, access statements, door opening forces, WC pans and suites is also updated with additional strategies included. Reference to Changing Places toilets in relation to toilet accommodation is included. Additional definitions are included.

2015 – Now split into two parts. Volume 1 – Dwellings and Volume 2 – Buildings other than dwellings. Requirement M4 ‘Sanitary Conveniences in dwellings’, has been replaced by 3 categories:

• M4(1) – Category 1: Visitable dwellings

• M4(2) – Category 2: Accessible and adaptable dwellings

• M4(3) – Category 3: Wheelchair user dwellings

Interestingly, whilst the requirement M4 is referred to as having been replaced by new requirements, it actually encompasses M1 which is ‘Access to and Use of buildings’ as well as just sanitary conveniences for dwellings.

Regulation M4(1) is applicable for ALL new dwellings, whereas M4(2) and (3) are optional. These would be specified as being required as part of the planning approval process for a development.

Remember, this Approved Document requires a level of accessibility for all new homes (including what we call class 1a buildings). They have been doing so quite successfully since 1999. But with the 2015 changes, there is far more information on dwellings as they have their own volume (Volume 1), plus they introduce the two optional areas (Category 2 and 3).

2016 Amendments – Corrections and clarifications

2020 Amendments – Changing Places toilets mandated for appropriately sized publicly accessible buildings.

WHAT IS COVERED IN APPROVED DOCUMENT M AS MANDATORY FOR ALL DWELLINGS?

Requirement

Category 1 – Visitable dwelling

Access and use

M4(1). Reasonable provision should be made for people to:-

(a) gain access to; and

(b) use, the dwelling and its facilities.

Briefly, this encompasses:

• the approach and access to the dwelling (with some exemptions for steeply sloping sites)

• the approach if alighting from a car

• access and use of the entrance storey including a sanitary facility (or where there are no habitable rooms on the entrance storey, the principal storey)

• switches and sockets in habitable rooms

So, ramps and stairs, circulation spaces, gradients and crossfalls, surface materials, door and corridor widths, communal lifts and stairs, sanitary facilities (which are required to have basins in the UK, you cannot have a room with a WC and no basin).

WHAT IS COVERED UNDER OPTIONAL REQUIREMENT M4(2)?

Optional requirement

Category 2 – accessible and adaptable dwellings

M4(2) Optional requirement

(1) Reasonable provision must be made for people to-

(a) gain access to; and

(b) use, the dwelling and its facilities.

(2) The provision made must be sufficient to-

(a) meet the needs of occupants with differing needs, including some older or disabled people; and

(b) to allow adaptation of the dwelling to meet the changing needs of occupants over time.

Briefly, this now covers a STEP FREE approach and entry to the dwelling, step free access to a WC and other accommodation on the entrance storey, plus to any outdoor private space. It provides for future adaptations to be carried out easily (e.g. strengthening walls for later grab rails), introduces more detailed spatial requirements and layouts for kitchens, living areas, bedrooms and sanitary compartments as well as bathrooms. Clear widths remain the same though for doorways and corridors. Apart from the principal entrance door (which requires a clear width of 850mm), internal doors still only need to be 750mm clear opening width, and 900mm clear width for corridors (when approached head on). There are additional requirements for controls and services.

WHAT IS COVERED UNDER OPTIONAL REQUIREMENT M4(3)?

Optional requirement

Category 3 – wheelchair user dwellings

M4(3) optional requirement

(1) Reasonable provision must be made for people to-

(a) gain access to; and

(b) use, the dwelling and it’s facilities.

(2) The provision made must be sufficient to-

(a) allow simple adaptation of the dwelling to meet the needs of occupants who use wheelchairs; or

(b) meet the needs of occupants who use wheelchairs

Briefly, it covers the same key areas as M4 (2) but with considerably more detail and additional circulation space information. Circulation space requirements around doorways are still very different to what we see in AS 1428.1 and in the SDA Design standards (850mm clear opening width is acceptable, with clearances either side of the door being determined as simply a 300mm nib to the leading edge and 200mm nib to the following edge). There is detail on transfer and storage areas for wheelchairs, lifts (including platform lifts), more information on room layouts, minimum floor areas, ceiling hoist provision and a lot more detail on suitable WC and bathroom layouts.

HOW DOES THIS RELATE TO AUSTRALIAN ACCESS REQUIREMENTS FOR DWELLINGS?

With the advent of M4(2) and M4(3), this brings a whole new level of accessibility to dwellings in the UK, not seen before other than as best practice. It is the planning process in the UK which stipulates if a development must incorporate accessible homes, and how many of each are required, over and above the minimum requirements for all new dwellings.

There has been ongoing research and dialogue from Government and non-Government bodies into appropriate housing to meet the needs of people with disabilities and also an ageing population and if the Building Regulations adequately meet these needs. These include the Joseph Rowntree Report in 2003 and more recently the Ministry of Housing, Communities and Local Governments consultation paper on ‘Raising accessibility standards for new homes’.

The difference being, compared to Australia, the UK building regulations have changed over time to at least meet some of these needs. There is still NOTHING in the NCC’s that cover class 1a buildings (single dwellings) in terms of accessibility.

However, I have my own opinions of where we should be aiming in terms of what should be mandated in ALL new homes. If it works in the UK, why should it not work here? They have, after all, spent nearly 30 years improving and refining their requirements and managed to garner support from industry bodies which are just as vociferous as they are here in Australia. But that discussion is best left for another article.