Bruce Bromley

Bruce has over 32 years of experience in disability access, architectural design, documentation & project management



He formed Equal Access Pty Ltd in 2006 in response to growing recognition, that whilst businesses were being urged to respond to their obligations under the Disability Discrimination Act, the majority of assistance available was focused almost entirely upon the needs of the individual with a disability without an understanding of the impacts and practicalities for building owners, managers and consultants.



Bruce also specialises in evacuation procedures and policy for people with a disability and is a member of the Standards Australia development committee FP-017 Emergency Management Planning – Facilities (AS3745)

The Failures of SDA and Fire Safety

Following on from my previous posts about the safety of participants in Specialist Disability Accommodation (SDA) I thought I would again challenge the status quo of what is perceived to be permitted building classifications vs safe building classifications.

How difficult is it to evacuate one SDA participant from a home in a fire? Now ask yourself, how you would evacuate 10, 20 or even 30 participants in an emergency? We have an SDA development on the books with 34 participants housed above ground level, how will they be evacuated?

We already know based on the SDA Pricing Arrangements for Specialist Disability Accommodation, building classifications 1a, 1b & 2 are permitted to house people with disability. But does everyone understand how quickly a home or apartment like this (without sprinklers) can be engulfed in a fire?

In the following video note the time the smoke alarm is activated, then how long until flashover is reached?

 

 

Now ask yourself. How many people could you evacuate? This applies to all four categories of SDA to varying extents, from High Physical Support, where participants rely heavily on carers due to mobility impairments, to Improved Liveability and Robust, where participants may have a sensory or neurological/cognitive/intellectual impairment also requiring carer assistance.

 

But such deaths will never happen!

 

Download free
Personal Emergency Evacuation Plan PEEP Templates

 

Questions that need to be asked

  • Should I be building Class 1a, 1b or 2 for SDA?
  • Should the building codes be stronger in their enforcement of the safety of people with disability?
  • Should certifiers and fire engineers do more to protect people with disability?
  • Do I want to own a Class 1a, 1b or 2 building for SDA where occupants are unsafe?

 

Why can’t I house multiple aged people in class 1b & 2 but I can house people with disability?

Emergency Evacuation Disabled

Let’s compare aged care occupants and fully accessible/ high physical support SDA occupants and examine what they both have in common.

  • Both cohorts have varying degrees of mobility impairment either from disability or aging.
  • Both cohorts may have cognitive issues due to their disability/ dementia etc.
  • Both cohorts may need assistance to transfer from their bed.
  • Both cohorts cannot self evacuate down multiple flights of stairs.

So why should Residential care buildings for people with disability not have the same controls and protection in place as for the aged? After all, you can’t provide supported accommodation for the aged in a class 1b or class 2 dwelling when they have very similar occupant profiles.

What does the Building Code of Australia say?

Classifications

Class 1a is one or more buildings, which together form a single dwelling including the following:

(a) A detached house.

(b) One of a group of two or more attached dwellings, each being a building, separated by a fire-resisting wall, including a row house, terrace house, town house or villa unit.

 

Class 1b — is one or more buildings which together constitute—
a boarding house, guest house, hostel or the like that—

(i) would ordinarily accommodate not more than 12 people; and

(ii) have a total area of all floors not more than 300 m2 (measured over the enclosing walls of the building or buildings); or

 

Class 2 — a building is a building containing two or more sole-occupancy units.
Each sole-occupancy unit in a Class 2 building is a separate dwelling.

 

A Class 3 — the building is a residential building providing long-term or transient accommodation for a number of unrelated persons, including the following:

  1. A boarding house, guest house, hostel, lodging house or backpacker accommodation.
  2. A residential part of a hotel or motel.
  3. A residential part of a school.
  4. Accommodation for the aged, children, or people with disability.
  5. A residential part of a health-care building which accommodates members of staff.
  6. A residential part of a detention centre.
  7. A residential care building.

 

Class 9c — a residential care building

 

Definitions of a residential care building.

Residential care building means a Class 3, 9a* or 9c building which is a place of residence where 10% or more of persons who reside there need physical assistance in conducting their daily activities and to evacuate the building during an emergency (including any aged care building or residential aged care building) but does not include a hospital.

*9a is a hospital

It is easy to argue SDA for most categories would be at 100% so why are we still building SDA accommodation that is not ‘residential care buildings’?

 

Provision of Sprinklers.

Table E1.5 Requirements for sprinklers

Occupancy Where sprinklers are required
Class 2 or 3 building (excluding a building used as a residential care building) and any other class of building (excluding a building used as a residential care building) containing a Class 2 or 3 part.

 

 Throughout the whole building, including any part of another class, if any part of the building has a rise in storeys of 4 or more and an effective height of not more than 25 m.

 
Class 3 building used as a residential care building Throughout the building and in any fire compartment containing a Class 3 part used for residential care.

Performance Requirements

Whilst the Building Code of Australian includes requirements for emergency evacuation this disappointingly do not include any prescriptive requirements for people with disability.

However, as the BCA is performance-based life safety for people with disability is included, however, typically it is ignored by consultants involved with the delivery os SDA.

 

The performance requirements are as follows.

 

DP4  Exits
Exits must be provided from a building to allow occupants to evacuate safely, with their number, location and dimensions being appropriate to—

        1. the travel distance; and
        2. the number, mobility and other characteristics of occupants; and
        3. the function or use of the building; and
        4. the height of the building; and
        5. whether the exit is from above or below ground level.

 

 DP6  Paths of travel to exits
So that occupants can safely evacuate the building, paths of travel to exits must have dimensions appropriate to—

        1. the number, mobility and other characteristics of occupants; and
        2. the function or use of the building.

 

When reviewing the definition of a Residential care building, it is clear that participants within SDA accommodation would be well above the minimum 10% of persons who reside there that need physical assistance in conducting their daily activities and to evacuate.

Why it is, therefore, acceptable to place SDA supported accommodation participants in buildings that have classifications that are not Class 3 or 9c?

 

Why should all four categories of SDA be built as Class 3

 

To answer this question we must refer back to the Pricing Arrangements for Specialist Disability Accommodation to understand who SDA is provided for.

SDA funding is only provided for participants who meet the eligibility criteria.
Participants who meet the eligibility criteria will have an extreme functional impairment and/or very high support needs.

It is not just required for people that use wheelchairs that cannot self evacuate in fully accessible and high physical support categories. This is because of the range of disabilities all participants may have:

 

  • Physical – wheelchair users, amputees, ambulant, etc:

Participants will not be able to independently evacuate downstairs or may take a lot longer to evacuate due to their disability or because they use a walking frame, crutches or other mobility aid.

 

  • Intellectual – autism, down syndrome, etc: Maybe able to
  • Psychiatric – schizophrenia, depression, etc.
  • Neurological – epilepsy, acquired brain injury, Parkinson’s disease, MS
  • Learning disabilities – dyslexia, dyscalculia, dysgraphia

Participants may not react to smoke and fire alarms either delaying their evacuation or not knowing they need to evacuate.

 

  • Sensory – hearing, vision, touch

Participants may not react to smoke and fire alarms due to deafness or participants with low vision cannot find their way out of a building due to low lighting levels.

 

NOTE: Remember, some participants will have multiple disabilities.

 

Should a ‘Wait in Place’ policy be considered?

My own personal opinion is a ‘wait in place’ strategy within suitably designed SOU fire compartments is the only solution. The design must ensure sufficient time for emergency services to access the site and then evacuate the participants’ floor by floor noting it typically takes four rescuers * to evacuate one person with a disability with a backup crew of four required for levels that are five floors above ground level.
* https://evaculife.com.au/blog/residential-high-rise-evacuation/

OOA and other staff cannot be responsible for the safe evacuation of participants as they do not have formal training. Additionally, OOA typically is provided at the ratio of one OOA to ten participants so having them try and manage an evacuation would be impossible. OOA has the same right as anyone else in the building to evacuate themselves as quickly as possible. The only people that can manage such an evacuation is the emergency services who are specially trained.

The provision of ‘evacuation chairs‘* should be considered within each participant room as this would then reduce the number of rescuers allocated to each participant. These would be adjusted to suit the participant and can be stored in a convenient place for easy access by emergency services. This in turn will significantly speed up the evacuation.

Refuges again should not be considered as it is not OOA (staff )responsibility to organise the transfer of participants into their wheelchairs and then transfer them into a refuge noting the size of the refuge that will be required to accommodate the number of participants on each level. Their OOA only role is to get out of the building and save themself.

 

 

*SDA Consulting is part of the Equal Access Group that also owns EvacuLife the leading supplier in Australia of evacuation equipment for people with disability.

 

 

So my question to you is,

How many deaths will it take before these regulations are applied correctly?

 

 

 

Q & A on Evacuation Planning for SDA

in case of fire do not use elevators use stairsA few weeks ago I received the following questions by a building surveyor/ fire engineer from a client. This from my perspective was very impressive that a building professional would make such an effort to understand the implications of fire safety on SDA participants.

The following details my responses to the questions raised and are typical of questions I am often asked as I believe they provide a better understanding of the risks for all parties.

  • Assuming 70% High Physical Support (HPS) is of limited consequence as we would need to consider a floor-by-floor case, which could have all HPS occupants.

Whether they classified as “high physical support” or “fully accessible” makes no real difference for an upper floor evacuation, neither cohort can self-evacuate.

  • Unless manager and live-in carer (as distinct from OOA carer) is required to be present 24/7, this support cannot be relied on in the assessment, and will only be considered as part of redundancy study.

It would never be expected that an OOA, manager or live-in carer would assist in an emergency evacuation. It is not part of their training nor part of the typical job description. Additionally, it takes a significant amount of time for an OOA to use a sling to hoist someone out of bed into a wheelchair chair/ evacuation chair. I do not consider this to be a viable option in a life safety scenario.

  • Need to understand what exactly HPS may mean – the NDIS Pricing Arrangements for Specialist Disability Accommodation talks about provision for ceiling hoists, but what is the expectation for occupants in the HPS category – is no ability to self-evacuate a reasonable expectation?

Understanding who the SDA is provided for is the first criterion. The SDA Pricing Arrangements states

“SDA funding is only provided for participants who meet the eligibility criteria. Participants who meet the eligibility criteria will have an extreme functional impairment and/or very high support needs

Fully Accessible
Housing that has been designed to incorporate a high level of physical access provision for people with significant physical impairment.
Participants typically use a manual wheelchair

High Physical Support
Housing that has been designed to incorporate a high level of physical access provision for people with significant physical impairment and requiring very high levels of support. Participants typically use a motorised wheelchair or are fully assisted.

It is important to understand, not all participants have a cognitive disability, their disability may be solely physical.

  • Also, consider the BCA definition which discusses persons who ‘need physical assistance in conducting their daily activities and to evacuate the building during an emergency.

All SDA participants based on the SDA price Pricing Arrangements have an extreme functional impairment and/or very high support needs therefore even people in the lowest category of ‘Improved Liveability’ will require assistance due to their disability such as vision impairment, cognitive and ambulant disabilities.

  • Assuming HPS occupants have no ability to self-evacuate, what procedures will the care provider have in place to manage the evacuation of SDA SOUs in a fire emergency?

My personal belief is the policy of evacuation for levels above ground and where an Evacuation Lift in accordance with BCA DP7  has not been provided should be to wait in place for emergency services evacuation. This can be managed as follows:

  • All buildings that accommodate SDA participants should have fire sprinklers.
  • All apartment are constructed as fire compartments as in a BCA class 3 or class 9c construction as they are residential care building.
  • If compartmentation is not provided, a fire refuge provided to accommodate all participants on the level they reside either adjacent to or part of the stair as a fire-rated and smoke protected space may have its merits for improved livability participants, it, however, will not be suitable for FA & HPS as it will be reliant on a person transferring them at night from their bed to a wheelchair, then relocating them into the separate compartment. More about refuges here evaculife.com.au/blog/emergencymanagement-and-evacuation/

 

  • What assumptions have been made that occupants of the Ground Level SOUs can evacuate without assistance? Does this mean no HPS SOUs will be located on Ground Floor?

On the basis participants have an extreme functional impairment and/or very high support needs Self-evacuation should not be considered.

  • We would assume from a fire safety perspective that it is preferable to locate as many HPS occupants as possible on Ground Floor, which appears to be counter to the proposed strategy in the email below.

From an evacuation perspective, there is very little difference in HPS & FA participant abilities when applied to evacuation.

  • Will all HPS occupants be able to be evacuated via a wheelchair? I.e. no occupants would be bed-bound, or otherwise unable to be immediately evacuated (with assistance) via a wheelchair – in other words, does the evacuation strategy and fire engineering response need to consider any other cases?

Most HPS participants will use motorised chairs and due to chair weights incl batteries and motors, it is not possible to carry them downstairs.

If an incident happens at night participants will be in bed. Both HPS & FA participants will most likely not be able to self-transfer back onto their chairs.

The use of evacuation chairs by emergency personal should be seriously considered to mitigate the risk from carrying etc. Consideration should also be given to those on ventilators and how breathing assistance will be maintained during evaculife.com.au/product/evaculife-elite-evacuation-chair/

  • Are some HPS occupants able to evacuate on foot, without a wheelchair, with assistance?

No, as HPS participants  have an extreme functional impairment and/or very high support needs and always use wheelchairs either independently or assisted,

  • Are there any other risks associated with a fire emergency that may impact on the ability to safely evacuate occupants, such as loss of mains power? – e.g. are occupants likely to be reliant on mains powered devices for communication (e.g. induction loop), medical reasons (e.g. ventilators) or the like?

Participants on ventilators as above, however, most have a battery back up built-in. The other cohort where evacuation can have serious impacts is people with conditions like motor neurone disease, Amyotrophic lateral sclerosis (ALS)/ Lou Gehrig’s disease where if a participant is tilted back in a seated position like in an evacuation chair they will have serious issues in breathing.

Additionally people in IL SDA maybe deaf and not hear emergency alarms.

  1. What is the criterion for triggering the presence of OOA? E.g. Is this only for HPS occupants?

OA can apply to all categories. It comes down to requirements of the individual and what is included within their NDIS plan. As an example, you may also have people that are deaf, vision impaired etc.

  • Is there a minimum ratio of OOA carers to SDA occupants?

The maximum permitted is 1:10 This post explains the options in more detail  https://www.accessarchitects.com.au/vista-access-architects-blog/what

  • Without getting into details of design at this stage, even at 2 storeys above Ground, evacuation via stairs is unlikely to be realistic in many cases. Therefore the design solution may need to focus on provisioning the lifts for emergency evacuation and creating temporary on-floor refuges where occupants can wait in relative safety to be evacuated by lift – this may involve use of lift lobbies and sub-dividing L1 and L2 into two separate fire compartments.

Unlikely to be realistic in many cases. Dividing a floor into separate fire compartments, the use of fire isolation lifts presents the same issues as fire refuges as discussed above. How do you get the FA & HPS participant out of their bed, into their chair and out to the place of safety?

Additionally should stairwells be a minimum 1200mm clear to allow for wheelchairs being carried by emergency personnel?

Building sprinklers add a lot to the fire safety design.

  • As part of one of the points above, lifts may be the only feasible way for carers and those providing assistance to evacuate to travel up the building in an emergency as going against the flow of egress from the fire stairs, which already have a reduced discharge width, may not be possible.

Carers assisting with evacuation must not be factored into the fire engineered solution. Carers provide care, that’s all.

  • Other design considerations will likely include upgrade of Ground to L2 to Class 3 equivalent (e.g. smoke detection system), a separate detection system for SDA SOUs connected to OOA SOUs, comms system between SDA SOUs and OOA SOUs (and FIP), separation of Ground Level public corridor with fire-rated construction between fire stair entry doors and glazed openings to car park, enhanced emergency lighting within SDA SOUs.

The alert system should also factor in participants that are hard of hearing.

  • What qualifications will carers etc hold?

Qualifications to care, not assist with evacuation and should not be considered for that role.

Want more information on the evacuation of people with disability?

Check out the following blog posts

Enrolling Specialist Disability Accommodation (SDA) with the NDIA

With the introduction of the SDA Design Standard, the NDIA has implemented a new process for all new as-built dwellings wishing to meet the criteria for enrolment as SDA.  As of 1st July 2021, Certification of the Design and As-built stages for new build SDA must be provided by an Accredited SDA Assessor.

Under the new process a dwelling is required to be certified by an Accredited Assessor to a particular SDA Design Category at two stages:

    1. Design (Provisional) Certification, and
    2. Final-as-built Certification (Mandatory for SDA enrolment).

The 2-stage certification process, as outlined in the Implementation Plan, aims to assure all parties involved that if the dwelling is constructed based on the certified design then the dwelling will most likely be approved for use by the NDIA.

At Design (Provisional) Certification stage, an Accredited SDA Assessor must be engaged to assess the design against the requirements of a particular SDA Design Category. Once satisfied that the design is compliant with the SDA Design Standard, the assessor will issue Design (Provisional) Certification. The certification is ‘Provisional’ at this stage as the dwelling has not yet been built. It is important to note however that Design (Provisional) Certification cannot be registered with NDIA, as only a built dwelling can get a Final Certification suitable for NDIA enrolment.

Young woman with a disability in wheelchair at home in living room.Once the dwelling is built, the SDA Assessor is required to undertake a site inspection to ensure all relevant features, as listed in the design requirements section of the SDA Design Standard for the relevant design category, have been provided. If the assessment is successful and the Final-as-built dwelling is deemed compliant, the Accredited Assessor will issue the applicant with a Final-as-built Certificate of SDA Category Compliance as well as a copy of the SDA Assessment Summary Form. These documents are required to enrol the dwelling as SDA with the NDIA.

All SDA dwellings must be enrolled with the NDIA before any SDA supports can be provided.  To enrol an SDA dwelling, registered providers must complete the SDA Dwelling Enrolment and Declaration form and submit it to the NDIA.

Only Registered SDA Providers can enrol a dwelling, as provider details must be recorded at the time of enrolment. Providers registering for SDA in all other states except Western Australia need to register with the NDIS Commission. Providers in WA, however, are required to comply with the NDIA Terms of Business, Guide to Suitability, and the Quality and Safeguards Working Arrangements.

A list of Registered SDA Assessors and more information on the NDIS SDA Design Standard and Implementation Plan can be found at the following link:

https://sdaassessors.org.au/

Additionally, further information regarding SDA Registration as well as the Dwelling Enrolment and Declaration forms can be found here:

https://www.ndis.gov.au/providers/housing-and-living-supports-and-services/housing/specialist-disability-accommodation/sda-registration-and-dwelling-enrolment#registering-as-a-provider-for-sda

What is a Breakout room in an SDA Robust home?

A separate room is designed to respond to the individual disability-related needs of the participant. This means the rooms contain finishes and equipment suited to the preferences of the resident and tailored to support their needs. It does not need to be a large room, however, should have enough circulation space for furniture and equipment.

For people in the community with very high needs, securing suitable housing can be a challenge – but now, Specialist Disability Accommodation (SDA) aims to change this. SDA is available to participants of the National Disability Insurance Scheme (NDIS) who are assessed as needing a special housing solution. It provides financial support to help people with high need disability to rent, buy or build a home that includes the support features that they need.

Robust housing is a category within the NDIS SDA design options, purposefully built to provide a high level of physical access provisions. A robust home is achieved using products, materials and features that minimize the risk to participants and the community and reduce the frequency of reactive maintenance.

The design includes adequate space and safeguards to support the needs of residents with complex behaviours and provides areas of retreat for other residents and staff to avoid harm.

Multi-Sensory-Rooms-and-EnvironmentsA recently added feature to the Robust category within the new standard is the Breakout Room, a separate room designed to respond to the individual needs of the participant. It is not designed for use as a study of living / dining area but aimed at providing opportunities for learning, exploring, or relaxation. This type of room would typically contain equipment, sound and lighting for appropriate activities to each resident.

It is important to note a breakout room is not used as a seclusion room, and there are stark differences between the two. A seclusion room provides for the sole confinement of a distressed or agitated person requiring separation for short periods at any time on an involuntary basis. Studies show the use of seclusion rooms to cause negative experiences in both participants and staff. The use of Breakout rooms however, are a less distressing approach intended to soothe, calm and encourage a sense of playfulness and curiosity.

The requirements of the breakout room within the new SDA design standard includes:

  • A dedicated area intended for use to enhance learning, exploration or positively impact mood. A living room used for both general recreation and for breakout purposes may cause conflict and unnecessary distress for residents.
  • The expected use of activities, equipment, sound and lighting in ways that are appropriate to current residents. When designing Breakout rooms where the proposed residents are unknown, flexibility and adaptability is key, where equipment can be used for a range of different activities or adapted to suit resident preferences. For example, lighting with interchangeable colour filters and sound equipment which offers silent vibrational features as well as audible tones.

It is important to note a breakout room is not a mandatory requirement in any SDA design category, however, it is highly recommended in Robust homes to enhance a resident’s coping mechanisms and support their quality of life.

In fact, studies have shown breakout rooms, or multi-sensory environments as they are also known as, to provide many benefits to health and wellbeing. The use of sensory rooms has been shown to create positive experiences for participants, such as letting go of control and increased self-confidence, emotional self-care and well-being.

For more information and guidance on what to include in your breakout room design, see https://www.disabilityaccessconsultants.com.au/multi-sensory-rooms-and-environments/

Funding for Robust SDA is available on new builds and existing stock. For compliance, all SDA dwellings must be designed and maintained to a standard that is consistent with the surrounding properties and neighbourhood, they must recognise the importance of outdoor areas and must be built on land that is an adequate size for the number of residents.

For more information on how to design and build Robust housing, see https://sdaconsulting.com.au/how-to-design-and-build-robust-housing/

Making Emergency Management Compliance of SDA’s Simple

Keeping everyone safe in a multi-storey building that contains Specialist Disability Accommodation, is the responsibility of both the SIL provider and the SDA owner/provider.

Unfortunately, the Australian Building Codes Board negligently ignores the rights and life safety of people with disability by excluding any prescriptive requirements within the deemed-to-satisfy sections of the Building Code of Australia that address the protection and safe evacuation of people with a disability. Like most things I personally think it will require an incident involving loss of life of people with disability before anything happens with building legislation, as if Kew Cottages, Childres Backpackers and Quakers Hill aged care were not enough.

 

Download free Personal Emergency Evacuation Plan PEEPs templates for Specialist Disability Accommodation SDA

 

For anyone developing SDA’s within a multi-story building you must ask yourself, is the environment I am providing or managing safe for the participants? What planning is in place should a fire or other emergency occur? How will people requiring a lift to access a building evacuate when lifts cannot be used?

EvacuLife_Elite_Evacuation_ChairKeeping everyone safe in a multi-storey building while also ensuring compliance with these standards doesn’t need to be so complicated. Industry-leading equipment designed to meet specific regulations around emergency evacuation planning for hospitals and facilities can make compliance far simpler—and keep people with disability far safer.

It’s this focus on simplifying compliance that led EvacuLife (Part of the Equal Access Group Pty Ltd) to release the Elite Evacuation Chair, which is considered the gold standard in evacuation equipment for people with disability or limited mobility, the elderly and people with medical conditions.

Light, safe and easy to move and use for a single operator, the chair has been designed for use in multi-story buildings with a braking system in its rear wheels that blocks forward, backward and rotational movement – even on steep slopes. And, with a special tracked system, the evacuation chair can grip firmly onto stairs for a safe descent.

Ultimately, if you seek to ensure compliance with emergency planning regulations for facilities, the Elite Evacuation Chair from EvacuLife is the ultimate all-in-one solution.

 

View the EvacuLife Elite Evacuation Chair
View other Evacuation Products

Useful Resources

How to Design & Build Robust Housing

Prepared in conjunction with Anna Fleming from Purposed Housing Australia.
Photography Bruce Bromley

When planning Robust Category Specialist Disability Accommodation (SDA) suitable for participants who may require positive behaviour support, there are many designs and operational factors that must be closely considered. From selecting the site itself to planning the environment on both the inside and out, designing and developing a space that meets the needs of the individual is key.

To do this, it’s important to create a dwelling that not only meets industry best practice standards but also suits each of the participant’s needs, including any highlighted in a positive behavioural support plan (BSP). For some individuals, this will mean adopting all of the following guidelines, while for others who have appropriate support in place, only some of the recommendations will be necessary. With this in mind, each robust setting should be designed, developed and operated in partnership with people who know the proposed participants and their individual needs and understand the requirements of any applicable BSPs. This will ensure the best outcome for participants in an environment that minimises the need for restrictive interventions.

So, if you’re looking for guidance to assist in the planning and implementation of accommodation suited to individuals in need of positive behavioural support, in this article, we’ll discuss in a high level of detail the best practice recommendations for Robust Category SDA design.

Some Notes on Restrictive Practices

There may be times when individuals (for example, some people with disabilities such as autism, severe mental health conditions and other psychosocial disorders) display behaviours that put themselves or those around them at risk. These behaviours are often due to a lack of ability to communicate and understand the world around them. It’s useful to remember that all behaviour is communication, and a Functional Behaviour Assessment and associated BSP will help to identify the function and precursors to the behaviour. Importantly, this will also provide proactive and reactive strategies as well as cues for escalation and appropriate responses that are in line with a current and authorised BSP.

If your dwelling requires environmental restraint, be aware that from July 1, 2019, the NDIS Disability Restrictive Practices and Behaviour Support Rules 2018 includes this as a reportable item. This is an important consideration for new builds, and further details can be found on the NDIS Quality and Safeguards Commission website.

Identifying and Minimising Triggers

In some cases, behaviours may be triggered by objects or sounds in the built environment. These will vary from person to person and could occur in one or more of the five senses (sight, smell, sound, taste and touch). The individual may be hypersensitive (where the sense is intensified) or hypo-sensitive (under-sensitive). It is essential to be mindful of possible triggers when planning a robust design category space and, where possible, minimise or avoid them.

Some examples of potential triggers for hypersensitive and hypo-sensitive individuals include:

  • Hypersensitive – a person with autism who is hypersensitive to sound may find some background noises unbearably loud or distracting. These sounds would largely go unnoticed by others; however, in those who are hypersensitive to sound, it can cause anxiety or even physical pain.
  • Hypo-sensitive – those who are hypo-sensitive may not feel pain or extreme temperatures, and they can also display a reduced awareness of their body. This makes it harder to navigate around rooms and avoid furniture and other obstructions, so including adequate space within the building is a must.

Challenging Behaviours

Environmental aspects can also trigger challenging behaviour, so it’s vital to look closely at the design to ensure the risk of this is minimised. Behaviours can include aggression (hitting, slamming doors, etc.), property damage (breaking furniture, doors and windows, etc.), self-injury (slapping, headbanging, punching, etc.) and other behaviours (switching on dials, eating inedible objects, running away). The built environment plays a big part in reducing the frequency and impact of these behaviours. When the layout is well-designed and the materials chosen with care, it promotes a feeling of calm, security and well-being, which reduces the risk of harm to the person, support workers and the property.

When designing a robust environment, it’s essential to look closely at factors (both internal and external) that could be potential triggers. These include:

  • noise
  • location
  • temperature
  • overcrowding
  • enclosed spaces
  • dark or bright rooms
  • materials or objects in the environment.

A key objective of this article is to assist those involved in the design of a robust dwelling project to greatly reduce (or, where possible, eliminate) the need for restrictive and/or positive behaviour support interventions. This requires a high level of interaction between the designer, carers and support providers and the proposed participant.

Design Elements

When planning and implementing robust category dwellings, some key design elements must be closely considered. These include:

  • Type of building
  • Site selection
  • Site access and safety
  • Outdoor spaces
  • Colours and furnishings
  • Living areas
  • Kitchen and meals
  • Bedrooms
  • Bathrooms and laundry
  • Walls, ceilings and windows
  • Doors, gates and locks
  • Corridors and flooring
  • Lighting and electrical equipment.

Below, we share the key points to factor in when planning and designing each of these elements.

 

Robust Television Enclosures

Introducing the Turtle Tough robust television enclosure – the ultimate solution for protecting your TV in high-risk areas and specialist disability accommodation. Crafted from 3mm steel and featuring a 12mm polycarbonate face, this enclosure is built to withstand even the harshest conditions.

 

Robust Television Enclosures available from Access and Safety

 

Type of building: It’s important to highlight that apartment buildings and double-storey properties are not suitable for robust design category dwellings due to the risks associated with participants and staff, i.e. falling or being pushed downstairs. However, single-level buildings that fall within the duplex, house and group home categories can be designed or adapted to meet the best practice recommendations.

Site selection: When choosing a site, look for accommodation that is well-placed within the building and also within the wider community as well. Consider the proximity to neighbours, roads and other environmental noise sources. Be aware of nearby schools, kindergartens, childcare centres, etc. and check the appropriateness against any restrictive requirements of the tenants. For example, some individuals may be on Community-Based Orders or Supervised Treatment Orders, and all conditions must be strictly adhered to.

Look at the location within the development and the ease of access to community facilities. Plan for adequate parking on site for both staff and visitors to ensure a shortage does not discourage family and friends from visiting. Keep in mind that there can be two or three staff on duty at any time, plus additional visits from allied and professional health services.

Site access and safety: Inside, each room should have a clear exit to allow participants and staff to remove themselves easily if required. It is recommended that the design allows for observation of the participants without creating a sense that they are under surveillance. For new builds, the inclusion of sound-dampening materials is recommended, and the layout and room proportions are designed to assist with good acoustics.

All windows and doors leading outside must be fitted with security locks, and secure boundaries must be maintained in the outside areas and garden. External doors should include peepholes, and the exit should never lead directly to an outside public space or road. Sensor lights installed near external doors will enhance security, as will a video intercom with an electronic doorbell that can be heard throughout the dwelling. Avoid pathways that are obscured by plants or corners, and ensure there is a clear and obvious pathway from the car park into the dwelling. As an additional safety measure, automated gates on the boundary may be considered for vehicle access.

Keeping safety and security provisions subtle creates a more relaxed environment that allows participants to move around freely. Access cards can be an effective way to achieve this. However, approval may be required. Locks may also be fitted to cupboard doors and drawers to minimise the risk of damage or injury from electrical cords, connections and other loose and potentially dangerous items (when approved in an individual’s BSP for safety). However, lock installation is classified as an environmental restriction, so always seek advice or approval before installing.

Outdoor space: When designing outdoor areas, promoting a sense of space and calm is key. Offer a range of outdoor zones if possible (including some covered space), utilising the front, back and side areas of the property to achieve this. Keep any landscaping layouts simple and open, with minimal obstructions. This will avoid a feeling of restriction or containment, allowing participants to relax and enjoy the space. Some ideas include a simple, circular pathway (with no odd corners), clearly delineated with textured hard landscaping. Avoid using pavers (due to the potential for removal and patterns) and loose stones and rocks (including pebble rocks in garden beds). Including sensory and interactive outdoor features such as a basketball ring, soccer net, nest swing, sculptures, sensory garden, herbs, vegetables, and water features can further enhance the use and enjoyment of the space.

SDA Robust Private Open Space with BBQ

Unscalable fences should enclose all outdoor areas with a minimum 1800mm height (or 2100mm if local council regulations allow). They may be complemented with on-ground low shrub borders to discourage exit over the fence, increase privacy and create a feeling of calm. The addition of plant life should always be discussed with carers first, as some participants may tend to remove vegetation. If possible, the outdoor space should include areas where tenants can celebrate special occasions with family and friends. This is especially important as some participants cannot tolerate public spaces, and it is often easier for everyone to get together in the tenant’s home.

SDA Robust Private Open Space with Relaxing Area

Colours and furnishings: In any robust design category dwelling, furnishings should be minimal and non-complex to reduce sensory stimulation. Getting the balance right is key to avoiding creating an institutionalised feel. Keep it simple, using a limited palette of colours, patterns and materials with subtle visual details such as contrasting coloured walls. Opt for a ‘less is more’ approach, leaving plenty of space for movement, as people with positive behavioural support can be more guarded about personal space, and any encroachment can trigger unrest.

Living area: When planning the living space, select minimal appropriate furniture to ensure safety and comfort. Choose built-in TV cabinets and provide bolted-down furniture where possible. The surfaces of tables should be scratch-resistant and heat-resistant and not made from glass or thin timber panels. Leather couches with a steel frame are preferred as they are quite durable and can be easily cleaned and bolted to floors. Vinyl is not recommended as it can be easily ruined (especially when participants exhibit obsessive behaviours such as ‘picking’ at details such as stitching, joints or sealant). All pictures displayed should be bolted to walls with no glass in the frame.

SDA Robust Living Areas

SDA Robust TVs

Kitchen and meals: In the meals area, bolted-down tables and bench seating are best, as chairs may not be suitable for some participants. Ideally, the kitchen should be located in a separate room that can be locked and may also include a servery shutter if required. In some cases, lockable cupboards and drawers will also be needed; check the tenants’ BSP for further guidance. All benches, cabinets and cupboards should have round corners and edges and a heat-resistant work surface, and electronic equipment should ideally have a master switch.

SDA Robust Kitchen 1

SDA Robust Kitchen 2

SDA Robust Kitchen 3

SDA Robust Meals Area

Bedrooms: When designing the bedrooms, include built-in cupboards, storage and secured TV cabinets. The family of the participant will generally provide all furnishings. However, the SIL provider will need to furnish if hardship is claimed. If requested, some bedrooms may include a mini kitchenette with a sink, bar fridge and tea and coffee-making facilities.

SDA Robust Bedroom 1

No glass is allowed on wall art, and all pictures must be securely bolted to the wall. In addition, some tenants may also require the bed to be bolted to the floor. When selecting the flooring, carpet is best avoided if the tenant has continence issues. It is also essential to provide a private outdoor courtyard, which may be enhanced by including painted murals on the fence.

SDA Robust Bedroom 2

Bathrooms and laundry: Creating a safe environment in the bathroom is paramount, so choose taps and showerheads that are simple, rigidly controlled and free from sharp corners. In the shower, a ceiling shower rose, and a detachable hose hand shower is recommended. Ensure the basin is fully recessed within the vanity and includes integrated overflow protection if possible. Set soap trays and toilet roll holders into the wall and ensure mirrors are made from non-glass materials firmly fixed to the wall. A bath should be included where a participant has requested for use as part of their relaxation or de-escalation therapy, and commercial-grade vinyl flooring and vinyl wallcoverings are recommended (for durability, hygiene and cleanliness).

SDA Robust En-Suite 3

SDA Robust En-Suite 2

SDA Robust En-Suite 1

In the laundry, there needs to be enough space for a commercial washing machine and dryer and a lockable storage space to hold cleaning chemicals and toiletries. Outside, hot and cold water supply and drain must be available to clean mops and items contaminated with faeces, vomit, etc.

SDA Robust Laundry

Walls, ceilings and windows: For robust design category dwellings, it’s recommended that internal walls be constructed using 600mm studs, covered by yellow tongue flooring and then Villaboard. Wallpaper is best avoided however, painted murals and pictures (that are screwed to the wall) are a good idea. For ceilings, high-impact plasterboard is preferred, with a ceiling height of three metres.

SDA Robust Wall Construction 1

SDA Robust Wall Construction 3

SDA Robust Wall Construction 2

Masonry Construction

Alternatively, Masonry construction will provide a better solution for all walls being constructed with brick or blockwork, as these walls cannot be damaged. This type of construction is also very common in areas with high humidity. A hard plaster finish can be applied over them or Villaboard. Avoid any product that is paper faced as participants can pick at it and peel it off.

Alternative wall lining solution

The following video details an alternate wall-lining solution.

All windows should be laminated glass-enclosed in aluminium frames and be set at a minimum of 1000mm above floor level. For each opening window, restrictors are to be fitted to sashes to allow a maximum of 100mm opening, and locks should also be provided for each sash (keyed-alike where possible). Curtains are not recommended; however, external aluminium automatic shutters to all windows are advised to control light and enhance security.

SDA Robust Window Coverings

Doors, gates and locks: For security purposes, steel door frames built into walls should be used in combination with doors that have four heavy-duty butt hinges. Solid core doors (minimum 39mm) are to be used throughout, with some participants also requiring tamper-proof screws. Select door handles that are minimalist in style with no sharp corners and a keyed-alike system is preferred.

SDA Robust Secured Automatic Gate Entry

Ensure any electronic access controls and keypads are recessed, and emergency exit doors are provided at either end of the residence, as well as the laundry, kitchen and staff room. In addition, fire and emergency exits should also include electronic strikes to all external gates. For each door, provide wraparound structural escutcheon plates to reinforce the latch set and lock, as well as three-door stops adjacent to the door to stop the door from banging and breaching.

Corridors and flooring: During design, allow for straight corridors, avoiding recesses and corners where possible, as this will allow for improved circulation and supervision. Choose durable, non-slip flooring with 100mm brushed aluminium strip skirtings that can withstand constant mopping and cleaning. Suitable options include polished concrete or woven vinyl flooring such as Bolon. Carpets and carpet tiles are not recommended due to incontinence issues, and domestic vinyl flooring should also be avoided as it is easily damaged, and some participants may pick at the joints.

SDA Robust Walls & Ceilings

Lights and electrical equipment: Throughout the dwelling, soft/warm LED lighting is to be provided. Room lighting should be recessed into the ceiling, while wall sconces are suitable for bedside lighting in bedrooms. Dimmers are recommended for lighting in bedrooms and common areas, and timers may be required for the night-time routine. It is highly recommended that night lighting or sensor lights be used in hallways to assist participants who need to leave their rooms at night.

All lights and power points are to use 30mm x 30mm rocker action switches, and electrical switches (especially those on the cookers, timers and consumer units) should be boxed in and lockable or enclosed inside lockable cupboards. TVs situated in both the bedrooms and common areas can be placed in a built-in TV unit that includes a break-proof polycarbonate cover. To maintain a comfortable temperature throughout the home, a reverse cycle cooling and heating unit is recommended, preferably ducted with ceiling-mounted outlets. However, in-slab heating should also be considered. Position any control panels within lockable cupboards.

Create a Robust SDA with Resilience, Safety and Comfort in Mind

When planning your robust specialist accommodation, there are many design elements to consider. Each of these elements plays a significant role in the safety and comfort of participants. Striking the right balance between resilience and a relaxed environment is key, and this can be achieved through careful planning, smart design and appropriate choices.

Use these best practice recommendations as a guideline, and if you have any questions about planning and implementing specialist disability accommodation, our team are always happy to help.

Staff Area

Office

SDA Robust Office Area 1

SDA Robust Office Area 2

SDA Robust Office Area 3

Bathroom

SDA Robust Staff Bathroom

 

Additional Resources

Fire Safety for Specialist Disability Accommodation

There will be fatalities! It’s not if, but when!

Specialist Disability Accommodation (SDA) first rolled out in 2013 and is aimed at designing houses for persons with ‘Extreme Functional Impairment or Very High Support Needs’. These are identified under the National Disability Insurance Scheme (SDA) Rules 2016 as an impairment resulting in an extremely reduced functional capacity to undertake in one or more activities of mobility, self-care or self-management and has a very high need for person to person support.

The result is that particular attention will need to be paid to design suitability for occupants of these dwellings in particular, life safety features such as fire alert/suppression systems, but is our current building legislative system set up to protect this new market and its residents?

Dangers of house fires

House FireHouse fires can cause extensive property damage and have disastrous consequences on life.

The number of avoidable house fires in Victoria is increasing. Home fires are on the rise due to small mistakes. There are hidden horrors lurking in every Victorian home. They are disguised in many forms, from the humble hairdryer, to the heater, and even your mobile phone. In 2015 there were 3211 preventable house fires in Victoria, up from 3170 in 2014, which included 9 deaths in preventable house fires.

There were 17 accidental fire deaths and more than 4,070 home fires in NSW in 2015 making it a deadly year for home fires.

According to the Australian Bureau of Statistics, fires tend to be more prevalent through the colder months of the year: approximately one third of house fires in NSW occur between June and August of each year. Although the number of deaths from house fires is relatively small (representing 1.5% of accidental deaths and 0.06% of all deaths nationally in 1998), all accidental deaths are generally regarded as preventable.

Accordingly, to improve fire safety the regulations brought into the Building Code of Australia (BCA) by the States has made the installation of smoke alarms in new homes mandatory. Victoria introduced a smoke alarm requirement into the BCA in June 1993, and most other States introduced a similar requirement in November 1994. A national requirement was introduced into the BCA in 1996. Victoria also introduced a retrospective regulation in February 1997 that existing homes built before August 1997 must be equipped with smoke alarms.

Causes of house fires

Wheelchair-bound man rescued from McKinnon house fireAlthough the causes vary – from dinner left to burn on the stove to overcharged laptops or clothing left to dry too close to a heater – all fires had one thing in common: a small mistake had serious consequences.

In 2015, 41 per cent of preventable house fires started in the kitchen, 9 per cent in the lounge room and 7 per cent in the bedroom. The most common causes of fire were unattended cooking (18%), heating (13%), smoking and faulty electrical appliances. There were 3,211 preventable house fires in Victoria last year, but there would be many more close calls which go unreported.

Information collected by the NSW Fire Brigade shows that fires identified as started by unattended heat sources caused 23% of accidental house fires in NSW in 1998 and increased by 86% between 1987 and 1998.

The biggest increases belonged to the suspicious (136%) and incendiary (310%) categories. These fires, which may be deliberately set, usually cause more damage than do fires that are ignited accidentally.

Whatever the main cause, many fires are triggered by some failure or malfunction in an appliance or a piece of equipment, whether attended or not. In 1987, 73% of all house fires had equipment misuse or malfunction as the main contributing factor. This proportion had dropped to 62% in 1998.

In the cooking equipment category (30% increase between 1987 and 1998), fires from ovens rose by 79% from 138 fires in 1987 to 247 fires in 1998. While not a major cause, fires from portable cooking and warming units also rose sharply by 119%, from 27 fires in 1987 to 59 fires in 1998 (Abs.gov.au, 2018).

NSW Fire Brigade Survey

The NSW Fire Brigade designed a questionnaire to be completed by experienced NSWFB firefighters. The survey was completed by 85 participants with the focus on utilising fire fighters who had attended a large number of house fires over a 10-20 year career or fire fighters who had been exposed to house fires over a 20+ year career.

The strength of this report lies in the information provided through statistics gathered from a widely experienced group of fire fighters from all over NSW. Over 96% of respondents had over 10 years experience and 48% of those had in excess of 20 years service. An estimated 10,000 house fires had been attended by the respondents.

From the questionnaire’s findings, over 75% of firefighters believed that the risks to firefighters had increased because of changes in the construction, design layout and contents of houses. Almost 50% believed that modern house fires were taking longer to bring under control due to the fuel loads within houses and the type of construction. Another important finding was that over 80% of respondents believed that the structural stability was lower in modern style houses during fire incidents.

The last two questions required the respondents to recall house fires they had attended and the responses reinforced the anecdotal evidence that had been observed over the past few years. The issues such as lightweight construction, air conditioning ducting, open plan design, lack of compartmentation, and household furnishings all ranked highly in having a significant impact on fire spread and structural integrity.

Other specific issues raised by the firefighters included I-beams, expanded polystyrene (EPS) cladding, and heating ducts.

In addition, 61% of senior NSWFB firefighters interviewed as part of this study believed that modern security measures such as deadlocks and security screens directly contributed to injuries and fatalities at house fires (Proceedings.com.au, 2018).

Case Studies

The following case studies look at three separate fires in accommodation for persons with disability, backpackers and aged care.

The first was a fire in 1996 at Kew Cottages, accommodation for the intellectually impaired, which led to improvements of fire safety for accommodation and better care for vulnerable members of the community.

The second case study is the Childers Palace Backpackers fire in 2000. Whilst this fire was deliberately lit, and the building complied with current building codes and standards at the time, the continued development of the building over the years, without a requirement to revisit suitability of existing safety features showed that complying with legislative requirements at the time of construction is not necessarily fit for purpose over the lifetime of a building.

The third case study is Quakers Hill Nursing Home fire which contained a large number of residents requiring assistance to evacuate. Again, inadequate fire safety features were either the direct cause or attributed to the death of 11 residents and illustrates how improved safety standards, such as sprinklers can save lives.

Kew Cottages Fire

Kew Cottage FireOn the evening of 8 April 1996, a fire occurred in Flat E, Unit 31 of Building 37 at Kew Residential Services [KRS], Kew. Tragically, the fire took the lives of nine intellectually impaired residents who required a high level of person to person support. KRS is operated by an agency of the Victorian Government, the Department of Health and Human Services and over the years had been the topic of continues criticism for the limited fire protection system. The one constant is that such residents should be protected from the devastating effects of fire by the government, and that that protection should have been in place to prevent the tragic events before they occurred.

The fire at Kew led to safer accommodation and care for vulnerable members of the community with Victorian Government making fire sprinklers mandatory within residential care buildings and requiring retrofit within those constructed before August 1997.

Childers Palace Backpackers Fire

Childers Backpacker FireChilders Palace was an old hotel built in 1902 which was converted to backpacker’s accommodation during the 1980’s.

On 23 June 2000 a fire broke out within the building that claimed the lives of 15 young people from Australia and other countries. From the accounts of survivors, it appeared that fire alarm systems were not operating. People who were familiar with the hostel said that there was only one exit door leading outside from the top floor at the rear of the building. However, it is understood that the hostel had complied with all regulatory requirements at the time for that style of accommodation and that the local council had had no concerns about the way that the hotel had been modified to become a backpackers’ hostel. (Parliament.qld.gov.au, 2018).

Quakers Hill Fire

Quakers Hill FireConstructed in the early 1980’s Quakers Hill was a nursing home for the aged.

On 18 November 2011 an early morning fire at Quakers Hill Nursing Home killed 11 elderly residents, seriously injured others and caused the evacuation of up to 100 people. Three people died in the fire, and a further eight residents of the home died later in hospital from their injuries. The fire started in two places and was regarded by police as suspicious.

A nurse working in the home was later arrested and charged with four counts of murder.

Part of evacuation of residents, due to their high level of physical support and a need to exit the building quickly required staff to leave patients in their beds and wheel them out and away from the building. However, during investigations resident’s beds were found to be abandoned and scattered in corridors and along exit ramps at points requiring 90 degree turns. The coroner found that due to insufficient turning circulations to turn beds they were abandoned which resulted in patients being physically carried or dragged out of the building, a slow inconvenient and somewhat hazardous process.

Also, apart from the ramp design, Supt Jurgeit also believed that the evacuation had been hindered by roof debris falling into the corridors. It is noted that this building was not sprinkler protected.

In December 2011 Fire & Rescue NSW carried out tests at the CSIRO re-constructing various bedrooms within the wards. The rooms’ dimensions were the same as the original although the construction methods differed from the original. Furniture was also included in the rooms to match each ward on the day.

In the first test, one of the resident’s bedrooms were replicated, with ignition starting halfway along the north side bed. The fire developed slowly and gradually spread to the adjoining bed. The fire then gained momentum and developed into a fully involved fire. The maximum temperature reached during the 24 minutes duration was 1070° C.

An identical room was then test-burnt to demonstrate the difference a sprinkler system would have made. It was dramatic and would have been life-saving with the test sprinklers activating after four minutes. The fire was confined to the bed of origin with minor smoke and heat damage to the room. The maximum temperature reached was 92° C (Coroners.justice.nsw.gov.au, 2018).

Subsequently the fire led to changes in the NSW Planning and Environment Act where existing Aged care facilities were required to retrofit sprinkler systems within their buildings over an 18-month period. Again, this is a case where buildings at the time of construction may be deemed fit for purposes but not suitable over the buildings lifetime.

Legislation

NCC-2016-Volume-OneFor most residential buildings, it is commonly assumed that compliance with the Deemed to-Satisfy (DtS) provisions of the National Construction Code Series Building Code of Australia Volume Two (the BCA) is sufficient to achieve a satisfactory level of performance and safety. However, it needs to be understood that except for specific disability access provisions, the BCA has been largely written around able bodied occupants, with little consideration for fire safety of people with disability or vulnerable persons.

Typically, the people that SDA is intending to cater for have been managed by government organisations such as the Department of Health and Human Services which have their own fire safety design requirements that go over and above the BCA to enhance the safety of people who may not have the ability to recognise or evacuate in an efficient manner without assistance.

However, with the introduction of SDA the NDIA has changed the standard model of management and now provides the opportunity for both private and government organisation to build and operate accommodation for persons with disability. This change is not necessarily negative, there just needs to be appropriate avenues to ensure that the safety of residents is a priority.

The NDIA estimates that by 2019 the NDIS will cover 460,000 participants at a cost of $22 billion each year. The roll-out of the NDIS means that buildings previously constructed as dwellings for Class 1a usage (hereafter referenced as Class 1a buildings) will be proposed for accommodation as part of NDIS funded plans for disabled persons eligible for funding under the scheme. Putting aside the question of whether the use of these buildings can remain as Class 1a dwellings, as opposed to another classification. If these buildings were assessed under the DHHS Guidelines, sprinkler protection would need to be provided for buildings having at least one resident with a DHHS profile of Type 2 or greater. Many of these buildings would need to be retrofitted with sprinklers but the associated cost is substantial – it being much more economical to fit sprinkler protection to a new building rather than an existing one. Furthermore, financial resources are limited and there are many competing demands, for example some buildings will be leased, and owners may not wish to have sprinklers installed in their building, due to increased long-term maintenance costs and other factors. It is noted that there are allowances for fire sprinklers within the Specialist Disability Accommodation Price guide to offset installation/maintenance costs. It is noted that the costs associated with a change of use from an existing BCA Class 1a may be very substantial, irrespective of the BCA DtS fire-safety requirements. Given that life-threatening fire is known to be a relatively rare event, there is a tension between having an appropriate level of fire safety in existing buildings and sufficient funding to achieve the intended purpose of the NDIS – an increase in the wellbeing of disabled persons (Fpaa.com.au, 2018).

Building Classes

According to the guidelines published by the ABCB, Building Classification that may represent Specialist Disability Accommodation may be;

Class 1a building – A single dwelling being a detached house; or one of a group of attached dwellings being a town house, row house or the like.

Class 1b buildings – Are a boarding house, guest house or hostel that has a floor area less than 300 m2, and ordinarily has less than 12 people living in it. It can also be four or more single dwellings located on one allotment which are used for short-term holiday accommodation.

Class 3 buildings – Are residential buildings other than a Class 1 or Class 2 building. They are a common place of long term or transient living for a number of unrelated people. Examples include a boarding house, guest house, hostel or backpackers (that are larger than the limits for a Class 1b building). Class 3 buildings could also include dormitory style accommodation, or workers’ quarters for shearers or fruit pickers. Class 3 buildings may also be “care-type” facilities such as accommodation buildings for children, the elderly, or people with a disability, and which are not considered to be Class 9 buildings (ABCB, 2017).

Class 9a buildings – Are considered Health Care buildings whose patients are undergoing a form of medical treatment and may need physical assistance to evacuate in an emergency.

The BCA and the advisory note published by the ABCB mentions both Class 3 and 9a may be a ‘care type’ facility or accommodation for people with a disability where residants may need physical assistance to evacuate.

One of the difficulties is that building surveyors may feel limited in Classifying a building with a higher set of standards that may also fall within another ‘less stringent’ building class. Under the Victorian Building Act 1993, Section 24, Subject to section 24A and Division 4, ‘the relevant building surveyor must not issue a building permit that imposes on the applicant lesser or greater standards or requirements than those prescribed by this Act or the building regulations, unless permitted to do so by this Act or the building regulations’.

In Victoria, a building surveyor could potentially be held liable for even Classing a Class 1b boarding house as a Class 3 if the house falls under the parameters of a Class 1b building, even if its purpose is to house people with significant disabilities. When we verbally contacted the Victorian Building Authority for comment, they referred us to Section 24 of the Victorian Building Act 1993 and also mentioned they would be reluctant to over impose the requirements found within the Victorian Building Act 1993.

Recommendations

People with disability are amongst some of the most vulnerable people within our population, but to add to this, SDA is only intended to house people at the highest end of the spectrum, increasing the importance of life safety features.

It is our opinion that although the ‘purposes for which it is designed’ may fall within Class 1a or 1b, the reality is the characteristic of the occupants vs the minimum safety requirements of these Classes are not fit for purpose. Both have minimal life safety features, Class 1b’s are slightly more stringent with Smoke detectors being required within every bedroom as well as common areas.

Considering the criteria for SDA eligibility is persons with ‘Extreme Functional Impairment or Very High Support Needs’ it’s not unrealistic to suggest that occupants will not have the physical capacity and/or cognitive ability to act in a swift and efficient manner to evacuate the building without some form of assistance. Kew Cottages and Quaker Hills demonstrate a prime example where the level of fire safety compared to occupant needs fell short, both initiating changes in legislation but only after people lost their lives.

With the introduction of SDA housing and the push for domestic style dwellings, we believe the regulations are still catching up to define appropriate requirements around persons with extreme disabilities living in housing designed for domestic purposes, and this could have disastrous consequences. These types of dwellings should be viewed as falling between Class 3 accommodation with occupants whose needs closely resemble those of occupants of a Class 9a healthcare building.

Subsequently, as a minimum we believe that all SDA properties should also be protected with Fire Safety features resembling Class 3/9a buildings, this includes;

  1. Sprinklers protection throughout;
  2. Fire/smoke Compartmentation;
  3. Materials i.e. floor/wall/ceiling lining that meet appropriate Fire Hazard properties.

In the end practicality and logical thinking are the key, what is the purpose of the building and how will it function. The last thing anyone wants is to be standing in the Coroner’s Court explaining why their decision caused the death of building occupants.

References:

ABCB. (2017). Available at: http://www.abcb.gov.au/Resources/Publications/Education-Training/Building-classifications  [Accessed 29 Jan. 2018].

Abs.gov.au. (2018). 4102.0 – Australian Social Trends, 2000. [online] Available at: http://www.abs.gov.au/Ausstats/abs@.nsf/2f762f95845417aeca25706c00834efa/1672d6d197020b08ca2570ec000e5353!OpenDocument [Accessed 28 Jan. 2018].

Courts.qld.gov.au. (2018).  [online] Available at: http://www.courts.qld.gov.au/__data/assets/pdf_file/0004/86647/cif-childers-palace-hostel-fire-20060707.pdf [Accessed 25 Jan. 2018].

Coroners.justice.nsw.gov.au. (2018).  [online] Available at: http://www.coroners.justice.nsw.gov.au/Documents/finding,%20recommendation%20and%20reasons%20-%20quakers%20hill%20fire.pdf [Accessed 28 Jan. 2018].

Fpaa.com.au. (2018).  [online] Available at: http://www.fpaa.com.au/media/243693/fire_safety_and_the_ndis.pdf [Accessed 29 Jan. 2018].

Graeme Johnstone, Inquest Findings, Comments and Recommendations into Fire and Nine Deaths at Kew Residential Services on 8 April 1996. Melbourne, State Coroners Office, 1997, p. 10

NSW, F. (2018). Media release page. [online] Fire & Rescue NSW. Available at: https://www.fire.nsw.gov.au/news.php?news=2314 [Accessed 1 Mar. 2018].

Parliament.qld.gov.au. (2018). [online] Available at: http://www.parliament.qld.gov.au/documents/explore/ResearchPublications/ResearchBriefs/2002/2002001.pdf [Accessed 25 Jan. 2018].

SDA Housing Density Requirements and Calculations

An often overlooked section of the “National Disability Insurance Scheme (Specialist Disability Accommodation) Rules 2020” is density.  Unfortunately, this has not been made clear in most documentation produced.

Anyone looking to create SDA within a single parcel of land must familiarise themselves with these requirements.

 

National Disability Insurance Scheme (Specialist Disability Accommodation) Rules 2020

Subdivision C—Density restriction

31  Density restriction

(1)  The density restriction applies in relation to a parcel of land if:

(a)  the parcel of land has 2 or more dwellings; and

(b)  at least one of those dwellings is either:

(i)  a new build; or

(ii)  existing stock.

(2)  If the density restriction applies in relation to a parcel of land, the total number of eligible participants that can receive funding for specialist disability accommodation in relation to all dwellings located on the parcel of land must not exceed:

(a)  if one of the dwellings on the parcel of land is enrolled to house 3 or more residents—the greater of the following:

(i)  10 eligible participants;
(ii)  10% of the total number of residents capable of residing on the parcel of land, assuming one resident per bedroom; or

(b)  if all of the enrolled dwellings on the parcel of land are enrolled to house no more than 2 residents and the dwellings are part of an intentional community—the greater of the following:

(i)  15 eligible participants;
(ii)  25% of the total number of residents capable of residing on the parcel of land, assuming one resident per bedroom; or

(c)  if all of the enrolled dwellings on the parcel of land are enrolled to house no more than 2 residents and the dwellings are not part of an intentional community—the greater of the following:

(i)  15 eligible participants;
(ii)  15% of the total number of residents capable of residing on the parcel of land, assuming one resident per bedroom.

 

How do I calculate specialist disability accommodation allowances for a property?

Farah Madon the lead author for the NDIS Specialist Disability Accommodation Design Standard has developed a density calculator that is freely available for architects and developers to easily calculate the number of rooms that can be allocated to SDA.

Importantly remember, the calculations are based on the number of rooms within the development which determines the maximum number of rooms permitted to be allocated for SDA and not the number of apartments.

 

Calculate Specialist Disability Accommodation Density Requirements For A Property

 

Use The NDIS SDA Density Calculator

Motorised Powered Stair Climber EvacuLife Power

Family homes or apartments with stairs present barriers for people with a mobility type disability restricting them accessing the greater community.

Additionally broken or out of serviced lifts are of no use in an evacuation nor are stairs when individuals don’t have the capacity to use them.

The EvacuLife Power MKII motorised powered stair climber and evacuation chair solves that problem and importantly is easy to use.

It’s the ultimate powered solution for movement of people with a disability for day to day activities or in an evacuation or medical emergency. With one push of a button you, can transport individuals comfortably and safely.

The EvacuLife Power is the ultimate in safety and stability with sophisticated motorised power ensuring a direct drive transmission.

 

Look At All These Features:

  • Extra wide track system
  • Three-position lift bar for safety
  • Two rear lift handles and rear castor with brakes
  • One-inch track-to-ground clearance provides smooth rolling over carpet and rough surfaces
  • Debris free and manoeuvrability using 75 mm front swivel wheels, extra tall 125 mm rear wheels
  • Motor controls work in any handle position
  • All metal aluminium allow frame construction provides durability and long life
  • Large patient seating surface panel and extended foot-rest
  • Maximum safety when going up and down stairs using an electronically controlled motor and direct drive transmission with chair tracks
  • Intelligent power system
  • Maximum load 160 kg
  • Easy operation when climbing or descending stairs with intuitive, easy-to-use push button controls
  • Rechargeable lithium-ion battery
  • Use with our Evacuation Chair Signage & Anti-Theft Alarm

 

Suitable for

  • Stadiums
  • Theatres
  • Concert Venues
  • Residential care facilities
  • Hospitals
  • Hotels and motels
  • Multi level buildings
  • Industrial workplaces
  • Schools and universities
  • Homes and workplaces

 

EvacuLife-Emergency-Evacuation-Products

The EvacuLife Power MKII – Motorised Powered Stair Climber & Evacuation Chair is available from EvacuLife.com.au

SDA Consulting & EvacuLife are both a part of the Equal Access Group Pty Ltd

 

Powered Stairclimber Extended Powered Stairclimber BatteryPowered Stairclimber Main Handle

Powered Stairclimber Folded

EvacuLife Power MKII Powered Stairclimber

The Critical Role Occupational Therapists Play in SDA

Enabling Independence Through Good Design

Working with an Occupational Therapist during the design phase of new Specialist Disability Accommodation (SDA) will ensure optimal outcomes for residents with complex disabilities.  While identifying the individual needs of residents with complex disabilities is a specialist skill and needs to be addressed through a formal assessment from an Occupational Therapist, it is evident that as we start to consider the needs of an individual and how their environment can either facilitate or hinder independence, the importance of both health and design professionals working collaboratively with residents to achieve successful outcomes and design quality homes has never been more critical.

As part of the planning process NDIS participants who qualify for SDA are required to provide a statement of goals, objectives and aspirations they wish to pursue within an environmental and personal context.  Like us all, participants goals will vary greatly.  For people some participating in meal preparation may be important, for others it may be about maintaining a current level of independence, or increasing independence with personal care tasks. Whatever the participant’s goals, it’s important that homes are designed to facilitate the achievement of goals and enable participation in activities that are meaningful and important to residents.  This means SDA needs to provide housing solutions that support an individual’s complex needs. In other words, resident’s individual needs must be driving design.

Occupational Therapist designed home modifications
Occupational Therapist designed home modifications

When designing a space to meet the needs of a particular person the relationship between the person, their environment and the activities they undertake, or wish to undertake within their environment must be considered holistically. For example, where a participant identifies one of their goals is to increase their level of involvement in meal preparation a number of factors in relation to the individual’s needs must be considered that will have a direct impact on the design of the kitchen. Such considerations may include suitable heights for joinery and clearances under workspaces to accommodate the person, including provisions for any aids they may use, or whether the resident’s reach range, endurance or cognitive function will impact on the layout of fixtures, fittings and storage facilities. Other considerations may include how the choice of door and tap hardware will impact on the resident’s ability to use and operate independently.

At Equal Access we have Registered Occupational Therapists who are also qualified Access Consultants who understand the complex relationship between people with disabilities and how their needs and level of function can impact the requirements of their environment. Our OT’s work collaboratively with the resident, building designers and building surveyors to ensure that homes are designed to meet the individual needs of residents while also ensuring compliance with all relevant statutory and legislative requirements.  We provide expert advice and deliver viable solutions which ensure a customised framework is established early on, avoiding the need for expensive and time-consuming retrofit down the track.  If you would like any more information regarding our services or would like to discuss a specific project, feel free to get in touch.

Why your SDA might be a Class 3 and not a Class 1a or 1b

Specialist Disability Accommodation (SDA) is setting new standards within the building industry, paving the way for the development of homes rather than institutions for people with a disability. However, this has created some ambiguity over when a home registered as an SDA no longer fits the model of a ‘Typical home’ under the Building Code of Australia.

The Building Code of Australia (BCA) is a technical building document adopted Australia wide which categorises how a building use shall be designed/constructed to safeguard health, safety and amenity of all occupants.

These uses are defined as ‘Building Classifications’ and include;

 

Class 1a – a single dwelling being —

  1. A detached house; or
  2. One of a group of two or more attached dwellings, each being a building, separated by a fire-resisting wall, including a row house, terrace house, town house or villa unit.

 

Class 1b

  1. Boarding house, guest house, hostel or the like—
    1. with a total area of all floors not exceeding 300 m2 measured over the enclosing walls of the Class 1b; and
    2. in which not more than 12 persons would ordinarily be resident; or
  1. 4 or more single dwellings located on one allotment and used for short-term holiday accommodation,

which are not located above or below another dwelling or another Class of building other than a private garage.

 

Class 2: A building containing 2 or more sole-occupancy units each being a separate dwelling i.e Apartment building.

 

Class 3:

‘A residential building which is a common place of long term or transient living for a number of unrelated persons, including—

  1. A boarding house, guest house, hostel, lodging house or backpacker accommodation.
  2. A residential part of a hotel or motel.
  3. A residential part of a school.
  4. Accommodation for the aged, children, or people with disability.
  5. A residential part of a health-care building which accommodates members of staff.
  6. A residential part of a detention centre.
  7. A residential care building.

 

While the principles of the SDA promote a focus on designing residential homes not every dwelling will fit this ideal under the BCA. For example, the classification of;

 

  1. A home where a couple reside with their kids and the spouse/partner is eligible for SDA funding would fall under your typical home i.e. Class 1a, whereas;

 

  1. A home in which multiple unrelated persons with disabilities are eligible for SDA funding with On-site Overnight Assistance would represent a Class 3. This requires a higher level of design features to protect occupant health, safety and amenity compared to a Class 1a.

 

Reading through what defines each Building Classification it seems that as soon as an SDA dwelling houses more than one person with a disability the only Building Classification suitable is a Class 3. This can throw some surprises to Providers who may not be familiar with the Building Code of Australia, especially in Victoria which requires the provision of sprinklers where 10% or more of persons need physical assistance in conducting their daily activities and to evacuate in an emergency.

This then gets more complex when you consider the difference between a class 3 for people with disability and residential aged care. A class 3 for people with disability does not require sprinklers up to three stories, but residential car does.

 

The following table provides a brief overview of some of the differences in the BCA design requirements between a Class 1a and 3.

`

Requirements under the BCA

 

Class 1a

 

Class 3

 
Internal Fire Ratings

 

 Not required Required
Enhanced provisions for escape during an emergency

 

 Not required Required
Sprinkler protection (Victoria)

 

 Not required Required over three storeys
Disability access provisions (Above SDA) For people with disability Not required Required over three stories
Disability access provisions (Above SDA) For residential care building Not required Required for entire building
Acoustic separation between bedroom/living spaces Not required Required. By default also provide fire protection

 

Note: This table is not representative of all applicable requirements, consultations should be sought from the relevant Sate or Territory responsible building authority such as a Building Certifier.

 

This is not to say that a dwelling defined as a Class 3 falls outside the potential of providing a suitable home for Participants, quite the opposite.  In most the cases with a diligent design team the additional features would not standout to the end user and more importantly aim to enhance a resident’s level of independence, participation and safety in their home.

The first step for anyone seeking to offer accommodation under SDA is to contact a Building Certifier to discuss the proposal to determine the relevant Building Classification and what design features are required. It is critical to get this right at the beginning of a development as an incorrect classification can have major implication such as: ineligibility for enrolment as SDA, orders from Local Councils to stop works/vacate the building, infringements notices, demolition and/or retrospective upgrade works, or worst-case detriment on a resident’s health.

 

Fire Safety

There will be fatalities! It’s not if, but when!

Read our thoughts on the fire safety requirements for Specialist Disability Accommodation on the following page There will be fatalities! It’s not if, but when!

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