FIA

The Disabilities Discrimination Act (DDA) reached the final phase of its implementation on 1st October 2004.

Introduced in 1995, the act places a responsibility on service providers to ensure that people with disabilities do not receive less favourable treatment than their able bodied counterparts. These responsibilities have been introduced in three stages:

Since 2nd December 1996 it has been unlawful for disabled people to be treated less favourably for reasons related to their disability.
Since 1st October 1999 service providers have had to make "reasonable adjustments" to accommodate disabled people, by providing extra help or making changes in the way services are provided.
From 1st October 2004, it has been necessary to make "other reasonable adjustments" to premises to overcome barriers to access.
The Act is policed by the Disability Rights Commission (DRC), which is an independent body that was established by an Act of Parliament in April 2000. The DRC helps disabled people to achieve their rights under the DDA and supports legal cases to test the limits of the law.

Since 1985 building regulations in England and Wales have required reasonable provisions to be made for disabled people to gain access and to use new buildings (and some extensions). Part M of the Building Regulations (Access and facilities for disabled people), was extended in 1992 and again in 1999. It now applies to: New buildings and ground floor extensions to existing buildings, but not the existing buildings themselves. The buildings to which Part M applies should make reasonable provision for access and use by disabled people. To this end Part M sets a series of objectives for building design, but they are not mandatory and alternative solutions, which may be more appropriate to the building, can be adopted.

As far as fire detection systems are concerned the only specific mention is the need to supplement audible alarms with visual signals, with Approved Document M stating:
4.24 Sleeping accommodation will satisfy Requirement M1 if:
e) all bedrooms have a visual fire alarm signal, in addition to the requirements of Part B
5.4 Sanitary Accommodation will satisfy Requirement M1 or M3 if:
g). any fire alarm emits a visual and audible signal to warn occupants with hearing or visual impairments;

(Note: M1 = Access and Use,
M2 = Access to Extensions to buildings other than Dwellings,
M3 = Sanitary Conveniences in Extensions to Buildings other than dwellings).
A further document which should also be referenced is BS 8300:2001 Design of buildings and their approaches to meet the needs of disabled people. Code of practice. This is based on the same foundations as Approved document M, and says:

Consideration should be given to the installation of alarm/alerting systems for people with impaired hearing, such as flashing beacons and vibrating devices, for use in conjunction with proprietary or conventional systems.
Note 1 these devices can take the form of wearable paging units, pillow vibrating units or under mattress pads designed to wake a person from sleep.
Note 2 Certain frequencies in flashing/stroboscopic light systems can cause confusion, disorientation, and in some people epileptic fits.
The standard goes on to specifically recommend that the fire alarm systems should be both visual and audible in kitchens, sanitary facilities and bedrooms.

This appears to be straightforward advice, but there are several issues which need to be addressed. The first is an understanding of what is meant by "reasonable".

The DDA is about making "reasonable" adjustments to buildings and what may be reasonable for one organisation may not be reasonable for another. It would not be reasonable, for example, to expect a small guesthouse to carry out similar works to a major hotel chain. Assessments of reasonable changes are to be based on many factors such as the service providers' resources, work that has already been completed and disruption that would be caused to the business itself. This is only likely to achieve some level of resolution once test cases have been through the courts.

The second issue is the engineering of beacons into alarm systems. Approved document M and The DDA itself require audible and visual alarms in bedrooms. Beacons of the xenon variety have never been popular with system designers due to their relatively high power consumption and in most cases the high surge currents they take from the power supply. These characteristics have made addressable versions all but impossible to create so generally they have to be driven via powered interfaces. Even conventional systems can struggle with the unfriendly loads imposed by a number of xenon beacons operating together.

The past couple of years has offered an alternative solution. The arrival of LED beacons, which can match the performance of the lower powered xenon beacons at less than a tenth of the current, has permitted the option to have addressable sounders, beacons and combinations of the two.

Upgrading an alarm system with xenon beacons could require considerable rewiring, upgrading of power supplies and expense while the advent of LED products has allowed the addition of beacons to a system, in most cases, with little impact. In some instances existing sounders can merely be swapped for combined sounder / LED beacons with no impact to wiring or power supply capacity.

So the audible and visual alarm requirement of the DDA has been neatly solved with the new technology - or has it?

The third issue. The intent of putting beacons into sleeping accommodation was indeed to wake sleeping people. Comment from the BSI working group who created BS8300:

In essence the beacon alongside an alarm sounder is to alert and waken a person who is not sensitive to an audible warning.
This is necessary in an environment where it is unlikely that an audible signal or staff will alert a person who is hearing impaired.
The beacon light and its intermittent flashing should be sufficient to disturb a sleeping person.
While this clarifies the beacons purpose it raises further questions as to light output and positioning.

At this time the UK has no guidance on the use of beacons apart from the rather sparse information in BS5839-1:2002 Fire detection and alarm systems for buildings. Code of practice for system design, installation, commissioning and maintenance. Neither does there appear to be any other source of information in Europe. This is the problem that faced the BFPSA's task grouping when trying to offer some guidance to its members.

The only comparable legislation is the Americans with Disabilities Act (ADA) where beacons are used for similar purposes.

Research sponsored by the American Access Board and the Underwriters Laboratory (UL) found that in order to wake a sleeping person visual alarms needed to have an output of 110 candela. It also concluded that visual alarms are not the technology of choice for waking sleeping people.

The task group therefore, lacking any other information, decided that some of the basic ADA guidance would be adopted to satisfy the DDA requirements until such time that any other valid advice came to light or further research could be conducted..

BS 8300 suggests that other warning devices may be used such as vibrating devices for under pillow or under mattress use, or wearable vibrating pagers. The pillow or mattress vibrators are intended for use in bedrooms for sleeping people, whereas the portable paging units may be employed in other situations.

The prospect of using higher brightness xenon beacons could add considerable cost to fire alarm systems and perhaps require a rethink of system architecture to cater for the increased number of devices required and their greater power consumption.

While the above recommendations are progressing towards a useful document we still have to define where the beacons produce 15Cd /110Cd, it is possible to produce a beacon with this level of performance in one direction and yet be almost ineffective in others. A definition of polar output is also needed for correct application of the products.

A further issue is that there are no beacons currently on the UK market that are specifically designed for this purpose so the provision of beacons for these applications may have to rely on imported product. The added complication is that there is no European standard for measuring beacons although EN54-23 Fire detection and alarm devices - Visual alarms is currently in preparation, but may yet be some way off publication.

In reality there is presently no one single answer to alerting the hearing impaired, and no doubt "reasonable" solutions will encompass combinations of many types of alarm device. We have entered the period of enforcement, but the only recommendation for ways of deploying beacons for these applications comes as a guidance note from the BFPSA (To be published as Fact File 12) and here we have guidance without necessarily any suitable products to meet its aims.

If as one report recently estimated that 80% of premises were non-compliant then there will be plenty of opportunities for test cases to develop judgements.

While doubt exists there will be considerable differences in interpretation and the term "reasonable" will come to have inconsistent interpretation.

Bob Choppen
Member of BFPSA (British Fire Protection Systems Association) Marketing Committee