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Well that was a result. Now, perhaps, the disability apparatchiks can look at more practical matters
Under the Railways Act 2000, responsibility for passenger representation passed from the Office of the Rail Regulator to the Strategic Rail Authority. Among the responsibilities handed over was disability provision, including the new Code of Practice which the ORR had been drafting.
Now the SRA was a touch inexperienced when it came to dealing with disability provision in trains. Its managers didn't appreciate that the nice men and women who welcomed them to meetings of the various disability bodies make Dolores Ibarruri look like an arch appeaser.
And when the SRA published its draft for consultation it was clear that someone had taken to the cleaners. In the July 2001 Modern Railways this column highlighted a number of concerns among the train operating companies and Rolling Stock Companies about the Code's proposed requirements on refurbishment, in particular, where the ultimate aim is for refurbished stock to be made fully Rail Vehicle Accessibility Regulations (RVAR) compliant.
This was reflected in the draft Code, with the SRA proposing that train operators would have to give ‘a minimum' 18 months notice of enhancements to be included under C6 or C6X heavy maintenance programmes to make the vehicles RVAR compliant. Ditto any refurbishment under franchise commitments.
On top of this, under a two stage process, any facilities for disabled passengers which were to be introduced or improved during refurbishment, would first have had to be discussed with the Disabled Passengers Transport Advisory Committee (DPTAC). Then, details of proposed disability provisions (or requests for dispensation) would have had to have been notified formally to both the SRA and DPTAC.
Following consultation, the SRA would then have advised the operator whether or not the proposed changes were acceptable. Simple changes, such as colour contrasts on doors, seat covers and handrails to meet RVAR standards would have been mandatory during C6/C6X programmes. However for minor maintenance schemes such changes would be subject to ‘reasonable practicality'.
Well, as remarked before, it is not the job of special interest bodies to be reasonable or concerned with practicality. As they see it, the people they claim to represent have their rights and it is the duty of the evil money grubbing railways to see the error of their ways and comply.
It is difficult for well meaning railwaymen to stand up to such moral aggression. But if they don't the special purpose groups, quite legitimately, will just up the ante. Note that another stated long term aim is an end date by which non-RVAR complaint rolling stock must be withdrawn.
But while the SRA may not have been streetwise, the ROSCOs were and, among other things, encouraged this column to expose the consequences of the more extreme demands. A classic example was the demand that doors on refurbished stock complied fully with the Rail Vehicle Accessibility Regulations.
One of the RVAR requirements is for a 3 sec pause between the doors close chime sounding and the doors starting to close. Whereas it is relatively easy to fit RVAR compliant control buttons during refurbishment, adding the 3 sec delay would involve hacking into safety critical wiring and logic.
Back in July 2001 I quoted the cost of fitting RVAR compliant buttons to the 32 doors on a four car class 31X at £17,000 – no argument. Adding the 3 sec delay would cost a further £80,000 for a ‘nice to have' rather than a ‘must have'.
Having demonstrated the unreasonable cost, the ROSCOs followed up with a practical reality check. Representatives from the various disability organisations were invited to Bounds Green Depot, shown a Mk 4 coach and provided tape measures so that variations from the RVAR could be checked and the problems appreciated.
And, when Train and station services for disabled passenger – A Code of Practice was published in February, it was clear that the forces of reason had won on the refurbishment issue. And won the argument convincingly.
While the list of refurbishment work which should be required to meet RVAR remains, a disclaimer in bold type now reads ‘This list is not designed to capture the mileage based maintenance regimes or the time based heavy overhauls in existing leases. On the other hand processes such as colour contrasting on the exterior ad interior of carriages are always expected to meet the standards set out in the RVAR'.
Also dumped was direct involvement of the train owner or operator with DPTAC in initial consultation. Instead, where changes not covered by the list are contemplated , the operator must consult with the SRA.
And the 18 months advance warning, which would have delayed the introduction of benefits for the very disabled travellers the Code is meant to help has disappeared too. Applications for dispensations must be made ‘in good time and before finalising designs, arranging finance or construction has started'.
This is a tad disingenuous. Until you do the design work, the cost of retrofitting disability provision will not be known. However, engineering is all about understanding orders of magnitude and all should be well provided that you can show the SRA calculations similar to that done for the 3min door delay.
Where dispensations are sought the SRA will consult with DPTAC, but only ‘where appropriate'. A point to note here is that rolling stock leases are coming up to termination, so any ‘marginally unreasonable' work could be funded through rentals in new contracts for existing pre December 1999 kit and reflected in subsidies.
Refurbishment thesaurusCounting as ‘refurbishment' for vehicles brought into use before January 1 1999 Replacement Renewal Renovation Significant alteration Facelifted Enhanced Refurbished |
Covered by refurbishmentExterior paint External doors and/or door controls External steps Flooring Seating (including mounts and frames) Interior transparent surfaces Handrails/hand-holds Audio/visual passenger information system Toilets Existing wheelchair spaces Sleeping accommodation Tables External and interior doorways which must be used to gain access to wheelchair spaces and wheelchair accessible facilities Telephones |
Spot the difference
‘In exceptional cases the Authority may decide that it is impractical or unreasonable for a passenger train operator to comply with RVAR standards …….' Draft Code of Practice April 2001
‘The Authority may decide that it is impractical or unreasonable for a passenger train operator to comply with RVAR standards …….' Published Code of Practice February 2002 |
Naturally, some anomalies got through into the published Code. One, in particular could cause problems for both the refurbishment and procurement of inner suburban trains – such as the Connex Metro described above. It applies to operators leasing trains that do not have toilets, or have toilets that are not accessible by disabled people
In such cases, says the Code, the operator ‘must' consider the provision of accessible toilets ‘if any part of the passenger environment is refurbished'. Should an operator decide not to provide accessible toilets, the SRA must be provided with reasons for non-provision. If accessible toilets cannot be fitted to a fleet, the operator is not allowed to remove the existing facilities.
This requirement appears to be aimed at inner suburban commuter fleets, such as the Class 313 and Class 455, which were not fitted with toilets when built. Technically, it is a non starter. Can you imagine the cost of hacking around a 313, even if you could find room for roof mounted water tanks and the underfloor effluent retention tanks?
Commercially, fitting an accessible toilet in such unit would also remove 20% of passenger accommodation in the vehicle affected, just when the demand on operators is to provide more capacity. It only goes to show that the Abilene Paradox is alive and well and living in 55 Victoria Street .
As a condition of their licence, operators are required to have due regard to the Code when providing facilities and services for passengers with disabilities. All train and station operators are also required to have Disabled Person's Protection Policies (DPPP). These will be reviewed and aligned with the requirements in the Code.
Revised DPPPs will have to state that they fully endorse and are committed to adopting the ‘services, standards and guidance in the Code'. The SRA will use the revised DPPPs to monitor progress on these commitments.
When Part III of the Disability Discrimination Act 1995 comes into effect from October 1 2004 all stations will have to be accessible. Part III requires any physical feature that makes it ‘impossible or unreasonably difficult' for disabled people to use a station, to be removed, altered or a reasonable means of avoiding it provided.
Railtrack and the Association of Train Operating Companies will be working together on working out how guidelines can be implemented. ‘Further discussions on how the guidelines in the Code of Practice will be funded' are promised.
Quite so. When I asked the SRA for their estimate of the likely cost of implementing the Code and DDA Part III, I was told ‘hundreds of millions'.
How many hundreds will depend, in part, on the SRA. since it will be responsible for applying the test of ‘reasonableness', to applications for exemptions to the requirements of the Code after DDA Part III comes into effect.
Roger's disability Rant
It is now just over two years since I pointed out to the Head of what was then the DETR's Disability Unit that GNER's all over blue coaches were a flagrant contravention of the requirement in the RVAR for doors to be painted a contrasting colour. She clearly thought it was a joke, commenting ‘how nice to see Modern Railways more draconian than us'. GNER's original trains and re-liveried Eurostars still run around in stealth blue, disadvantaging some of the 1.97million people in the country with impaired vision. Clearly Christopher Garnett has a blind spot when it comes to customer care. Having got absolutely nowhere with something simple like painting doors, let's see if that scourge of train builders, my feisty chum Bert Massie, can do something about ticket vending machines (TVM). Mr Massie is Chairman of the Disability Rights Commission and also the chair of DPTAC's Rail Exemption working Group.
Real goLast August he had a real go at the iniquities of the TOCs and train builders. He was quoted as saying that since the introduction or the RVAR ‘we have been reasonable for two years and tried to understand operators' and manufacturers' difficulties' In the early days of the regulations the committee weighed delay against pragmatism. ‘A train that was not quite accessible – if the outside (door warning) noise level was not quite right, was better than nothing at all'. Subsequently, there had been cases ‘where we believe that the TOCs have not been rigorous … disabled access doesn't get the same priority as safety modifications' Given that most exemptions for new stock covered detail that Mr Ramsbottom would have called ‘piddlin' and small', I reckon fitting TPWS probably does come ahead of having external speakers for the doors closing chime or door buttons which are not 30mm too high.
Quickfare quagmireNow Bert Massie knows whereof he speaks, because he is a wheelchair user who travels extensively by rail. So why, instead of straining at the train builders' motes, is he not fulminating against the socking great RSJ being dumped on stations throughout the SouthEast
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Accessible ticket machinesFor automatic ticket vending machines to be physically accessible to all passengers, none of the operating parts or the coin slot must be higher than 1200mm or lower than 700mm from the ground. Operating buttons must be at least 20mm in diameter and must protrude sufficiently to be used by those who rely upon palm pressure. Extracts from Technical Note 71 SRA Code of Practice |
Back in 1997 at the ATOC Ticketing Fare, Rail Settlement Plan unveiled an upgrade (sic) of the well established Ascom Quickfare TVM dating back to Network SouthEast. Photo 1 shows the original withg its two sets of buttons, the green block for destinations, the yellow column for ticket type.
Ergonomic it was not. Nor was it disability friendly because the amount-to-pay screen was at standing eye level with the coin slot just below. It did not take credit cards.
Photo 2 shows the upgrade (huh) launched in 1997. It now has a screen in place of the buttons and takes credit cards. It has PC hardware running under Windows software (pshaw). Note that it is not a touch screen. The five buttons on each side of the screen point to text boxes on the display.
This configuration is not intuitive, well not to me. The modified Quickfare takes 45 seconds to issue a ticket and give change, compared with 35 seconds for the old version. It seems to be less reliable. There are three machines at Finsbury Park station. One day recently one was out of change, one was dead and one was showing a Windows fault message on the screen.
When I moaned about the weired screen/button concept in 1997, I was told it was an age thing. So when one arrived at my local station (Photo 3) I was enormously encouraged when I had to coach young people as well as the odd senior on how to use the infernal engine so that I could get to it myself.
Unfortunately, travelling a deux, I encouraged Mrs F to buy the tickets and stood back timing the transaction, having warned her that it was not easy. Alas first time on the machine, she whizzed through the procedure twice, handed me the tickets and asked what my problem was. Hey ho.
Anyway, do you know what? No seems to have noticed that with DDA coming into force in 2004, RSP is equipping stations with these ticketing machines, modified to be even less compliant with the SRA's Code of Practice.
On the modified Slowfare, the lowest button beside the screen is 1400mm above the ground and the highest 1500mm. The Code say 1200mm max. The coin slot and card reader are both 1500mm high. While I was at it, I measured the Permit to Travel machine. The coin slot is 1450mm above the ground.
And while the old version also non compliant, I suspect that using buttons available below the 1200mm ceiling you could buy a railcard and pay with a note.
All this, I contend, puts some of the nit picking over dimensions on first generation post privatisation trains into perspective. What does it take for the disability brigade to address these serious practical issues which I seem to have no trouble in identifying? Letters to Forum please.