Australia needs a non-regulatory handbook to provide the building and construction industry with best practice advice on emergency egress for people with disability.
While we continue to ignore this issue, we fail to consider the needs of all building occupants in an emergency.
In September 2014, the Australian Building Codes Board (ABCB) released the Emergency Egress for Occupants with Disability, Consultation Regulation Impact Statement (RIS). The document quoted an important finding from a review by the House of Representatives Standing Committee on Legal and Constitutional Affairs:
"Every Australian has the right to expect that reasonable provisions will be made to allow them to leave buildings safely in the event of an emergency. Moreover, it is crucial for equitable, dignified, and independent access to buildings that people with disability can be confident that they will also be able to evacuate from a building in a safe, dignified and independent fashion in the event of an emergency."
The words "every Australian" have some significant implications. According to the Australian Bureau of Statistics' (ABS) Population Clock, our population is at 24,035,924 and growing. Statistically, ABS data from 2012 found that 18.5 per cent of the population has a disability, which equates to approximately 4.4 million people using our current population as a guide. Collectively, that’s a lot of people who need to feel confident that they’ll be able to evacuate from a building in a safe and independent manner.
What’s more interesting is a comment by the ABCB provided in response to the above.
“Therefore, not providing egress from buildings for people with disability is considered unlawful and discriminatory unless a case of unjustifiable hardship can be demonstrated,” the ABCB said.
‘Unlawful’ is a very strong word. Yet fast forward to March 2015 when the Final Decision of the RIS was released by the ABCB and there were some surprising outcomes:
- The National Coronial Information Systems Database reported only three fatalities in non-residential buildings over five years, but none of these were people with disability.
- The Metropolitan Fire Brigade (MFB) reported only two fire fatalities since 2000 involving people with disability in non-residential buildings.
- Only 23 stakeholders responded to the RIS, but these included some industry organisations, such as the Association of Consultants in Access Australia, HIA, FPA, MFB, Property Council of Australia and Vision Australia.
- The proposed changes to the ‘deemed-to-satisfy’ provisions of the Building Code of Australia, being ‘Option 1’ of the RIS, were rejected on the basis of there being no cost/benefit. The five proposed changes included visual alarms installed in accessible areas of buildings; tactile alarms in all bedrooms in small boarding house type buildings and in accessible hotel rooms; co-location of fire-isolated exit within six metres of a passenger lift; accessible egress paths; and accessible features in fire-isolated and external exit stairs. The ABCB’s commissioned research found that the “cost of implementing Option 1 is however considered large and the intangible benefits are unlikely to outweigh the costs.”
- Whilst ‘Option 2’ of the of the RIS proposed that a non-regulatory handbook be developed to provide guidance to industry on emergency egress for people with disability. To quote the ABCB, “Under this option the proposals outlined in Option 1 would be released as a handbook for reference and use on a case-by-case basis by State, Territory and Local Governments and the building industry.”
- Disappointingly, the final sentence of the RIS concluded that based on COAG best practice regulation requirements the RIS recommends that the status quo remains.
And so, some 12 months later the status quo does indeed remain the same. The new National Construction Code (NCC 2016) becomes law on May 1, 2016 and there are no changes introduced to improve egress for people with disability. There’s also no sign of the non-regulatory handbook on the topic to help guide industry to provide for people with disability.
The ABCB believes that “from a life safety perspective, the risk to life is very small.” This might be the case; it is true that emergency events are rare in Australia and that we build very safe buildings with good design methods and fire protection systems, but there is still a risk, and this risk is not being managed very well.
There must be a holistic approach to the area of egress for people with disability. This approach must begin at concept design stage and continue through into occupation and into the ongoing emergency management of the building. This approach must include greater considerations for the occupants within each building, with consideration to their characteristics. Can occupants identify alarms? Can they respond to the alarms? Can they move safely and independently to a safe place outside the building? If not, what can be implemented to make the building safer and more equitable?
This issue needs an increased level of awareness across all sectors and begins with project stakeholders asking these questions at the beginning of any project. For this to be successful, the ABCB must release the non-regulatory handbook to facilitate ease of acceptance of any performance-based approach to achieving compliance with the NCC Performance Requirements. Such a handbook could provide consistency, provide simple to adopt design scenarios and use universal design concepts that consider the needs of all occupants.