Congratulations to everyone who submitted feedback, during the discovery phase of the Disability (Access to Premises – Building) Standards review, about the difficulties that people living with environmental sensitivities have in accessing public buildings. It paid off – we’ve been heard!
The outcome of the discovery phase, which concluded on 30 November 2020, is a consultation paper that draws on the findings of the initial stage of the review. This paper asks for more detailed feedback.
Environmental sensitivities have been included as one of the seven themes identified in the consultation paper.
The Premises Standards review consultation paper defines environmental sensitivities as ‘Adverse effects or chronic condition whereby a person has symptoms when exposed to low level of chemical or other environmental and communication agents, such as Wi-Fi, in the built environment’.
Appendix A (p. 20) of the consultation paper provides a graphical representation of the seven key themes: it shows that environmental sensitivities were discussed by ten per cent of submissions in the discovery phase. According to a more detailed breakdown on p. 23, which identifies sub-themes, electromagnetic hypersensitivity led the way at 5.3%, followed by cognitive disability (2.9%) and multiple chemical sensitivity (1.3%).
The Premises Standards team is now asking for feedback on the consultation paper. This is due by 16 April 2021.
We need to identify changes in order to improve the Premises Standards! This will assist the team to write a report by mid-2021 for the Australian Government.
As pointed out in SSMA’s post on the initial phase of the Premises Standards review, the existing Premises Standards make NO provision for people who are electrically sensitive. They also make no allowance for people who have multiple chemical sensitivity, which often goes hand-in-hand with electrical sensitivity.
This means that the National Construction Code, which contains these standards, fails to take into account the needs of people living with these conditions.
There is currently no requirement for public buildings to provide safe access for people living with environmental sensitivities – despite Australia having a Disability Discrimination Act which provides a very broad definition of disability.
We need to ensure that the Premises Standards provide people living with electromagnetic hypersensitivity dignified, equitable, cost-effective and reasonably achievable access to public buildings. We also need to make sure that people working within the building industry have a clear understanding of their legal obligations in this regard.
Again, the Premises Standards team has made it easy for everyone to participate in this review. It’s up to you if you want to take an online survey, upload a written submission, video or audio, talk to the team on the phone, send your feedback by email or mail. You can choose to make your submission confidential.
The consultation paper asks you to consider questions about each of the themes that have been identified, but you are welcome to only provide input on your preferred topics – even if these haven’t been included in the scope. Three of the questions are specific to the environmental sensitivities theme. Please provide examples of issues that you have encountered and give possible solutions that might be addressed through better design and construction of public buildings. Let’s work towards making our schools, libraries, hospitals, auditoriums, holiday accommodation and other buildings that fall within the ambit of the Premises Standards accessible to all people living with disability!
To find out more and participate in the Premises Standards review, go to the consultation hub at: https://consult.industry.gov.au/premises-standards-review-team/2020-premises-standards-review-consultation-paper/.
If you would like to view the Disability (Access to Premises – Buildings) Standards 2010, which are currently in force, go here.