VOLUME 2 Guidance Notes on Completion of Self Audit Form Disability Discrimination Act 1995 (Part III) Self Audit Pack Volume 2 - Foreword 1.0 Foreword These Guidance Notes are designed to help you develop your own policy for your own business. Your business is unique and only you can work out the appropriate strategy for that business and implement it. We want you to decide the 'Best practice' for your business when it comes to complying with the Act. When you have evaluated your own situation and decided on your own specific policy and the strategy by which you aim to achieve it, communicate! Make sure your staff know all about your approach to complying with the Act and that they understand their legal obligations for compliance with it. Even more importantly, make your policy known to your customers as well. Make sure that they are on your side and see clearly how you and your staff are responding to the new requirements by improving access and service levels across the board. Don’t forget! It is the responsibility of owners, managers and staff to ensure that all customers’ rights are recognised and that no one suffers discrimination. 2.0 Introduction Volume 2 is designed not only to help you in determining your own policy and strategy, it includes supporting information to help you complete the Self Audit questionnaire contained in volume 3 (Volume 3 is available as an Adobe Acrobat pdf file - please contact the DAC for assistance if required. DAC contact details at bottom of this document). These guidance notes will help you reach decisions about the reasonable adjustments you can make in order to comply with the Act. The advice given is an accumulation of practical examples gathered from established research, the expertise of individuals and various disability organisations. We believe it offers service providers a wide range of feasible improvements within the context of a continuous review process. Under the Act, it is your duty as a subpostmaster to make reasonable adjustments to the services you provide. It is important to show that you have considered all the issues relating to your premises and the ways in which you provide your services. You should establish reasonable solutions based on this information and by gathering ideas from your disabled customers and from other local sources. Finally, bear in mind that your duty under the Act is ongoing and cannot be considered once and then forgotten. Your plans and actions should be reviewed regularly and updated as your business evolves. 3.0 General Observations Buildings that have been designed to be inclusive and accessible for all customers have space in which people can move, interact and use the physical features of the environment with ease. The way a building is used and managed has an important effect on how well your business performs in relation to the needs of a wide variety of customers. But we should always remember that your employees are part of this equation too, both in terms of their own interaction with customers and the ease with which they work within their physical environment. Accessibility is the important word when it comes to the physical barriers that can hinder your customers benefiting fully from the services you provide. For example, cluttered floor space, counters that are too high for wheelchair users or too low for the general public, lack of colour and tonal contrasts between the walls and floors, can all form physical barriers to the service you provide. When it comes to accessibility, however, customers should also have easy access to complaints procedures. Check if the services that you offer are meeting the needs of all your customers. Ask disabled customers and disability organisations on a regular basis if the services you provide meet their requirements. If you make changes that make life easier for disabled customers you will also improve the shopping experience for all your customers. Through this, you will increase customer loyalty and generate more opportunities to improve your business. And don’t forget, disabled customers have an estimated spending power in excess of £60 billion per annum. You may already be doing many of the things required, but make sure you get your fair share of this income. Finally, do remember to include your general shopping area in the review - all these comments apply just as importantly to this area as they do to your Post Office section. 4.0 Routes To Your Business The immediate environment outside your premises and the route to your door taken by customers, either as pedestrians, vehicle users or customers using sticks, is the first thing to evaluate. You may not be able to control these factors directly, but be aware of the things that can make difficulties for your disabled customers. For some of these access problems on the approaches to your premises, you may need to inform your Landlord or Local Authority (usually the Highways Department). Major standards and guidelines about approaches to premises include: 4.1 Parking provisions Ideally, suitable well-lit car parking bays for the vehicles of disabled people should be located within 50 metres of your premises. Most sub-post offices won’t have this, or even direct control of such facilities. However, try to get your disabled customers or local disability groups to help improve a poor situation by lobbying the Local Authority, for instance. 4.2 Pathways The footpaths approaching your premises should be well laid, correctly maintained and be free of potential hazards such as cracked flags, or poorly fitting manhole covers. 4.3 Paving and street furniture The condition of paving and other street furniture immediately outside your business is a critical consideration. Footpaths should be level, non-slip and in good order. Your Local Authority is responsible for this on public highways. Seating and bollards should be grouped where possible and be adjacent to, but positioned off the direct line of pedestrian travel. Ensure the safety of ‘A’ frame type signs and displays placed on the pavement (including newspaper, lottery, fruit and flower displays) as they will obstruct or endanger visually impaired customers and, technically, are illegal under the Town and Police Clauses Act. 4.4 Drain covers Drain covers should be in good order and fitted flush with the pavement. Although this is obviously not your direct responsibility it is good practice to report problems to the appropriate Local Authority or Landlord. 4.5 Street lighting The provision of good street lighting is of prime importance and footpaths need to be well illuminated, particularly on dark early mornings and on late afternoons in winter. Additional lighting can be used to identify hazards and also provides a friendly and clear identity for your premises. 5.0 External Facilities 5.1 Windows and doors Any windows that open onto a public footpath must be checked to ensure that they do not cause an obstruction or a health and safety hazard when open. 5.2 Buzzers Where the access is not a level one, a buzzer, together with a sign indicating that assistance may be summoned is often a good idea and should be made available at an appropriate spot. This and any other buzzers should be situated between 950mm and 1200mm from floor level. Such an adjustment may not be needed if the customer is clearly visible from the counter and you or your staff can go outside your premises to serve the customer. Of course, you will need to take security into account when planning any such adjustments and alterations to the service you provide. 5.3 Signs Signs should indicate clearly the auxiliary aids and facilities available. The use of internationally recognised symbols and visible type colours (e.g. black on yellow pictograms) is recommended whenever possible. 6.0 Access Into Your Premises Remember, as far as the Act stands currently, physical adjustments are not required to be in place before 2004. Apart from the fact that time has a habit of rushing by, it is good practice to plan now and implement those plans as soon as possible. 'Do it now' should be your watchword and just think of the P.R. value for your business. To start the process, evaluate everything from your customers’ point of view. For example, walk the journey they need to make into your establishment and try to put yourself in the shoes of a disabled person making that journey. Make careful notes about the following: 6.1 Steps Well-lit and clearly marked steps should stand out from the pedestrian route. Best practice advice is for their edges (nosings) to be colour/tonally contrasted, ensuring that they can be seen clearly. They should have suitable handrails on both sides. 6.2 Handrails Handrails should be non-slip and between 45mm and 50mm in diameter. They should have good colour / tonal contrast to distinguish them from their surroundings and be fixed securely. There should be a vertical clearance of 50mm between the rail and handrail support 6.3 Ramps They are essential for wheelchair users and people with push chairs to enter the premises. If you have ramp access into or inside your premises, they must be slip resistant and well maintained. Normally ramps should be sited alongside or close to steps and not have an incline steeper than 1 in 12 (1 in 15 preferred). 6.4 Entrance doors The clear opening width of an existing entrance door should be at least 800mm and the threshold should be flush wherever possible. If your premises have a double door entrance, the clear opening width of one leaf of that door should be a minimum of 800mm wide. Be aware that protruding door furniture may limit the width of the opening. Importantly, if you are planning to build new premises or have extensive refurbishment carried out on existing premises, you are strongly advised to take the opportunity of ensuring that all doors have minimum clear opening widths of 900mm - wider still if it is an electronic door. Doors should be kept free of obstructions and be easily visible. This can be achieved by using good lighting and a colour/tonal contrast for the frame or door surface (compared to the background and environment at large). It is essential that fully glazed doors have contrast strips in or on the glass. If the door is not glazed, a vision panel is required in order to avoid collisions. The zone of visibility is between 500mm and 1500mm from the floor. Doors should be capable of being opened easily with a single one-handed motion. Many people have problems pulling or pushing doors manually, therefore, set automatic, mechanical ‘Closures’ at minimum pressure. 6.5 Automatically controlled doors Always a good idea, they need to be set to open and close slowly. Ideally, a button (located on the same side as the handle at a height of between 750mm and 1000mm from the ground) should control the door. It must be illuminated at night. Like manual doors, solid automatic doors need a vision panel and it is particularly important that glass automatic doors have colour/tonally contrasted vision bands running through the glass. Both features help avoid unnecessary accidents. 6.6 Door handles Door handles need to be easy to use for people with a wide range of disabilities. Lever handles of a horizontal design are best and should conform to the minimum specification of 45mm finger space between the handle and the door (to prevent loss of grip or trapped clothing). Handles should also have a diameter of 20mm to 35mm, and be situated 50mm in from the edge of the door at a height of 950mm from the floor. Colour and tonal contrast are again important features in assisting identification by disabled people. 7.0 Inside The Premises 7.1 Lighting All customers benefit from good, consistent lighting throughout the premises and, correctly planned, it can be used to accentuate interior colours, tone and texture. Lighting should be arranged in a way that it does not cause glare, reflection or areas of dark shadow. Also, don’t forget! Windows, blinds and lamps all need a regular clean to maximize the light available. 7.2 Floors and furnishings All floor surfaces should be flush and level, non-slip and non-reflective. Deep pile carpets and rush matting are best avoided as hazardous to those with mobility problems and a cause of drag for wheelchairs. Loose mats are definitely a danger because they present trip hazards, so foot wipe mats should be recessed and flush with the floor. Avoid coir (dirt) mats as they deflect wheels on prams/pushchairs and wheelchairs. Remember that patterned carpets can cause visual confusion and reduce good colour and tonal contrasts between floors and walls. 7.3 Circulation space/queuing system It is recommended that aisle widths are a minimum of 1000mm wide. At the end of all aisles, turning space should not be less than 1200mm wide. Ideally, circulation around counters should be 1500mm wide though it is recognised that this may not be possible in all situations. If this is the case then 1200mm wide is the minimum deemed reasonable. Where a queuing system is in use consideration should be given to: (a) Width of barriers - they should be wide enough for a wheelchair to turn within the queuing system. (b) Call system - where you have one installed you will need to adjust the auditory volume and possibly provide a visual signal as well. (c) Illuminated numbers at cashier points - when installed, their size and visual clarity must be adequate for partially sighted customers. (d) Seating for those needing to rest while waiting for service - should be designed so that users do not lose their place in the queuing system because of their disability. (e) Queuing - a reasonable alternative method of service should be advertised and provided for an individual who has difficulty standing in a queue for any length of time. For example, such people may need to be served immediately by your staff and queuing thus avoided. (f) Clear signs - are needed to show where disabled people should go to in order that they may receive additional assistance and service. (g) Auxiliary aids - such as easy grip pens and lap trays should be readily available. 7.4 Walls, ceilings, skirting boards, door frames Matt surfaces with good colour/tonal contrasts between walls and floors enable those with visual disabilities to identify objects and avoid hazards. Changes in the colour and tone of floor finishes help to outline circulation routes. 8.0 Fixtures And Fittings Fixtures, fittings and other furniture in retail outlets create barriers to customers, non-disabled and disabled people alike. Remember! Aisle widths should be maintained at a minimum of 1000mm wide, so do not restrict them with non-essential furniture. Keep them as clutter free as possible. 8.1 Public telephones Telephones should be located in positions that allow ease of use for all customers, including those who are wheelchair users. The coin slot or top button should be at a maximum height of 1200mm from the floor. If you are unsure as to the needs of disabled customers consult them as well as your telephone supplier. 8.2 Internal post boxes and stamp machines Internal post boxes and stamp machines should allow easy access for all customers. People with dexterity problems may have difficulty using the stamp machine and those who are seated or short in stature may not be able to reach the post box slot. Consideration must, therefore, be given to the height of the boxn slot and stamp machine and the 1200mm height above floor level is still a good guide. 8.3 Seating Somewhere for people to sit down can be a help to all customers and it is particularly beneficial for disabled and elderly customers. Consult with your customers about their needs and find out what they would like (See also 7.3 (d). above). Flimsy, lightweight, plastic chairs should be avoided. They can topple over too easily. Seats should have armrests connected to the front and back of the seat (to avoid the seats tipping when pressure is exerted on them). Don’t forget that it is important to allow space beside the seats for the use of wheelchair users. 8.4 Vending machines and merchandising displays For short people and wheelchair users the controls on a vending machine should be within reach (again, no higher than 1200mm from the ground). Controls should be easy to operate and should not be flush with the front surface of the machine. Instructions should be easy to read. Displayed items should be at an accessible height and if this is not possible then a sign inviting customers to ask for help will be needed. 8.5 Writing desks/shelf The provision of a wheelchair accessible writing desk is an important requirement. However, if this is absolutely impossible, a lap tray, for example, may be an acceptable alternative. Don’t overlook the need to ensure good lighting at all times which helps all customers, particularly those with visual impairments. 8.6 Pens Pens should be useable by all, including anyone with manual dexterity problems. An easy solution, for example, is to slip a pen grip over the barrel of the pen to make the girth fatter. Chain or cord attachments that are too short will prevent wheelchair users from using them. 8.7 Post office counter / points of sales Counter space should be sufficient to allow your customers to fill out documents and forms. They should be at a height that can be used by both seated and standing users and should be fitted, if at all possible, with low as well as high sections. (If this cannot be arranged, then a lap tray is a reasonable alternative). The preferred height for wheelchair accessible counters is between 750mm and 800mm. Ideally, there should be 600mm (minimum 400mm) clearance for the wheelchair user to gain knee access. Edges of counters should be blunt and well rounded and a raised (tonally contrasting) lip at the edge of a counter helps all customers with the picking up of their goods and their money. At least one induction loop system should be installed for customers with hearing aids but should not be fitted to every counter position, only at the first position (there are good technical reasons for this). Where there are 8 or more counter positions an additional induction loop may be fitted at the second position in from the end of the counter. All loops must be tested regularly on a routine basis and staff must be trained and fully conversant in their operation. Finally, don’t forget that counters and screens should be well lit but free from glare and that adequate circulation space (minimum 1500mm) should be available in front of the counter for wheelchair users. 9.0 Ancillary Equipment 9.1 Post boxes Post boxes should be situated in a prominent and well-lit position. Many post boxes are unsuitable for disabled customers and there may be difficulties with the height of the slot and the size of the text on the posting information panel. A reasonable alternative method of giving assistance in such circumstances could be to provide a notice stating that help in posting may be obtained from one of your staff. This is particularly important in the case of external boxes. 9.2 Stamp machines External stamp machines often have signs that are difficult to see and may also be positioned too high for users with a disability. The 'Good Practice' height should be no higher than 1200mm above the floor. Appropriate lighting will be needed for dark winter evenings or early mornings. 9.3 Scales Many customers may have difficulty using manual scales because of the small printed figures on the face of the dial. Electronic (LCD display) may also be too small for those with visual impairments, unless you provide an especially large display. 9.4 Clocks Clocks vary greatly in size and positioning. The positioning, the size, the clarity of numerals on the clock-face and use of tonal/colour contrasts are all important considerations when deciding on what type of clock to provide. 9.5 Signs Design your signs with clarity and simplicity. Always make them from non-gloss materials to cut down reflections and glare. Clear colour contrasts are important and help visually impaired people to read a sign. The best contrast will be obtained by using black on yellow or white backgrounds. Signs should be simple to understand and easy to read. Text should be consistent and use large size print with an appropriate font. Most visually impaired people can read lettering of 50mm in height from a distance of 1500mm and this knowledge will help you to position the signs suitably in the most appropriate place for all concerned. Try not to have too many separate signs and avoid clutter at all costs. Signs should be placed at eye level whenever possible (though suspended signs should never be lower than 2100mm above floor level) and must not be placed where they cause an obstruction. You and your staff should check the positioning of the signs frequently. 9.6 Fire exits Many sub post offices have only one entrance so they may have only one means of escape should a fire occur. However, larger Post Offices usually have more than one way out. Fire exit signs must be placed where they can be seen clearly by all customers. Exits must be clearly marked and direction to the fire exit shown by the internationally accepted pictograms. Never clutter exits with packages or furniture. Advice is available by contacting your Health and Safety Executive to check the sufficiency of your arrangements. 9.7 Fire alarms Fire alarms should have visual and audible signals in order to alert customers with hearing disabilities and visual impairments respectively. <-------------------------------------------------------> Glossary Of Terms Accessible - This means that all customers can use all the facilities and services provided, including using low-level counters, where they are installed. Service providers should indicate the access with internationally approved sign/symbols. Accessible parking- This is better known as disabled persons parking. These are designated parking spaces for the use of orange/blue badge holders, which have hatched markings to allow space for transferring from the car to a wheelchair. Alternative services- This means that you provide an alternative method of delivering a particular service for disabled people allowing them access to your services. For example you may provide a buzzer at the entrance to your premises that alerts staff to the fact that a disabled person needs assistance. Ambulant- Some people with mobility difficulties prefer to walk rather than use a wheelchair and are said to be ‘ambulant’. They may use a stick or walking frame for stability. Audible alarms- A sound alarm system will alert most customers to the evacuation procedures, except those with a severe hearing impairment. Automatic doors- Such doors open automatically either as someone approaches as the result of a motion sensor or, if a person presses a button or remote control. Best practice- This is a term to describe the most up to date way of making the environment accessible to everyone. Circulation Space- This is the area designated for customers to move in. A building can be designed to have plenty of circulation space, but still be inaccessible to disabled people if furniture and fittings leave passageways too narrow. Colour contrasting and blister paving - This indicates to blind and visually impaired people that they are leaving the safety of the pavement, and the crossing point. At uncontrolled crossing points the tactile surface should be a buff colour. This provides a contrast with the surrounding path. At controlled crossings red modified blister paving should be used. Colour/tonal contrast - These are colours that stand out from their background. They help orientate visually impaired people. An example of good colour/tonal contrast is black lettering on a yellow background. Poor tonal/colour contrast would be white on pale cream. DDA 1995 - The Disability Discrimination Act 1995. Disability equality training - Equality training provides knowledge and skills to enable people to begin to understand the experience of disability and the importance of non-discriminatory practice. Dropped Kerbs - These are lowered kerbs, which are between the pavement and the road. They are essential to allow easy access for wheelchair users. They should be installed where there are orange/blue badge bays, entrances to buildings and at crossing points. Enhanced lighting - Lighting is increased. Better illumination benefits visually impaired people. Induction loops - These enhance sounds and help those with hearing aids to hear announcements and communications across a counter or in a meeting. Lap Tray - A Lap Tray is a plasticised or hardboard surface with a beanbag or cushion base that allows it to mould into the user’s knee, creating a stable work surface. Lever type handle - Levers are door handles that are pushed down to open. These should be of a horizontal design and have at least 45mm finger space between the handle and the door. Obstruction free - This is an area, which is free of clutter such as stock, rubbish, inappropriately placed signs etc. Orange/blue badge holders - People who have an orange or blue badge are unable to walk or to be virtually unable to walk. Orange/blue badge holders are allowed to park on double yellow lines for 2 hours at a time. Positive Policy - This is a policy that takes on board the needs of disabled people and offers them the same standard of service as non-disabled customers, which may mean providing more time to give that service. Push/pull handles - Push/pull handles should be ‘L’ shaped and are pushed or pulled to open the door. Ramps - Ramps are either permanently fixed or can be placed at an entrance to allow wheelchair users to access the premises. Signage - Good signage is important. Signs should be easy to read, positioned appropriately and have good tonal/colour contrast with consistent text and font throughout the building. Slip-resistant - This is material that will not become slippery when it is wet. Suspended signs - Signs that are hung from the ceiling cannot be positioned at eye level or they will endanger those with visual disabilities. Tactile - People who are blind or visually impaired feel their way using tactile information. Tactile information is touched. Braille is an example of such information. Words are felt as a series of raised dots. Voice transfer unit - This is a system to overcome difficulties where a screen is situated between the customer and the clerk. Vision bands - These are bands or stripes that are placed on glazed or partially glazed doors. They help customers and staff to identify the door. Vision panel - These are glass panels that allow people to see through to the other side of a door. The glazed area should be between 500mm and 1500mm from the floor. Visual alarms - These alarms alert people with hearing impairments to hazards by the use of flashing light signals. As an addition to an audible alarm system they are invaluable to prompt evacuation. Visually impaired people - These are people who have some residual sight. Walking Aid - Crutches, walking frames or sticks are all mobility aids. Wheelchair accessible counters - These are counters that are for wheelchair users to use. Wheelchair users - This applies to people who use a wheelchair to propel them around. Wheelchairs can be powered or manual. <-----------------------------------------------> Sources of Help and Advice Publications: DDA Code of Practice - the elimination of discrimination in the field of employment against disabled persons or persons who have a disability Stationery Office (HMSO) ISBN - 0 - 11 - 270954 - 0 Northern Ireland ISBN - 0 - 337 - 09435 - 7 DDA Code of Practice - Rights of access - goods, facilities, services and premises. Stationery Office (HMSO) ISBN - 0 - 11 - 271055 - 7 Northern Ireland ISBN - 0 - 337 - 371 - 091 British Standard BS 8300: 2001 - Design of buildings and their approaches to meet the needs of disabled people - Code of Practice, ISBN - 0 - 580 - 38438 - 1 The Building Regulations 1991 Approved Document M Department of the Environment and Welsh Office, (Technical Standards in Scotland) Barrier Free Design by James Holmes-Siedle Published by Butterworth Architecture ISBN - 0 - 7506 - 1636 - 9 Building Sight - A handbook of building and interior design solutions to include the needs of visually impaired people RNIB, ISBN - 1 - 85878 - 074 - 8 Sign Design Guide - a guide to inclusive signage JMU Access Partnership ISBN - 18578 - 412 - 3 Funding: Some financial aid may be available to your area, particularly if it is a Listed Building, or a conservation area. Contact the Access Officer at your Local Authority for information and funding generally. Local Access Groups may also be able to offer advice (contactable from the the Access Officer). English Heritage will provide advice on the availability of any funding in conservation areas (contactable through your Local Authority). <---------------------------------------------------------> Organisations: Remember your Local Authority Access Officer will be happy to offer advice on access issues. Disabled customers and local access groups representing them can also help in areas relating to disability. These should all be listed in your telephone directory. Royal Mail Disability Action Centre Disability Helpline 0114 241 4731 Can give advice on employment and access to goods and services issues. Disability Rights Commission Contact Centre Freepost@MID 02164 Stratford upon Avon CV37 9BR Tel. 08457 622 633 Free helpline and general information on requirements for disabled people. The Employers’ Forum on Disability Nutmeg House 60 Gainsford Street London SE1 2NY Telephone 020 7403 3020 Provides guidelines and good practice booklets to member companies. RADAR The Royal Association for Disability and Rehabilitation 12 City Forum 250 City Road London EC1 8AF Tel. 020 7250 0212 Gives free general information on the requirements of disabled people. RNIB Royal National Institute for the Blind 224 Great Portland Street London W1N 6AA Tel 020 7388 1266 Provides support and advice for people with visual impairments. Dickinson Associates Chartered Surveyors and Access Consultants 17a Coopies Haugh Coopies Lane Morpeth Northumberland, NE61 6JT Tel. 01670 505600. Provides access audits, design appraisals, training and property consultancy. <--------------------------------------------------------------------------> Royal Mail Disability Helpline Telephone: 0114 241 4731 Fax: 0114 241 4534 Calls are welcome through RNID Typetalk and BT Text Direct Email: dac@royalmail.com Website: www.royalmail.com/dac Royal Mail is a trading name of Royal Mail Group plc. Registered number 4138203. Registered in England and Wales. Registered office: 148 Old Street, LONDON, EC1V 9HQ