Approved Document Part M is out on 1 May. In the first of a two-part examination, we suggest that you argue with Building Control to provide what disabled people really need
'Access for disabled people' was the title of the 1987 first edition of the Part M Approved Document. For the 1992 and 1999 editions it was 'Access and facilities for disabled people'. For the new ADM, which will be brought into force on 1 May, the title is 'Access to and use of buildings'.With it comes a radical shift; out has now gone the 'for disabled people' brief and in its place it simply mentions 'people', presumably meaning everybody.
The new ADM1 states that 'reasonable provision shall be made for people to gain access to and use the building and its facilities. In general, it covers the generality of new public and employment buildings and alterations to existing ones. Requirements M2 and M3 apply to extensions to buildings other than dwellings, and M4 to sanitary conveniences in dwellings.
The extent to which the ODPM was able to embrace this aim was, however, severely restricted; the impediment being that for the generality of building users, people who were not disabled, they had no instructive British Standard Code of Practice to guide them. They were obliged to rely on the 'for the disabled' BS 8300:2001.
Parity begins with a 'P' The 12 pages of section 5 in ADM 2004, 'Sanitary accommodation in buildings other than dwellings', are devoted almost exclusively to the special needs of disabled people, in particular the needs of independent wheelchair users. No guidance is presented on provisions for adult able-bodied people, for children, or for women by comparison with men.
In public buildings generally, though, most notably in department stores and in theatres and concert halls, it is women who are most vulnerable to what may be called architectural discrimination or architectural disability.
When seeking to use public WCs they often have to queue while men do not.
A contributory cause of the discrimination to which women are subjected may be that the architect who designed the building planned equal WC areas for men and women, thereby providing men with some twice as many amenities (urinals and WCs) as women were given; as equal floor areas actually equates to twice as many facilities for men.
To achieve parity for women, the male/female ratio ofWC space in new public buildings needs to be of the order of 25/75, or in the case, for example, of department stores and theatres, 20/80.
British Standard 6465, 'Sanitary Installations', was issued in two parts, in 1994 and 1996. In neither part was there any reference to sanitary appliances for disabled people, BSI's reason being that these were in the domain of BS 5810:1979.
BS 6465 is currently being revised, and it would be valuable were it to present guidance on the design of suitable sanitary facilities for disabled people and the provision for pushchair users, in a form that could be referred to and illustrated in an update of the new ADM.
The planning of public WCs In buildings which comply with Part M, normal sanitary facilities such as public WCs would have level access;
they would be accessible without the need to negotiate steps or stairs, and thereby conveniently reachable for ambulant disabled people or pushchair users.
Just over 10 years ago, a survey of men's WC cubicles in public buildings revealed that, on average, they had an internal depth of 1,472mm, a width of 825mm and an in-opening door giving a clear opening width of 634mm.
Women's WCs may well have been equally small, but they are more commonly disadvantaged by the constricted size and awkward configuration of a typical WC cubicle, not least because they are more likely than men to take an infant or small child in with them. Preferably, the next update of ADM 2004 might advise that for men the dimensions ofWC cubicles with an in-opening should be, say, 850 x 1,800mm, and 900 x 1,800mm for women. A WC compartment which incorporates a wash hand basin on the rear wall by the WC might have dimensions of, say, 1,400 x 1,500mm. Where possible, architects should take these dimensions on board and design to them, over and above the basic dimensions asked of them under the revised regulations.
Enlarged WC compartments The design consideration in paragraph 5.6 of ADM 2004 says: 'The provision of an enlarged cubicle in a separate-sex toilet washroom can be of benefit to ambulant disabled people, as well as parents with children, and people (eg those with luggage) who need an enlarged space.'
The advice is repeated in paragraph 5.12, though again with no diagram showing the suggested plan layout of the enlarged compartment. Not mentioned in paragraph 5.6 or 5.12 is the desirability of its accommodating pushchair users or a baby-changing facility. Curiously, paragraph 5.6 mentions an adult changing table? some mistake, surely?
ADM 2004 thus acknowledges that WCs convenient for ambulant disabled people ought not to be exclusive to them. To satisfy the M1 requirement provision 5.14 (d), it says that: 'An enlarged compartment for those who need extra space (based on the compartment for ambulant disabled people) is 1,200mm wide and includes a horizontal grab bar adjacent to the WC, a vertical grab bar on the rear wall and space for a shelf and fold-down changing table.' But the findings of the sanitary provision research project clearly demonstrated that among ambulant disabled people the need for grab rails in WC compartments was marginal by comparison with the need for level access.
The new recommendations for WC cubicles for ambulant disabled people has 800 x 1,500mm dimensions with an outward-opening door and horizontal and vertical grab rails on both side walls. For severely disabled people, this is unsatisfactory;
the unisex WC compartment (diagram 18) is much more suitable.
Indeed, for the great majority of ambulant disabled people normal WC cubicles or an enlarged WC compartment with a single horizontal rail on the side wall would be sufficient.
The height of wash basins The advice in ADM 2004 (diagram 20) is that the height to the rim of wash basins should be 720 to 740mm for use from a WC and 780 to 800mm when standing - 'any wheelchairaccessible washroom has at least one washbasin with its rim set at 720 to 740mm above the floor', 5.14(g).
A feature of a basin with a rim height of 720-740mm is that a wheelchair user's knees obstruct access to the basin rather than the front of the wheelchair armrest. Assuming that the underside of the basin is typically 170mm below the rim, its clear height above floor level will be 550-570mm, significantly lower than most wheelchair users' knees But a basin placed so that it gives space for knee access would suit most wheelchair users. It would give closer approach to the basin than permitted by the recommended condition, so making hand and face-washing easier, whether done independently or with assistance. A basin rim with an inclined underside would be helpful.
Actually the rim would be better situated at 810-830mm above floor level and it might be worth arguing the toss with the building inspector.
Independent wheelchair users with sound upper limbs have no trouble reaching higher than that.
The data contained in Alexander Kira's influential book, The Bathroom, indicates that basin rim heights between 900 and 950mm would be convenient for ambulant disabled people. For ambulant disabled people with back impairments, a height of 720 to 740mm would oblige them to bend down to reach the basin, undoubtedly causing themselves severe pain.
There is no single level at which a basin can be fixed so that it is comfortably usable by both wheelchair users and ambulant disabled people. A reasonable compromise is perhaps between 780 and 800mm, the level advised in ADM 2004 for people standing.
ADM 2004 diagram 20 shows a wash basin with two vertical grab rails above it. The need for this is unclear.
Where there is a row of washbasins, one at the end of the row might have a rim height of 700mm to suit wheelchair users and children; others would have a rim height of 900mm to suit standing adult people.
For different users, a suitable combination of basin rim heights might be:
l wheelchair users and children only: 700mm (with knee access);
lusers seated on a WC: 720-740mm;
lcompromise for seated wheelchair users, standing children, able-bodied adult people and ambulant disabled people: 780-800mm;
lstanding adult people only: 900950mm.
Selwyn Goldsmith is the author of many definitive volumes on disability accessibility, most recently Universal Design