Transport Consultation

This consultation has concluded

Prepared by Booz Allen Hamilton On behalf of the National Disability Authority

Foreword

The National Disability Authority (NDA) works to promote and helps to secure the rights of people with disabilities in Ireland. The publication of this Consultation Paper for the Development of Operational Guidelines for improving access to Bus, Rail and Light Rail Services for People with Disabilities in Ireland is an important step towards the achievement of the NDA's mission.

Transport is an essential prerequisite to enabling people with disabilities to participate in normal activities of daily living, i.e. work, education, leisure and social activities. Also, it should be noted that all people will benefit from the provision of accessible public transport.

Almost 10 years ago, the Commission on the Status of People with Disabilities (1996) commented on the negative experience of people with disabilities in using public transport in Ireland. Since the Commission published its report a substantial level of investment has taken place in making transport services accessible to people with disabilities.

In recent times, the Department of Transport has started a process of fundamental reform of the way in which transport infrastructure and services are delivered in Ireland. In the Department's 'Outline Sectoral Plan for Accessible Transport 2004', the department's objective with regard to Transport Accessibility is stated as:
'that all passenger transport providers should provide the highest possible degree of accessibility, subject to available resources and competing priorities and rules of practicality.'

The Department of Transport is responsible for the regulation of public transport, including the issuing of guidelines, such as those proposed in this document. The National Disability Authority is looking forward to continuing to work in partnership with the Department of Transport in developing Operational Guidelines and putting them into practice.

Table of Contents
Part 1 - Context of the Consultation Paper. 3
Chapter 1 - Introduction. 3
1.1 Who is this Consultation Paper for?. 3
1.2 What will the Operational Guidelines Cover?. 4
1.3 How to Use this Document?. 4
1.4 Why Improve Access to Public Transport?. 5
1.5 How can the Change be Managed?. 5
Chapter 2 - Barriers to Travel6
2.1 Introduction. 6
2.2 How does the Physical Environment Create Barriers?. 8
2.3 How do Policies, Procedures and Systems Create Barriers?. 8
2.4 How do Staff Create Barriers?. 9
2.5 What Barriers Arise in Information Provision?. 9
2.6 How do People's Attitudes Create Barriers?. 9
2.7 How can a Service be Audited?. 10
Chapter 3 - The Supporting Framework. 11
3.1 Why is Guidance Required?. 11
3.2 What is the Policy and Legislative Support ?. 11
Part 2 - Draft Operational Guidelines. 14
Chapter 4 - Information Provision. 14
4.1 Introduction. 14
4.2 Why does Information Matter?. 14
4.3 What Information should be Provided and When?. 14
4.4 Who should Provide the Information?. 16
4.5 Where should Information be Provided?. 16
4.6 How should Information be Provided?. 17
4.7 In what Formats should Information be Provided in?. 18
4.8 How can Information be Audited?. 20
Where should Operators go Next?. 20
Chapter 5 - Infrastructure and Buildings. 23
5.1 Introduction. 23
5.2 How to Improve Access to Bus and Light Rail Stops. 23
5.4 Access to Transport Buildings (including Stations)24
5.5 Transport Buildings and Stations. 25
5.6 Auditing for Accessibility. 26
Where should Operators go Next?. 27
Chapter 6 - Vehicles. 28
6.1 Introduction. 28
6.2 What is an Accessible Vehicle?. 29
6.3 What is Best Practice Guidance for Accessible Vehicles?. 29
6.4 How to Deliver an Accessible Fleet of Vehicles?. 29
6.5 How to Make Sure Operating Practices are not a Barrier?. 31
Where should Operators go Next?. 32
Chapter 7 - Customer Relations. 33
7.1 Introduction. 33
7.2 What Approach should be Taken?. 33
7.3 What is Important when Communicating with People with Disabilities?. 34
7.4 What about Training?. 35
7.5 How to Make Sure Standards are Maintained?. 35
7.6 How to Audit Public Transport Service Provision?. 36
Where should Operators go Next?. 37
Chapter 8 - Disability Awareness Training. 37
8.1 Introduction. 37
8.2 Who should be Trained?. 38
8.3 What Training should be Provided?. 38
8.4 How should the Training be Provided?. 41
8.5 When do People need Training?. 42
Where should Operators go Next?. 43
Chapter 9 - Disruption and Emergency. 43
9.1 Introduction. 43
9.2 Development of Plans and Procedures. 44
9.3 Assessing, Auditing and Testing. 46
Where should Operators go Next?. 46
List of Useful Contacts. 47

Part 1 - Context of the Consultation Paper

Chapter 1 - Introduction

1.1 Who is this C onsultation Paper for?

This Consultation Paper represents the first step in developing Operational Guidelines for use by bus, rail and light rail operators in Ireland who wish to make their services more accessible to passengers with disabilities. The intended primary audience for this document comprises the following operators / organisations:

  • Corás Iompair Éireann;
  • Iarnród Éireann/Irish Rail;
  • Bus Átha Cliath/Dublin Bus;
  • Railway Procurement Agency;
  • Connex Transport Ireland;
  • Bus Éireann/Irish Bus; and
  • Private bus operators providing public transport services.

People who need accessible public transport services, especially people with disabilities, will also find the Guidelines helpful in understanding what they can expect from bus, rail and light rail operators.

1.2 What will the Operational Guidelines Cover?

The Guidelines are intended to help public transport operators provide a good, comprehensive and readily usable service to people with disabilities. They cover information provision, infrastructure and buildings, vehicle design, customer relations, disability awareness training and procedures for disruption and emergencies. In addition, the Guidelines explain the barriers to travel faced by passengers with disabilities, and outline the current Irish legal and regulatory position.

1.3 How to Use this Document?

This document is structured in two parts. Part One, Chapters 1-3, provides information on the rationale for improving accessibility and information on the barriers to accessibility.

Part Two, Chapters 4-9 is structured so that there are individual chapters for different elements of the public transport business. These chapters set out the questions that need to be addressed. Each of these chapters contains a "Where should Operators go Next?" section that provides information and sources of more specific and detailed guidance that can be used.

1.4 Why Improve Access to Public Transport?

There are a number of reasons why Operators should improve the accessibility of their services.

Firstly, improving accessibility is good for business. It is widely accepted that the profile of passengers (and potential passengers) of public transport is changing. Not only is the number of people with disabilities growing but the proportion of older people in the population is also increasing. These demographic changes will require improvement in the accessibility of public transport services. Improving accessibility will attract passengers who would not previously have considered using public transport. Existing passengers, who may or may not have disabilities, will be encouraged to make more trips by public transport because it is easier or more convenient to use, more pleasant, and satisfies their needs to a fuller extent.

Secondly, the legislative and regulatory framework has become more demanding for all parties (the State and operators) in relation to providing fully accessible public transport services (refer also to Section 3.2). The Government, in the National Development Plan 2000-2006 (NDP), makes a commitment that "new and upgraded bus and rail stations, light rail vehicles, new suburban railcars and new urban buses will be fully accessible". In the Outline Sectoral Plan under the Disability Bill 2004, the Department of Transport has stated that obligations arising from its objectives with regard to accessibility "will apply to all providers of public transport services, both public and private" .

Finally, there is a strong moral argument for making public transport fully accessible. This is founded on the principle of equal treatment and the ability of public transport to enable people to have access to all society has to offer.

1.5 How can the Change be Managed?

Improving access for passengers with disabilities is similar to implementing any type of change - there are challenges that need to be managed. This can be achieved by:

  • having a clear and shared vision across the company, backed by an understanding of the business case;
  • having visible and effective leadership from senior management;
  • developing relationships with passengers with disabilities and their organisations;
  • acquiring functional and technical skills through training;
  • communicating changes in a timely fashion to all the operator's staff, to passengers and to potential passengers that are currently excluded from services; and
  • setting out detailed plans for improving accessibility and monitoring progress.

Chapter 2 - Barriers to Travel

2.1 Introduction

When passengers with disabilities make a journey, they have the same basic expectations as other members of the public. They expect to be able to leave the house, get to the station or stop from which they are catching the bus, light rail vehicle or train, board the vehicle, travel in reasonable safety and comfort, alight from the vehicle and get to their destination without any difficulties. Passengers with disabilities, in particular, need to be confident that every stage of a journey will work effectively and consistently. If even one component of the journey presents a barrier, then the journey cannot be undertaken.

Information, travel to bus stop, wait for bus, board bus, travel in bus, alight from bus, travel to destination, information

If a person using or attempting to use public transport has a bad experience it may undermine their confidence in public transport. The person may assume that they cannot rely on public transport to meet their travel needs and as a result their mobility and quality of life may diminish.

It is now accepted that it is barriers in the transport system that prevent people with disabilities using transport services, not their impairment. For example, it is the lack of audible announcements informing passengers where they are and what the next stop is, that disables a visually impaired person and prevents them using public transport with confidence or at all.

Barriers in the transport system affect passengers with particular disabilities differently, for example:

  • A flight of stairs is a barrier to a wheelchair user, whereas a visually impaired person might have less difficulty.
  • Visual information with no audible backup might present a visually impaired person with serious difficulty, whereas a person with hearing difficulties might not find it a problem.
  • Lack of visual information is a problem both to deaf passengers and to passengers with learning disabilities.
  • Glare from the glass screen at a ticket counter is a problem for passengers with hearing impairments because they cannot see the other person's face for visual clues or lip-reading. It is also a problem for visually impaired passengers because it makes use of their residual vision more difficult.
  • A confusing station layout is a problem to someone with walking difficulties, who may in consequence have to walk farther. It is also a problem to someone with a learning disability, who may lose their way.


It is therefore important to think about every aspect of the service, to identify the barriers that passengers with disabilities are likely to encounter and to plan to remove them.

It can help to think of barriers in five categories:

  • physical barriers;
  • barriers in policies, procedures and systems;
  • barriers caused by staff practices;
  • information barriers; and
  • barriers caused by attitudes - staff or customer.

2.2 How does the Physical Environment Create Barriers?

Physical barriers are barriers in the built environment like steps and stairs, narrow doors, heavy doors and obstacles. These are the obvious barriers. Less obvious barriers also exist including for example, confusing station layout, inadequate lighting, lack of seating, poor colour contrast or inadequate signage. An automated ticket barrier can present a barrier to someone who is oversized or easily hurt, for example someone with brittle bones or someone with haemophilia. Equally, it may be intimidating for passengers who cannot see or understand how the barrier opens and closes.

Attention to detail is important. There are many examples of accessibility improvement schemes which have had to be rebuilt because of poor detailed design. Costly refits can be avoided by following design standards in their entirety, and by auditing (disability proofing) designs before proceeding to implementation.

2.3 How do Policies, Procedures and Systems Create Barriers?

Policies, procedures and systems that have been set up for good reasons can present barriers to passengers with disabilities in the transport environment.

In order to minimise boarding times and reduce staffing levels, for example, an operator might require passengers to purchase a ticket before they board a vehicle. If it is difficult or impossible for a person with disabilities to purchase a ticket because the ticket machine is not accessible or too complex to operate, then the requirement of having to buy a ticket beforehand compounds the barriers that a person with disabilities experiences. The effect of this can be lessened if staff understand that certain passengers may not have been able to purchase tickets, and staff are flexible in their response to this. Quality customer service policies, procedures and systems can help to compensate for poor access in the physical environment.

2.4 How do Staff Create Barriers?

Even when policies, procedures and systems are well-designed and flexible, the way that staff implement these may in itself create barriers to passengers with disabilities. For example, a bus stop may be well-designed and the policy may state that drivers should pull in to the kerb so that passengers can board more easily. If drivers do not or cannot follow this practice consistently, the result is that some passengers experience difficulties when attempting to board.

When implementing changes to infrastructure and vehicles, procedures need to be in place that ensure the correct use of the facilities by staff. Unless everyone in the chain of command is clear about the importance of accessibility and is familiar with working new systems, then the potential exists for small 'errors and omissions' to become significant barriers to access and efforts to create an improved facility may fail.

2.5 What Barriers Arise in Information Provision?

Information needs to be accurate, consistent and accessible. Not providing enough information, providing information in the wrong format or providing conflicting or inconsistent information creates barriers for passengers. Issues of availability of information, format, print size and colour should be addressed in a user friendly manner.

2.6 How do People's Attitudes Create Barriers?

Public attitudes towards people with disabilities have improved considerably over the past few decades. However, there are still those who may believe that passengers with disabilities should not be out and about by themselves - or perhaps should be using some other form of (segregated) transport.

Operators' staff can be educated to understand more about the barriers faced by passengers with disabilities. Standards can be set for customer service and expectations for passengers on transport services that will result in an improved journey experience for passengers with disabilities and other passengers alike.

Customer service standards can be assessed in a variety of ways, for example, through customer research, customer service surveys and consumer panels. The organisations selected to carry out this work should be experienced in doing so in relation to disability, and make use of a good range of passengers with disabilities.

2.7 How can a Service be Audited?

In order to ensure that a service is barrier free, public transport operators can carry out a customer service audit. Assistance may be required in setting this up, for example, by creating a clear methodology and identifying the needs of particular groups of passengers with disabilities. This is something that public transport operators can implement with limited effort and preparation, as follows:

  • describe each stage of the journey;
  • determine what a passenger needs (or may want) to achieve at each stage;
  • use these Draft Guidelines to help identify the barriers that passengers with different impairments will come across when they are using public transport services;
  • ask passengers with different types of disabilities to take part in the audit and record their observations;
  • review all company information available (management information, results of surveys etc.) to understand the needs and aspirations of passengers with disabilities and whether existing services meet those requirements; and
  • establish a plan to remove these barriers - some will be easily removed and can be addressed quickly, others will need building into future maintenance and development plans.

Chapter 3 - The Supporting Framework

3.1 Why is Guidance Required?

One of the more important findings from the National Disability Authority's (NDA) recent research work in this area was the absence of national guidance which public transport operators could utilise in their efforts to improve the accessibility of their services to passengers with disabilities.

As a result of these findings the NDA undertook to produce a document for consultation on the development of Operational Guidelines for improving access to bus, rail and light rail services for people with disabilities in Ireland, in partnership with the Department of Transport. The Department of Transport envisages develo ping Operational Guidelines based on this consultation document in due course.

3.2 What is the Policy and Legislative Support ?

Clear Government support for improving the accessibility of public services and, in particular, public transport has been demonstrated in recent times. Support and commitment was explicit within the Social Partnership agreements Programme for Prosperity and Fairness (PPF) and Sustaining Progress.

The National Development Plan 2000-2006 (NDP)states that:
'The Government is committed to improving accessibility to public transport for mobility impaired persons and people with disabilities. New and upgraded bus and rail stations, light rail vehicles, new suburban railcars and new urban buses will be fully accessible. New implementation structures will be put in place.'

Section 32 of the Disability Bill 2004 states that:
the sectoral plan of the Minister for Transport shall contain information concerning-

  • a programme of projected measures for the provision of access to persons with disabilities to passenger transport services for the general public provided by the Minister or by a public body in relation to which he or she performs functions or by a person or body licensed or regulated by the Minister,
  • measures to be taken for the purpose of facilitating access by persons with disabilities to such services and the time within which such measures are to be taken,
  • arrangements proposed are to be put in place by the Minister and the Minister for the Environment, Heritage and Local Government to facilitate access to the vehicles providing the passenger transport services by such persons from a public road, and
  • any other matter which the Minister considers appropriate.

The Department of Transport's Outline Sectoral Plan under the Disability Bill 2004 states that:
"the Department is committed to the comprehensive development of accessible public transport services for the greatest number, and the largest categories as possible, of those with mobility and sensory impairments in the shortest possible time having regard to resource, technical and other constraints".

The Department's objective is:
'That all passenger transport providers should provide the highest possible degree of accessibility, subject to available resources and competing priorities and rules of practicality'.

In promoting this objective, and the consequent obligations on providers of public transport services, the Department stresses that the benefits of improved transport accessibility extend to all transport passengers.

In the Outline Plan, the Department has set targets for improving the range of accessible services in the bus and rail sectors. The Outline Plan has been prepared having regard to the likely lifespan and replacement costs of existing public transport vehicles and infrastructure. It will be reviewed and updated on a periodic basis.

Further legislative support is provided by the Equal Status Act 2000. The Act outlaws discrimination in the disposal of goods and delivery of services. The Act makes it illegal for people to discriminate when they are providing goods or services to the public, whether for free or where the goods are paid for.

The Act makes it illegal to discriminate on the grounds of gender, martial status, family status, sexual orientation, religion, age, disability, race and membership of the traveller community.

In the Act,
"service" means a service or facility of any nature which is available to the public generally or a section of the public, and, without prejudice to the generality of the foregoing, includes -

  • Access to and the use of any place
  • Facilities for-
  • Banking, insurances, grants, loans, credit or financing,
  • Entertainment, recreation or refreshment
  • Cultural activities, or
  • Transport or travel …."


Furthermore, the Act (Sections 17 and 18) enables the sponsoring Minister, with the agreement of the Minister for Transport, to make regulations with respect to the accessibility of public transport vehicles (new road and rail passenger vehicles) and with respect to the provision of facilities at stations so that they are "readily accessible to and usable by persons with a disability". Section 18, which relates to station equipment specifically, refers to making "regulations requiring operators of bus and rail stations to provide facilities so that they are readily accessible to and usable by persons with a disability."

Part 2 - Draft Operational Guidelines

Chapter 4 - Information Provision

4.1 Introduction

Information is crucial to people making journeys by public transport. For passengers with disabilities, good information can be the difference between being able to make a journey or not.

4.2 Why does Information Matter?

Good information that enables passengers, including those with disabilities, to make journeys safely and successfully can build confidence in the public transport system. Good information enables independence and reduces reliance on staff and on other passengers. It also increases passengers' safety by reducing the risk of unplanned incidents occurring, for example, a passenger getting off at the wrong stop.

The majority of passengers do not have to rely on one information source. For example, they hear an announcement and visual clues in the environment confirm that announcement or aid in their comprehension. However, a person with a visual impairment may not benefit from these visual clues and will need to depend solely on the announcement which, if unclear or not given, can cause confusion or travel disruption.

4.3 What Information should be Provided and When?

There are four key stages at which passengers, including those with disabilities, need information.

  • before they set out on their journey;
  • at the train station or the bus or light rail stop (including at interchanges);
  • on the vehicle; and
  • when they have completed their journey.

The following table shows the sort of information that should be provided at each of these stages.

Information Requirements for Journey Stages
Journey StageInformation Requirements

Before the journey

Easy to use journey planner

Timetable information - routes, times etc.

Information on which services are accessible and which are not and what to do if services are not accessible

Information on connections with other modes of transport.

Facilities available: lifts, seating, services (toilets, shops, refreshments)

Details of the assistance available and how to get that assistance

Requirements such as ticket purchase, fares, making reservations, booking seats, etc.

At the stop or station

Service and timetable information - arrivals and departures, routes and destinations served

Instructions on how to get assistance

Instructions on how to buy tickets - especially at ticket machines

Information on safe boarding, alighting and waiting

Information on facilities available, if any

Information on delays, including how long the delay will be - real time information

Instructions on what to do in the event of disruption

Useful telephone numbers and help phone

On the vehicle

Instructions on how to get assistance

Visual and audible information at each stop and in advance of the next stop

Location and details of the facilities, if any

Information on delays, including how long the delay will be

Instructions on what to do in the event of an emergency or a disruption to the service

After the journey

Details of connecting services (rail, light rail, bus and taxi), and how to get to them

Instructions on how to provide feedback


An operator should have policies and procedures in place to ensure that certain (predetermined) information is available in the most requested formats and media and that all other information is available in accessible formats on request.

4.4 Who should Provide the Information?

In terms of verbal enquiries, not all staff will be able to know everything about all services or be able to answer all the questions that passengers might want to ask. However, all relevant staff should be able to tell a passenger with disabilities where to get the information they need. In addition, all relevant staff should know how to provide information to passengers with disabilities. They should also know about the specific needs of passengers with disabilities. Training can help to ensure that staff can fulfil the information needs of passengers with disabilities. (Chapter 8 of this report which deals with Disability Awareness Training can aid with this).

4.5 Where should Information be Provided?

Information should be easy to find. Passengers may require specific information, for example, about how to board vehicles and how to receive assistance. Information may be delivered through different mechanisms and at different locations such as public counters, public address systems, queuing systems, loop systems, telephones and public access terminals. For each mechanism, different accessibility issues may arise. In relation to queuing systems, for example, an operator needs to ensure that the design of LED displays is accessible and that auditory information is provided.

Specific information needs to be available on how to get assistance. Passengers who have problems standing need to know what seat provision will be made available to them. This kind of 'specialist information' can sometimes be hard to find for passengers with disabilities who do not know how the system works, passengers who recently acquired disability, or passengers with disabilities who have not travelled before or do not travel often. Making it easy for people to find the required information will encourage more people with disabilities to use public transport services.

To provide this information, operators should consider creating a clearly identifiable section on websites, timetables, brochures, signage etc. Good design and appropriate naming of this section will ensure that those who most need assistance will seek it. If it is called 'disabled assistance', some passengers who need it, for example, frail older people, may not think it is for them. On the other hand, some passengers with disabilities reject the notion that they have 'special needs'. The best approach may be to give the section a title such as - "additional assistance for passengers with mobility and/or sensory impairments" or simply "for passengers who need extra assistance", with an explanation of what the operator means by that.

4.6 How should Information be Provided?

The European Conference of Ministers of Transport (ECMT) requires that information be clear, concise, accurate and timely.

Clear
ECMT define clarity of information as information that is easily legible and easily understood. Clarity of information therefore presupposes that people will be able to distinguish between the different types of information that they receive in the transport environment. Information on the transport environment can be divided into three levels:

  • level 1 information, such as urgent safety information or immediate bus or train departures
  • level 2 information, such as general timetable information and general safety information
  • level 3 information, such as advertising.

It is important that these three levels of information are clearly distinguished.

Although commercial advertising can be an important source of revenue, advertising that is too prominent can distract passengers who are relying on clear visual information to make their journey. If background information is given equal weight to immediate information, timetable changes or disruption information may not be sufficiently clear and understandable. All passengers will also experience the benefits of information which has been 'rationalised' in this way. They will be able to find their way much more quickly and easily.

Concise
Information should be complete but concise. Too much information makes it difficult for people to retain.
Accurate
All information provided should be accurate and consistent. Information that is not accurate is worse than useless. Conflicting information can add to the stress that passengers experience and, because this consistency is so important, failures in provision, however infrequent, will diminish passengers' confidence in the system.

Timely
In general, information should be provided at the time when it is needed, for example, at the point of departure on a journey. However, many people with disabilities would like to have information about their intended journey well in advance. Timely information also means that the information should be up-to-date. Where, for example, a lift or a toilet is out of service, passengers with disabilities need to be informed promptly.

Provision of information in a bilingual format (Irish and English) raises particular challenges to operators, which can often be overcome. Accessibility should not be ruled out in favour of a rigorous Irish language information provision.

4.7 In what Formats should Information be Provided in?

Operators should understand that the format in which information is provided is as critical as the information itself. Information which is typically provided in written form, in spoken form and in electronic form, should be in a format that people with disabilities will be able to use. In many cases this will involve providing the information in an alternative format, such as large print, Braille or Easy Read.

It is good practice to ensure that the marketing department, communications staff and anyone else who produces information in the organisation follows the requirements of clear print and plain language. For example, producing written documents in a 14 point Sans Serif font makes them more readable by a wider range of visually impaired people and people with learning disabilities. It also means that fewer people will need to be provided with alternative formats.

For written documents, people with visual impairments may need large print (18 point or larger), Braille or audiotape. People with learning disabilities may also find audiotape or Easy Read version useful. Irish or English may not be the first language of people who are Sign Language users, and they may also find an Easy Read version more helpful. In any event, they will need plain language with any jargon explained.

Simple pictures should be added to information wherever possible as these should make information more accessible for passengers with learning disabilities. (In the built environment, signage should use pictograms that conform to ISO standards. Chapter 5 of this document which deals with Infrastructure and Buildings will help with this.)

It is reasonably easy to have large print versions of documents available for visually impaired passengers and passengers with learning disabilities. It may be necessary to get Braille, audiotape and Easy Read versions, produced by a specialist. If there is a substantial number of documents to produce in alternative formats, it may be worth acquiring the equipment and developing the expertise in-house. To begin with, it is advisable to find an agency that can produce good quality translations.

The use of journey planners on websites offers the potential for detailed and precise journey details to be worked out before the trip is made.

Some people with disabilities have problems with standard website design. In particular, people who use screen readers are unable to access many websites, because their screen reader softwa re cannot recognise important elements of the website. Websites that rely on sound or that require use of the mouse for navigation, for example, also present problems to people with disabilities. Thinking about accessibility when developing or updating a website, is worthwhile as it can reduce problems associated with trying to improve accessibility at a later stage. See the 'Where should Operators go Next?' section for additional guidance.

4.8 How can Information be Audited?

Information can be audited (disability proofed) to ensure that it is accessible. The audit will need to:

  • make a list of the information that is provided: web-based, written and spoken;
  • review the information to determine how much is accessible now by checking it against the guidance. It may be useful to consult with organisations for and of people with disabilities in order to prioritise actions;
  • prioritise which pieces of information need to be developed in alternative formats and be readily available;
  • identify suppliers of alternative formats, such as Braille and audiotape, and provide them with copies of the text so that they can provide alternative formats on request;
  • develop a plan for putting all information into accessible formats in priority order; and
  • consult passengers with disabilities about the information they find easy to use. It may also be useful to 'pilot' information with a group of passengers with disabilities with a range of impairments, as the experience of using the information in a 'live' situation is a very different test to a more controlled audit situation.

Where should Operators go Next?

Written documents:

  • National Council for the Blind of Ireland provides some outline guidance for making written documents accessible at http://www.ncbi.ie/information/access_and_awareness/documents_accessible.php
  • For guidance on producing documents in plain English, visit the Plain English Campaign website at http://www.plainenglish.co.uk/ or for guidance on producing plain language documentation from the US, try the US government website at http://www.plainlanguage.gov/ (this is designed more for government documents, but it has some useful pointers)
  • Signage and Information is dealt with in Chapter 10 of Inclusive Mobility: A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure, by Philip Oxley (2002) for the UK Department for Transport's Mobility and Inclusion Unit
  • Disabled Passengers Transport Advisory Committee (DPTAC) (1996) Legibility of Bus Timetable Books and Leaflets, a Code of Good Practice,

Websites:

  • For guidance on website accessibility and the manual checklist to test a website for accessibility visit http://www.accessit.nda.ie/technologyindex_1.html
  • For a general guide on making websites accessible for people with disabilities, contact the UK Employers' Forum on Disability (+ 44 (0) 20 7403 3020) to buy a copy of their Customer Action File 4 "Accessible Website Design -- a practical and strategic guide"
  • For a web-based tool to check whether the company's website is accessible, visit http://bobby.watchfire.com/bobby/html/en/index.jsp. Compliance with Bobby does not equal achieving the maximum level of accessibility
  • For additional guidance on website accessibility from the World Wide Web accessibility initiative visit http://www.w3.org/TR/WAI-WEBCONTENT/
  • The W3C Web Accessibility Initiative (WAI) homepage http://w3.org/wai
  • The Web Content Accessibility Guidelines v 1.0 (WCAG 1.0) http://www.w3.org/TR/WCAG10/
  • Accessibility Toolbar - a plug-in for MS Internet Explorer. A very useful Web Accessibility Evaluation tool. Links to lots of tools that are online.http://www.nils.org.au/ais/web/resources/toolbar/
  • "Dive Into Accessibility", a good online tutorial on accessibility by Mark Pilgrim: http://www.diveintoaccessibility.org/
  • Tips on how to maintain an accessible website using MS Word and XML: http://www.xmlw.ie/events/04-01-03.html

Interactive information:

The Irish National Disability Authority IT Accessibility Guidelines include guidelines for the web, telecoms, software applications and public access terminal: NDA IT Accessibility Guidelines are available at http://www.accessit.nda.ie/technologyindex_2.html

General information:

  • Guidelines for the Design of Accessible Information and Communication Technology Systems - http://www.tiresias.org/
  • For more general guidance on making various kinds of information accessible for visually impaired people, see the UK RNIB's website http://www.rnib.org.uk/xpedio/groups/public/documents/code/public_rnib001951.hcsp
  • For more general guidance on making information accessible for people with learning disabilities, see the UK Mencap website: http://www.mencap.org.uk/html/accessibility/accessibility_guides.htm
  • For guidance on producing Easy Read documents see the UK Disability Rights Commission's website http://www.drc-gb.org/
  • For more general guidance on making information accessible for people with hearing impairments, see the UK RNID's website http://www.rnid.org.uk/html/factsheets/stop.htm
  • To buy a picture resource for making information more accessible for people with learning disabilities, see the UK CHANGE website http://www.changepeople.co.uk/
  • For a general guide on making information accessible for people with disabilities, contact the UK Employers' Forum on Disability (+ 44 (0) 20 7403 3020) to buy a copy of their Customer Action File 2 Producing Accessible Information - a practical and strategic guide

Chapter 5 - Infrastructure and Buildings

5.1 Introduction

Accessible infrastructure and buildings are essential if people with disabilities are to access and use public transport services in a safe, secure and confident manner.

It is recognised that it is challenging to improve the accessibility of some existing infrastructure and buildings which were designed to the standards of a previous era. These challenges may take some time to overcome. This should not prevent practical improvements to other aspects of accessibility in the short term. Neither should these challenges prevent new and refurbished infrastructure and buildings being designed, built and managed according to best practice.

5.2 How to Improve Access to Bus and Light Rail Stops

Bus, rail or light rail rarely provide "door-to-door" services (as a taxi can, for example). To access a bus or light rail stop, most passengers need to walk, use a wheelchair or travel by car. Satisfactory access arrangements are consequently an important factor in determining whether people with disabilities can actually use a bus, rail or light rail service. Features that need consideration include:

  • smooth, level footpaths to and from stops and station entrances/exits with drop-kerbs at road crossing points;
  • safe, accessible, road crossing facilities;
  • good lighting; and
  • safe, convenient drop-off and pick-up facilities for people with disabilities at railways stations.


Locating bus and light rail stops and railway station entrances as close as possible to the activities they serve optimises access, because walk distances are minimised. Bus routes and the location of bus stops (existing or proposed changes) can be audited in consultation with local stakeholders to ensure that they meet the needs of the communities they serve.

As operators very rarely own the surrounding infrastructure, improving access to bus and light rail stops will normally require multi-agency action. Transport operators are often well placed to lead such multi-agency initiatives which would involve local councils, the Gardaí and possibly other stakeholders such as schools, hospitals and representatives from other community based facilities.

5.3 Bus and Light Rail Stops
The overall design and maintenance of bus and light rail stops should consider the following points as critical to the development of the type of high quality infrastructure that can improve passengers' confidence.

  • location;
  • footpaths and crossing facilities;
  • traffic management, including parking and loading/unloading restrictions;
  • shelters;
  • lighting;
  • security;
  • markings and signage including bus stop poles;
  • seating;
  • information provision; and
  • maintenance and cleaning.

5.4 Access to Transport Buildings (including Stations)

Bus and rail stations and transport buildings are accessed by a variety of methods including by foot or wheelchair, by car (drop-off or parked), other public transport modes including buses and light rail and other transport means including specialised transport services and taxis. The general principle is that no matter what method is used to arrive at the station or building, the approach should be accessible.

The approaches to and the environment around the station or building need to be clearly signed so that passengers know where they are going. The following questions all need to be answered if appropriate:

  • Is there a drop off zone - or a short term waiting zone?
  • Where is the car park and where are the accessible car parking spaces?
  • Where to purchase parking tickets (if required)?

Not all entrances to station buildings will be accessible, so it is important that the accessible entrances are easy to find.

5.5 Transport Buildings and Stations

Access into and within transport buildings and stations requires careful consideration through the design and construction process. The 'Where should Operators go Next?' section at the end of this chapter highlights useful publications which provide more detailed guidance on how to make these environments more accessible.

It is often useful to assess the reasons why people visit transport buildings and stations and what their resulting needs are with regard to accessibility. People visit transport buildings and stations for a:

  • primary reason - to use the services themselves or to meet or 'drop-off' someone else using services; and/or
  • secondary reason - to deal with customer services, for example, obtaining information, purchasing tickets in advance, or making complaints etc.

Operators can reduce the need for all customers to visit their buildings for secondary reasons through the introduction of initiatives such as web based ticket sales and information provision. Web-based initiatives should complement but not replace other methods of communication.

Improving accessibility will involve taking a holistic view of the building in question and ensuring that all the following areas are considered:

  • access to and from buildings;
  • movement within buildings including changing levels (horizontal and vertical circulation), space, lifts, escalators, footbridges, steps;
  • interface with trains or buses - station platforms and boarding the train;
  • facilities including ticketing offices and machines, information points, telephones, waiting and refreshment areas/rooms, seating, luggage, toilets and assistance points;
  • signage and information; and
  • lighting and security.

Where existing infrastructure and buildings present physical challenges, easily achievable elements of accessibility should be addressed first. More emphasis can be placed on customer care to compensate for poor physical access. This is referred to as Equivalent Access and defined as a process, often involving the provision of direct assistance, under which an operator is permitted to vary the equipment or facilities that give access to a public transport service, so long as an equivalent standard of amenity, availability, comfort, convenience, dignity, price and safety is maintained.

Interventions such as modifications to heritage (listed) buildings or even installing new bus stop shelters require planning permission and this should be factored into improvement programmes. Planning authorities should not automatically rule out accessibility improvements in favour of rigorous protection of heritage buildings or other planning constraints.

When contemplating improvements in access as part of refurbishment projects, the consultation and decision-making process should be similar to that for new buildings. Also, the option of a significant improvement in accessibility over a short period of time against a series of less significant improvements over a longer period of time should be examined, because the more significant improvement may represent better value for money.

5.6 Auditing for Accessibility

Auditing can play a very important role in a number of ways. Auditing can assist operators, regulators and passengers to determine just how accessible the current infrastructure and buildings are, how effective accessibility improvements have been and how accessibl e new schemes are. Professional accessibility auditors can be employed to do this type of work.

The audit should:

  • examine the access features and requirements for all passengers; and
  • identify existing physical and communication barriers to access.

Building for Everyone: Inclusion, Access and Use (NDA, 2002) recommends that audits are much more proactive when it comes to prioritising the audit findings and proposing solutions. It also recommends that any solutions which are proposed should reconcile access needs with any requirements for building and site conservation.

Where should Operators go Next?

  • Building Regulations, 2000, Part M: Access for People with Disabilities, (Department of the Environment, Heritage and Local Government) on how to make adequate provision to enable people with disabilities to safely and independently access and use a building
  • For information on retro-fitting and refurbishment of buildings, general guidance on transport terminals and a good general guide on inclusive buildings and environments refer to: Building for Everyone: Inclusion, Access and Use, National Disability Authority, 2002, ISBN 1 870 499 034.
  • Improving Transport for People with Mobility Handicaps. A Guide to Good Practice, (ECMT, OECD, Paris, 1999)
  • The latest station design handbook is "Eur 20807 - COST Action 335 - Passengers' Accessibility to Heavy Rail Systems", ISBN is 92-894-6074-1, European Commission Directorate-General for Research, 2004
  • A key document for the design of tramways is The Railway Safety Principles and Guidance (RSPG), Part 2, Section G, Guidance on Tramways (Health and Safety Executive, UK)
  • For information and guidance on bus stop infrastructure, including the location and physical layout of the stops, refer to Bus Stops: A Design Guide for Improved Quality (Translink and DOENI, 1997), Transport in the Urban Environment (Institution of Highways and Transportation, 1997), Guidelines for Planning for Public Transport in Developments (IHT, 1999), and Guidelines for the Design of Bus Bays and Bus Stops to accommodate the European Standard 12 metre length bus (London Bus Priority Network Steering Group, London, 1997)
  • For useful information on how to improve access to bus and light rail stops and a discussion on bus partnerships which are defined as "an agreement (either formal or informal) between one or more operators for measure to be taken up by more than one party to enhance bus services in a defined area.", obtain a copy of Quality Bus Partnerships Good Practice Guide, by The TAS Partnership for the Department for Transport, published by TAS and available on their website at: http://www.tas-passtrans.co.uk
  • Inclusive Mobility - A Guide to Best Practice on Access to Pedestrian and Transport Infrastructure by Philip Oxley for the Department for Transport UK, 2002. This document can be ordered from the following website: http://www.publications.dft.gov.uk/
  • Train and Station Services for Disabled Passengers: A Code of Practice, SRA UK, 2002. Available to download from http://www.sra.gov.uk/publications/general_default
  • Access Audits: a guide and checklists for appraising the accessibility of buildings for disabled users, Denis Fearns, 1999, ISBN 0 903976 250.
  • Access to the Historic Environment: meeting the needs of disabled people, Lisa Foster, UK, 1997, ISBN 1 873394187.
  • For information on signage use the National Council for the Blind of Ireland Recommendations for Signage at http://www.ncbi.ie/information/access_and_awareness/signage.php

Chapter 6 - Vehicles

6.1 Introduction

Public transport vehicles including buses, coaches, trains and light rail vehicles are perhaps the most visible element of the total journey process, as described in Chapter 2. Chapter 2 also highlights how important confidence is to travel and experience of travelling on these vehicles can play a significant role in developing this confidence.

The current situation in Ireland has changed greatly since the 1990s with a significant increase in the number of accessible vehicles in use by both bus and rail operators throughout the country. This is primarily because all the CIÉ Group companies (Iarnród Éireann, Bus Átha Cliath and Bus Éireann) and some private operators have undertaken significant fleet/vehicle renewal programmes. New vehicles, whether bus or rail, are much more accessible than the vehicles they are replacing.

6.2 What is an Accessible Vehicle?

ECMT states that an accessible vehicle must incorporate as a minimum:

  • full access for wheelchair users, including where appropriate accessible toilet facilities;
  • features to aid people with difficulties in walking, gripping, reaching or balancing (including non-slip surfaces, hand rails and handholds);
  • facilities to assist people with visual impairments (including consistent use of colour contrast, clear sighting and lighting, non-reflective surfaces, audible as well as visual announcements and tactile and audible guidance and warning surfaces and systems (where appropriate); and
  • facilities for people with hearing impairments (including visual as well as audible announcements and clear signs)

It is also important that vehicles should be kept clean and equipment is used and kept in good working order.

6.3 What is Best Practice Guidance for Accessible Vehicles?

Current practice in Ireland is to follow the UK Public Service Vehicles Accessibility Regulations 2000 (PSVAR) and the UK Rail Vehicle Accessibility Regulations (RVAR) and the guidance accompanying these regulations. For example, the RVAR Guidance was used by Iarnród Éireann and the Railway Procurement Agenc y in specifying the new suburban commuter trains (Diesel Multiple Units) and the Luas light rail vehicles respectively.

It is recommended that operators use or continue to use the UK PSVAR and RVAR guidance. It is critically important that the guidance is followed in its entirety, otherwise vehicles will not be fully accessible.

6.4 How to Deliver an Accessible Fleet of Vehicles?

An outstanding issue in relation to vehicles is that of standard wheelchair design. Today there are a number of different wheelchairs and mobility devices on the market including manual, electrical wheelchairs and mobility scooters. Some of these exceed the standard dimensions set out in the guidance and therefore present problems for public transport operators. As yet, there is no agreement on the maximum size, weight and dimensions for 'public transport compatible wheelchairs'.

Buses and Coaches
Buses and coaches provide different types of services and are therefore designed differently. A bus is used for local urban or rural services, typically over shorter journey distances, whereas a coach is unlikely to be used for local services, instead being used for long distance and express services, and also for touring. Coaches generally have a high floor and a hold for storage of luggage under the floor. The manufacture of low-floor accessible buses has meant that the bus fleet is in general far more accessible than the coach fleet in Ireland.

Within the last number of years, significant progress has been made in the design and production of wheelchair accessible coaches. Fully operational wheelchair accessible coaches are now on the market. UK regulations state that from 2005 all new coaches operating public scheduled services will have to be wheelchair accessible. The 'Where should Operators go Next?' section at the end of this chapter gives more details on the operation of accessible coaches.

Generally, there is no economic case for structurally modifying buses or coaches because of their relatively short service lives (about 12 -15 years). This should not prevent an operator from implementing other accessibility improvements on these vehicles.

Rail Vehicles
New rail vehicles
The best way of ensuring that a new vehicle is fully accessible is to purchase fully accessible vehicles which have been designed and specified in accordance with the guidance.

Care is required to ensure that vehicles built by different manufacturers are consistent in terms of features such as the position of door opening controls or the sound of the door opening audible warning.

It is recommended that the accessibility requirements should be treated as an integral part of the vehicle specification and consequently should be checked at the normal design review phase and also during the vehicle construction phase as part of the standard vehicle construction checks.

Purchasing second hand vehicles which have not been modified for improved accessibility is not recommended.

Existing rail vehicles and interim improvements

Rail vehicles (trains and light rail) are expected to last in excess of 30 years. During this period there will be a number of opportunities to make accessibility improvements to the vehicles during the periodic maintenance overhauls and vehicle refurbishment programmes.

6.5 How to Make Sure Operating Practices are not a Barrier?

A common cause of complaint across a variety of transport networks and systems is that the equipment is there but that it is not being used. This is the equivalent of not having the equipment at all. It is vital that the use of the best possible equipment is matched by efficient and effective staff, fully trained in the use and limitations of the vehicles and systems in use.

During the transition period between partially and fully accessible services, when there may be a mixture of accessible and non-accessible vehicles in the fleet, the accessible vehicles should be introduced on a route-by-route basis to create accessible routes. A casual mix of vehicles on the same route creates uncertainty for passengers with disabilities, ultimately denying the full benefits of the investment. If a mixture of vehicles is unavoidable, then the timetable should display clearly which services are accessible.

Equipment on board vehicles, in particular Passenger Information Systems, should be regularly checked to ensure they are working correctly and that they are used appropriately.

6.6 How to Audit the Fleet?
In order to ensure that the current fleet of vehicles is accessible, it may help to perform an audit. Annex A of the UK Rail Vehicle Accessibility Regulations (RVAR) Guidance contains a "Compliance Checklist" for rail vehicles which would be suitable to use. There is no similar checklist within the UK Public Service Vehicle Accessibility Regulations (PSVAR) Guidance although operators could develop their own.

Where should Operators go Next?

  • Rail Vehicle Accessibility Regulations 1998 - Guidance, UK Department for Transport (modified 2003). The regulations, which were introduced in 1998 under the Disability Discrimination Act 1995, address the design of all new rail vehicles, and refurbishment of existing rolling stock. The Guidance document can be found at: http://www.dft.gov.uk/stellent/groups/dft_control/documents/contentservertemplate/dft_index.hcst?n=10265&l=2
  • Public Service Vehicles Accessibility Regulations 2000 - Guidance UK Department for Transport (modified 2004). This can be found at: http://www.dft.gov.uk/stellent/groups/dft_mobility/documents/pdf/dft_mobility_pdf_503298.pdf
  • Accessibility Specification for Small Buses Design to Carry 9 to 22 Passengers (Inclusive), Disabled Passengers Transport Advisory Committee (DPTAC), 2001 http://www.dptac.gov.uk/pubs/smallbus2001/index.htm
  • For guidance and discussion on the issues surrounding interim improvements to existing rail vehicles the following document may be useful: "Consultation on Government's proposals to amend Rail provisions in Part V of DDA". This document can be ordered from the following website: http://www.publications.dft.gov.uk/publist.asp?sortby=author&level1id=24&level2id=0&page=1
  • For information on wheelchair accessible coaches and current trials and operations visit the following websites:
  • http://www.redwing-coaches.co.uk/mobility_coach.html
  • http://www.radar.org.uk/RANE/Templates/Article1.asp?lHeaderID=370
  • http://www.oxfordtube.com/
  • Cost 349 - Accessibility of Coaches and Long Distance Buses for People with Reduced Mobility http://www.cordis.lu/cost-transport/src/cost-349.htm

Chapter 7 - Customer Relations

7.1 Introduction

Passengers with disabilities are a sizeable potential market for transport services. Good customer service can help to alleviate the barriers currently encountered by passengers with disabilities.

Many people with disabilities have never or rarely used public transport because of its historical inaccessibility. Others are likely to have experienced some poor or failed journeys. Because of this, passengers with disabilities need to experience a high quality of service each time they travel if their confidence in using public transport is to improve.

A passenger's relationship with their public transport operator is affected by many different aspects of the service and not simply by the behaviour of the staff. It is inappropriate to increase expectations of staff and passengers with disabilities if the transport service itself is deficient and there is no investment programme in place to improve it.

7.2 What Approach should be Taken?

The corporate values of a public transport operator need to reflect principles of quality customer service. Service to passengers with disabilities should be an integral part of an operator's service standards. Passengers with disabilities should be involved in the development of these service standards. Standards must be clear, relevant and consistently communicated to all staff. They should be available to people with disabilities who want to see them.

Operators should employ people with disabilities. Doing so will help to deliver good customer services to passengers with disabilities. Employing people with disabilities will assist the operator in gaining a better understanding of the preferences and requirements of people with disabilities.

In order to further improve the operators' understanding of the preferences and requirements of people with disabilities, operators should undertake market research and regularly consult with people with disabilities on the quality of service.

7.3 What is Important when Communicating with People with Disabilities?

Public transport operators need to ensure that passengers with disabilities are informed as to how they can make best use of the system, and what to do when the system fails. When developing advertising and customer communication campaigns, there is a need to reflect a diverse customer base that includes passengers with disabilities. Customer feedback mechanisms, such as complaints procedures, should be accessible to passengers with disabilities. A wide range of formats should be used in communications w ith customers. Chapter 4 of this document which deals with Information Provision can help with this.

Contact with passengers with disabilities can be formal or informal. Public transport operators need to make sure that, where contact is informal, there is a way of capturing the feedback from passengers with disabilities about the service. Informal contact is generally through staff who work with customers on a daily basis and may come across passengers with disabilities more regularly. Where staff have regular contact with passengers with disabilities, their experiences can be drawn upon to improve services. The establishment of an effective feedback mechanism so that staff can let managers know where changing the service delivery system could improve levels of service to passengers with disabilities. Staff can be encouraged to do this, possibly with a rewards system.

Formal contact requires planning. Public transport operators can ask for feedback in the form of customer comments. In doing this, it is necessary to ensure that the mechanisms for providing feedback are fully accessible. Chapter 4 of this document which deals with Information Provision can help to make sure that feedback requests are fully accessible. However, there is also a need to allow passengers with disabilities to provide their feedback in the full range of formats, and to make it clear that it is possible for them to do so. Possible formats are written, spoken (face-to-face or over the phone), text phone, tape, or e-mail. It is unlikely that feedback will be received in Braille although the feedback forms should be available in Braille format. Internal systems that can cope with different feedback formats would need to be set up, for example, if someone chooses to provide feedback by telephone, a member of staff will need to record and process that feedback accurately. This requires a little more organisation than just processing written feedback forms.

Public transport operators may want to consult people with disabilities about specific issues. This can be achieved by meeting people in groups, or by issuing a consultation document, or by a combination of the two. The NDA's guidance on consultation will help to do this effectively (see 'Where should Operators go Next?' section). It is essential to be clear about why consultation is being carried out, and what is planned to be done with the feedback received from people with disabilities. The views of people with disabilities are frequently sought by private and public sector bodies. This can lead to 'consultation fatigue'. It is also disrespectful to people with disabilities to consult them if it is not intended to take their views seriously.

7.4 What about Training?

Specific steps should be taken to raise awareness of disability and equality among all employees. Training should communicate service standards and equip employees to achieve these. Staff will need training in communication with passengers with disabilities. Chapter 8 of this report which deals with Disability Awareness Training can help with this.

7.5 How to Make Sure Standards are Maintained?

It is important to monitor the delivery of the service to passengers with disabilities to ensure that the established standards are being met consistently. Information obtained from monitoring the service to passengers with disabilities should be part of the routine performance review process of the business with reporting at an appropriately high level.

Where there is a failure in service delivery, there should be sanctions available and they should be applied. Any sanction needs to be comparable to that issued for other breaches of customer service policy; otherwise staff will cease to respect the initiative to provide good customer service to passengers with disabilities. Likewise, where staff are providing effective customer service they should receive credit for it.

An example of an indicator of success is provided by measuring the number of people with disabilities using transport services when compared to the number of people with disabilities living in the respective area. This can be done as part of regular customer surveys. It is also possible to set targets from this baseline data against which performance can be measured. Another mechanism is through consultation with representative groups for and of people with disabilities.

It is also important to ensure that those who do use public transport services are satisfied with the level of service they receive. It should be ensured that passengers with disabilities are adequately covered by customer service surveys and other customer service monitoring programs. Specific surveys for passengers with disabilities can be initiated, but it is also necessary to ensure that demographic information collected for mainstream surveys can be analysed along disability lines.

7.6 How to Audit Public Transport Service Provision?

In order to ensure that the current customer service reflects good practice, it helps to perform an audit which would:

  • consider the environment in which services are being provided and the barriers to passengers with disabilities;
  • consider how enhancing the services might help to overcome those barriers, for example, by providing additional passenger assistance or training staff in new skills;
  • review customer service standards to ensure that they reflect the needs of passengers with disabilities and the proposals for meeting those needs;
  • update customer service standards and procedures where necessary;
  • measure the numbers of passengers with disabilities who are using the services and review this figure regularly; and
  • ensure that staff are trained in the new standards and procedures and that senior management give out a consistent and clear message to the entire workforce that passengers with disabilities are as important as all other passengers.

Where should Operators go Next?

  • For guidelines on effective consultation with people with disabilities, see the NDA's publication Ask Me, available at: http://www.nda.ie/Resource.nsf/askme.pdf
  • For guidance on providing quality service as a public service body, see the Principles of Quality Customer Service for Customers and Clients of the Public Service on the Department of the Taoiseach website: http://taoiseach.gov.ie/index.asp?docID=800
  • Refer also to Better Government website which sets out more details on the Quality Customer Service Initiative http://www.bettergov.ie/index.asp?docID=237
  • For practical advice for staff on assisting passengers with disabilities, contact the UK Employers' Forum on Disability (+ 44 (0) 20 7403 3020) to buy copies of their booklet Welcoming Disabled Customers

Chapter 8 - Disability Awareness Training

8.1 Introduction

It is important that staff understand the needs of passengers with disabilities and are able to respond to them appropriately. One of the most effective ways of ensuring that staff learn about people with disabilities and their needs, and how to improve the industry's employment record on disability, is to implement a programme of disability awareness training. Many operators have implemented training programmes and already have in-house guidelines for Disability Awareness Training.

8.2 Who should be Trained?

All staff need training in disability issues including but not limited to drivers, mechanics, board members, cleaning staff, managers, designers and frontline/customer-facing staff. Training just the frontline/customer-facing staff is not enough, even if these are the staff who work with passengers with disabilities on a daily basis. Therefore, everybody in the operator's organisation should understand the needs of passengers with disabilities as they relate to their own jobs in order that individual members of staff can provide good quality, appropriate and respectful service to passengers with disabilities. Staff that have been trained on disability issues will also be better prepared to work alongside people with disabilities within an organisation.

8.3 What Training should be Provided?

The range of issues that needs to be covered in training can be considered as follows:

  • the business case - including financial and marketing issues;
  • the law - employment and customer service;
  • challenging stereotypes and assumptions;
  • relating to people with disabilities - language, etiquette;
  • working with people with disabilities - practical skills and use of equipment;
  • inclusive working - removing barriers in practices, policies and procedures;
  • inclusive design - removing barriers in the physical environment; and
  • inclusive information - removing barriers in communication and information provision.

Not all staff need the same training. It is necessary to provide the right sort of training to staff with different roles. Senior managers will need to know more about the law, the business case, and how to develop organisational systems and policies that will enable good employment practice and quality customer service to passengers with disabilities. Staff who work directly with passengers will need to understand the more practical aspects of disability, for example, how to guide a visually impaired person or how to use a particular piece of equipment. They will also need to know when it is appropriate to respond with flexibility to issues that passengers with disabilities may experience. Designers will need to understand the principles of inclusive design in whatever field they are working, for example, architecture, vehicle design, information technology and so on. The following table provides guidance on the minimum requirements for different staff roles and levels.

Staff Training Requirements

Staff role/level

The business case

The law

Challenging stereotypes

Relating to people with disabilities

Working with people with disabilities

Removing barriers -- practices etc

Removing barriers - physical

Removing barriers -- information

Senior management

Y

Y

Y

Y

N

Y

N

N

Human Resources

Y

Y

Y

Y

N

Y

Y

Y

Non-customer-facing operational staff

N

N

Y

Y

N

N

N

N

Customer-facing operational staff

N

N

Y

Y

Y

Y

Y

Y

Designers/architects/engineers

Y

Y

Y

Y

N

N

Y

Y

Property managers/Maintenance staff

Y

Y

Y

Y

N

Y

Y

Y

Marketing/customer service

Y

Y

Y

Y

N

Y

Y

Y

Occupational health

Y

Y

Y

Y

Y

Y

Y

Y

IT

Y

Y

Y

Y

N

N

N

Y

 

8.4 How should the Training be Provided?

Disability awareness training should form part of an integrated training programme. It does not have to be delivered in the classroom. Depending on the nature of the training and on-the-job demands of the staff being trained, on-the-job training, distance learning, briefings, workshops, or project based learning can all be used to good effect. Senior managers may find a briefing on the business case for accessibility the most acceptable way to receive the information. Training in the use of equipment for frontline/customer-facing staff is better delivered in the working environment, perhaps as part of a wider programme. General disability awareness training has also been successfully delivered via distance learning courses.

When it comes to who delivers the training, there are similar choices to be made to the choices that need to be made for other training courses. Using in-house staff ensures that trainers understand the operator's specific business issues and the nature of the business. However, in-house staff may lack the expertise and the experience to deliver truly effective training. Using people with disabilities as trainers to deliver training face-to-face provides a role model for the staff who are receiving training, and helps to accelerate changing attitudes and behaviours.

In addition, there should be some consideration of the pace of the delivery of the training programme, so that staff can be trained within a reasonable period of time. The pace and resources of the training programme should reflect the size of the operator's organisation. For large operators, it is appropriate to measure progress in this area as a percentage of staff trained rather than absolute numbers of staff trained.

There are a number of important things to bear in mind with disability awareness training:

  • Training should be equality orientated, focusing on the fact that the custom of passengers with disabilities is as valuable as that of all other passengers and that they must be afforded the same right to travel.
  • It is essential to involve people with disabilities in the design of the training.
  • If the trainers are not people with disabilities, it should be ensured that they have worked extensively alongside people with disabilities, or have been trained by appropriate registered organisations specifically to deliver the training.
  • The views and experiences of people with disabilities should be heard in the training, however that training is delivered. Courses, for example, could include video footage of people with disabilities discussing their experiences. In written training material, case studies of people with disabilities and their experiences could be included.
  • Nominated trainers should have some understanding of how the transport industry operates and the pressures involved. It may be helpful to arrange for them to speak with drivers and customer service staff while designing the course.
  • The training event itself should reflect the principles of good access. Training should be held in accessible venues. Delegates should be asked about their own access needs, and those needs should be met. Failure to do this sends out a message that disability is not really considered to be important. It will be necessary to review all existing training courses to ensure that good access principles are adhered to.

8.5 When do People need Training?

The most appropriate times to provide training to staff are:

  • at induction;
  • three to five yearly refresher courses as part of an integrated programme; and
  • if staff change their role and require different skills (see table above).

If disability awareness training to staff has not previously been provided, or there is uncertainty as to the quality of the training that has been provided, it will be necessary to establish a programme that ensures all staff receive disability awareness training over a specific period.

Where should Operators go Next?

  • For details on the FÁS Disability Awareness Training Support Scheme which is open to all companies in the private sector log onto http://www.fas.ie/services_to_businesses/new_grants_disability.html
  • FÁS also provides a list of registered trainers on a National Register of Trainers Search Engine at http://jobbank.fas.ie/ntr/appSearch.jsp
  • For guidance on organisation-wide training on disability issues, contact the UK Employers' Forum on Disability (+ 44 (0) 20 7403 3020) to buy copies of their booklet Promoting Change
  • For high level recommendations on training operators may find it useful to refer to ECMT Consolidated Resolution No. 2001/3 on Accessible Transport.
  • Also a recent publication by ECMT and UITP entitled Improving Access to Public Transport (in E-book PDF Format) refers to (on page 45) a supplementary report on Good Practice for Staff Training which is "currently under preparation" by the ECMT - UITP Task Force (November 2004). This should be available towards the end of 2005 on the ECMT website http://www1.oecd.org/cem/index.htm

Chapter 9 - Disruption and Emergency

9.1 Introduction

Public transport operators need to have plans and procedures in place to prepare for and deal with disruptions and emergencies which may occur.

Disruptions can be defined as events which interrupt the normal course of services, for example an unplanned disruption could be a service disruption caused by a bus breakdown, or a planned disruption could be the closure of an escalator or lift for maintenance reasons.

Emergencies are more serious as they can be defined as unforeseen circumstances which result in the requirement for immediate action. Examples could include a fire or serious fault on board a vehicle or a bomb threat.

9.2 Development of Plans and Procedures

In order t o prepare for and deal with disruptions and emergencies, it is necessary to prepare and develop appropriate disruption plans and emergency plans. Existing plans should be reviewed periodically and should be assessed to ensure that the needs of passengers with disabilities are identified and catered for.

The more prepared a business is for these events the better able staff will be to deal with situations as and when they arise. Furthermore, if these plans and procedures are implemented correctly it will also reduce the numbers of complaints received from passengers. Passenger frustration is often strongly related to not knowing what is going on, rather than to the actual disruption itself.

Dealing with disruptions which arise on a more frequent basis requires simple and effective procedures to enable staff to communicate with passengers. Public transport operators and service providers need to ensure that this is done in a way that all passengers, including passengers with disabilities, can understand.

There are two accepted rules for this:

1) Provide information on the disruption at the earliest opportunity

Providing information at the earliest opportunity allows people to make alternative arrangements. Advance warning of planned disruptions is a minimum requirement. For unplanned disruptions, providing people with information before they purchase tickets, for example, is much better than after they have purchased tickets. Providing information on disruptions before people leave home is best and this can be done in a number of ways (radio, website, text (SMS) messaging).

Disruptions during the journey, i.e. when passengers are on board the vehicle, should also be communicated to passengers, as this will allow passengers to make alternative arrangements such as informing people waiting for them at the end of the journey. The way in which this information is given should reflect different people's information needs. The general rule is that passengers should be informed if the disruption or delay is likely to be greater than 10 minutes.

2) Provide relevant information

Providing only relevant information is important. Passengers are less interested in what has caused the disruption than in knowing how long the disruption will last and what actions are being taken. If a bus is broken down, passengers should be informed whether a replacement bus will be provided. If a station lift is out of service, passengers should be informed which alternative station to use.

Plans and procedures for dealing with disruption should be communicated to staff and included in staff training programmes.

Planning for emergencies, which should be less frequent, is still a significant exercise and will involve identifying possible emergencies that may occur and designing plans and procedures to deal with them. Emergencies will often require the evacuation, or part evacuation, of a building or vehicle and, as such, much more consideration is needed on how all passengers, including those with disabilities, can evacuate to an appropriate place of safety. Obviously the more accessible a building is the more easily it can be evacuated during emergencies. Public transport operators and service providers should also note that there are statutory requirements regarding fire prevention which must be complied with. In November 2003, the Irish Wheelchair Association (IWA) made a submission to the Department of the Environment regarding Part B of the Draft Building Regulations in relation to Fire safety. The IWA stated:

'In the opinion of the Irish Wheelchair Association the current draft regulations do not adequately reflect the fact that a significant proportion of the users of a building may have a visible or hidden impairment which, in the event of a fire alert, would make the usual means of escape inadequate or inappropriate.'

9.3 Assessing, Auditing and Testing

Plans and procedures should be subjected to assessment and auditing as well as actual practical testing of procedures. It is important that public transport operators and service providers ensure that they cater for the requirements of all their passengers and there is a strong argument for involving people with disabilities in the auditing and testing of the plans and procedures. Additionally, professional accessibility experts should be employed as they will be able to assess against a wide range of accessibility parameters and different types of impairments which non-expert auditors, even people with disabilities, may not be able to do.

Where should Operators go Next?

  • Access Audits: a guide and checklists for appraising the accessibility of buildings for disabled users, Denis Fearns, 2004, ISBN 0 903976 250
  • Building for Everyone: Inclusion, Access and Use - Part 4 Buildings in Use, National Disability Authority (2002), ISBN 1 870499 034. This provides guidance on the day-to-day management of buildings and in particular, guidance on access and safety in emergency situations
  • The Irish Wheelchair Association's review of the Department of the Environment's Draft Building Regulations in relation to fire safety is a useful reference at http://www.iwa.ie/advocacy/Fire-Safety.doc
  • Escape of Disabled People from Fire: a measurement and classification capability for assessing fire risk, BR301, TJ Shields, KE Dunlop, GW Silcock, BRE, London, 1996, ISBN 1 86081 0675
  • Fire and Disabled People in Buildings: Building Research Establishment Report, BR 231, TJ Shields, BRE, Watford, 1993, ISBN 1 90137015 - at http://www.brebookshop.com/

List of Useful Contacts

The National Disability Authority

25 Clyde Road,

Dublin 4,

Ireland.

TEL: (01) 608 0400

FAX: (01) 660 9935

www.nda.ie

The National Disability Authority Library

TEL: (01) 608 0433

FAX: (01) 660 9935

EMAIL: library@nda.ie

The Department of Transport

Transport House,

Kildare St.,

Dublin 2,

Ireland.

TEL: + 353 1 670 7444
or Locall 1890 443 311
EMAIL: info@transport.ie

European Conference of Ministers of Transport

http://www1.oecd.org/cem/

The term "people with disabilities" used in this document corresponds to the term "people with mobility and sensory impairments" used by the Department of Transport.

"The Department's objective with regard to Transport Accessibility is:

That all passenger transport providers should provide the highest possible degree of accessibility, subject to available resources and competing priorities and rules of practicality."

The obligations arising from this objective will apply to all providers of public transport services, both public and private." (Department of Transport (2004), Outline Sectoral Plan under the Disability Bill 2004, Dublin: Government Publications).

NDA (2004), Towards Best Practice in Provision of Transport Services for with People with Disabilities in Ireland, Dublin: NDA Publications.

Department of the Taoiseach (2000), Programme for Prosperity and Fairness. Social Partnership Agreement 2000-2003, Dublin: Government Publications. In particular, Framework 3 for Social Inclusion and Equality, Paragraphs 19 and 20 under Disability - Accessibility of Public Services, states the following:

19 Each Government Department will ensure that reasonable steps are taken to make its services and those of agencies under its remit accessible to people with disabilities. To facilitate effective action and acceptable standards in this regard, the NDA will issue guidelines in accordance with international norms and will award an accessibility symbol to compliant public offices. Government Departments and agencies will take all reasonable action to qualify within five years.

Department of the Taoiseach (2003), Sustaining Progress. Social Partnership Agreement 2003-2005, Dublin: Government Publications.

The Outline Plan also notes that "it is inevitable that some people, because of the severity of their disabilities, will not be able to be accommodated on public transport services. In these cases, specialised non-public transport services would be the alternative form of transport".

Charter on Access to Transport Services and Infrastructure, adopted by the ECMT in May 1999 in Warsaw, http://www1.oecd.org/cem/topics/handicaps/pdf/tphCharter.pdf .

NDA (2002), Building for Everyone: Inclusion, Access and Use, NDA Publications

On public roads, it is the responsibility of the Gardaí to site bus stops in safe locations and the responsibility of the local authority to provide adequate space for bus stops.

Retro-fitting and Refurbishment, Chapter 11 of Building for Everyone, NDA (2002)

Retro-fitting and Refurbishment, Chapter 11 of Building for Everyone, NDA (2002)

ECMT Charter on Access to Transport Services and Infrastructure, 19-20 May 1999.

Cleanliness is of particular importance to people with disabilities because they have to touch more things than other people do, as they need extra support and guidance. People with visual impairments cannot see whether what they are touching for guidance is clean or dirty.

Accessible coaches generally provide lifts for wheelchairs, normally at the middle of the bus and accessible toilets, which can be used when the bus is stationary.

The regulations do not apply to coaches used for non-scheduled services such as touring holidays, private hire, day tours etc.

Service life will depend on a number of factors including age, mileage, road conditions and maintenance record.

See the "Where should Operators go next?" section for a reference to the Principles of Quality Customer Service for Customers and Clients of the Public Service developed as part of the Strategic Management Initiative. The Strategic Management Initiative (SMI) was launched in 1994 with the stated objective of presenting public service management with an opportunity to make a substantial contribution to national development, through the provision of services to the public which were both excellent in quality and effective in delivery. In 1996, Delivering Better Government (DBG) expanded on the framework set out in SMI and presented a vision for the civi l service built around six key organisational themes. These included a greater openness and accountability, a mission of quality customer service, and the efficient and fair operation of simplified regulations.