Compliance Versus Functionality in DSAPT

farctatemountainousUrban and Civil

Nov 29, 2013 (3 years and 11 months ago)

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1


Compliance Versus Functionality in DSAPT


Contents

Mobility Aid restraint

................................
................................
..............................

1

Way Finding

................................
................................
................................
.........

2

Bus stop slab grad
ients

................................
................................
..........................

2

Cross
-
river Ferry seating

................................
................................
........................

2

Ramp / stair combinations with lifts.

................................
................................
........

3

Premises Standard and DSAPT inconsistency

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............................

3

Appendices

................................
................................
................................
...........

4

DSAPT Part 9.11 Movement of mobility aid in allocated space

................................
..

4

DSAPT
Part 18.1 Location

................................
................................
....................

4

DSAPT Part 8.1 Boarding points and kerbs

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.............................

4

AS 1428.1

2001, Clause 5, WALKWAYS, RAMPS AND LANDINGS

............................

4

AS 1428.1

2009, Clause10, WALKWAYS, RAMPS AND LANDINGS

...........................

4

DSAPT Part 9.5 Number of allocated spaces to be provided


ferries

........................

5

DSAPT Part 9.4 Number of allocated spaces to be provided


buses

.........................

5

Seating Capacity of three Brisbane Transport Buses

................................
................

5

AS5100.1
-
2
004, Clause 9.11 Pedestrian bridges

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....................

5


Engineering culture is often compliance driven. Alternative solutions, though they may
have a better functional outcome than compliance, are not usually well received unless
the ‘improve
ment’ is easily quantifiable.
Building certifiers are also usually reluctant to
sign off on non
-
compliant solutions. While usually a commendable approach, this also
stifles alternate solutions and innovations.

In order to give confidence to engineers an
d
certifiers
, a

means of quantifying

the benefits of

innovations a
nd

improvements is
required. By the same token, when unjustifiable hardship provisions are exercised, a
way of assessing whether a design remain
s

functional
despite non
complian
ce

would
grea
tly assist engineers
,

certifiers

and the public
.


The
alternative
‘g
ood practice


solutions and practices
might be
published

in the DSAPT
Guidelines

or in a handbook published by a relevant professional body
.

What constitutes

good practice


in terms of accessibility and function
should
first be
agreed through a
national discussion.


The following
headings
offer examples of compliance either falling short of function or
function being maintain
ed despite non
compliance.

They are not intended to

be
comprehensive.


Mobility Aid re
s
traint

Allocated spaces in buses, trams and light rail
must
by some means ensure the
stability
of a mobility aid in
the

space in order to comply with DSAPT Part 9.11. “
An allocated
space must contain movement of a mobility aid towards the front or sides of a
conveyance.” Acceleration forces experienced in a bus are as great if not greater than
deceleration / braking forces. To be properly functional, Part 9.11
should

a
lso require
containment of movement towards the rear of a conveyance.
Mere compliance with Part
9.11 is not sufficient to always allow safe travel for people who
ride in

their mobility aids
when
in bus allocated spaces.


2


Way Finding

DSAPT’s requirements for the location of TGSIs
on public transport premises and
infrastructure
are dealt with in
DSAPT
Part 18.1. This cites AS1428.2
-
1992, clause 18.1
as its technical reference. No mention is made in the AS
’s

clause

18.1

of directional
TGSIs and where it is appropriate to deploy them.
None of the editions of AS1428.4
adequately address the use of directional TGSI
in public transport premises and
infrastructure,
though some
technical guidance
is provided.


Currently, p
eople with vision

impairment
complain that they too

easily lose orientation in
a DSAPT compliant environment due to lack of directional cues.
Equally, people with
mobility impairments protest that a proliferation of TGSIs makes pedestrian areas less
safe for them.
A nati
onally agreed position on direction
al

TGSI use is required

in order
to ensure a consistent
, safe

outcome across public transport modality types.


Bus stop slab gradients

Constructing compliant DSAPT bus stops in the three dimensions of an urban or
suburban

streetscape can be challenging. In some instances bus stops can be relocated
to more favourable topography, but in other instances this is impracticable.
A national
position on what constitutes a functional though noncompliant
slab gradient or crossfall

is required.
No attempt should be made to diminish the DSAPT requirements in this
dialogue however it could define what is acceptable in the case of legi
timate unjustifiable
hardship.


DSAPT Part 8.1 (1) specifies that boarding points shall have “
a firm
and level surface to
which a boarding device can be deployed”.


Nowhere
in DSAPT
is ‘level’ actually defined.
The
Australian
Human Rights Commission
attempt
ed

a definition in Clause 4.8 of their Bus Stop Guidelines, stating that AS1428.1
-
2001 stipulates a

crossfall on an access path of not steeper than 1:40 (Clause 5.1.1(b)).
However, this figure is not consistent with AS1424.1
-
2009, referenced in the Premises
Standard. Clause 10.1(d) of that Standard maintains 1:40 on surfaces other than
bitumen. On bi
tumen it permits 1:33.
These crossfall gradients in Clause 10.1(d) are
primarily required for drainage, “
a camber or crossfall shall be provided for shedding of
water”, rather than
accessibility for
pedestrian
s
.


A

wheeled mobility aid
’s

tendency or abili
ty
to roll is determined by the quality of its
wheel bearings rather than the
material
from which paving is constructed
.
A wheeled
mobility aid

will
roll as freely
on a
bitumen pavement with a
1:33
gradient
as it will on
another pavement material with

a 1:33 gradient
.

Is a 1:33 concrete slab to be
considered functional then, though noncompliant
, if it is not bitumen
? If
so,

is 1:33 an
acceptable gradient or crossfall
for concrete
where 1:40 cannot be achieved? A national
discussion leading to a
cons
ensus
position
on this
and other acceptably functional but
noncompliant slab gradients
is required.


Cross
-
r
iver Ferry seating

Brisbane’s
single
-
deck
m
onohull ferries have 53
-
54 passenger capacity
. DSAPT Part 9.5
requires two allocated spaces for the first 32 passenger capacity and two further
allocated spaces for each additional hundred
(or part thereof)
passenger capacity.
This
puts a requirement
four allocated spaces

on these ferries
.
When re
trofitted, t
he
allocated spaces
reduce the
ferry’s
seating capacity by 10 seats

even when folding seats
are fitted to the allocated space walls.

These ferries are cross
-
river services that take
not more than a few minutes to complete a journey between fer
ry terminals.

3



Buses with a carrying capacity greater than a ferry require a minimum of two allocated
spaces where carry capacity exceeds 32 regardless of maximum capacity under DSAPT
Part 9.4.
Brisbane
T
ransport low floor buses commonly carry in the rang
e of 62
-
98
passengers.

These are used on often long haul commuter routes. A means of
rationalising the functional carrying capacity of existing small, cross
-
river ferries, bearing
in mind the seating allocations of buses, is required.


Ramp / stair

combi
nations with lifts.

DSAPT requires no more than an access path that
reaches all necessary features and
facilities of a premises or infrastructure.
To meet
this,

lift and stair co
-
locat
ion

is
sufficient for compliance. In reality though
,

this does not del
iver an equal

access

outcome
at all times
. Lifts, and particularly those in outdoor locations, are prone to
breakdown, vulnerable to vandalism and unserviceable due to maintenance schedules.
This problem is magnified at public transport stations as most
rail or bus platforms
require at least two functional lifts

to the overbridge

in order to complete the journey
over the
rail
corridor or
bus carriageway
.


Good practice is to provide a ramp alternative to the lift.
A pedestrian ramp complying
with AS5100.1
-
2004
Bridge Design
,
Clause 9.11 may have a gradient as steep as 1:8.
Where space permitted
,

this could be used instead of stairs. While a 1:8 ramp with a
vertical rise of 5.5 m could never be classed as an access
ible ramp for people with
mobility impairments, many people using powered mobility aids would still be able to
traverse this gradient if lifts were unserviceable.


Premises Stand
ard

and DSAPT inconsistency

In many of their technical references the DSAPT
and Premises Standard are inconsistent.
The Premises Standard is the later document, and it has both diminished and increased
various technical requirements for compliance. This creates a situation where a mobility
aid might be accommodated by one but no
t the other. In that structures and premises
covered by both
Standards
commonly abut or overlap
,

this creates tension and
uncertainty between the compliance regimes. Examples of this tension are easily found.


West
E
nd Ferry Terminal is
located in Orleig
h Park and
has a
n

accessible
unisex toilet
.
This toilet need only comply with AS1428.1
-
2001 as it is located within the terminal
structure and under its roof. The 2001 edition requires a minimum circulation area of
2000 mm x 1600 mm. Were the toilet det
ached from the terminal by only a few meters
and associated with the park it would be required to meet AS1428.1
-
2009, which has a
2300 mm x 1900 mm circulation area.
As it happens
,

Brisbane City Council built to the
2009 edition and should be commended fo
r providing the extra functionality of the larger
unit, even though not required to do so in order to comply.


At Brisbane’s Central Station, s
tepping from the lift
connecting platform and concourse
puts the passenger in one of two regulatory environments.

Stepping onto the platform,
the DSAPT determines the accessibility and layout of the facilities and structures.
Stepping onto the concourse the Premises Standard holds sway. In
a single step,

the
technical requirements for compliance have changed

despi
te the functional requirements
of the mobility aid remaining unchanged
.


A dialogue
dealing with

the
harmonisation of the
technical requirements
of the two
Disability
Standards
is
required
. The outcome should
diminish
n
either, but rather should
give a
more functional outcome for both than currently exists.


4


Appendices

DSAPT Part
9.11 Movement of mobility aid in allocated
space

An allocated space must contain movement of a mobility aid towards the front or sides of
a conveyance.

Conveyances

*
Buses, exce
pt dedicated school buses

*
Trams

*
Light rail


DSAPT Part 18.1 Location

Tactile ground surface indicators must be installed on an access path to indicate
stairways, ramps, changes of direction, overhead obstructions below a height of 2000
mm, and hazards
within a circulation space or adjacent to a path of travel (
AS1428.2
(1992) Clause 18.1
,
Tactile ground surface indicators
).

Infrastructure

Premises

except premises to which the Premises Standards apply


DSAPT Part
8.1 Boarding points and kerbs

(1)
Operators and providers may assume that passengers will board at a point that has a
firm and level surface to which a boarding device can be deployed.

Infrastructure

Premises

except airports that do not accept regular public transport services


AS 1428.1

2001, Clause
5
,

WALKWAYS, RAMPS AND
LANDINGS

5.1 General

5.1.1
Circulation space

Accessways, walkways, ramps and landing shall have


(b) an unobstructed vertical clearance of not less than 2000 mm, and the gradients and
crossfalls of the surface
area within a landing or circulation space shall not exceed 1:40.

5.2 Walkways

The requirements for the design and construction of walkways are as follows:

(a) Walkways shall be provided with landings as specified in Clause 5.7, at intervals not
exceeding
the following:

NOTE: Landings are not required where walkway gradients are flatter than 1 in 33.


AS 1428.1

2009, Clause
10
,

WALKWAYS, RAMPS AND
LANDINGS

10.1 General

Walkways, ramps and landings that are provided on a continuous accessible path of
travel
shall be as follows:

(d) For walkways and landings having gradients in the direction of travel shallower than
1 in 33, a camber or crossfall shall be provided for shedding of water and shall be no
5


steeper than 1 in 40, except that bitumen surfaces shall ha
ve a camber or crossfall no
steeper than 1 in 33.


DSAPT Part 9.5 Number of allocated spaces to be
provided


ferries

(1) A minimum of 2 allocated spaces must be provided for the first 32 passenger
capacity on a ferry.

(2) An additional 2 allocated spaces
must be provided for each additional 100 passenger
capacity.

Conveyances

*
Ferries


DSAPT Part
9.4 Number of allocated spaces to be
provided


buses

(1) At least 2 allocated spaces must be provided in each bus with more than 32 fixed
seats.

(2) At least
one allocated space must be provided in each bus with less than 33 fixed
seats.

(3) An allocated space is additional to the fixed seating capacity.

Conveyances

*
Buses except dedicated school buses


Seating Capacity of three Brisbane Transport Buses

M.A.N
A69 18.310

Seating: 44 | Wheelchair: 2 | Capacity: 62


Scania K310UB6x2

Seating: 54 | Wheelchair: 2 | Capacity: 98


Volvo B10L

Seating: 37
-
41 | Wheelchair: 2 | Capacity: 58
-
62


http://btbuse
s.info/?GoTo=FleetModels



AS5100.1
-
2004, Clause 9.11 Pedestrian bridges

The geometric requirements for pedestrian bridges shall be as given in Table 9.11.


6







Submitted by
Spinal Injuries Association

109 Logan Rd

Woolloongabba, QLD, 4102

www.spinal.com.au