In the second article on the new Approved Document Part M we offer more guidance to challenge the building inspectors
The erroneous presumption which seems to have affected a number of recommendations in the revised Building Regulations Approved Document Part M (ADM 2004) is that what is convenient for independent wheelchair users will automatically suit other building users. A unisex WC geared to the needs of independent wheelchair users may not be conveniently usable by wheelchair users who have to be helped by someone else. And for ambulant disabled people and standing adults it may not actually be convenient to use wash basins placed at a height which suits wheelchair users.
Unfortunately, a recurring feature of the new Approved Document Part M (ADM) 2004 is its accommodation to independent wheelchair users to the detriment of others - even though there is no explanation of who independent wheelchair users are.
Actually, they are those who use a selfpropelled wheelchair, are unable to walk, whose upper limbs are in good working order, and who, in accessible environments, are able to get into and around public buildings on their own and use their facilities without needing to ask someone else to help them. They represent a small proportion of all the wheelchair users who use public buildings, perhaps only about one in 20, and a tiny proportion of all disabled people, perhaps only about one in 1,000.
Independent wheelchair users use wheelchairs which are commonly of a standard size. They tend, unlike wheelchair users who can walk or who need to be pushed, to have common physical capabilities. From their seated position they can reach upward, forward, laterally and downward, operate light switches and other lowlevel controls, open and close doors, and turn their wheelchairs around in a 1,500mm-diameter space. An effect of this uniformity is that the new Part M design standards for independent wheelchair users can be readily established. No other group of building users has this benefit.
No compromise To satisfy the M1 requirement, provision 5.7(b) reads: 'At least one wheelchair-accessible unisex toilet is required at each location in a building where sanitary facilities are provided for use by customers and visitors to a building, or by people working in the building.' In a range of circumstances - for example in a building where employment conditions will not suit wheelchair users - this is not reasonable.
Nor is it reasonable for design consideration 5.5 to advise that wheelchair-accessible unisex WCs should not be used for baby-changing. There are certain building types, for example supermarkets, where it is more sensible to have the baby-changing facility in the wheelchair-accessible unisex WCs than placing one in both male and female lavatories. The notion that wheelchairaccessible unisex WCs ought to be regarded as the exclusive domain of wheelchair users is unreasonable. Furthermore, for compliance with ADM 2004 there are items - the height of a wash basin where one only is provided, for example - where convenience for adult able-bodied people has to be compromised in order to accommodate wheelchair users. Similarly, a reasonable person in a wheelchair would think it only fair that he or she should accept compromises too.
Turning point Compared with the ADM 1999 unisex wheelchair-accessible WC, which was in accord with the BS 5810:1979, that shown in diagram 18 of ADM 2004 is slightly larger. Its depth is 2,200mm rather than 2,000mm.With its 1,500 x 1,500mm turning space, it is suitable for independent wheelchair users but it may not be convenient for a wheelchair user who needs to be assisted.
To manage conveniently, an assistant who pushes a disabled person in a wheelchair needs a space wider than 1,500mm, possibly 1,700 or 1,800mm.
1The advice in ADM 2004, paragraph 5.9, that a WC in accordance with diagram 18 will enable one or two assistants of either sex to assist a disabled person, is misguided.
The better layout is the peninsular layout. Besides permitting transfer from either side, its advantages are the more generous space for wheelchair manoeuvrabilty, and with it space for two people to assist with transfer where a wheelchair is weighty and cannot be handled by one person alone.
Unisex provision In ADM 2004 the only special feature for ambulant disabled people which has to satisfy the M1 requirement is the 800mm-wide WC compartment shown in diagram 21. It is not satisfactory. For severely disabled ambulant people, the unisex wheelchair-accessible WC (see AJ 19.2.04) is much more convenient; its 2,200 x 1,500mm plan layout gives an ambulant disabled person ample space to manoeuvre. Furthermore, it provides space for a helper to assist and, most importantly, it has a washbasin reachable from the WC.None of these benefits are afforded by the WC cubicle shown in diagram 21.
In ADM 2004, the en-suite bathroom for wheelchair-accessible hotel bedrooms (see layout above) has plan dimensions of 2,500 x 2,700mm, giving a floor area of 6.75m 2, a 40 per cent increase over the area advised in ADMs 1987, 1992 and 1999.
To satisfy the M1 requirement, provision 5.21(d) advises a transfer seat to the bath which has a depth of 400mm; but in diagram 25 a seat with a depth of 750mm is shown. The need for the additional 350mm is unexplained.
Furthermore, small washbasins such as that shown in the diagram are not convenient for disabled people. In an en-suite bathroom where the bath incorporates a hand-held shower, a removable bench seat with suitable grab rails on the side wall may enable a wheelchair user to use the shower. This could be of benefit to ambulant disabled people. (Instead of displaying an inadequate and unsatisfactory bathroom layout of the kind shown in diagram 25, the ADM 2004 might have simply advised the need for there to be a 1,500mm-diameter turning space in a wheelchair-accessible bathroom. ) Slippery slope The rigidity of ramp gradient recommendations isn't helpful. A relevant example is a small high street shop which has two steps at the entrance door, with a rise of 500mm. To make it wheelchair accessible, it may be practicable to place a level platform in front of the door, with steps being incorporated on one side and a ramp on the other. On account of the shop's narrow frontage, the ramp might have to have a gradient as steep as 1:7, making it insuperable for an independent wheelchair user. But a short 1:7 ramp could be manageable for a powered wheelchair or by a person in a wheelchair pushed by someone else. It would also make it easier for those with infants in pushchairs to access the building and use it. However, the prevailing ADM rule seems to be that convenient provision for independent wheelchair users has to be pre-eminent.
Doors wide open For internal doors the minimum clear width will now be 800mm. That is, the width between the internal face of the opening jamb and the most protruding point of the opposite jamb taken perpendicular to the wall - this is likely to be the door handle.
(This will preclude standard 900mm doorsets which give an opening width of 775mm. ) But a standard wheelchair has a width of just 600-630mm, and a competent independent wheelchair user or the pusher of a person in a wheelchair can comfortably pass through a 750mm opening. In the ADM 1999 (page 13), a minimum clear opening width of 750mm was prescribed for rooms within buildings, other than the 1,000mm doorset for unisex WCs. The corresponding minimum clear width for external doors to buildings used by the general public is 1,000mm, thus a single door that could have a 1,150mm doorset or a double leaf door a 2,150mm doorset. The reasons for this are not explained.
The advice in ADM 2004 (paragraph 2.10) is that an automatically operated opening door is the most satisfactory solution for most people.
What is not acknowledged is that a double-leaf automatic door could come with narrower width conditions than those prescribed in Table 2, so beware when specifying.
Blind spot For the benefit of blind people, diagram 4 shows 'corduroy' warning surfaces at the head and foot of stairways. These can be discomforting for ambulant disabled people, as can tactile pavings at street crossings. Interestingly, no substantive evidence has yet been adduced which supports the hypothesis that either surface genuinely helps blind people.
Disabling strategy A disturbing feature of the ADM 2004 is the complexity of the advice in sections 21 for satisfying the M1 requirement and the difficulty the architect will have when attempting to interpret it all.
Previous editions of ADM did not require the architect who presents a scheme for building control approval to apologise for what they have not done that they were told to do. Under the terms set out on pages 16 and 17 of the ADM 2004, the architect now has to produce an access statement. In it, the architect has to explain the reasons why all the various components of a building do not precisely follow the recommendations in the Approved Document for meeting M1 requirements, and why the arrangements (perhaps none at all) proposed in place of the prescribed provisions are sensible and reasonable.While for any particular proposed building not all of the provisions prescribed in sections 1-5 will need to be checked, by my reckoning there are 280 of them altogether.
As described above, the most vexing is section 5, 'Sanitary accommodation in buildings other than dwellings'. For WC accommodation there are four sets of design considerations, and with them 40 provisions for satisfying the M1 requirement.Hopefully, this article will go some way to providing credible ammunition in the verbal battles architects may have to face with local authorities in order to provide decent, meaningful, universal provision for disabled and able-bodied alike.
Selwyn Goldsmith is the author of many definitive volumes on disability accessibility, most recently Universal Design Reference 1.DOE.Vol 2. p165-9