Design for Dignity – Retail Guidelines

Produced by Major Sponsors

Reviewers and Supporters

1

Design for Dignity - Retail Guidelines

Contents

Contents ............................................................................................................................... 1

1 Introduction .................................................................................................................... 2

2 What do we mean by ‘disability’? ................................................................................... 2

3 What matters to customers with disability? ..................................................................... 6

4 Designing for dignity .................................................................................................... 28

5 What are your responsibilities? .................................................................................... 40

6 Guidance on premises ................................................................................................. 49

7 Guidance on contact centres........................................................................................ 80

8 Guidance on online retailing ......................................................................................... 85

9 Guidance on customer service ..................................................................................... 89

10 Providing Feedback ................................................................................................... 102

11 Disclaimer .................................................................................................................. 103

12 References ................................................................................................................ 103

13 Appendix .................................................................................................................... 106

2

1 Introduction

Shopping is an integral part of life and is more than just buying goods and services.

Whether it is shopping for groceries, going to the bank, visiting a café, the Post Office or

shopping for the latest fashion trends, we all gain a level of social engagement and

interaction from these activities.

The aim of this guide is to provide retail business owners, service providers, shopping

centre owners and managers, designers, builders and certifiers with an understanding

of how to make the shopping experience for people with disability more independent,

pleasurable and dignified.

It is broadly accepted that organisations with a good understanding of the impact of disability

on their customers will reach a wider market.

A UK survey found that 83 per cent of people with disability had avoided a business, having

been unable or unwilling to make a purchase.

In addition, 76% of people who did not have a complaint successfully resolved indicated they

would be prepared to leave for a more accessible provider.1

The challenge is how we develop a more inclusive view of how people with disability access

and engage with place, and importantly, how this can be done seamlessly with equity and

dignity.

2 What do we mean by ‘disability’?

Disability, for the purposes of this Guideline, is an experience where people with sensory,

cognitive, physical or other impairments experience unintended barriers when engaging with

our projects or designs2.

There are of course many definitions of disability.

In Australia in 2015 the Australian Bureau of Statistics (ABS) estimated there were 4.1

million people living in households, or 17.6% of the population, in Australia who experience

1 According to an Australian Network on Disability (AND) survey of over 200 people with disability in April 2016.

2 The UN Convention on the Rights of Persons with Disability defines disability in the following way: “Persons with disabilities include those who have long term physical, mental, intellectual or sensory impairments which, in interaction with various barriers, may hinder their full and effective participation in society on an equal basis with others”.

3

disability. This is around 13% of everyone under 65 and about half of everyone over the age

of 65.

The number of people experiencing disability in later life is expected to increase as the baby-

boomer generation ages and the prevalence of chronic health conditions such as diabetes,

cardiovascular and mental illnesses increase.

The spectrum of disability is therefore broader than the stereotypical images of people in

wheelchairs, intellectual disability, deafness and blindness. The graph below3 shows how the

probability of disability increases with age, from an 8% chance at age 25 to 53% chance at

age 75:

“A typical misguided viewpoint is that someone is either disabled or fully able, yet a

wide spectrum of capabilities is clearly apparent within any population. An

understanding of quantitative population statistics can also inform design

decisions.” 4

3 Australian Bureau of Statistics, Survey of Disability, Ageing and Carers (2015)

4 Inclusive Design Toolkit http://www.inclusivedesigntoolkit.com/betterdesign2/ Viewed September 2016

3

10 8 812

16

23

32

38

44

53

65

75

85

0

10

20

30

40

50

60

70

80

90

% li

kelih

oo

d o

f d

isab

ility

Age Bracket

Likelihood of disability

4

Some people with disability use aids that assist in their daily lives. ABS data shows that only

18% of people with disability use mobility aids and 27% of people with disability use some

form of communication aid.

These could be very familiar devices like a mobility scooter, wheelchair or walking frame or

they might be less apparent like a hearing aid, a smart phone to assist communication by

typing messages, or a sonar cane that helps someone know when there are barriers in close

proximity.

7

15

22

42

50

62

164

183

186

200

275

310

390

641

0 100 200 300 400 500 600 700

Cochlear implants

Car modification

Speaking aid

Scooter

Other hearing aids

Cane (white ane, sonar canes etc)

Wheelchair

Reading or writing aid

Email or internet

Other mobility aid

Walking frame

Walking stick or crutches

Mobile or cordless phone

Hearing aid

Use of Mobility or Communication Aids (000)

5

These factors have significant implications for how we design and build future shopping

centres and retail outlets, as well as the connecting transport and service infrastructure.

Integrating accessibility and inclusion principles at the early stages of design should

therefore be an essential step, shifting away from solely compliance-driven approaches and

the often, more expensive retro-fitting solutions implemented as an afterthought, during later

stages of development.

“Regardless of the nature of the disability, retail design features have the power to

support individuals’ desire to feel independent and competent, or to disable them,

making them feel disempowered and incapable. Further, inclusive design sends

positive messages to people with disabilities, messages that tell them ‘you are

important,’ ‘we want you here,’ and ‘welcome.’”5

Having more ‘universal’ or ‘inclusive’ design also makes good business sense to attract as

many people as possible to accessible developments. Thriving people places reinforce

stronger rental income streams and asset values, and an overall competitive advantage for

the developer and asset owner.

5 Yu, H., Tullio-Pow, S., Akhtar, A., March, 2015, Retail design and the visually impaired: A needs assessment, Journal of Retailing and Consumer Services p122

6

Goss (2003)6 in a study on UK pharmacy chain, Boots, notes that “Potential property

purchasers need to be aware of this, and could demand that a property is not considered for

purchase before a fully accredited DDA compliance audit has been undertaken and all

remedial works identified or costed.”

An access audit undertaken from a member of the Association of Consultants in Access

Australia could help reduce this risk under the Disability Discrimination Act 1992.

3 What matters to customers with disability?

The Australian Network on Disability (AND) is a member based not-for-profit organisation.

Organisations and businesses join to access specialist information and training that supports

their ability to include people with disability in all aspects of their business.

In addition, for many years, AND has conducted research with people who have lived

experience of disability and people who support, assist or care for people with disability.

In 2012, a comprehensive survey was conducted with 298 people with disability in Australia

about their retail shopping experiences.

The research referenced in this Guideline is taken from these studies and includes the voice

of people with disability in quotes and reflections about their retail experiences. Some of

these quotes are provided in italics.

3.1 Good customer experience

It makes sense that the more a customer enjoys the shopping experience, the more goods

and services they will buy.

The better the store design and customer service the more likely they are to recommend a

place to friends and family.

Researchers looking at drivers of customer satisfaction for customers with disability find that

that both store accessibility and customer service factors are important for customers with

disability.

Goodrich and Ramsey (2011) 7 found that ‘accessibility appears to be an overriding issue in

the service quality domain for consumers with disabilities’ but that ‘service intangibles’ such

as empathy and assurance ‘have the strongest effect on perceived service quality.’ The

physical accessibility factors that they tested and found to be significant were:

6 Goss, S, 2003, Putting the Disability Discrimination Act into perspective. Journal of Retail & Leisure Property p126

7 Goodrich, K. and Ramsey, R., (2012) Are people with disability receiving the services they need? Journal of Retailing and Consumer Services p127

7

Ramps are not too steep.

Aisles are sufficiently wide and not cluttered.

Store layout makes it easy to move around.

Rest rooms and fitting rooms are accessible.

Availability of working wheelchairs or motorised carts.

Doors are sufficiently wide.

Intangible service factors that positively influenced customer satisfaction were also quite

clear:

Employees are consistently courteous (assurance).

Employees help make the overall experience pleasurable (assurance).

The behaviour of employees instils confidence (assurance).

Employees are never too busy to respond to requests (response).

Employees give prompt service (response).

People feel safe in their transactions with the company (assurance).

Services are provided at the times promised (reliability).

Employees speak to individuals as they would every other customer (empathy).

Employees have the knowledge to answer questions (assurance).

3.2 Being treated fairly

People basically just want a fair go when it comes to going about their business.

8

The ABS reported that 8.6% of people with disability8 felt that they had been discriminated

against in the 12 months before the 2015 census.

People with different types of disability experienced very different outcomes.

More than 20% of people who experience intellectual disability or a disability related to social

interaction felt that they had been discriminated against, while less than ten percent of

people with sensory disability or mobility restrictions reported discrimination.

Younger people felt that they had been discriminated against to a much higher degree

(20.1% of 15-24 year-olds) than older people (9.4% of 55-64 year-olds).

While there has been no research into this data yet, it may be that younger audiences are

more familiar with their rights and have greater expectations that older people with disability.

8 Persons aged 15 years and over with disability, living in households, types of situations avoided due

to disability in the last 12 months–2015, proportion of persons

7%

21%

9%

22%

16%

0%

5%

10%

15%

20%

25%

Sensory andspeech

Intellectual Physicalrestriction

Psychosocial Head injury,stroke or

acquired braininjury

% in

th

e la

st 1

2 m

on

ths

Impairment

Discrimination

9

ABS data also tells us where the experience of unfair treatment is likely to happen by asking

people with disability about the situations they avoid because of discrimination.

In public settings, people with disability avoid shops, restaurants, cafés and bars most

frequently.

There is a significant opportunity for accessible retail shopping centres, outlets and dining

venues to ensure that they give everyone an equitable and dignified experience.

21%

18%17%

14%

9%

2%

0%

5%

10%

15%

20%

25%

15–24 25–34 35–44 45–54 55–64 65+

% in

th

e la

st 1

2 m

on

ths

Age Bracket

Discrimination

9%11%

33%31%

25%

19%

0%

5%

10%

15%

20%

25%

30%

35%

Educationfacilities

Medicalfacilities

Shops Dining venues Publictransport

Recreation

% in

th

e la

st 1

2 m

on

ths

Situations Avoided

Public situations avoided

10

Baker (2006)9 studied the value of shopping to customers with vision impairment.

The study found that people wanted to be treated like other consumers and gained

satisfaction and identity from shopping in four ways:

“I am here” – being in the shopping centre or shop, purchasing things and being

involved in the shopping experience.

“I am me” – people wanted to be viewed for their unique needs and personality first

and their disability second.

“I am in control” – people wanted primary control over their shopping purchase

decisions.

“I belong” – they want to be a regular and expected part of the shopping.

The research found that while an accessible retail environment can attract new customers, it

is the service that they receive in-store that creates the environment that retains customer

loyalty.

3.3 Travelling to the store

For a customer with disability, the journey to the store is just as important as the design of

the store itself. Being able to get to the store by public transport or find an accessible parking

space, navigate the shopping centre and easily locate and use accessible toilets are an

important part of the shopping experience.

“Allocate more car parks for people with a disability and change location of

accessible car parking to being adjacent to front door.”

“Disabled parking with room for ramp to come out of the back of the car and not

be in the way of other traffic.”

For people who are blind or have low vision, drop off zones for taxis and other ridesharing

vehicles – and clear navigation from these to the entrance is beneficial.

Without clear and consistent zones, grades and path surfaces for exiting the vehicle and

navigating to the entrance, there is a higher risk of accidents and reduced independence for

people reliant on taxis and ridesharing as a form of transport.

Being able to travel through the shopping centre without incurring obstacles such as steps,

ramps, turnstiles, unmarked glass doors and unmarked head height obstacles is critically

important as it impacts customers with a variety of disabilities.

A 2012 study10 examined the phenomena that people walking in a natural environment

without stable visual landmarks often get lost and start walking in circles. The test

9 Baker, S. M., 2006, Consumer Normalcy: Understanding the value of shopping through narratives of consumers with visual impairments. Journal of Retailing, 82 (1) pps 37-50

10 Bestaven, E, Guillaud, E, Cazalets, J, 2012 Is “Circling” Behaviour in Humans Related to Postural Asymmetry, Universite de Bordeaux, PLOS One 7(9)

11

blindfolded people and tracked where they walked without the ability to see landmarks. The

chart below, shows how people who can’t see veered off course during their testing. After

140 metres, few were still on track.

What does that have to do with retail? For a person who is blind or has very low vision, this

has an influence on whether the design of shopping centre areas with significant open space

is intuitive to use and dignified or not.

For people who are blind, having pathways with a distinct finish or texture can let people

know where the pathway is located. In the absence of tactile indicators, people who are blind

tend to navigate by ‘shore lining’ or following the line of buildings or shopfronts.

This also means that having obstacles in front of stores like ‘A frame’ signage or

merchandising displays can be a dangerous obstacle. For people with low vision, having a

distinct luminance contrast between the pathway and surrounding floor can significantly ease

stress in wayfinding.

12

Shopping centre in Hong Kong with Warning and Directional Tactile Indicators

Tactile maps are maps which allow people, including a person who is blind or has low vision

to orient themselves with the shopping centre. Key features or pathways on the map have a

tactile profile that can be detected and understood by someone who is blind. These are also

combined with braille descriptions. There are competing technologies now that allow people

with disability to navigate within shopping centres.

“Provide tactile way finding or audio way finding for all smartphones and audio

eftpos.”

13

Picture courtesy of Brailliant Touch Australia

Many older shopping centres have designated accessible toilets that do not meet current

standards and have not been upgraded.

Additionally, where these facilities are shared with baby change rooms they are rarely

available for customers with disability or the baby change facilities impede on the use of the

accessible toilet facilities.

The experience of carers who need to assist changing teenage or adults in an accessible

toilet area is also difficult and undignified.

Changing happens on the floor of the bathroom which can be wet or dirty and discourages

people from participating in the retail experience.

Designs for dedicated accessible facilities with additional circulation space, adult change

facilities and assistive hoists are available through Changing Places

(changingplaces.org.au).

14

3.4 Inside the store

Yu et al (2015)11 examined the issues and barriers that people with vision impairment

experience when shopping and how retailers can provide a combination of physical and

services factors, to address the issues. The main findings on the physical environment were:

The shop’s “hardware”, from location, parking, entrance, to store layout, fitting rooms,

and ambience factors such as lighting, colour, and signage.

For vision impaired customers, mobility and navigation was the biggest daily

challenge faced and limited the range of places and stores available.

Shoppers with low vision face mobility hindrances that seem insignificant to someone

with clearer vision. Customers with low vision have double the chance of slips, trips

and falls and placement of display stands along the path of travel created difficulties.

The accessibility of fitting rooms was singled out by customers with vision

impairment. The experience of closing the door, finding a chair, hooks and retaining

balance, often in poor lighting was a problem.

Labelling and signage stood out as problem areas in the physical environment: label

and tag issues with small fonts and poor colour contrast and the need for signage

with better letter size, font style, sign colour, location and content.

In surveys across different service industries AND has found that customers with disability

tend to rate attitude, disability confidence and availability of employees very highly. When

physical access or poor process threatens to make a bad experience, employee disability

awareness can often rescue the situation until a resolution can be found.

90% Attitude and disability awareness of employees.

Employee awareness was the most highly rated attribute within a store by survey

respondents with 90% of people saying it is very important or critically important. Being

aware of the needs of customers and treating people as individuals is a fundamental

element of good service. Having basic strategies in place for communication, service and

payment will assist in building a loyal customer base.

“Educate their staff about keeping aisles clear from obstacles, how to guide

someone who is blind or has low vision, how different disabilities affect people's

functional ability and encourage some basic kindness.”

83% Availability of employees for assistance.

Not every customer needs assistance in shopping, but there are times for all shoppers when

assistance is needed. For someone experiencing disability, the assistance may be in

navigating the store, finding items on shelves, having the differences between products

11 Yu, H., Tullio-Pow, S., Akhtar, A., March 2015, Retail design and the visually impaired: A needs assessment, Journal of Retailing and Consumer Services

15

described to them, reaching products that are placed on a higher shelf or display unit or

assistance with paying for the goods or services.

“Provide assistance to someone with a disability to collect items off shelves. I use

a carer to assist me but there are times I am by myself so having access to an

employee to assist me would help a great deal.”

Yu et al (2015) found that the extent to which activities could be undertaken independently

and without assistance from family members and store assistants was important. Common

issues in a retail environment that were service related were over-servicing (patronising),

reluctance to serve (lack of disability confidence), insensible payment procedures (unable to

see the cost of items, payment terminal or not having change counted back properly) and

lack of product knowledge.

82% Aisle width and room to move around.

No one likes to go shopping in crowded or awkward places. For people with a range of

disabilities, well laid out spaces without clutter and obstacles is even more important as

these can be physical barriers, trip hazards, or simply a confusing diversion as the person

tries to purchase goods or services.

“Wider aisles please I am blind and use a long cane, nothing obstructing the

walkways either - they are a hazard.”

81% Price and product information – readability.

Being able to clearly read price and product information is necessary for all customers.

Large font size, simple font types and good colour contrast can help people independently

identify what they are after. How different zones of a store are coloured or marked out can

assist people in quickly finding their way around.

“Maybe colour code the different sections/signs/labels of the supermarket e.g.

food, electrical, pet food, freezer, greeting cards, hygiene because currently all

the sections look the same and the signs in every aisle could be better positioned

and easily identifiable.”

75% Items placed within reach.

Balancing the need to maximise product display areas and shelving with the need to be able

to reach products and maintain good access can sometimes be a challenge. Customers in

the survey suggested how items are stocked and having customer service staff who are

aware of people with disability can greatly assist.

“In my case I needed to shop with a carer but it would be nice in some cases to

be able to use the store independently with the assistance of store people. That

16

would be to get a limited amount of items from the shelves, bagged and paid for

with assistance.”

73% Employment of people with disability.

While not an immediately obvious factor, the survey showed that employing people with

disability was thought to improve the understanding of the rest of the team. This didn’t seem

to be motivated by ‘tokenistic’ behaviour, but having a co-worker with disability who is able to

do the job would drive a better sense of inclusion and understanding.

“Employment of people with a disability I believe would help with education and

awareness of people with a disability. Inclusion and equality would go a long way

in improving the service.”

72% Clear overhead signage.

Clear overhead signage allows people to more easily navigate larger stores and find the

most direct route or services that may be required such as toilets.

47% Home delivery services.

The ABS12 tells us that 40 percent of all people with reported disability made their last

journey somewhere to do shopping. Of that number 57 percent drove a car to get there, 29

percent were a passenger in a motor vehicle, 9 percent walked and 5 percent took public

transport. For some people who can’t drive or have limited mobility, home delivery becomes

a very practical and useful service. For others, assistance in getting goods to a car can be

just as helpful.

43% Directional and tactile signs.

Being able to independently find your store is the starting point of the relationship. For larger

stores, signage within the store is equally important in quickly locating the goods or services

that you offer. Directional signage that has a simple font style, large print, good colour

contrast, consistent use of pictograms and can be seen from a distance is best. Where you

are providing directional signage to toilet facilities you should use the mandated range of

standard signage including the International Symbol of Disability.

So what is tactile signage? Tactile signage is signage that includes either braille or raised

lettering, shapes or figures to convey meaning to someone who can’t see your signs. You

12 Adapted from Australian Bureau of Statistics, Survey of Disability, Ageing and Carers (2012) Table 23. Persons with disability aged 15 years and older, living in households, Disability status by mode of transport and reason for last journey

17

will most commonly see them on lifts and signage for accessible toilets. Tactile signage can

be used imaginatively to let people know where they are within your store.

Users of braille also benefit from braille signage and information in other ways. Emergency

instructions in lifts in braille mean that someone can understand instruction in an emergency.

Braille menus in a restaurant setting ensure that the person is able to independently know

what is on special and to order for themselves. Wimpy Burgers13 in South Africa launched

braille menus with a unique social media campaign that gave people who used braille the

ability to ‘see’ their food before they tasted it for the first time.

26% Hearing augmentation.

In the surveys, hearing augmentation described a range of solutions that can be provided by

businesses to assist people who use hearing aids to hear the sales or service conversation

better. The requirements for hearing augmentation in premises are listed later in this guide,

but in retail stores they are particularly useful where:

Employees and customer talk through a screen.

Employees and customers talk at a distance such as across a counter.

There is a meeting room with an amplification system.

In 2005 architect Hansel Bauman (of hbhm architects) and Gallaudet University established

the DeafSpace Project14 It was a project involving the university’s design students to

understand how the university campus could be designed to better include people who were

Deaf.

It was an exercise that recognised that people who use sign language often adjust their

surroundings to enable better communication. Using sign language requires space between

people to be able to see hand movements and the person’s face. This has implications for

design of pathways and ensuring spaces are uncluttered so that two people in conversation

can focus on each other rather than obstacles (or blind corners at passage intersections). It

also requires that the lighting is sufficient to see, but also that it is diffused to reduce glare,

eliminate strongly back-lit situations and enable longer conversations without eye-strain.

People who use hearing aids or cochlear implants can also be very sensitive to sound

reverberating off hard surfaces.

The implications for retail design overlap with the needs of many other users:

Ensure sufficient space for people to interact and communicate, especially when

walking.

13 Wimpy Burger Promotional Video: https://www.youtube.com/watch?v=5YAchE0-o-o Viewed September 2016

14 http://www.gallaudet.edu/campus-design/deafspace.html Viewed September 2016

18

Ensure that lighting is even and bright lighting isn’t directed at customers entering the

stores.

Seek to reduce noise reverberation and noise from external sources.

Consider the line of sight for people as they travel, especially at blind corners.

3.5 Checkout

Getting to the checkout or payment desk and paying for your purchases is a routine that

most people take for granted. The considerations for people with disability are more complex

and are a critical factor in whether the person can shop independently and can purchase

goods in the same way as others.

80% Assistance from employees.

Getting assistance from employees can be a positive or a negative depending on how it’s

handled. Baker (2006) 15describes how providing unwanted assistance can reduce a

person’s sense of independence, yet can be critical in enabling the person to shop. The AND

survey also found that getting the right assistance is about striking a balance, but the first

15 Baker, S. M., 2006 Consumer Normalcy: Understanding the value of shopping through narratives of consumers with visual impairments. Journal of Retailing, 82 (1) pps 37-50.

19

principle is to ask the customer how you can help rather than taking control out of a

customer’s hands.

“Have staff readily available to assist those with a disability [during] the checkout

process.”

“Some people look like they need assistance when in fact they don’t so it's about

striking a balance.”

78% Access to payment terminal.

Payment terminals pose challenges to customers in a number of areas, including instances

where:

They are placed out of reach for people who are seated or of short stature.

Terminals are on a cord which prevents someone placing it on their lap or using

one handed.

Terminals that can’t be used independently by people who are blind are used.

Irregular placement of multi-purpose cheque, savings and credit buttons occurs.

Selecting numbers tends to be easier as they are usually in the same place and

the number 5 will usually have a raised dot on it.

Cash payment can also pose difficulties. Consider a person who is blind who hands over

$50 for an item in a store. The person is reliant on the assistant to correctly count back the

notes and provide them in a way that the person can easily put away.

“EFTPOS machines are fixed and out of reach for those using a wheelchair.”

71% Space at the counter.

Having space at, and around, the counter allows people to bring goods to the counter and if

necessary pass by the counter to get out of the store. In supermarkets, keeping dedicated

wider aisles open and clear ensures that people using wheelchairs, mobility scooters and

prams can easily do their shopping.

64% Counter height

Survey respondents with physical disability felt that the counter height and space underneath

was very important. The effective height of a counter is also increased when merchandise,

computers and sales information is placed on top. It creates a very unequal customer

experience with standing sales staff peering over the top and people approaching the

counter at a lower level.

“Provide low height payment counters with leg room underneath or beside it for

wheelchair uses to be able to use from a seated position.”

20

3.6 Customers on the telephone

In a 2013 AND survey of telecommunications customers with disability it was found that

communication is a key issue. Frustration occurs when a person with disability struggles to

understand the operator or cannot get their message across. This is compounded if there

are operational issues encountered such as long automated voice options or the caller is

using the National Relay Service and the operator does not understand how to work with

this.

“Entering long account codes - with limited vision and one working arm it is

impossible for me to do this so I require assistance to call.”

Where someone depends on a partner or carer to make contact, this is also difficult due to

identification processes. When the process works well, the business benefits:

“The company I am with do have excellent and respectful representatives and do

their best to assist me so I can understand and do not make me feel silly.

Consequently, we have our two mobile (partner's and mine) phones, landline and

broadband packaged together and my partner can talk on my behalf if I am

unable to do so.”

In the survey, AND asked participants to detail any specific barriers or obstacles they faced

when using a contact centre/call centre and describe how the experience made them feel.

Some comments that didn’t relate to accessibility have been left out, but the feedback

supports the sorts of issues and experiences you might expect. Difficulty hearing strong

accents or against background noise and difficulty getting people to understand their

particular needs and to assist were common issues.

Clarity

“A big problem is the lack of clear spoken English on the part of many customer

service people. Americans and Indians speak far too quickly and do not slow

down sufficiently even when asked to do so repeatedly.”

“Ringing back until you get experienced, well trained staff with no strong accent is

very time consuming [when I] register new SIM cards.”

“I have to get my partner to ring back as I can't hear what the representative is

saying. This makes me feel frustrated. I particularly have problems understanding

certain accents.”

Noise

“Difficult to hear conversation due to background noises from my end and other

end.”

“Hearing the information is very difficult over the phone.”

“Only difficult to hear the conversations due to background noises from my end

and the other end.”

Understanding

21

“Staff did not understand my disability related needs. Eventually left service

provider.”

“The call centre staff don’t usually understand what it means to have a disability.

So when you explain to them you can’t read something they just keep asking for

that information. Sometimes you give them personal information to look up your

details and they say they can’t find you or that their department doesn’t have

access to that information.”

“Call Centre staff did not understand what a disability was. Also how important it

is that I had continued service on my phone.”

Accessible alternatives

“I feel quite stupid when trying to work with phone company staff who can't find a

way to cope with alternatives in being unable to access another phone or

messages while talking to them - really frustrating.”

Systems

“It appears that organisations expect customers to use the internet to address

needs.”

“The phone call can require you to say something and the automated computer

thingy does not understand you and you say it again, and again, and again. It just

does not work well. I hate being on hold and not knowing how long I am needing

to be on hold.”

Often retailers have a call centre or contact centre to assist with product or service enquiries

or to make ‘out-bound’ sales calls. Research commissioned by the independent regulator

and competition authority for the UK communications industries, Ofcom, conducted research

into the needs of customers with disability

“Things disabled people tell us16 ” include the following:

People who are blind or have low vision have reported that call centre workers

assume that callers can see, and are unable to divert from the script - even when

they know that the customer with disability17 cannot do what they are asking, e.g.

read a serial number.

People who are deaf report that call centres regularly hang up when they call via the

text relay service.

People who are hard of hearing have told us that requests to speak more slowly are

often ignored.

16 “Disabled people” is acceptable terminology in the UK and New Zealand, but Australia and the US use the terminology “People with a disability”.

17 http://consumers.ofcom.org.uk/ofcom-for-business-consumers/help-for-disabled-business-customers/disabled-customers-and-call-centres/ Viewed September 2016

22

People who have learning disability or have experienced a head injury tell us that

they find menus and entering numbers (e.g. their account number) difficult.”

3.7 Purchasing online

The ABS measured access to computers and internet for people with disability in 2012. It

shows that 85.3 percent of people with disability aged between 15 and 64 living in

households had access to a computer, and that 84 percent had access to the internet at

home. In the 12 months before the survey, 75 percent had accessed the internet at home

and 39.6percent had accessed the internet away from home.

It is common for people with disability to use the internet with the assistance of specialised

hardware or software. Increasingly, the in-built features of the device being used (like

smartphones) enables interaction with a website. Some technologies that people will use to

read, understand and use your website will include:

Electronic braille display: A device that displays a line of braille characters by

raising and lowering the dots (pins) dynamically so that a website can be understood.

Screen reader: Software that reads the content of a website and communicates it to

the customer.

Screen magnifier: Software that allows customers to magnify a website in a similar

manner to a magnifying glass. It is different to enlarging the font as the software

allows the user to move across the page to magnify what they want to read.

On-screen keyboard: Virtual keyboard displayed on a screen so that it can be used

by touch or a range of easy-to-use devices.

Voice recognition software: Software that can be trained to recognise a person’s

voice and convert this to text or to issue commands to the computer.

In the 2012 and 2013 Australian Network on Disability surveys into the accessibility of

shopping experiences and telecommunications companies, people with disability provided

the following information about website accessibility and features that they found difficult. In

essence, simpler was better. Accessibility for screen reading software and assistive

technology was essential.

Simplicity

“Having spent [a] long time looking for info, it’s annoying and limiting to have to

ring and can be hard to approach doing on multiple occasions.”

“The site is difficult to use. It is hard to find information, and it times out too

soon.”

“The simpler the format the more comfortable it is for my vision to cope with.”

“Was frustrating as I couldn't do what I needed in a reasonable amount of time.”

“Make the online site very accessible, and easy and quick to use. Shopping from

home is infinitely easier and less stressful than going into a store, but it always

23

takes me hours to navigate the online site and choose what I want, so it's still

ultimately quicker to go to the local shop.”

Accessibility

“Some portions of internet sites are compatible with voice activated software, but

not all parts are. This makes me feel angry and marginalised.”

“I have only visited the site once due to the pop-ups disturbing my vision. Also I

frequently have problems signing in with my password - for some reason it is not

always accepted.”

“They often have advertisements playing when you first log in which means you

can’t hear what the screen reader is telling you- all you hear is the ad. You have

to wait for the ad to finish before you can read through the page.”

“Create and maintain an accessible website, decrease delivery costs and

increase availability of delivery times, especially during weekends.”

“Improve the online accessibility of the website as it assists multiple audiences

with disability. For me this is the number one priority.”

“Ensure “all” components/sections of their online shopping website are easily

navigable/accessible for vision impaired persons using screen-reading

technology.”

Case Study: Telstra dumps Captcha

Telstra to kill CAPTCHA: ACCAN calls on others to follow18

3 December 2013

ACCAN, Australia's peak body for communications consumers, congratulates Telstra on its

plan to delete discriminatory online CAPTCHA tests from its websites and encourages other

providers and businesses to follow suit.

18 http://accan.org.au/our-work/media-releases/710-telstra-to-kill-captcha-accan-calls-on-others-to-follow and https://www.telstra.com.au/aboutus/community-environment/community-programs/disability/disability-action-plan

24

Telstra's decision to delete CAPTCHA tests is included in their 6th Disability Action Plan,

launched today on the International Day of People with Disability. It follows ACCAN's "kill

CAPTCHA" change.org petition launched in August.

CAPTCHA tests require web users to fill out a box with squiggly numbers and letters to

prove they are human. Unfortunately, the tests block out millions of people who are blind or

vision impaired from many online activities as their screen reading software is unable to read

the CAPTCHAs. Alternative audio CAPTCHAs are provided but they are just as inaccessible

due to the use of a distorted voice and background noise.

"CAPTCHA tests fundamentally fail to recognise people with disability as human. We are

pleased that Telstra have taken the lead on this issue and we encourage other providers and

businesses in Australia to kill their CAPTCHAs too," said ACCAN disability policy advisor

Wayne Hawkins.

ACCAN is also encouraged by another component of Telstra's 6th Disability Action Plan – to

include accessibility as a requirement in their ICT tenders. ACCAN has been a leading voice

on accessible ICT procurement, having previously called on government to adopt this

strategy as it would increase the employment opportunities for people with disability and

result in cheaper and more available accessible products and services. This policy was also

recommended by the recent IT pricing parliamentary inquiry.

"Government and big business can really lead the way in helping people with disability get

employed and stay in the workforce. Their enormous purchasing power can also stimulate

the market to give us greater choices and cheaper prices for accessible products and

services," said Mr Hawkins.

About one in five Australians have some form of permanent disability.

Ends

3.8 Emergency evacuation

Australian building legislation does not currently mandate an inclusive approach to safe evacuation of buildings. This presents as a significant risk for people with some form of

25

disability in the event of an emergency evacuation, particularly those with a mobility impairment.

This is perhaps most pronounced in multi-level office tenancies, but similar issues exist for retailers:

What planning should be undertaken to ensure that staff and customers with disability are able to evacuate safely?

Is there an accessible path out of the building to safety?

How will people with different disabilities know that there is an emergency?

What is the role of teammates, emergency services and others?

What should be designed into new buildings to ensure people can evacuate safely?

What assistive devices are available and suitable for emergency evacuation?

Lee Wilson (2016)19 is Australia’s leading authority in this area and has produced a

guidebook which comprehensively discusses the legislative gaps, issues for emergency

evacuation of people with disability, and provides practical recommendations.

Lee says that “Building occupants deserve to feel safe. People go about their day to day

activities without putting too much thought to the emergency procedures in place within a

shopping centre or retail store in which they work or visit. People assume that they are

protected from harm. Unfortunately, history tells us that we need to plan for emergencies.

This responsibility rests with business owners and shopping centre management to ensure

that effective emergency management plans that consider the needs of all occupants have

been developed.”

When developing an emergency plan he recommends that it not only considers people with

disability but other people too, including the very young, older people, those injured in the

emergency, pregnant women and those experiencing emotional stress.

He suggests there are a number of key factors to consider when planning for an emergency:

Ensure emergency management procedures are in place, with mechanisms to identify the needs of individuals, including employees or members of the public.

Implement tailored Personal Emergency Evacuation Plans (PEEPs) for employees and develop General Emergency Evacuation Plans (GEEPs) within retail spaces. Lee’s guidebook includes templates for both.

Nominate Fire Wardens in all locations who can supervise the evacuation, remove any barriers and ensure people are not left behind in retail spaces, change rooms or in toilets.

Employees need to have familiarity with the emergency plans, including rehearsing worse case scenarios.

19 Wilson, L., 2016, Evacuation of People with Disability & Emergent Limitations: Considerations for Safer Buildings & Efficient Evacuations, 2nd Edition. Viewed at https://accessibleexitsigns.com/evacuation-guide/

26

Conduct regular inspections of exit routes to ensure they are not obstructed with stock, displays or boxes.

Provide an accessible exit route that can be negotiated independently, but where this cannot be provided (i.e. on an upper level of a building), consider using other assistive devices such where evacuation lifts have not been provided.

Display evacuation diagrams showing the accessible exit routes (including identifying where exit doors, evacuation lifts, refuge areas, evacuation chairs and fire stairs are provided).

Supplement alarm notification systems with visual and audible alarm devices, including within change rooms and toilets.

Provide accessible handrails on both sides of all fire stairs.

Identify exit doors with a contrasting colour for ease of recognition.

Employees, security and centre management should always be on the lookout for unusual behaviour.

The use of security cameras is also advantageous to monitor people’s behaviour and movement within exit routes, particularly important to identify people who may find the evacuation difficult.

Shops and centre management need to develop effective communication and wayfinding strategies to relay information to occupants during the emergency.

Employees with evacuation responsibilities should attend training on disability awareness and methods of assistance, including the use of any evacuation devices such as evacuation chairs or evacuation lifts. This would include all Fire Wardens and security staff.

Though the above list is not exhaustive, it aims to provide some basic steps that can be

adopted to provide a safer environment for everyone should there ever be an emergency.

27

3.9 "Pictures courtesy of Egress GroupEvolving needs and higher

expectations

The most recent AND survey on Banking accessibility in 201620 revealed a higher level of

sophistication, expectation and advocacy than had been seen in many previous surveys.

People are asserting that their rights as consumers and citizens should be met saying things

like: “Treat me like I am a valued customer” and “Organise interpreters when needed”.

AUSLAN

“Providing AUSLAN to gain access to information that hearing people have access to without a problem. I want to be able to feel comfortable and relaxed without any worries - that would make my day to have the "PAH" (meaning "I understand") and leave the building with a smile on my face!”

“It would be phenomenal to be able to receive information and services using my native language... AUSLAN! Australian Sign Language, by means of educating the staff or easy access and provision of interpreters and translated information in AUSLAN online!”

Caption their videos online and recognise the national relay service as an acceptable communication channel.”

Systems

“Banks should provide an individualised access profile [like] a centralised platform where the consumer with a disability can advise the bank about their access issues, which are resolved and reasonable adjustments are put in place and implemented throughout the banking experience.”

“Have a fingerprint application that would enable my son to access his account. But, due to financial carelessness, that the fingerprint scan option would ideally be coupled with a cap.”

“Being able to communicate directly with the customer service in branch using AUSLAN and/or using chat online directly with customer service officers instead of using NRS.”

“Organise an iPad where I could access a video relay interpreter on the spot, and this would provide me the opportunity to speak with a banker and have information be 100 percent accessible. Subtitles to be included in all the videos on social media.”

Integration

“Be more integrated, products and services are spread across multiple areas

making dealing with multiple enquiries/issues difficult as you need to interact with

multiple people and systems all with different levels of accessibility.”

20 Survey was across all bank customers and verbatim comments could be about any bank or credit union.

28

Marketing

“I have never seen any advertising or marketing campaign that is either about

the services my bank provides or represents people with a disability in the

mainstream advertising campaign - that would wow me.”

Disability specialists

“Provide someone I can call and get through to without much automation, this

person would specialise in helping people with disabilities, be understanding,

helpful and friendly. They would make sure that I understand or ask if someone

else can help me also.”

“An opportunity to meet my local branch staff so we can get to know each other

would be great because relationships built on trust are important to me. Then I

would feel more confident about talking to my friends at the bank when I needed

help with my banking.”

Good process for key moments

“To ensure that the bankers don't ask each time for our Power of Attorney docs

that they know each time that we have the right documentation on file and that

we have the rights to act on behalf of the person with the disability. This would

remove the stress of attending to our transactions.”

4 Designing for dignity

4.1 What is Design for Dignity?

Design for Dignity encapsulates this feedback and research into some simple principles to

follow. Dignified access for a customer with disability means that a design or process

enables:

More independent access to premises, goods and services: it doesn’t assume that

assistance is required.

Equitable or fair access: it doesn’t take longer or make you go further.

Participation of people experiencing a disability as a natural and expected thing.

A place where people feel at-ease, safe and connected.

Design for Dignity means that all aspects of a retail experience come together in a consistent

way to deliver a great experience. It is about physical architecture and service architecture

working together to deliver a more productive and inclusive retail environment.

29

4.2 Identify elements, processes and interactions

The first step is to deeply consider how people engage with your business.

In a typical retail store setup the people usually think about the ‘elements’ in the design like

the path of travel, lighting, displays, payment counter and facilities, change rooms, store

rooms and bathroom facilities.

The reality is that the retail experience is also about much more than this.

Here is a small list of other things to consider:

How people find the store online.

Home delivery options.

How to navigate the store.

How service staff respond to a customer with disability.

How refunds are managed.

How contracts are understood and signed.

Privacy and low-noise spaces.

Alternatives to printed marketing material.

Remembering customer preferences for alternative information across channels and

over time.

4.3 Influencing the brief

The easiest and cheapest time to get the design right is at the beginning. As the design

progresses the cost of re-work increases.

Tell your architect or designer that you want to ensure that the retail experience is

really accessible and dignified. Often they will assume that people just want to

comply with minimum standards.

30

Ask retail architects to come up with ideas and suggestions for better accessibility.

If your architect has access to it, ask for fly-through technology to come up with some

fly-through images at standing and wheelchair height to experience the space and

sight-lines from different perspectives.

Include people using wheelchairs or mobility devices in concept design drawings,

including elevations, to demonstrate the accessibility of retail premises.

4.4 Testing your elements, processes and interactions

For each design, fixture, fitting or interaction in the retail experience, retailers and designers

should ask the following questions to understand the accessibility of their design:

How hard is it to use the design for different people with disability?

How can the design be modified to ensure that more people can access the design in

a dignified way?

The following areas21 provide a useful framework for thinking about how every element of a

design interacts different human impairments:

Vision is the ability to use the colour and brightness of light to detect objects,

discriminate between different surfaces, or the detail on a surface.

21 Inclusive Design Toolkit, University of Cambridge, http://www.inclusivedesigntoolkit.com/betterdesign2/usercapabilities/usercap.html Viewed September 2016

31

Hearing is the ability to discriminate specific tones or speech from ambient noise and

to tell where the sounds are coming from.

Thinking is the ability to process information, hold attention, store and retrieve

memories and select appropriate responses and actions.

Communication is the ability to understand other people, and express oneself to

others (this inevitably overlaps with vision, hearing, and thinking).

Mobility is the ability to move around, bend down, climb steps, and shift the body

between standing, sitting and kneeling.

Reach and stretch is the ability to put one or both arms out in front of the body,

above the head, or behind the back.

Dexterity is the ability of one or both hands to perform fine finger manipulation, pick

up and carry objects, or grasp and squeeze objects.

Within each of these areas there is a range of human capability.

Hearing, for example, ranges from being able to hear nothing at all, to only being able to

hear certain frequencies, to being able to hear clearly.

The property and service solutions for each part of this ‘spectrum’ vary. The intent of

designing for dignity is to design in a way that seamlessly includes the greatest number of

people.

The following table uses some of the capability descriptions from the University of

Cambridge Inclusive Design toolkit as they give ‘every day’ meaning to the challenges

people face. The table also includes a couple of examples of design responses that increase

32

the number of customers that are included by the design. (Much more detail is provided in

the Premises section of this guidebook).

Capability High level

(Mainstream design)

Medium level

(Includes more customers)

Low level

(Includes most customers)

Vision Full vision Cannot see well enough to read a newspaper headline. Design response

Large print for signage.

High contrast of lettering and easy font styles.

Eliminate complex floor patterns.

Cannot tell by the light where the windows are. Design response

Ensure that queueing systems don’t rely solely on a visual indicator to signal ‘next in queue.’

Tactile and braille instructions and wayfinding.

Digital equivalents of all paper brochures.

Clear path of travel to minimise trips.

Hearing Full hearing ability Cannot hear a doorbell, alarm clock or telephone bell. Design response

Hearing loop installed.

Quiet space for customer interactions.

No visual distraction behind reception counter (distracts lip reading).

Cannot hear sounds at all. Design response

Ensure that queueing systems don’t rely solely on a noise to signal ‘next in queue.’

NRS awareness.

AUSLAN knowledge.

DeafSpace design.22

Thinking 23 Full thinking ability Can do half of the items in the footnote list.

Cannot do any of the items in the footnote list.

22 See later section

23 1. Hold a conversation without losing track of what is being said. 2. Think clearly, without muddling thoughts 3.Tell the time of day, without any confusion 4. Watch a 30 min. TV programme, and tell someone what it was about 5. Read a short newspaper article 6. Write a short letter to someone without help 7. Count well enough to handle money 8. Remember a message and pass it on correctly

33

Capability High level

(Mainstream design)

Medium level

(Includes more customers)

Low level

(Includes most customers)

Design response

Repeated use of symbols and colour for direction.

Instore IT displays simple to use.

Clear buttons / icons.

Design response

Staff training.

Provision of summary information for enquiries.

Communication Full communication ability

Is very difficult for strangers to understand. Is quite difficult for people who know them well to understand. Finds it difficult to understand strangers. Finds it quite difficult to understand people who know them well.

Design response

Staff training.

Tools to facilitate typed communication or charts with common store objects.

Is impossible for people who know him/her well to understand. Finds it impossible to understand people who know him/her well.

Design response

Staff training

Tools to facilitate typed communication or charts with common store objects.

Locomotion Full mobility Cannot bend down and pick up something from the floor and straighten up again. Can’t walk long distances.

Design response

Seating at queue area.

Display cabinets that place objects in reach.

Cannot walk at all.

Design response

Auto doors, accessible path of travel.

Display cabinets that place objects in reach.

Counters and payment terminals that can be used from a wheelchair.

9. Remember to turn things off, such as fires, cookers or taps 10. Remember the names of friends / family that are seen regularly 11. Do something without forgetting what the task was whilst in the middle of it

34

Capability High level

(Mainstream design)

Medium level

(Includes more customers)

Low level

(Includes most customers)

Path of travel clear of obstacles.

Reach and Stretch Full reach & stretch ability

Has difficulty putting either arm up to head to put a hat on.

Design response

Display cabinets that place objects in reach.

Path of travel clear of obstacles.

Home delivery alternatives.

Cannot hold out either arm in front to shake hands.

Design response

Staff training.

Staff assistance.

Home delivery alternatives.

Dexterity Full dexterity ability Has difficulty unscrewing the lid of a coffee jar or using a pen and pencil.

Design response

D shaped door or cupboard handles.

Display items or furniture items do not require griping and turning.

Rocker style switches.

Cannot pick up and hold a mug of coffee with either hand.

Design response

Door or cupboard opening solutions that do not require grip.

Staff assistance where requested.

Design to include more people with impairments in these areas increases access, inclusion

and a retailer’s customer base. It can also reduce the likelihood of discrimination claims.

4.5 Testing with customers

Testing concepts and designs with people who have lived experience of disability is a great

way of seeing whether your design is accessible.

Inclusive design can be complex and its impact across disability groups can be quite varied

and at times conflicting. For example, tactile markers are beneficial to someone with limited

vision, but can be more difficult for those using a wheelchair or mobility aid.

There will not be one straightforward solution, so it is important to manage stakeholder

expectations.

35

Even so, taking a participatory approach enables stakeholders to exercise their citizenship,

by appreciating the issues and complexities first hand and have their voice listened to on

their own terms when exploring inclusive solutions.

The Disability Council of NSW24 recommends the following tactical tips for facilitating the

engagement process.

Ensure there is a balanced cross section of representation from the disability

community.

Develop an agreed engagement protocol in collaboration with key stakeholders.

Ensure appropriate advance notice of engagement, sessions, outlining agenda,

objectives and outcomes.

Provide flexibility to enable stakeholders to contribute to agenda setting.

Check to ensure engagement information is communicated in accessible formats that

meet the needs of all key stakeholders (e.g. braille, AUSLAN, Easy English).

Be clear about engagement boundaries, process and timings and manage

expectations sensitively.

Avoid overly large consultation groups as it will limit ability for all voices to be heard.

Ensure the venue for engagement session is appropriately accessible and can

accommodate carers if necessary.

24 Scales, I.,1997, Consultation and People with a Disability, Disability Council of NSW

36

Ensure appropriate length of time is allocated to discussions.

Ensure facilitator is culturally competent to run the engagement process.

Check if additional communication formats are needed during facilitated sessions

(e.g. an AUSLAN interpreter).

Actively listen with a demonstrably open mind and frame understanding of issues

without ‘ableist’ bias.

Close the loop on engagement by ensuring appropriate and timely follow up of

findings and next steps.

Follow through on agreed actions and use accessible technologies for stakeholder

feedback.

Many disability advocacy organisations are usually able to facilitate connections to their

audiences or members. The Australian Federation of Disability Organisations (AFDO) is a

good starting point.

4.6 Isn’t compliance good enough?

Since 2011 The Building Code of Australia (BCA) incorporates most of the provisions of the

Federal Disability (Access to Premises-Buildings) Standard 2010.

This means that complying with the minimum requirements of the Building Code provides

protection from Disability Discrimination complaints in regards to compliant design.

So, is the minimum standard good enough?

Minimum standard customer experience

It is rare in business or design that organisations set out with “minimum standard” customer

experience in mind. Designing to minimum accessibility standards is saying that this group of

customers doesn’t deserve the same degree of thought, innovation and insight that is

invested in other customers. Designing for dignified access gives a better customer

experience by truly understanding and including more people.

Aren’t Australian Standards best practice?

The main Australian Standard AS1428.1 Design for access and mobility: General

requirements for access – New building work (AS1428.1) is designed to allow general

use of buildings and facilities by people with disability. It does however have some

limitations:

Australian Standards are a negotiated outcome between advocacy groups and industry

experts. They seek to deliver practical guidance to designers, builders and certifiers, but

are designed explicitly as minimum requirements which, if met, are ‘deemed-to-satisfy’

the intent of the BCA goals for ‘safe, dignified and equitable access.’

They are based on data representing people aged between 18 and 60 years. With an

ageing and engaged population, designers need to think beyond compliance to capture

older people with a greater likelihood of disability.

The majority of measurements in the most critical areas are based on data from 1983.

37

The dimensions of wheelchair and user contemplated by the standard represent 80% of

users (90% in critical access areas). Whilst materials in wheelchair design have become

lighter, many new electric wheelchairs are larger (also reflecting that individuals are

weighing more).

Motorised scooters are not included in the requirements at all. Motorised scooters

require a much larger turning circle than manual scooters and cannot turn within the

space allowed within Australian Standards.

Exposure

While old business premises don’t need to be fixed retrospectively (unless being renovated),

The Disability Discrimination Act (1992) requires that people with disability have equal

access to premises as well as goods and services. This exposes organisations to the risk of

breaching the act, but relies on individuals lodging complaints with the Australian Human

Rights Commission (AHRC).

“Refurbishment of small-scale retail units is an opportunity of addressing the issue of better

or inclusive access. The success of this process can result in successful implementations of

DDA regulations.” 25

Case Study: Commonwealth Bank of Australia – Branch Design Process

At the Commonwealth Bank, as we plan the next generation retail branches, we started with

a strong commitment to access, inclusion and dignified design.

The role of the Commonwealth Bank’s retail network is changing, and the focus of our

branches is to excel at satisfying customer needs in more ways via personal relationships

and world-class technology. Branch design is changing to support quality interactions with a

move away from the traditional ‘counter and screen’ service to a more open and

collaborative design.

This change has created opportunities for customers and team members with disabilities to

interact and work in a branch that was created using dignified design principles.

“As we strive to be the most accessible bank in Australia for our people and our customers,

it is important that we continue to strive for an environment that is fully accessible for

all. Our next generation branch design project is an exciting part of that evolution.” Bryan

Fitzgerald - EGM CEO & Group Strategic Advisor and ENABLE Employee Group Co-Chair

“We are incredibly committed to ensuring we design retail branches that respond to the changing needs of the community. Utilising design thinking methodology to identify the

25 Dever, E., Sertysesilisik, B. and Rostron, J.,2009, The refurbishment of small-scale retail premises in relation to the Disability Discrimination Act 1995, Journal or Retail and Leisure Property,

38

diverse range of requirements within our portfolio, while ensuring our focus on inclusion remains the guiding principle.” Teri Esra (Head of Property Design and Delivery)

Design process

The next generation branch design has four clear accessibility objectives:

More independent access that does not assume assistance is required

Equitable or fair access to our services

Participation of people experiencing a disability as a natural and expected thing

A place where people feel at ease, safe and connected

The design process was split into five stages:

Stage 1 - Understand Existing

A detailed review of our current branch design was undertaken to clearly understand

opportunities for improvement and enhancement. These findings, together with an in-depth

understanding of the way in which customers now use a branch, formed the backbone of the

brief.

Stage 2 – Concept Design

Based on stage 1’s findings and recommendations, the layout plan and design concept were

developed to consider how each element in the branch would be used by people with

different disabilities.

Stage 3 - Raw Prototyping

This involved constructing a mock-up of critical branch elements and signage in the

Commonwealth Bank’s testing Hub to understand the space and potential accessibility

implications.

Frontline team members were involved in the design process as they have the most direct

experience of customer needs and issues. Staff and customers were regularly engaged to

walk through and review each element of the prototype branch.

In addition to the Bank’s stakeholders, the prototype will be assessed by customers and staff

with Vision, Hearing, Cognitive, Communication, Mobility, Physical and Dexterity disabilities.

Stage 4 – Detailed Design & Branch Prototype

Feedback from Stage 3 will be incorporated into the detailed design and a full branch

prototype will be constructed for review.

All plans and elevations will include visuals on how people with physical disabilities interact

with the site. These include door clearances, wheelchair turning spaces and people using

wheelchairs in all elevations.

39

Lighting reflection angles on signage will also be considered from standing and seated

positions in the design documentation and iteratively tested in the prototype branch.

A test period will be conducted after the prototype is delivered to review the success of the

branch against goals set out in the design brief. The recommendations to come out of this

review process will be used to adjust the design and provide a better customer experience

and work environment for everyone using the space.

Stage 5 – Standard Design Roll-out

The final prototype design will be used as the basis to create the standard roll-out

documentation for the retail bank.

Resulting recommendations include:

SIGNAGE

Matt-finishing signage to reduce difficulties in reading due to glare and light

reflections.

Considering tactile text /Braille signage some key signage zones.

Contrasting strips across the glazing in ‘bar-code’ format to avoid bumping into glass.

Using of pictograms in signage.

Providing gender neutral signage to selected bathrooms for better inclusion.

TECHNOLOGY

Placing iPads in positions accessible to customers using wheelchairs (not in

corners).

Ensuring staff are trained to understand how to turn on the accessibility feature.

PHYSICAL SPACE

Including a quiet space for hearing impaired customers or people with

communication difficulties.

Providing seating clusters to allow for easy manoeuvrability and spatial allowance to

accommodate wheelchair parking.

Considering way finding indicators that make the journey through the branch more

intuitive.

Providing visual and audio emergency alarms in staff areas.

Catering for mobility scooter turning circles in large branches.

FURNITURE

Ensuring sufficient contrast between seats and carpet.

40

Providing a mix of furniture – with at least 30% accessible. This means seating with

a seat height of at least 450mm, a back rest at 110° and arm rests to assist users

entering and exiting the chair.

All seats (in particular banquette seating) will be designed with clear foot space under

the seat pad. This enables users to place their feet under their body weight to help

them exit the chair easily.

JOINERY

Avoiding use of twist knobs or finger pulls, and rather using proper grab handles.

Providing some height-adjustable desks.

Adding low height storage cupboards in kitchen.

Placing microwaves at an accessible height.

Locating taps/hardware to ensure they are accessible eg Side of sink, not back.

DOCUMENTATION

Ensuring all elevations/documentation include customers in wheelchairs as well as

able-bodied people.

Where to from here?

It is clear that the Commonwealth Bank has a very large footprint and we are already on a

journey to providing better access for people and team members with disabilities within our

current design.

This is an ongoing journey - this design process provides us with a strong set of

recommendations to guide next generation branches. These recommendations give the

design team greater insight into inclusion and dignified access.

Our goal is to be the most accessible bank in Australia. This is important to us as we want

to ensure that we are delivering an inclusive space that provides the best possible

experience to all Commonwealth Bank’s customers and staff.

5 What are your responsibilities?

As retail business owners, service providers, shopping centre owners and managers,

designers, builders and certifiers you have a responsibility to provide access to premises

and goods and services that is free from discrimination.

A summary of some of the legislation and obligations at International, Federal, State and

Local levels is provided in the Appendix.

41

5.1 Human Rights

The UN Convention on the Rights of Persons with Disabilities (2008) is the global foundation

for setting out the rights of people with disability. It comprises a number of principles

including respect for inherent dignity, individual autonomy and full and effective participation

and inclusion in society.

In Australia, there are a range26 of federal and state legislation and policies in place

governing the rights of people with disability. The Commonwealth Disability Discrimination

Act 1992 Cth (DDA) and state legislation such as the Anti-Discrimination Act 1977 NSW

recognises the rights of people with disability to be treated equally before the law and

making it unlawful to discriminate on the grounds of a person’s disability.

The Disability Discrimination Act 1992 Cth makes it unlawful to discriminate in a range of

specific situations that are relevant to retailers and the shopping experience of customers

with disability and people or service animals who assist them. These areas include:

Section 15 - Employment of people with disability.

Section 23 - Providing access to premises and facilities for customers with disability.

Section 24 - Providing access to goods, services and facilities for customers with

disability.

Standards arising from the DDA, have been systematically developed, including for

education, transport27 and premises. For the built environment, the Disability (Access to

Premises - Buildings) Standards 2010 seeks to provide:

Dignified, equitable, cost‑effective and reasonably achievable access to buildings,

and facilities and services within buildings.

Certainty for building certifiers, building developers and building managers.

5.2 Building Code of Australia

The Building Code of Australia (BCA) is a state based regulation and also sets out the

requirement to provide safe, equitable and dignified access to buildings, and facilities and

services within buildings, nationally.

The accessibility objectives are to provide, as far as is reasonable, people with safe,

equitable and dignified access to a building, and the services and facilities within a

building, and safeguard occupants from illness or injury while evacuating in an emergency.

The key focus is on the physical construction of the building or new additions or upgrades to

an existing building. Compliance with the BCA is triggered at the application for building

26 Refer to: Link to AHRC International rights information

27 The accessibility standard for Transport is the Disability Standards for Accessible Public Transport, 2010 and regulates public transport buildings and conveyances.

42

construction approval and has, since May 2011, formally included a number of access

requirements related Australian Standards.

5.3 Australian Standards

There is a range Australian Standards28 which are technical and prescriptive to consider as

well. The BCA references some Australian Standards and others are not mandatory.

Mandatory

AS1428.1 Design for access and mobility: General requirements for access – New

building work.

AS 1428.2 Enhanced and additional requirements for access – building and facilities

(Only in Public Transport buildings).

AS/NZS 1428.4.1 Means to assist the orientation of people with vision impairment –

Tactile ground surface indicators

AS 1735.12 Lifts, Escalators and Moving Walkways.

AS/NZS 2890 Part 6 Parking Facilities.

Optional

AS 1428.2 Enhanced and additional requirements for access – building and facilities

(Non-public transport buildings).

AS 1428.3 Requirements for children and adolescents with physical disabilities

(Obsolescent).

AS 1428 4.2 Wayfinding (draft).

AS 1428.5 Communication for people who are deaf or hard of hearing.

AS 3745-2010/Amdt 1-2014 Planning for emergencies in facilities.

5.4 Local Council Requirements

These are also many and varied but include things like:

Local planning policies and guidelines.

Footpath dining/trading licensing and policies.

Regulations on use of A-frame boards and advertising.

28 See also for example, NSW Department of Planning guidance for local councils regarding SEPP Seniors Living 2004 - Housing for Seniors or People with a Disability

43

5.5 Heritage buildings

The AHRC provides good information on the sometimes conflicting pull of heritage value and

accessibility.29

Under the DDA, heritage status is not a defence for conducting business in an inaccessible

building. Everyone has the right to dignified, equitable access under the Act. One exemption

that is relevant is where making changes to be non-discriminatory would impose

‘unjustifiable hardship’ on the organisation. This is not defined in the DDA and is ultimately

up to the Federal Court to decide on a case-by-case basis.

Organisations owning or trading from inaccessible heritage premises should look to cost

effective mechanisms to enable alternative access to their premises, goods or services,

upgrade their premises or consider moving.

“If heritage buildings are not readily and economically able to be modified to provide

equitable access, then unless the heritage value of the building is an essential part of the

business, consideration should be given to moving to alternative premises better suited to

modern requirements including disability access.”

“Heritage values which might justify preservation of a building do not necessarily justify

modern business or government activities being conducted there. After all, the heritage

value of premises which failed to meet modern human rights standards in other respects -

such as gallows or inhumanely small and dark cells - may require the preservation of the

premises, but would not be argued as requiring or justifying their continued use for their

original purpose.”

5.6 Who is responsible for what?

In the Australian retail environment, there is often uncertainty about who is responsible for

ensuring that premises and the supply of goods and services are accessible.

The Disability (Access to Premises - Buildings) Standards 2010 S2.2 makes it clear that

there are obligations for building certifiers, developers and managers to the extent that they

have responsibility for new building or buildings that have work approved after May 2011.

Role Responsibility Examples of who this might be

Building certifier The person who has responsibility for, or control over the building approval process.

Private certifiers

Building surveyors

Local councils

29 https://www.humanrights.gov.au/frequently-asked-questions-access-premises Viewed September 2016

44

Role Responsibility Examples of who this might be

Building developer The person who has responsibility for, or control over, the building design or construction.

Property developers

Property owners

Building designers

Builders

Project managers

Property lessees

Building manager

The person who has responsibility for, or control over, any matters in the Premises Standards that apply to the Building other than matters relating to its building or construction.

Property owners

Property lessees

Property managers

Operational staff

The Premises Standards provide a number of exceptions and concessions. These include a

limited exemption in cases of unjustifiable hardship, an exemption for acts done under

statutory authority, and concessions in cases of existing accessible lifts, sanitary facilities,

and where the application for building approval is submitted by a lessee of the premises.

The following chart summarises the obligations in retail settings in Australia. It doesn’t cover

residential developments, bed and breakfast lodgings, hotels, boarding houses, swimming

pools and other specialised places such as aged care homes or educational facilities.

45

• Area being

upgraded only.

• No requirement to

upgrade access

ways unless within

leased area.

• Area being upgraded.

• Principal entrance.

• Path of travel from

entrance to new works.

• Toilets on floor being

upgraded.

• Lifts which form the path

of travel.

Buildings to which Premises Standards apply

New building

Existing building

Premises

Standards

do not

apply

Customers

may

complain

under DDA

1992

Building being

upgraded

Building not being

upgraded

Building approval

required for

upgrade

Building approval not

required for upgrade

Lessee upgrades

shop

Owner (or Lessee of

whole building) initiates

upgrade

Small building (concession on lifts if upper

floors are less than 200m2 each but other

requirements apply)

Not a small building (all

requirements apply)

Store or shopping centre Private dwelling

attached to store

46

5.7 Practical applications

Scenario 1

A retailer leases the whole of a small building for her store and is undertaking work that

requires a building approval. There is a step from the street to the front door and a toilet in

the rear of the property which can be used by customers and staff. No accessible toilets are

located within the building.

What does the retailer need to make accessible? The retailer has responsibility to ensure

that the following areas of the building is accessible:

Area being upgraded.

Principal entrance.

Path of travel from entrance to new works.

Toilets on floor being upgraded.

Lifts which form the path of travel.

Scenario 2

A retailer leases a single shop contained within a shopping centre. The retailer is

undertaking work at the rear of the store which requires building approval. Customers

regularly complain that the shopping centre does not have a fully accessible toilet and that

there are areas of the store that cannot be accessed because of the way that the display

units are organised.

The retailer has responsibility for the area within their store. They have no requirement to

upgrade the accessible toilet in the shopping centre.

The shopping centre owner has responsibility for the area leading to the leased premises

and the accessible toilet in the common area. They only need to make any changes as part

of a building approval in the shopping centre.

Scenario 3

A retailer operates their store from leased premises located on the upper floor of a small

building. The building has three floors and each floor is less than 200m2. There are some

small steps at the front of the building with no other way in. There is no lift in the building and

older customers are finding it difficult to get to the top floor. The building owner is upgrading

aspects of the building and requires a building approval but does not want to install a lift.

Under the concessions listed in the Premises Standards, the lift does not need to be

installed in a small building of not more than three floors (each floor less than 200m2). Other

aspects of accessibility would need to be delivered such as making the front entrance

accessible.

The outcome is not a very good one for the retailer who may consider finding more

accessible premises at the end of their lease.

47

5.8 Dealing with issues

When a customer feels that they have a disability discrimination complaint against a

business they can make a complaint in writing to the Australian Human Rights Commission

(AHRC) who will also assist with documenting and translating the complaint if required.

People do not require a lawyer to do this and it is free.

If the AHRC decides to investigate further, they will contact the organisation, provide details

of the complaint, and potentially ask for comments and more information to understand the

issue. They then decide if the complaint has some basis for complaint and probably seek to

conciliate a solution between the customer and the organisation. This processes happens in

a variety of different ways including face-to-face, over-the-phone and sometimes through an

exchange of information.

If the complaint is not resolved, or is discontinued by the AHRC, then the customer has 60

days to take the complaint to the Federal Court of Australia. The customer needs to do this

for themselves and seek the assistance of a lawyer. There are several organisations that

represent customers with these types of complaints.

The following flowchart helps to outline the process and responsibilities:

48

The following cases, which relate mostly to retail environments, are drawn from the

Australian Human Rights Commission’s conciliation register30. The AHRC administers the

Disability Discrimination Act 1992 Cth and can conciliate between parties on cases of

discrimination.

2015, a customer that uses a wheelchair complained to a restaurant that the

accessible toilet had no lock on the door. The restaurant said that the door was built

to regulations and that no-one has previously complained. The AHRC conciliated

between the two parties and the restaurant installed a lock on the door and offered a

meal voucher.

2015, a dentist refused to allow an assistance animal to remain in the waiting room

claiming he was afraid of dogs. The AHRC conciliated between the two parties and

the dentist wrote and apologised to the client.

30 Developed from https://www.humanrights.gov.au/complaints/conciliation-register Viewed September 2016

Customer issue or incident

Customer comes to you Customer makes inquiry about

the situation with AHRC

Work with customer to try and

resolve the issue.

Be proactive and ensure that your organisation is barrier free and employees

are disability confident

Incidents and issues less likely

Lodges complaint with AHRC

Conciliation

Resolved Unresolved

AHRC

terminates

complaint

Customer

feels the

issue is

unresolved

and goes to

Federal

Court

Unresolved

AHRC seeks information from you

49

2015, a person who was a wheelchair user claimed that a hotel was not fully

accessible and did not have an accessible toilet.The hotel worked through

conciliation and provided accessible toilet facilities and permanent ramps.

2015, a customer of a telecommunications company who was blind and therefore did

not drive was required to provide a driver’s licence (and refused alternative photo

identification) to buy one of its products. The company agreed to pay the customer

$3,000 and outlined its policies and procedures and staff training on discrimination.

2014, a customer of a medical practice with physical disability who used a motor

powered wheelchair claimed that the medical practice refused to let him in because

of the size of the wheelchair. They were concerned that it posed a risk because of its

size, but during conciliation the custoTGSImer demonstrated that they could safely

manoeuver and they agreed to allow him to use it in the future.

2014, a customer in a shopping centre used an assistance animal used to alleviate

the effects of bi-polar disorder and social anxiety. The security guard refused her

access because she was not ‘blind’ despite being shown identification information

about the dog. Through conciliation the shopping centre and security company

assured the customer that they would be welcomed with their dog in future and

provided training for their staff.

2014, a customer was refused access to a bread shop with their guide dog. The staff

told the customer that health regulations prevented this. The shop’s owner agreed to

conciliation and apologised to the customer. Staff training was provided and a

donation made to a charity.

2012, a person who was vision impaired complained that a shopping centre was

difficult to access because there were no TGSIs or handrails. Through conciliation

the shopping centre agreed to carry out work to make the shopping centre more

accessible to people with vision impairment.

2012, a customer of a bank complained that a step at the front entrance of his local

bank branch prevented him from using it. He had used walking sticks to assist him to

walk. The bank installed a handrail to assist him to use the branch and resolved the

person’s complaint.

2012, a customer of a bank that used a mobility scooter had been served by bank

staff outside the branch doors because the scooter was too large to manoeuvre on

the landing. When the bank stopped this arrangement due to the risks to staff

handling money outside the premises, the customer complained. The bank agreed to

make modifications to the landing area so the customer could access the branch.

6 Guidance on premises

This section summarises the key accessibility requirements for retail environments. It also

provides some Design for Dignity tips that help create environments that are better able to

cope with an ageing population and the needs of customers with disability. Design for Dignity

suggestions are just that – they are optional ideas that will make it easier for customers now,

and into the future.

50

6.1 Finding your store online

The journey to a store often begins when someone looks at products and services online.

Websites can be more-or-less accessible for people with disability depending on how they

are designed. People who are blind, have low vision or even dexterity restrictions still use

the internet to investigate products and services, often using assistive technology that helps

navigate and read a website. There are standards to help ensure that websites are

accessible.31

Design focus

Ask your developer or web host if your website is accessible according to global

standards.

Does your website tell people whether your store or stores are accessible? Can you

search based on the accessibility features32 of your store, such as:

o Automatic doors

o Accessible toilets

o Recharge points for mobility scooters and electric wheelchairs

o Flat and level entry

o Wheelchair access

o Level access

31 http://www.w3.org/ Viewed September 2016

32 See Barclays Bank http://ask.barclays.co.uk/branchfinder/ Viewed September 2016

51

o Hearing loop

o Internal ramp

o External ramp

o Low height counter

o Accessible parking

Can your contact centre staff and instore staff describe the accessibility of your sites?

Is there any signage to indicate that it is accessible? This is a signal to people with

disability that your competitors may not have put in place.

6.2 Wayfinding principles and guidance

Wayfinding is the system of communication that allows people to navigate through their

environment using their available senses. It can take the form of tactile clues (TSGIs,

changes in surface texture, tactile maps), visual clues (signs, maps, changes in colour for

different zones or levels), audible clues (beacon technology telling your smartphone where

you are and providing direction, noise from water features, a row of restaurants or a road),

architectural clues (physical barriers or distinctive pathways) or even aromatic such as

food smells from a restaurant.

Wayfinding Design Guidelines (2007)33 state that a successful wayfinding system should

“reassure users, create a welcoming and enjoyable environment and ideally, provide

answers to potential queries before users have to ask for assistance”. This captures the

spirit of independent and dignified navigation.

33 Apelt, R. and Crawford, J. and Hogan, David J. (2007) Wayfinding Design Guidelines. CRC for Construction Innovation, Brisbane Viewed at http://digitalcollections.qut.edu.au/1719/ Viewed September 2016

52

Image courtesy of Brailliant Touch

The key criteria for successful wayfinding are also suggested in guidelines and they neatly

describe the core requirements for shopping centre, and large store, navigation. It should

provide information for users to:

Confirm that they are at the correct start or finish point of an individual journey.

Identify their location within a building or an external space.

Reinforce that they are travelling in the right direction.

Orient themselves within a building or external space.

Understand the location and any potential hazards.

Identify their destination on arrival.

Escape safely in an emergency.

Design focus

In a retail setting, wayfinding could take the form of:

53

A tactile map located near the front door of a large store to orient people within the

store and locate key services like the service counter, lifts and toilet.

Tactile and braille indicators on the path of travel for changes in direction and on stair

handrails to indicate changes in floor or place or change of direction.

Beacon technology and tactile maps at key points to gain orientation and direction.

Clear directional signage for emergency evacuation.

Signage legibility (size, font, contrast, glare reflection, ability to read from different

angles) at appropriate expected distances.

Different floor surfaces (texture and contrast) for the walkway to assist people in

navigating the store.

Use of colour or design to indicate different floors, wings or zones.

Common pictograms like the International Symbol of Access to direct people to

accessible toilets.

Defining different areas of the store in clear zones that make finding the way easier.

Using symbols as well as English to assist people from different cultural backgrounds

as well as people that may have difficulty understanding.

Case study - Wayfindr

The Royal London Society of the Blind and a digital product studio called ustwo launched a

joint venture to use beacon technology to enable people who are blind or have low vision to

navigate successfully on the London underground. Google.org funded a trial of the app

called Wayfindr at Euston station in London. The Wayfindr joint venture has created an

Open Standard for the use and implementation of digital wayfinding on mobile devices using

audio navigation.34 Similar technology is being piloted by Transport NSW at Chatswood in

Sydney’s North.

6.3 Interactive navigation screens

Some shopping centres provide touch-screen information directories to allow customers to

navigate and find their way around. These directories should be placed at a height that are

accessible from a seated position and not reflect the glare of overhead lighting when viewed

at that level. Some screens offer an accessibility option represented by the International

Access symbol so that people can operate the controls whilst seated. AND’s experience of

these alternatives is that they don’t always provide the same information and often don’t

work well.

The information is usually only accessible for people who are able to see the screen as they

are touchscreen applications with no braille or tactile controls or audio directions. Directions

are also sometimes very complex, in three dimensions or not oriented in the same direction

as the person viewing the map.

34 https://www.wayfindr.net/ Viewed September 2016

54

Design focus

Test the navigation system in your shopping centre from the perspective of someone

who is using a wheelchair or someone who cannot see the controls or the directions.

Do they have equitable and dignified access to the same level as others?

Consider the alternatives to a touchscreen.

Is there a shopping centre information desk?

Are there tactile maps available in the shopping centre or other braille or tactile

signage available?

6.4 Car parking

Access to accessible parking can be an attraction to people using a store or shopping

centre. AND’s research has found accessible parking is critical or very critical for 80% of

survey respondents with physical disability.

Design focus

The number of accessible parking spaces required in a shopping centre is determined by the

BCA and other regulations:

In a carpark of up to 1000 car spaces there must be as a minimum 1 space for every

50 car parking spaces and an additional accessible space for every 100 spaces after

that.

Some jurisdictions require more than this. For example, in the ACT, the ratio of

accessible space to total spaces is 3%.

No dedicated spaces are required if the car park has 5 spaces or less.

55

Carpark spaces (‘angled parking’)

The space requirements and layout of accessible parking spaces is quite specific and

documented in the Australian/New Zealand Standard AS/NZS 2890.6. The requirements

include:

Overhead clearance at the entrance and to the accessible parking spaces of

2200mm and 2500mm at the parking space.

A firm, flat, slip resistant space for the driver/passengers to exit the car.

Dedicated space which is 2400mm wide and 5400mm long.

A marked shared space and high contrast bollard (a minimum of 100mm diameter

and at least 1300mm high) next to the parking space so that people can safely

unload a wheelchair and transfer across to it.

The shared space can be located between two accessible parking spaces.

Clear, yellow, slip resistant line markings around the space and an International

Symbol of Access on the space.

Street parking (‘parallel parking’)

Where spaces are provided parallel to the road (for example in strip shopping precincts),

they should include:

A parking space 3200mm wide and 7800mm long.

A firm, flat, slip resistant space for the driver/passengers to exit the car.

Space on the passenger side that is 1100mm wide and 7800mm long.

The additional space can be at footpath height, but needs to have access with a kerb

ramp.

Clear, yellow, slip resistant line markings around the space and an International

Symbol of Access on the space.

Additional considerations for dignified access

Ensure that ticketing and vending machines have the buttons, controls and slots at

an accessible height.

Consider having more than the minimum number of spaces.

Ensure that the spaces are close to the main entrance of the store.

Provide clear direction from the entrance of the car park to the accessible parking

spaces.

Provide above-ground signage at the accessible parking space to make it easier to

find.

Consider emergency refuge areas in exit stairs in car parking levels of shopping

centres.

If the parking spaces are outside, consider how the spaces are protected from

weather extremes. Loading and unloading a wheelchair, or getting in and out of the

car can take extra time for people with disability.

56

6.5 Directional and category signage

The mandatory requirements for access signage in retail stores are found in the BCA. They

largely cover braille and tactile access signage for bathrooms, exits, hearing devices and for

re-direction to more accessible facilities.

Appropriate braille and tactile signage is required for:

Sanitary facilities.

Spaces with hearing augmentation.

Emergency exits.

Direction from pedestrian entrances that are not accessible to the nearest accessible

entrance.

Direction from a bank of toilets that are not accessible to the nearest accessible

toilet.

Location

On the wall next to the door (door handle side rather than hinge side).

Specified height from floor.

Specifications

Specifications of the braille and tactile characters (height, width, depth, braille type,

luminance contrast) are provided and should be used to check manufacturer’s claims

of compliance. More information is also available in AS 1428.1 showing the form of

the signs required.

Beyond toilets, entrances, emergency exits and hearing augmentation, there is no other

clear guidance for the accessibility of signage within stores. The combination of braille and

tactile signage will increase the opportunities for people who are blind to independently

navigate stores and shopping centres. Placement of braille and tactile signage in a

57

consistent way (for example same height and colour, at entry and changes of direction and

on the path of travel) will enable people to find and use it more frequently.

Design focus

Written messages are everywhere in the retail environment including: product labels,

marketing brochures, directional signage, terms and conditions documents, computer

screens that provide customer information, advertising plinths, store signage and logos.

Here are some simple tips to help ensure that messages can be seen by more people by

making them easier to see for people with low vision.

Contrast

The difference between the text colour and brightness and the background on which it

appears is the Contrast. Having highly contrasting text and background makes your

message more easily understood by people who have low vision.

You should use dark coloured text against a light background where possible. Light coloured

text on a dark background can also be acceptable.

Black and white are the highest contrasting colours. Colour should not be used as the sole

means for differentiating information or symbols, as people who are colour blind or have low

vision may not be able to understand your message.

Font size in-store material

Opinion varies on the appropriate font size for general printed material. There are some

regulations in Australia which determine minimum font sizes in advertising so that

consumers are able to read them. For general printed and online material, a minimum print

size of 11 point is best. Where people require “large print”, a font size of 16 point or above is

best.

Font size for signage

Australian Standard AS 1428.2 provides some guidance for the size of signage which can be

applied in shopping centres and stores:

58

Required Viewing Distance

Minimum Height of Letters

2m 6mm

4m 12mm

6m 20mm

8m 25mm

12m 40mm

15m 50mm

25m 80mm

35m 100mm

40m 130mm

50m 150mm

Source: AS 1428.2 Table 2 Height of Letters for varying Viewing Distances

Signs should have lighting that does not produce unwanted glare or reflection. Viewing signs

from different positions and levels (seated and standing) can help reveal if customers will

experience issues. Ideally signs which have sufficient circulation space in front of them

should be at a height that makes them easy to read for people sitting and standing.

Typefaces

In general terms, the simpler a font, the more easily it will be read. You may read about serif

fonts (e.g. Times and Century) and sans (‘without’) serif fonts (e.g. Arial and Helvetica).

Serifs are the small lines that trail from the end of letters. In summary, the general opinion is

that fonts without serifs like Arial are easier to read.

There are many font styles available which can be difficult to read if your audience has low

vision. Quirky, fancy fonts can be fun, but there is an increasing number of customers who

may not pick up the message quickly or easily.

59

Font styles

A font style is the treatment you apply to a font type. For example, you can italicise, bold,

underline or CAPITALISE your font. Use these treatments sparingly. People also recognise

the patterns of letters within a word and often you can recognise a word before they see all

of the letters which is why motorway signs are not done all in uppercase. Fully capitalised

words are also difficult for people with dyslexia and those with learning difficulties.

Khattab (2015) 35 tested elements within supermarket settings and found the customers with

vision impairment benefited from:

Clear aisle signage and aisles free from fixed barriers.

Product category signage which has good contrast and is free from glare.

Projecting aisle numbers on the floor.

Raised text signage.

6.6 Continuous accessible path of travel

The Premises Standards apply to work in stores approved after 1 May 2011. The standards

apply to any new part of a building but also the main pedestrian entrance to the building and

the path of travel to and around the store.36

The rationale for having a continuous accessible path of travel from the main entrance is to

allow people with disability to access goods and services in the same way as people without

disability. The customer experience starts with arriving at the shopping centre and travelling

to the store.

35 Khattab, D., 2015, Rethinking the grocery store: inclusive wayfinding system for visually impaired

shoppers in Grocery stores,,Journal of Accessibility and Design for All, Canada

36 Disability (Access to Premises – Buildings) Standards 2010, Federal Register of Legislative Instruments

60

Powered door button at Bupa Barangaroo

Design focus

The basic rules for accessible paths of travel are well documented in the Australian

Standards:

Cannot have a step, stairway, turnstile, revolving door, escalator, moving walkway or

other impediment along the path of travel with no alternative way of getting in.

Nothing you could bump into when travelling to or through a store at a height of up to

2000mm or 1980mm at doorways (imagine that you are using a cane to navigate and

can’t see a head high obstacle).

The minimum unobstructed width of the pathway is 1000mm (except where

otherwise specified like doorways).

Turning space required for a 180-degree turn is 2070mm in the direction of travel and

1540mm wide and 1500mm by 1500mm at a 90 degree turn..

Pathways have spaces 1800mm wide which allow two wheelchairs to pass at the

same time.

75mm solid, non-transparent, contrasting strip across glass entrances and other fully

glazed areas that could be mistaken for a door, including auto-doors.

Manual doors should be easy to open.

Smooth, slip resistant surfaces with a very low tolerance for uneven surfaces.

Ensure that a path of travel doesn’t lead to a dead-end which requires people to

‘reverse’ more than 2 metres unless a turning space is provided.

No grates with gaps larger than 13mm wide and oriented in a way that wheelchair

wheels don’t fall into them.

Additional considerations for more dignified access

Additional spaces for turning and passing

61

1200mm wide pathway is the better practice and, depending on traffic levels, even

wider to accommodate people using prams, mobility scooters and larger electric

wheelchairs.

Turning space for full 360-degree turn could be increased to 2450mm by 2450mm.

Wide corridors that allow people to pass - Barangaroo

6.7 Stairs

Where a store has stairs they should be designed according to Australian Standards. Stairs

cannot be the only means to reach the next floor and signage should tell customers how to

get to the lift.

Design focus

Handrails and TGSIs must not cross the property boundary as this would create a

secondary obstacle.

Stairs should be set back from property boundaries and internal corridors so that

handrails and TGSIs do not protrude.

Stairs must have opaque (in-filled) risers .

Stair nosings should not protrude beyond the face of a step as it causes trip hazards

for people with restricted movement.

There must be a contrasting strip across the full path of travel so that people with low

vision can better see the edge of each stair tread.

62

The strip can be set back a maximum of 15mm from the front edge of the step and

cannot extend more than 10mm down the face of the step and provide a minimum of

30% luminance contrast.

Stairway Handrails

Handrails must be on both sides of the stairs with no vertical sections.

At least 50mm clearance between the handrail and the wall makes it easier to grip.

The rail must extend 300mm beyond the last riser at the top and bottom of stairs, but

can’t extend into a circulation space.

A cross section of the handrail must be circular or elliptical, 30-50mm wide and 'hand

slide-able' all the way along.

Height of handrails must be between 865mm and 1000mm and consistent across the

handrail.

The end of handrails must turn down through 180 degrees or return to wall.

Additional considerations for more dignified access

Ensure that the basics are actually delivered. Often stairs without risers or

contrasting strips are overseen and approved.

Ensure that there is sufficient lighting on stairs and landings.

Installing tactile indicators like a raised button on the handrail to let people who are

blind or have low vision know that they have reached the bottom. Consider including

braille and raised lettering to signify which floor the stairs have reached.

Floor level numbers at change of floors.

63

6.8 Passenger Lifts

Where there is a change in level within the store that is not accessed via a ramp, there

should be a compliant lift. Small buildings don’t need a passenger lift if they are no more

than three storeys and each storey is less than 200m2.

Design focus

There are several types of lifts that are common in retail environments.

Passenger lifts

The usual lift that that people use in multi-storey shopping centres. They should include:

Control buttons on the landings and in the centre of the control panel inside the lift

located at an accessible height.

Lift door clear opening of 900mm to help people with mobility restrictions, but also to

load and unload more efficiently.

A handrail installed inside the lift for support and stability.

Lift doors should remain open long enough for people to exit and enter (Australian

Standards say it should stay open for 6-8 seconds depending on the number of lifts).

All of the symbols and letter on controls buttons inside and outside the lift in raised

tactile lettering and braille.

Emergency hands-free communication, including a button that alerts a call centre of

a problem and a light to signal that the call has been received.

64

Lifts serving more than two levels should have automatic audible information within

the lift car to identify the level each time the car stops, and an audible and visual

indication at each lift landing to indicate the arrival of the lift car.

Additional considerations for more dignified access

A fire engineered design solution for a large shopping centre complex might make

allowances to use at least one lift in each location during emergencies

Having emergency instructions in braille assist people who are blind. This is often not

provided.

Similarly, emergency intercoms and telephones in lifts are not accessible for people

who are deaf. Whilst a light may show to register that the call has been received, call

centre staff may assume that there is no one in the lift. The person who is deaf may

also be unable to receive communication about how long it will take or what is being

done. A solution to this is to have an SMS number displayed in the lift which can be

used in case of emergency.

Some lifts have a system where the customer selects their destination floor from a

point outside the lift area and is directed to a pre-determined lift, and as a result, they

have no controls (other than emergency controls) inside each lift car. These are

usually installed in office buildings with multiple lift cars rather than retail settings, but

also need to be accessible. This includes: the ability to access a lift if instructions

cannot be seen; the ability to access the lift if instructions cannot be heard; and the

ability for people with restricted mobility to access the lift in time.

Clear signage that lets a person know what is on each floor included in tactile and

braille or audio.

Platform lifts

Platform lifts are lifts that enable a person to move between two levels where a ramp is not

practical. These lifts are often controlled by the application of constant pressure to a control.

The BCA requires that these lifts must not travel more than 4m (if enclosed) or more than 2m

if unenclosed. They should not be used in high traffic public use areas such as shopping

centres.

Additional considerations for more dignified access

The constant pressure button to keep the platform lift in motion can be difficult for

customers with limited dexterity or strength.

Platform lifts are invariably locked by facilities managers with directions to call a

central desk. This adds time and makes the process even less dignified.

Stair lifts

Stair lifts are lifts that are fixed to stairs to enable a customer using a wheelchair to travel up

the stairs where no other alternative is practical. The BCA states that they must not be used

to serve high traffic public use areas such as a shopping centres, or where it is possible to

install another type of passenger lift.

65

Additional considerations

Stair lifts are a last resort retro-fitted into difficult, older sites. They should not be a

first, or even second, choice by design.

Stair lifts also reduce the ability to provide safe handrail access to other users.

The design is not dignified, as it creates a spectacle around gaining basic access to a

building.

Depending on how the stair lift is enclosed it can also feel quite unsafe when a

person using a wheelchair is in motion.

6.9 Ramps, landings and walkways

The infrastructure requirements of buildings, ramps, landings and walkways is well specified

in the Australian Standards.

Slope or Gradient

Retail environment terminology

Kerb ramp: as the name implies, a kerb ramp is a ramp that gives access from a footpath to

a roadway. Kerb ramps are usually the responsibility of the local council and must have a

slope of no more than 1:8 and a slip resistant surface.

Step ramp: like a kerb ramp but not attached to a kerb. It might assist someone to ascend a

small step (no more than 190mm) in a store but can’t be longer than 1900mm or steeper

than 1:10. It must have a slip resistant surface.

Threshold ramp: a short slip reistant ramp which allows access to a doorway. They can

only service a rise of 35mm and can’t cover a distance of more than 280mm (a maximum

1

1

1

8

10

14

1:8

1:10

1:14

66

slope of 1:8). A threshold ramp will enable people with prams, strollers and mobility devices

such as wheelchairs to access the store or shopping centre more easily.

Ramp: this is the commonly understood meaning of the term ‘ramp’. It is a walkway that lets

people walk between two levels or landing places on a gradual slope. It is steeper than 1:20

(which is almost flat), but shallower than 1:14 and be slip resistant

Design focus

Key features included in the Australian Standards are:

Ensuring that there is sufficient width (1000mm between handrails) on walkways and

ramps that is impacted by intrusions such as door handles, signs and shelves.

Passing spaces (at least 1800m wide and 2000mm long) that allow two people using

a wheelchair to travel in opposite directions at the same time.

Landings or circulation spaces are provided at changes of direction, doors or gates.

Maximum slope of a ramp that is longer than 1900mm is 1:14.

Regularity of landings on ramps depends on the slope 1:14 (at least every 9m), 1:20

(at least every 15m).

Handrails on both sides.

Ramps should be set back from property boundaries and corridors so that handrails

and TGSIs don’t intrude into the path of travel.

Ramps must have kerbs or kerb rails on both sides to stop the wheels of wheelchairs

catching vertical handrail supports.

6.10 Tactile Ground Surface Indicators

TGSIs are a visual and tactile aid that allows people who are blind or vision impaired to

orient themselves and make sense of other environmental clues. They would most

commonly be used in the shopping centre itself, as most stores don’t have the types of

potential hazards that TGSIs assist with.

Overhead obstacles, or those which protrude in a way that a person using a cane would not

perceive, should be avoided within the store rather than marking out with TGSIs internally.

TGSIs, whilst serving a critical purpose for people who are blind or have low vision, also

create a more difficult surface for people with mobility restrictions.

Design focus

Hazard or warning TGSIs (Round)

They are to be placed across the full width of the direction of travel at the top and

bottom of stairs, ramps, escalators and moving walks and to highlight overhead

obstacles.

They should be between 600mm and 800mm deep and set back 290mm to 310mm.

The TGSIs themselves must be made according to a specified design and

arrangement standard (height no more than 5mm above base, dot spacing at 50mm,

slip resistant, high luminance contrast and no likelihood of edges lifting).

67

Directional TGSIs (Strips)

Used to designate a route to be taken to avoid a hazard or to indicate a path of travel

across an open space. They are prescribed for application in transport settings.

More information on TGSIs can be found in AS 1428.4.1.37

Additional consideration

It is tempting to ‘over-use’ TGSIs in an effort to over-comply. The Standards

themselves note that a person may “become disoriented if presented with an

unpredictable, incorrect, incomplete or over-supplied set of indicators.”

Maintenance of TGSIs is often neglected and should be incorporated as part of

regular property maintenance reviews.

Ensure that the luminance contrast of TGSIs is high against the background upon

which they are laid.

6.11 Hearing augmentation

The BCA requires that a hearing augmentation system is to be provided where an inbuilt

amplification system (typically a PA system), other than one used only for emergency

warning, is installed. The types of retail settings that are required to have hearing

augmentation are where a store might have a meeting or conference room, or an area where

there is a screen between the customer and the employee such as a ticket office, teller’s

booth, reception area or similar.

37 AS 1428.4.1 Design for Access and Mobility Part 4.1: Means to assist the orientation of people with vision impairment – Tactile ground surface indicators.

68

International Access Symbol for Hearing

There are broadly two main types of hearing augmentation hearing augmentation: fixed and

installed in the building, or portable requiring the use of receivers. Hearing loops are installed

in the infrastructure of a building such as under the carpet or in the ceiling and provide

discrete and effective hearing, as people can activate the T Switch or telecoil on their

hearing aid or cochlear implant to hear what is being said. Other systems (such as an infra-

red system or FM system) require the customer to use a receiver which is much more

obvious and less dignified. Receivers also need to be regularly maintained and tested. Both

sorts are acceptable for minimum compliance, but the Premises Standards and BCA dictate

the coverage required by the each type of system.

Design focus

Hearing augmentation where your premises has a meeting or conference area or a

service counter screened from the public.

Where hearing augmentation is installed, the International Symbol for Deafness

needs to be used. It is a stylised picture of an ear with a diagonal slash through it.

The reason for using the symbol is that people wearing hearing devices with a T

Switch need to switch it on to utilise the hearing augmentation.

The proportionality of the symbol is defined in AS1428.1 and the colours are white on

ultramarine (blue).

Additional considerations for more dignified access

Interconnecting systems into the buildings emergency communication system, as

outlined in AS 1428.5

Consider installing hearing augmentation at service desks that are not screened as

well, where the environment is slightly noisier and customers with hearing aids would

benefit.

Use hearing loops where possible rather than systems with receivers as this provides

more dignified, discrete access and creates less maintenance issues with cleaning

and charging of the receivers..

The size of the symbol is further defined in AS 1428.2 depending on the viewing

distance38. In most stores viewing distance from the counter is less than seven

metres which indicates a minimum symbol size of 60mm x 60mm. For viewing

distances between 7m and 18m the required size increases to 118mm x 118mm.

6.12 DeafSpace design

DeafSpace design is a set of guidelines developed to improve the accessibility of premises

for people who are deaf. It is an initiative created by architect Hansel Bauman (hbhm

architects) and Gallaudet University in 2005 but has continued to evolve.

38 AS 1428.2 Design for Access and Mobility: Enhanced and additional requirements: Table 1

69

“Our built environment, largely constructed by and for hearing individuals, presents a variety of surprising challenges to which deaf people have responded with a particular way of altering their surroundings to fit their unique ways-of-being. This approach is often referred to as DeafSpace.”

“When deaf people congregate the group customarily works together to rearrange furnishings into a ‘conversation circle’ to allow clear sightlines so everyone can participate in the visual conversation. Gatherings often begin with participants adjusting window shades, lighting and seating to optimize conditions for visual communication that minimize eyestrain. Deaf homeowners often cut new openings in walls, place mirrors and lights in strategic locations to extend their sensory awareness and maintain visual connection between family members.”

“These practical acts of making a DeafSpace are long-held cultural traditions that, while never-before formally recognized, are the basic elements of an architectural expression unique to deaf experiences.”39

Design focus

Some of the key guidance is:

Other than hearing augmentation systems, there is no guidance in BCA.

Additional considerations for more dignified access

Design that allows people maximum 360-degree visibility as they travel around.

Sufficient space for two people using sign language to stand apart so that signing

and facial expressions can be seen.

Design of circulation spaces and paths of travel so that people can use sign

language and continue to walk. An example would be rounded corners rather than

blind corners.

Avoid lighting conditions that interrupt visual communication or lead to eye fatigue or

loss of concentration.

Minimise hard surfaces which cause reverberation and can be distracting for people

using assistive hearing devices.

6.13 Customer interaction counters, tables and worktops

A desk or counter should be appropriate to the task. The expected length of time a customer

interaction will take, the nature of the conversation and requirement to view and use a

shared screen will dictate the style of desk and seating. Longer conversations requiring a

shared screen view and discussion of personal details is better with a lower desk, more

comfortable chair and a quieter space. Shorter conversations about products or services

39 http://www.gallaudet.edu/campus-design/deafspace.html Viewed September 2016

70

may be more appropriate for a stool and bench conversation but alternatives should be

available.

“No individual table, counter or worktop height and clearance beneath will suit all

users with disability. A bench with easily adjustable height with a range of 700mm to

850mm from the finished floor is preferred.”40

Pictures is a good example of sit-stand self-service counter at Bupa Barangaroo.

Reception or payment counters

Access is not just about the physical ability to reach the counter. Design should also

consider the equity of the experience of customers that purchase goods or services. A

counter with a uniform height over 1100mm can create the impression of a barrier between

the employee and customer. Adding to that difficulty is the depth of the desk and presence of

computer monitors which raise the effective interaction height even further. It would also

make it difficult to employ a person who is a wheelchair user or of short stature in store roles.

If the primary purpose of this counter is payment for purchases, then easy access to the card

reader should be a focal point of the design. Access to the counter, visibility of the screen if

required and the ability to have a face-to-face conversation is enabled in many bank

branches by the provision of a low height section in the counter.

40 Australian Standard Design for Access and Mobility: Part 2: Enhanced and additional requirements AS 1428.2 (1992) P33

71

Payment counter at Barangaroo at an accessible height

Checkout counter at Barangaroo with easy access to payment facilities

Design focus

72

Premises Standards don’t dictate how reception or payment counters should be set

up.

Additional considerations for more dignified access

The highest section of a counter, including things placed on the counter, should be

no more than 1100mm.

More recently, counters are being designed with a lower overall height or in a way

that does force a person into the ‘special’ section of the counter.

AS 1428.2 suggests counters ideally have at least one place with a low height

section (830mm to 870mm) knee and foot clearance of 800mm to 840mm and wide

enough for a wheelchair (900mm).

The card reader should be within reach of customer and able to reach the customer’s

lap whilst sitting at the counter.

Customer service and self-service tables

Using a combination of table heights with good under table clearance is good design.

The use of dividers between customer terminals for privacy and noise reduction assist

people with disability as well.

Design focus

Premises Standards don’t dictate how customer service tables should be set up.

Additional considerations for more dignified access

Consider adjustable height tables with good under-desk clearance.

Interactive screens or keyboards within reach distance from a seated position.

Stool seating can be more difficult for an ageing population and provision needs to be

made for more alternative seating.

Seating and table arrangements should provide the degree of privacy required for the

nature of the conversation.

Where customers and staff share a screen as the basis of a discussion, enable the

screen to be fully rotated to the customer.

If computer screens are used to share information with customers, information will

need to be described and/or provided in a format that the person can access.

If audio content is played to a customer (for example, playing an audio version of a

long insurance clause), how will that be provided if the person cannot hear it?

73

6.14 Seating

Seating in stores should reflect a variety of user capabilities and take account of a rapidly

ageing population who are working until later in life. The range of seating should match the

heights of customer interaction desks, but also consider the need for customers who might

need to sit whilst waiting or require additional time for conversations in a quieter part of the

store.

Design focus

Additional consideration for more dignified access

Ensure that there are a variety of styles which maximise the range of customers that

can be seated.

Lower seating has arms that allow customers to assist themselves in and out of the

chair.

Alternatives to stool seating, as these require stability and balance to use

Clear space between the legs of the chair.

Chairs should have good contrast to the background to make them easier to see.

Expected placement of seating allows clearance around the chair and away from

paths of travel.

Chair height is appropriate to the desk and the expected reach.

AS1428.2 covers “Street Furniture”, some of which is useful in guiding seat design for

waiting areas. A summary of some relevant sections is provided below:

74

Seats should be a minimum of 500mm away from the path of travel.

Objects should have a contrasting colour and luminance to their background.

Seats should be 400mm to 450mm high (or 520mm high when used by people who

are elderly).

There should be a clear space between the legs of the seat and out to 150mm in

front.

Armrests at a height between 220mm and 300mm above seat.

6.15 Product or display walls

Being able to reach products and services is important for sales and also a person’s self-

respect and dignity when they are shopping. Trying to make goods available at a variety of

heights whilst maximising display space is a challenge, but creates independence.

Design focus

The main requirement in Premises Standards is for people to be able to access

goods and services. This has clear implications for how they are displayed and

arranged, but no specific guidance is provided.

A food display cabinet at Barangaroo that can be viewed from a seated or standing

position

Additional considerations for more dignified access

75

A principle that assists in maximising access to shelving is to align similar goods in

columns rather than rows so that a selection of each type of good is accessible at a

reasonable height.

Team members also play a pivotal role in assisting customers who have reach and

stretch restrictions.

Consider the issue of glare when viewing products and information from a seated

position.

Ensure that product walls or display tables have clear access in front of and around

at least 1m so that customers can view your goods in comfort.

Check that information content is easily understood, easily seen, unobstructed and

jargon-free.

Consider the ‘reading age’ of the content as it will enable people of different

communication capabilities, including English as a second language, to better

understand what you are selling.

Can your products be accessed to test, feel and manipulate?

6.16 Lighting

Good lighting is necessary for people to read about products and navigate retail stores. This

is especially true for people with low vision who may require better than usual lighting.

Design focus

Lighting levels

Entrances, passageways, stairs, walkways and ramps should be lit at 150 Lux.

Effective lip reading at 150 Lux.

Counter tops at 250 Lux.

General displays at 200-300 Lux.

Source: Australian Standard Design for Access and Mobility: Part 2: Enhanced and

additional requirements AS 1428.2 (1992).

Glare and direction

Lighting also has a relationship to product displays and glare. Viewing displays from

different angles, including from low heights, will assist in helping all customers find

out about products and services on display.

Lighting should not point directly at customers entering the store.

6.17 Floor patterns

Bold patterns can give the impression of movement, changes in level and also the

perception that there is an object when one does not exist. In the photo below, floor pattern

gives the impression that the floor is undulating, but is actually quite flat. Whilst it is intended

to be very stylish, this hotel foyer creates significant issues for people with low vision or have

a diminished sense of balance.

76

Design focus

Premises Standards and BCA give no guidance on this.

Additional considerations

Avoid patterns which create an altered perception of depth, slope or change of level.

Utilise floor patterns which give people with low vision a clearer sense of direction

and pathway.

Simple is better. Ensure good contrast between the walls and floor as well as

between the furniture and the floor.

6.18 Floor materials

Flooring materials can create easier or more difficult conditions for people with disability.

Deep carpets make using a wheelchair more difficult, as do cobbled surfaces or even rough

surfaces over longer distances. Flooring material can also create an acoustic and tactile path

that assists people who are blind or have low vision to stay on path and navigate more

effectively. All floors should be non-slip in wet or dry conditions.

77

6.19 Accessible Toilets41

In most instances, customer toilet facilities are not provided within the store but in the

shopping centre. Customer toilet facilities, when built within the store, must meet Australian

Standards.42 These are summarised in the end notes of this publication.

The most frequently encountered issues with accessible toilets are:

Doors are too difficult to open and pass through.

Privacy latch to show the toilet is occupied is too small making it hard to turn

Circulation space is too small.

Cleaners leaving the sanitary disposal unit at a distance from toilet, not against the

wall next to the toilet.No colour contrast between walls and floor, or toilet seat and

floor.The accessible toilet is used to store extra equipment, products or even

wheelchairs

Facilities are frequently used by people who have no specific need to use an

accessible toilet, but prefer the extra space or are parents with children, usually of a

differing gender.Case study: Changing Places toilets

Meeting the needs of people with disability who require assistance or additional facilities in

public bathrooms is an area that is very relevant to ‘dignified access’. The current situation in

compliant accessible toilets is that carers and people with disability have insufficient space

and are forced to choose between changing on the floor of an accessible public toilet or

avoiding the shopping centre altogether. This is not dignified access.

Changing Places is a not for profit organisation that advocates and enables the installation

of bathrooms that specifically meet the needs of people with disability and their carers. The

facilities include adult sized adjustable change tables, a ceiling hoist, sufficient circulation

space, toilets that are accessible from both sides with fold-down grab rails and result in a

safe and clean environment. This need for assisted facilities was not envisaged by the

current BCA and Australian Standards, and as a result the Changing Places facilities are not

counted as an accessible toilet for compliance purposes as they cater for a different user

group..

The Changing Places website provides information about the experiences of people that

need and use these facilities, comprehensive information about the benefits of implementing

them as well as detailed information about the designs and how to implement them.43

41 A disabled toilet is one that is broken.

42 Toilets constructed prior to May 2011 that meet the requirements of AS 1428.1 (2001) do not need to be upgraded to the AS1428.1 (2009) standards.

43 www.changingplaces.org.au Viewed September 2016

78

6.20 Restaurants

Whilst AND has not conducted research into the dining experiences of consumers with

disability, personal experiences and common sense point to some basic suggestions. These

are a mixture of premises and service pointers.

Pre-Service – Before a diner even enters the restaurant, it is important that service staff are

able to accurately describe the accessibility of the premises. Often staff do not know what

diners with disability are referring to. Basic training in the what the restaurant has to offer is

important as people rely on this. For example, “We have a flat entrance and automatic

doors. We have a right hand transfer unisex accessible toilet. The restaurant also welcomes

assistance animals”. Disappointment from customers can often end up on social media. It

also helps if service staff can ask about and note accessibility requirements of patrons so

that seating can be organised or paths of travel adjusted beforehand to create a more

dignified experience.

Service – Service techniques are covered towards the end of this publication. In restaurants,

service staff can smooth the way and provide more dignified access:

Ask a person who is blind how you might assist, and know the basics of doing this.

Don’t dictate where a person using a wheelchair will sit. Ask as you would for anyone

else and arrange the seats accordingly.

If you only have a paper or blackboard menu, offer to describe the menu or have an

alternate format in large print or braille available..

79

Place the bill in the middle of the table rather than assuming a person with disability

is not paying.

Lighting – Mood lighting in restaurants creates issues. When your customers need to use

their smartphone lights to read the menu, it is time to improve the lighting. People with low

vision may face the indignity of having the menu read to them and people who lip read may

not be able to see to understand. 150 Lux is the minimum recommended lighting for lip

reading.

Menu – Menus should have a reasonable font size (>11 point for menus at the table – more

if the lighting is lower), simple font style and good contrast. Have the full menu available

online in an accessible format (HTML or Word) so that people can pre-plan if they cannot

see a paper menu. Consider having the menu printed in braille for people who are blind and

can read braille.

Space – Ensure that there is a minimum 1m gap around all tables and pathways – more

where there is likely to be people passing each other or congregating (doorways, payment

counter, entry to kitchen and entry to toilets).

Seating – Make sure that there is a variety of seating available and that a space can be

created for a diner using a wheelchair without fuss or spectacle.

Noise – Many restaurants are very noisy and for people with hearing impairment,

conversations become very difficult. Hearing aids tend to focus in on the loudest noise on

the side of the hearing aid (usually the next table). Ensure that the restaurant has a mix of

hard and soft surfaces to absorb some of the noise.

Toilets – Be aware of whether your facilities really are accessible. Check out the guidance in

this publication. Don’t use the accessible facilities as a storage place for the cleaner’s

equipment. This makes the toilet unusable for guests.

Payment – Offering the bill to the table rather than to the dining companion of the person

with disability is good practice. Explaining the options for credit card payment when

someone can’t see it. For example, “The amount of the bill showing is $67.80. You have the

option of providing a tip which can enter first and then press the enter key. The next buttons

you press will be your PIN followed by enter. The terminal is on the table just to the right of

your plate. Would you like a receipt?” or “We have Paypass and the bill amount is $67.80.

The terminal is on the table just to the right of your plate. Would you like a receipt?”

6.21 Employee areas

Under the DDA it is illegal to discriminate against a person on the grounds of disability. In an

employment context this means that workplaces need to be accessible unless it would

create unjustifiable hardship to the employer.

Back of house area

80

Many stores have a ‘back of house’ area for staff members to sign in, store their gear or

even get changed and eat meals. The same considerations that apply to the customer areas

of a store apply to the back-of-house areas:

Is the path of travel including doors accessible?

Do the staff bathroom facilities have an accessible toilet (in premises or the centre)?

Are a range of lockers available at an accessible height?

Do any kitchen facilities allow access for a person using a mobility device or

wheelchair?

Dangerous places

The BCA and Disability (Access to Premises – Buildings) Standards Section D3.4 provides

that some areas (and travel to them) need not meet full accessibility standards based on it

being ‘inappropriate’ because of its specific use, or that would ‘pose a health or safety risk

for people with a disability’. The Australian Capital Territory has additional provisions.

Deciding that an area is ‘inappropriate’ or would ‘pose a health or safety risk’ is an

exemption from the BCA that a building surveyor or certifier would decide based on evidence

provided during the approval of a building or workplace. It is not sufficient to just decide that

the premises doesn’t need to be accessible because of perceived safety concerns.

The sorts of examples contemplated by the Explanatory Statement44 are “rigging lofts, waste

containment areas, foundry floors, loading docks, fire lookouts, plant and equipment rooms

and other similar areas”.

7 Guidance on contact centres45

There are no ‘rules’ for how contact centres should be structured to deliver the best

experience for people with disability. What follows are some suggestions drawn from a

variety of sources including the AND surveys mentioned elsewhere and several international

guidelines.

44 Explanatory Statement — Disability (Access to Premises—Buildings) Standards 2010 p34.

45 Contact centre or call centre? A Contact Centre is a place that manages in-bound and out-bound

calls, email contact, manages social media communication. A call centre usually means just in-bound

and out-bound phone conversations. Some elements of the discussion applies equally to smaller

businesses that has a person who answers the phone.

81

7.1 Keep call menus short

Some contact centre interactions start with a long menu of options. For example, “Press 1

for X. Press 2 for X. Press 13 for X”. While this makes it easy for the business to target calls

to the right person, it makes it harder for customers as they listen to a long menu. For people

who may be hard of hearing or find it hard to retain attention or focus, a long menu is difficult

and confusing unless the options can be quickly written down.

7.2 Depth of menus and the path to help

Best practice for dignified access for people with disability is to have shorter menus with

limited sub-menus. Speak to an operator options should be prominent and direct to an

operator.

7.3 Voice recognition

Some contact centres now have voice recognition. “In a few words please tell me what your

call is about”. This style of system can work for people who don’t have the capacity for long

menu options, but of course is limiting if you have a speech impairment. Again, the best

option is the ability to quickly secure a conversation with a person.

7.4 Operator clarity

In the Australian Network on Disability’s research, it is very clear that operators who speak

very quickly, softly or have strong accents are very difficult for people with hearing

82

impairment to understand. Effort should be made to ensure that operators are able to clearly

communicate or adopt strategies to make themselves understood.

7.5 Information and formats

Contact centres are a common way for someone to seek information that they have not been

able to access elsewhere. People who are blind or have low vision commonly request

information in different or ‘alternate’ formats such as braille translation of a contract or

statement. While electronic mechanisms such as screen reading technology now exist,

braille is still regularly used and retailers should be prepared to provide equivalent access to

people who are blind by providing braille alternatives. Contact centre staff should be aware

of the processes for doing this. Vision Australia is able to assist with this.

7.6 Identity

When a carer or assistant is calling on behalf of a customer with disability, they often

encounter issues in relation to “privacy”. In most cases the operators are following

instructions and rules that seek to protect personal information or data and are doing so with

the right intent. From the customer’s perspective, this feels like unwarranted bureaucracy.

Where you have more complex relationships with customers and maintaining confidentiality

is important, contact centre operators need to be able to do two things:

Explain why the identification of the caller is important in simple to understand terms

rather than simply stating, “No, it is privacy.”

Give people a path to resolution. For example, “I can provide you with a consent form

that means we don’t have this issue in the future”.46

7.7 National Relay Service (NRS)47

The National Relay Service (NRS) is an Australia-wide phone service for people who are

deaf or have a hearing or speech impairment. This service allows people to talk to a

business (or family or friends) through an NRS relay officer. The NRS is an Australian

Government initiative funded by a levy on eligible telecommunications carriers.

46 Barclays Bank has an excellent website describing its Accessible services. It has a section for Shared Banking which gives customers clear instructions about how to organise this. https://www.barclays.co.uk/Accessibility/AccessiblecommunicationsAccessibilityHelpandInformation/P1242657780139 Viewed September 2016

47 Explanatory picture and review provided by National Relay Service

83

How does it work?

Your customers who use the NRS are making phone contact with you using a range of

different technologies. The caller can be speaking, typing or signing.

There are eight NRS call channels that an NRS user can use. All calls involve a relay officer

whose role is to relay information between you and your caller. In most of these call

channels, staff can talk to the relay officer if there are any queries about the call process.

Staff do not need any special equipment to receive a call.

The NRS is available 24 hours a day, every day, and relays more than half a million calls

each year throughout Australia.

What do you as a business need to do?

When taking a call through the NRS, your staff need to conduct the conversation in the same

way as you would with any customer who phones you. Speak directly to the caller - not the

relay officer. Each time you have finished speaking, it is helpful to say ‘Go ahead’ or

something similar. Speak in short, clear sentences at a moderate pace. A call made through

the NRS may take longer than a standard call. The NRS supports businesses in becoming

more accessible by offering free training, education and learning resources.

Is it OK to discuss personal and confidential information with the caller during a call?

Yes. The Privacy Act specifically exempts NRS relay officers from being

considered third parties in a phone call. The Office of the Australian

Information Commissioner states that “Businesses, service providers and

government agencies do not need an NRS user’s written or verbal permission

84

to collect, use or disclose the NRS user’s personal information in the presence

of or with the assistance of an NRS relay officer. Businesses, service

providers and government agencies will not be breaching the Privacy Act by

collecting, using or disclosing personal information with individuals through the

NRS”48

Top tips for call centre staff49

Speak clearly and into the microphone.

Don’t speak too quickly, and slow down if requested to do so.

Stay on topic.

Be prepared to repeat or rephrase.

Give the caller time to explain fully - don't interrupt and be patient if they are having

difficulty speaking or hearing.

If you receive a call via National Relay Service (NRS), don’t hang up - the relay

officer will help with the call if necessary.

Don't assume the caller can see (for example, to read a serial number) - it may be

necessary for someone else to help with this, so please be patient.

7.8 Top tips for businesses using call centres50

All call centre staff should be given disability awareness training.

Offer customers the choice of contacting your business by post or email as well as

phone.

When customers have to confirm complex details over the phone, offer them the

chance to have information posted or emailed for confirmation.

Call centre speech levels (at headset and system output) should meet international

standards and should be checked on a regular basis.

If you advertise a TTY 51 number, make sure that your staff know how to answer and

use the TTY machine.

Music or a waiting signal helps people to know they have not been cut off.

Keep call routing menus short (4 is a good maximum) and give an option of speaking

to an operator in the initial menu.

Allow the caller the option of repeating the menu.

48 https://www.oaic.gov.au/agencies-and-organisations/faqs-for-agencies-orgs/businesses/will-businesses-service-providers-or-government-agencies-be-breaching-the-privacy-act-by-providing-information-to-customers-through-the-nat Viewed September 2016

49 Adapted from http://consumers.ofcom.org.uk/ofcom-for-business-consumers/help-for-disabled-business-customers/disabled-customers-and-call-centres/ Viewed September 2016

50 Adapted from http://consumers.ofcom.org.uk/ofcom-for-business-consumers/help-for-disabled-business-customers/disabled-customers-and-call-centres/ Viewed September 2016

51 TTY is an older technology that allows people to type messages that the relay operator (or your business if you have one of these machines) can read.

85

The system should transfer the caller to an operator if no option is chosen or if the

caller cannot do what is being asked, e.g. enter an account number.

Menu options should be logical for the customer rather than based on your

organisational structure.

In 2012, the Contact Centres & Telemarketing Council in the UK published a guide for

businesses with call centre operations52. The particular focus was on how to identify

customers that were vulnerable.

“Organisations have little understanding of how to pick up signs of a vulnerable

consumer, or how best to handle such situations with care and respect. Staff may not be

equipped to deal with the situation, and there is often no policy for addressing any

problems that may arise. This means that despite their best intentions, organisations

may not give consistent quality service.”

The guide is very practical and covers how to identify vulnerable consumers, practical tips

when talking to vulnerable consumers and steps to take before making a sale to someone

suspected of being a vulnerable customer. Importantly, the guide makes recommendations

about the things that businesses should do to ensure the equitable and dignified treatment of

customers including:

Steps for senior management and project engagement including outsourced call

centre partners.

Procedural steps that can be taken such as allowing extra time in call time KPIs for

these calls, marketing planning and marketing materials, returns/cancellation

processes and complaints processes.

Staff training actions.

Capturing customers’ needs in a database for consistent treatment over time and

across channels.

Post call quality assessment procedures.

8 Guidance on online retailing53

This section is intended as a guide to influence the design of your website, rather than being

a rigorous guide for developers. The standards themselves are very comprehensive and

52 White paper Guidelines for call centres dealing with vulnerable consumers, 2012, Contact Centres & Telemarketing Council viewed at http://dma.org.uk/uploads/call-centres-vulnerable-consumers_final_53d7c237289c1.pdf Viewed September 2016

53 See Australian Network on Disability, Beyond Recruitment Guide and www.w3c.org

86

every effort is made to make them accessible to the non-technician. They can be found on

W3’s website.

8.1 What is the benchmark for accessibility?

When considering the accessibility of your website, software applications or intranet, there is

plenty of guidance available, but it can seem quite technical and it can be difficult to

determine whether you are ‘doing it right’. This section seeks to de-mystify the acronyms and

language and explain how you can determine if your sites are accessible.

What is WCAG?

Web Content Accessibility Guidelines (WCAG) 2.0 is the international standard used by web

developers to ensure that websites are accessible to people with disability. Meeting the

standards means your website will be accessible to the widest possible audience, but it may

not meet the needs of all combinations and degree of disability.

WCAG Levels

The Standards have three levels: A, AA and AAA. Unsurprisingly AAA is best, but is seen as

aspirational and most organisations and people with disability find AA level gives a level of

access which lets people do most things online.

Website accessibility principles

Under the web accessibility guidelines, there are four foundation principles which are

essential for the development of web content. In simple terms, the four principles for good

accessible website design are:

1. Perceivable: Users must be able to perceive the information being presented (it can't

be invisible to all of their senses).

2. Operable: Users must be able to interact with your website (it cannot require

interaction that a user cannot perform).

3. Understandable: The content or operation of your website cannot be beyond the

understanding of the user.

4. Robust: Users of a wide variety of assistive technologies must be able to use your

site now, and in the future as technologies evolve.

What types of things do the standards cover?

For each principle, there are one or more guidelines that assist web developers and those

commissioning work on the web to better understand what is required to deliver on each

principle.

Perceivable

87

o Provide text alternatives for any non-text content so that it can be changed into

other forms people need, such as large print, braille, speech, symbols or simpler

language.

o Provide alternatives for time-based media.

o Create content that can be presented in different ways (for example simpler

layout) without losing information or structure.

o Make it easier for users to see and hear content including separating foreground

from background.

Operable

o Make all functionality available from a keyboard.

o Provide users enough time to read and use content.

o Do not design content in a way that is known to cause seizures.

o Provide ways to help users navigate, find content, and determine where they are.

Understandable

o Make text content readable and understandable.

o Make web pages appear and operate in predictable ways.

o Help users avoid and correct mistakes.

Robust

o Maximize compatibility with current and future user agents, including assistive

technologies.

8.2 What is the right level?

The Australian Government has endorsed the Web Content Accessibility Guidelines

(WCAG) version 2.0 for all government websites, and has required all Australian, state and

territory government websites to conform to the guidelines.

The Government also announced in August 2016 that Australia was to become the first

country outside Europe to adopt the European standard for accessibility in procurement (EN

301 549). It is the first step in embedding accessible ICT in public procurement requirements

and provides a benchmark for private sector organisations wanting to be sure the technology

products and services that they buy are usable by people with a disability. An ‘Accessible

ICT Procurement Toolkit’ for understanding how this works can be found at Accessible IT

Procurement Toolkit.54

8.3 Working with your Information Technology supplier

It is possible that your IT supplier is already informed and has a good understanding of what

is required. This section is aimed at helping you have a more informed discussion and

systematic approach.

54 http://mandate376.standards.eu/ Viewed September 2016

88

What are your most commonly used internal and external pages? Your IT team

should be able to provide this information quite easily.

Be clear about whether you are talking and thinking about your external website or

the internal website of your organisation.

If cost is an issue, focus your attention on those sections where your organisation

and people with disability will get the greatest benefit. These may be your most

commonly used pages, but may also be the pages that suggest to potential

applicants that your organisation is accessible, such as:

o Online shopping site.

o Company profile pages.

o Recruitment and selection section and links.

o Website accessibility guidance pages.

8.4 Questions for the IT supplier or team

Has there been an accessibility review of the business's internet and intranet sites?

Is that the whole site or just some pages?

Which A, AA and AAA criteria do we meet for our most commonly used pages?

What would be the quickest ways to improve accessibility for our most commonly

used pages?

What are the issues that users cannot get past as opposed to those which are an

inconvenience?

Are links to other applications, systems or landing pages (for example, job seeker

application forms) accessible?

What accessibility factors are taken into account when designing and/or upgrading

information technology systems?

Is there induction training for IT developers on accessibility standards?

Do you have online authoring standards?

How does the organisation assess alternative technologies and their compatibility

with the internal systems environment (screen reading software, etc.) for new

employees?

8.5 How do I determine if my site is A, AA or AAA?

There are many providers that can assessment the accessibility of your website. Two

popular choices are:

Vision Australia

Media Access Australia

8.6 How does the technology team know if we meet the requirements?

Success Criteria are “testable” propositions or criteria that that determine whether a

guideline has been achieved. The success criteria are graded as A, AA and AAA, with AAA

representing the most accessible designs.

89

A particular web page or web site may have some features which are A, some which are AA

and others which are AAA.

There is extensive information about each success criterion on the W3C website.

8.7 Delivery

Shopping online can be of great benefit for people with restricted mobility who have more

difficulty taking goods home from your physical store. Other people just enjoy the

convenience. Having goods delivered home can pose issues for some people with the

following impairments:

Hearing: Can’t hear doorbell. A solution is leaving a missed package delivery behind.

Physical: Restrictions which make getting to the door more difficult.

Vision: Missed package delivery cards are written on paper and cannot be read.

It is really important to give customers the ability to nominate delivery instructions.

9 Guidance on customer service

9.1 Service architecture

The research provided shows that people who experience disability highly rate the attitude

and disability awareness of customer service staff as a very important or critically important

attribute of a good retailer. We also know that these customers are prepared to move their

business elsewhere when service is not up-to-scratch or the business is not accessible.

How can businesses consistently deliver a dignified experience for customers who

experience disability?

90

Basics

The first step is to ensure that the premises or store is accessible. If a customer cannot get

in and around independently, the service experience is not very relevant.

Service principles

Agree on simple principles or steps that team members can follow that lead to an

independent, dignified experience. Some examples of these principles or guidelines are

listed below, but it is important that they mesh with the service principles within your

business already.

Treat the person as being ‘expected’ not a surprise that needs to be ‘dealt with’.

Don’t over service by taking control away from the customer.

Use the same respect and courtesy you would give everyone else.

Be polite and patient when offering assistance, and wait until your offer is accepted.

Don't assume that the customer with disability will want or need your help; wait for

specific instructions. Often customers with disability won't need or want any

additional assistance.

If you feel like you've embarrassed someone; apologise, but don't dwell on it or avoid

the situation. Try and see the lighter side of things.

Avoid asking personal questions about someone's disability as this can be intrusive

and inappropriate.

Be considerate of the extra time it might take some customers to do or say some

things.

91

Use “person first” language. Refer to a “person with disability” or “people with

disability.”

Training

Training is one aspect of learning and is very important. As the feedback suggests, having

staff members that have been taught what to do is very important. Training needs to be

current and re-enforced.

My speech is difficult to understand - but I have something to tell you! 55

Ron’s Story: “A wonderful birthday lunch for mum!”

“Last year I took mum out to lunch on her birthday to a local club. The whole family

came as well. I couldn’t fault the service. I swear that the waitress had training in

disability awareness. She took the family’s orders first. This is the way I wanted it

because I didn’t feel pressured. This gave me more time to work out what I wanted

and to type the message into my communication aid. She was patient and gave me

time. When it was my turn, I was able to type what I wanted for lunch. She waited

patiently. Even when I was typing long words like cappuccino which are harder to

spell, she didn’t interrupt. I felt great. It was nice to be able to go out for lunch with my

family and for things to go smoothly.”

Employment of people with disability

The AND survey-based research tells us that people with disability as customers perceive

that this is an important way for the organisation to learn about disability and to drive more

acceptance. Retail environments that are built for staff members experiencing disability are

more likely to be accessible for customers.

55 Case Study care of Scope Australia

92

A study by Kalargyrou and Volis (2014)56, looks at disability inclusion initiatives in eight

hospitality companies. The study lists a number of benefits that hospitality businesses report

from proactively integrating people with disability into the workforce, while only two of the

eight companies reported challenges. Benefits include: improved innovation, problem-

solving abilities, and unique ideas; improved customer satisfaction and customer-service

capabilities; and establishing a positive company image, improving marketing initiatives, and

attending to social sustainability.

Overall, the study reports that integrating people with disability into the workforce improves

business performance and business success. Given the high employee turnover ratios

frequently experienced by hospitality companies, the authors suggest that findings that

workers with disability are loyal, reliable, motivated, productive, and prompt in attendance

should influence employers to consider disability inclusion as a way to save money, improve

worker consistency, reduce turnover, and ultimately improve the success of the corporation.

The study focuses on companies that have a strong initiative to integrate people with

disability in their workforce. Based on the research questions, common themes are identified

56 Kalargyrou, V., Volis, A. A., 2014, Disability inclusion initiatives in the hospitality industry: an exploratory study of industry leaders, Journal of Human Resources in Hospitality & Tourism, Vol. 13, No. 4, pp. 430-454

93

among the eight hospitality companies surrounding "best practices" for integrating people

with disability into the workforce. Among the findings of the study, it is reported that most of

the featured companies suggest that establishing diversity inclusion councils, teams,

foundations, or task forces is important to the proactive recruiting, hiring, and supporting of

employees with disability. The companies have also created alliances or partnerships with

social service and vocational rehabilitation agencies and other organisations involved in

raising awareness about people with disability as a way to identify and recruit candidates for

employment. To help integrate people with disability into the workforce, most companies

also provide education and training to employees without disability to include working and

interacting with employees with disability.

Non-property related inclusions

‘Service’ architecture extends beyond who is in the team and how team members behave

with customers. There are many small features that can be used to assist in delivering and

reminding staff of their responsibility to customers with disability:

Braille menus for a restaurant.

Website describing accessibility features of stores.

Signs welcoming assistance animals.

Space for assistance animal at the table.

Communication picture boards showing the main products or services.

A pen and paper or iPad for typing messages if someone is Deaf (and you don’t

know AUSLAN).

94

Scope Australia assisted the National Disability Insurance Agency57 to develop a series of

communication boards that assist people with communications difficulties to get their

message across. The boards use symbols or words to convey pre-selected messages so

that visitors to any NDIS office can communicate in a dignified way. Communication boards

can be tailored to suit a business, and ensure that customers with different abilities have

equitable access to products and services in retail settings.

57 http://www.scopeaust.org.au/how-can-i-communicate-at-the-national-disability-insurance-scheme-ndis/ Viewed September 2016

95

9.2 Mobility

People with physical disability may be restricted or limited in the way they move around or

communicate. Some people with physical disability may use a wheelchair to get around,

others may use crutches or a walking stick, while others may have restricted upper body or

arm movements, or may be without any obvious signs.

Wheelchair Users

People who use wheelchairs to get around need level access.

Stairs, narrow or crowded aisles, or uneven footpaths can make it very difficult for

wheelchair users to move around safely.

In addition, thick carpet or rugs, computer or telephone cables, and even protruding table

and chair legs can create barriers and hazards to wheelchair users.

Customers who use wheelchairs or other mobility aids have the same rights as all other

customers and should be made to feel welcome in every situation.

Ways you can help

Offer a stable surface such as a clipboard for the customer to write on if a counter is

out of reach.

Make sure that EFTPOS machines and other systems are cordless or are on a cord

long enough to pass to someone in a wheelchair.

You may have to come out from behind a counter in order to help a customer unload

their shopping basket items onto the counter, or to hand the customer an EFTPOS

machine or clipboard to sign.

For detailed transactions, try and put yourself at eye level with the customer and

speak directly to them.

Ask the customer if they would like any assistance before assuming. For example,

offer to carry bulky items or open heavy doors.

When passing something to a customer, if they can't take hold of it, ask them how

they can best take receipt of it. For example, the customer may suggest you hang the

shopping bag on the back of their wheelchair.

For people who experience fatigue, or people standing in queues, consider offering

them a chair.

Make sure you know where the accessible bathrooms are and ensure that they are

free from unnecessary items. Know the most accessible route into and out of the

premises.

Avoid:

Touching or moving the customer's wheelchair unless asked to do so by the

customer.

Standing behind a wheelchair user.

Patronising or talking down to a wheelchair user.

96

Be aware that:

Customers in a wheelchair may hang bags or other things on their wheelchair. Their

wheelchair is a part of their individual personal space and should be respected.

Customers who use crutches or other mobility aids may require extra assistance

when carrying things, or getting up and down stairs. Offer to help but always

remember to ask before helping any customer.

It is important to make sure crutches and walking sticks are safely out of the way, but

never move a customer's belongings without their knowledge and consent.

9.3 Vision

Around 357,000 people in Australia are blind or have a vision impairment that cannot be

corrected by glasses. Most of these customers have some vision, but it may be cloudy,

distorted or blurred. Only a very small percentage of people who are considered legally blind

have no vision at all.

People who are blind or have low vision may use a cane or a guide dog to help them to

navigate and may also use “Assistive Technology” to access information.

Ways you can help

Introduce yourself and your role when you approach and ask how you may help.

A person with a guide dog may want their guide dog to follow you. If that's the case,

walk normally.

If the customer wants you to guide them, offer them your elbow for them to hold onto.

Don't take their arm.

Describe the layout of the area for the customer, particularly any obstacles such as

stairs or displays. Be specific. ie. “The desk is one metre in front of you.”

Check the customer has taken all their possessions with them when they leave.

You may need to read out small print to the customer.

Make sure the signage for entries, exits and toilets is clear and illuminated where

possible.

Avoid

Assuming that the customer may need your help.

Patting a guide dog or other assistance animal, or distracting it with food.

Walking away without letting the customer know you're leaving.

Crossing the customer's path of travel - they might not be able to see where you are

going.

9.4 Hearing

People who are deaf or hard of hearing may use a hearing aid, may lip read or may use sign

language to communicate. It is estimated that over three million people in Australia have

some kind of hearing impairment. A small percentage of people who are deaf use AUSLAN

97

(Australian Sign Language) and may need an AUSLAN interpreter to assist them in

conversation.

“Assistive Technology” such as hearing aids, hearing loops or FM systems may help some

people who are hard of hearing to participate in conversations more effectively.

“Sometimes I have to tell shop assistants that I'm deaf and need a pen and paper to

communicate. It's great when they take the time to support me.”

Some people who are deaf or hard of hearing may be accompanied by a hearing dog. You

should treat the dog the same as you would any other assistance animal, and don't pat or

distract it in any way.

Some customers who are deaf or are hard of hearing may also have a speech impairment,

may not speak as clearly as other people, or may not speak at all.

Ways you can help

Get the customer's attention by moving into their line of sight or gently touching them

on the shoulder or elbow.

Make sure you are facing the customer when you speak.

Use their name first, if you know it.

98

Speak directly to the customer when they are accompanied by an interpreter.

Ask how you can help the customer. They may be happy to lip read, or they may

prefer you to write information down.

Move to an area that is hearing loop enabled if the customer has indicated that this

will assist.

Suggest moving to a more private area if sensitive or personal information needs to

be discussed.

Check that the customer understands you and make sure you understand what the

customer is saying to you.

Avoid

Speaking louder than normal to try and make a difference.

Over-exaggerating hand gestures or speaking extra slowly.

Covering your mouth when talking to the customer.

Continuing to talk when you turn away from the customer.

9.5 Communication58

There are many disability types that can affect person's ability to read, write, speak or

understand information. You may have customers at your business who have difficulty

communicating what they want to say, for example, their speech might be difficult to

understand. You may have customers who find reading or writing difficult, for example,

someone with an intellectual disability. Other customers may have trouble understanding

what you say.

There are many ways you can make your business welcoming to customers who have

communication difficulties. Firstly, remember there are many different ways to communicate.

It’s ok to ask how a person likes to communicate. Secondly, consider having communication

tools available at your business. A picture board at the reception counter is a great start.

Finally, and most importantly, be welcoming and friendly to all customers and don’t make

assumptions about a person’s ability.

Your business can be awarded the Communication Access Symbol® and become

recognised as a retail space that provides excellent customer service to all customers,

including those with communication difficulties.

Ways you can help all customers with communication difficulties

Be welcoming and friendly.

Approach the customer as you would any other customer.

Treat the customer with dignity and respect.

Know there are different ways to communicate.

Ask the customer what will help with communication.

58 Scope Australia kindly provided the suggestions and content in the Communication section. Scope can be contacted through their website http://www.scopeaust.org.au/contact/ or on 1300 4 72673

99

Be willing to use the customer’s method of communicating.

Speak directly to the primary customer, not the person with them.

Don’t assume that the customer doesn't understand the information simply because

they have difficulty speaking, reading or writing.

Don’t patronise or talk down to the customer.

Ways you can help if a customer is having difficulty getting their message across

Find a quiet place.

Listen carefully

Don’t pretend to understand.

Be patient - give the person time to respond.

When you can’t understand the person, let them know you are having difficulty.

If you are having difficulty understanding - try asking questions so the person can

answer yes or no.

Ask the person to repeat or try another way if you don’t understand.

Check back that you have understood correctly.

Don’t finish the customer’s sentences or interrupt what they are saying.

Ways you can help if a customer is having difficulty understanding what you are

saying

Be patient and positive.

Take time to explain things.

Use simple language.

Communicate one idea at a time.

Be as clear, concise and concrete as possible.

Give specific choices rather than open ended questions.

Speak directly to the person and make eye contact (there are some people who may

not want you to look at them, e.g. some people with autism spectrum disorder).

Speak normally. You don’t have to raise your voice or slow your speech.

Ways you can help customers who have difficulty understanding written information

Use plain English in written material.

Offer information in alternative formats such as Easy English, large print, audio,

electronic or braille.

Have picture based resources at your business or service, e.g. a picture based menu

or a picture based communication board.

Different ways of communicating

There are many different ways to communicate, other than oral speech. Customers with

speech or language problems might rely on methods to tell you what they want, for example:

Natural gesture or pointing.

Paper and pen.

Keyword sign.

Word or picture communication books.

100

Electronic speech generating devices.

You might want to have resources available at your business or service to help customers

who have difficulty with speaking or understanding. Tools you might consider are

Picture or photo based communication boards.

Spelling boards.

Picture based menus.

Picture board courtesy of Scope Australia

101

Spelling board courtesy of Scope Australia

The Communication Access Symbol

There is now a symbol that informs members of the public that the business or service is

communication accessible. The Communication Access Symbol® was launched in 2011,

and in 2012 an international copyright process began leading to the symbol being registered

as an Australian Trade Mark in 2014.

102

To be awarded the Communication Access Symbol®, key points where customers make

contact with the business are assessed, such as front reception desks, service counters, and

call centres. Trained communication access assessors, who are people with communication

difficulties, use a checklist to determine if a place meets the standards to be awarded the

Communication Access Symbol. The criteria assessed include:

Staff customer service skills.

Display and information about products and services.

The communication environment.

Signage and wayfinding.

Currently, the Communication Access Symbol® has been awarded to over 200 businesses

and services in Victoria, across eight sectors, including retail and hospitality, local

government, transport, health, recreation, leisure and sport, arts and culture, libraries,

tourism, banking and state government services such as the Victorian Electoral Commission

(VEC), the Victorian Equal Opportunity and Human Rights Commission (VEOHRC) and

Public Transport Victoria (PTV).

10 Providing Feedback

The Design for Dignity Guidelines are intended to be an ‘open source’ document. We

welcome feedback and suggestions and the Guidelines will evolve over time. Visit The

Design for Dignity blog to keep updated.

103

11 Disclaimer

Thess are non-mandatory guidelines designed to assist in making retail environments more

accessible and inclusive for people with disability. However, neither Lendlease,

Commonwealth Bank of Australia, Australian Network on Disability and Design for Dignity

Pty Ltd nor the groups which have endorsed or been involved in the development of the

guidelines, accept any responsibility for the use of the information contained in the

guidelines and make no guarantee that the information is an exhaustive treatment of the

subject. Indeed, the focus is to raise awareness, create discussion and create new solutions

for greater inclusion. Users are required to exercise their own skill and care with respect to

its use and should and should obtain appropriate professional advice relevant to their

particular circumstances. The guidelines do not guarantee compliance with Discrimination or

other laws, the Building Code of Australia or other regulations or codes.

12 References

ACCAN http://accan.org.au/our-work/media-releases/710-telstra-to-kill-captcha-

accan-calls-on-others-to-follow. Viewed September 2016

Australian Human Rights Commission https://www.humanrights.gov.au/frequently-

asked-questions-access-premises. Viewed September 2016

Australian Human Rights Commission

https://www.humanrights.gov.au/complaints/conciliation-register Viewed September

2016Viewed September 2016.

Australian Bureau of Statistics, Survey of Ageing Disability and Carers (2012).

Australian Bureau of Statistics, Survey of Ageing Disability and Carers (2015).

Australian Network on Disability, Beyond Recruitment Guide.

Australian Network on Disability, Welcoming Customers with Disability Guide.

Australian Standard AS1428.1 Design for access and mobility: General requirements

for access – New building work.

Australian Standard AS 1428.2 Enhanced and additional requirements for access –

building and facilities (Only in Public Transport buildings).

Australian Standard AS/NZS 1428.4.1 Means to assist the orientation of people with

vision impairment – Tactile ground surface indicators

Australian Standard AS 1735.12 Lifts, Escalators and Moving Walkways.

Australian Standard AS/NZS 2890 Part 6 Parking Facilities.

Australian Standard AS 1428.2 Enhanced and additional requirements for access –

building and facilities (Non-public transport buildings).

Australian Standard AS 1428.3 Requirements for children and adolescents with

physical disabilities (Obsolescent).

Australian Standard AS 1428 4.2 Wayfinding (Draft).

104

Australian Standard AS 1428.5 Communication for people who are deaf or hard of

hearing.

Australian Standard AS 3745-2010/Amdt 1-2014 Planning for emergencies in

facilities.

Baker, S. M., 2006 Consumer Normalcy: Understanding the value of shopping through narratives of consumers with visual impairments. Journal of Retailing, 82 (1)pps 37-50.

Barclays Bank http://ask.barclays.co.uk/branchfinder/ Viewed September 2016Viewed September 2016.

Barclays https://www.barclays.co.uk/Accessibility/AccessiblecommunicationsAccessibilityHelpandInformation/P1242657780139 Viewed September 2016.

Bestaven, E, Guillaud, E, Cazalets, J, 2012, Is “Circling” Behaviour in Humans Related to Postural Asymmetry, Universite de Bordeaux, PLOS One 7(9)

Contact Centres & Telemarketing Council, Guidelines for call centres dealing with vulnerable consumers, 2012, viewed at http://dma.org.uk/uploads/call-centres-vulnerable-consumers_final_53d7c237289c1.pdf Viewed September 2016.

Apelt, R. and Crawford, J. and Hogan, David J. (2007) Wayfinding Design Guidelines. CRC for Construction Innovation, Brisbane Viewed at http://digitalcollections.qut.edu.au/1719/ Viewed September 2016DeafSpace design http://www.gallaudet.edu/campus-design/deafspace.html Viewed September 2016.

Dever, E., Sertysesilisik, B. and Rostron, J., 2009, The refurbishment of small-scale retail premises in relation to the Disability Discrimination Act 1995, Journal or Retail and Leisure Property

Disability Standards for Accessible Public Transport, 2010, Federal Register of Legislative Instruments.

Disability (Access to Premises – Buildings) Standard 2010, Federal Register of Legislative Instruments.

Explanatory Statement — Disability (Access to Premises—Buildings) Standards 2010.

Goodrich, K. and Ramsey, R., 2012, Are people with disability receiving the services they need? Journal of Retailing and Consumer Services

Goss, S, 2003, Putting the Disability Discrimination Act into perspective. Journal of Retail & Leisure Property.

Inclusive Design Toolkit http://www.inclusivedesigntoolkit.com/betterdesign2/ Viewed September 2016.

Kalargyrou, V., Volis, A. A., 2014, Disability inclusion initiatives in the hospitality industry: an exploratory study of industry leaders., Journal of Human Resources in Hospitality & Tourism, Vol. 13, No. 4, pp. 430-454.

Khattab, D., 2015, Rethinking the grocery store: inclusive wayfinding system for visually impaired shoppers in Grocery stores, Journal of Accessibility and Design for All, Canada.

NSW Department of Planning guidance for local councils regarding SEPP Seniors Living 2004 - Housing for Seniors or People with a Disability.

Ofcom http://consumers.ofcom.org.uk/ofcom-for-business-consumers/help-for-disabled-business-customers/disabled-customers-and-call-centres/ Viewed September 2016.

Privacy https://www.oaic.gov.au/agencies-and-organisations/faqs-for-agencies-orgs/businesses/will-businesses-service-providers-or-government-agencies-be-

105

breaching-the-privacy-act-by-providing-information-to-customers-through-the-nat Viewed September 2016.

Scales, I. 1997, Consultation and People with a Disability, Disability Council of NSW.

Scope Australia http://www.scopeaust.org.au/how-can-i-communicate-at-the-national-disability-insurance-scheme-ndis/ Viewed September 2016.

Telstra https://www.telstra.com.au/aboutus/community-environment/community-programs/disability/disability-action-plan Viewed September 2016.

UN Convention on the Rights of Persons with Disability.

W3C http://www.w3.org/ Viewed September 2016.

Wayfindr https://www.wayfindr.net/ Viewed at June 2016.

Wilson, L., 2016, Evacuation of People with Disability & Emergent Limitations: Considerations for Safer Buildings & Efficient Evacuations, 2nd Edition https://accessibleexitsigns.com/evacuation-guide/ viewed September 2016

Wimpy Burger Promotional Video: https://www.youtube.com/watch?v=5YAchE0-o-o Viewed September 2016.

Yu, H., Tullio-Pow, S., Akhtar, 2015, A., Retail design and the visually impaired: A needs assessment, Journal of Retailing and Consumer Services.

106

13 Appendix

13.1 Obligations summary

Jurisdiction Responsibility

International

UN Convention on the Rights of Persons with Disabilities (2008). o Australia is a signatory along with 157 other countries. o Doesn’t impose obligations on Australian business except to the

extent that businesses choose to, or it is picked up in Australian Legislation such as the DDA.

Federal Government

Disability Discrimination Act 1992. o Prohibits discrimination against people with disability with specific

comments on premises, provision of goods and services and a range of other matters.

o Allows the government to set ‘disability standards’. These have been on Premises, Transport and Education.

Disability (Access to Premises – Buildings) Standards 2010. o “Premises Standards.” o Covers building access requirements for people with disability. o Applies to new buildings and approvals after 1 May 2011 o Existing buildings that are have not had a building approval for

renovations or works are still subject to the DDA. o Makes mandatory certain Australian Standards. o Makes some concessions that are not in the Building Code of

Australia. o Complying with the Premises Standards provides protection against

discrimination claims in the area that is compliant.

Disability Standards for Accessible Public Transport, 2010 o “Transport Standards.” o Requires that transport premises and associated infrastructure as

well as ‘conveyances’ (buses, trains, aircraft etc) are accessible, to what standard and over what time frames.

o References and makes mandatory certain Australian Standards o Effective from 23 October 2002. o Complying with the Transport Standards provides protection against

discrimination claims in the area that is compliant.

State and Territory Governments

Building Code of Australia (2016). o Aligns to Premises Standards from 1 May 2011. o Whilst it is the Build Code ‘of Australia’ it is actually empowered by

State and Territory legislation. o Mandates a range of Australian Standards which provide detailed

technical advice. o Performance based systems which means that it sets high level

guidance and allows compliance through meeting specified standards or providing ‘performance solutions.’

Anti-Discrimination Acts. o Australian Capital Territory - Discrimination Act (1991). o New South Wales - NSW Anti-Discrimination Act (1977). o Northern Territory - Anti-Discrimination Act (2011). o Queensland - Anti-Discrimination Act (1991). o South Australia - SA Equal Opportunity Act (1984).

107

Jurisdiction Responsibility

o Tasmania - Anti-Discrimination Act (1998). o Victoria - Victorian Equal Opportunity Act (2010). o Western Australia - Western Australia Equal Opportunity Act

(1984).

Various State Legislation and Regulation (Too many to list).

New South Wales

o Environmental Planning and Assessment Act 1979 No 203. o State Environmental Planning Policy (Housing for Seniors or People

with a Disability) 2004. o Heritage Act 1977.

Victoria

o Planning and Environment Act 1987. o Building Act 1993. o Environment Effects Act 1978. o Heritage Act 1995.

Australian Standards

• AS1428.1 Design for access and mobility: General requirements for access – New building work.

• AS 1428.2 Enhanced and additional requirements for access – building and facilities (Only in Public Transport buildings).

• AS/NZS 1428.4.1 Tactile Indicators. • AS 1735.12 Lifts, Escalators and Moving Walkways. • AS/NZS 2890 Part 6 Parking Facilities.

Local Government

These are also many and varied but include things like:

Local planning policies and guidelines.

Footpath dining / trading licensing and policies.

Regulations on use of A Frame boards and advertising.

13.2 Accessible Toilets

Key retail requirements

AS 1428.1 has extensive detail on the design of accessible toilets. A summary of key points

is provided below:

General

Water taps have lever handles, sensor plates or similar.

Lever handle has >50mm clearance to surface for easy grip with operable parts of

the lever within 300mm from the front of the basin.

Hot on Left, Cold on Right OR Hot on Top, Cold on Bottom.

If hot water provided water comes from mixed spout.

Top of toilet seat to ground 460-480mm.

Front of toilet bowl to back wall 790mm - 810mm.

108

Centre of toilet bowl to side wall 450mm to 460mm.

Seat not open fronted.

Load certified 150kg.

Seat contrast 30% luminance contrast to wall/ floor.

Lid remains upright when raised.

Have a backrest with load capability of 1100N.

Backrest width 350 to 400mm.

Backrest height 120 to 150mm from seat.

Flushing control (back) in zone height 600 to 1100, width 500mm from centre of toilet

to non-wall side.

Flushing control (side) in zone height 600 to 1100, width centred on 300mm either

side of toilet front.

Toilet paper holder 700mm from floor and not further than 300mm forward of toilet

front.

Grab rails behind and to the side at a height 900 to 1100mm and rising in front to

assist person rising.

Doors can be hinged or sliding but must be easy to open (less than 20 Newtons).

In use indicator / privacy latch with a bolt or catch and easy to grip snib which is at

least 45mm from the centre of the spindle .

Washbasins

Wash basin to be provided at 800 to 830mm from floor.

Room underneath for footplate and knee clearance.

Fixtures and fittings

Mirror width >350mm. Height <900mm from floor and to >1850mm above floor.

Shelf adjacent to washbasin as part of vanity or separate fixture.

Soap, paper dispensers etc. 900 to 1100mm, one hand operation.

Clothes hanging device located between 1200 to 1350mm from floor.

Sanitary unit placed on wall side of toilet (as people use the other side to transfer

from the wheelchair).

Showers (summary)

Two or more clothes hanging devices.

Self-draining, no kerbs or hobs.

Grab rails.

Shower head on flexi hose.

Circulation spaces

109

2300 x 1900mm clear space.

Signage

Full signage specifications in the AS1428.1..

13.3 Mobility scooter case study

The ABS, Survey of Ageing Disability and Carers report of 2012 states that there are 42,000

motorised scooter users in Australia. The current Australian Standard minimum turning

spaces specifically exclude mobility scooters in their considerations.

The minimum standards (AS 1428.1) state that space that should be allowed for person

using a wheelchair to turn their wheelchair around is 2070mm by 1540mm. This is based on

the assumption that 80 percent of wheelchairs have a footprint of 1250mm by 740mm

(including the person) and that 90 percent of wheelchairs have a footprint of 1300mm by

800mm. This allows someone 10cm of space to turn around on each side.

The ‘enhanced standard’ AS 1428.2 suggested a larger turning circle of 2250mm by

2250mm. This allows more space for people to turn around. This is much more dignified

than a “ten-point turn” when trying to change direction.

What does that mean for retailers?

We saw earlier that in 2012 there were 42,000 mobility scooters in Australia compared to

164,000 wheelchairs (manual and electric). The hidden wave of customers in these statistics

is the 310,000 walking stick or crutch users and 275,000 walking frame users. It is entirely

possible that the growth in mobility scooters in coming years will be significant.

Mobility Scooters come in a vast range of styles but cannot achieve the same “turn on the

spot” performance of most manual wheelchairs. As a result, the turning circles are much

larger. Larger mobility scooters cannot even turn in the ‘enhanced standard’ circulation

space.

Mobility scooter use has already started to create issues as users come into contact with

retail and hospitality venues that are not built to cope with their size or lack of

manoeuvrability. The Australian Human Rights Commission59 and the RSL & Services Clubs

Association Limited NSW produced a paper outlining the rights and obligations of hotels as

well as scooter users as a result of the difficulties many hotels and users were having with

access. The guidance is not binding but provides some useful insights for clubs on how to

better accommodate patrons with mobility scooters including signage, parking, and providing

clear space around fixtures and fittings. The paper mostly pushes responsibility back onto

mobility scooter manufacturers rather than suggesting that design standards could be better.

59 https://www.humanrights.gov.au/our-work/disability-rights/projects/mobility-scooters-registered-clubs Viewed September 2016

110

“It would also be in the interests of all manufacturers and retailers of scooters to alert

purchasers to the restrictions on the use of scooters on public transport and in public

buildings.”