The Victorian Council of Social Service (VCOSS) welcomes this opportunity to provide input to the Australian Building Codes Board’s (ABCB) Accessible Housing Project. Introducing minimum accessibility standards in the National Construction Code (NCC) delivers long-term social and economic benefits. It provides technical certainty for builders and improves everyday Australians’ lives, including people with a disability, older people, and people with young children.
Minimum accessibility standards are a universally beneficial prevention measure, like seatbelts in cars, or pool fences in backyards. They open up homes for people facing access barriers, and reduce the personal and public costs of injuries, death, loneliness, social isolation, future modifications to the home, and forced relocation.
Minimum accessibility standards must be regulated to deliver appropriate homes for Australia’s ageing population. Failing to change the NCC now will affect millions of Australians for many years. The ABCB’s Regulation Impact Assessment (RIA) must account for all the benefits minimum accessibility standards deliver, not only the costs. Some of these benefits cannot be easily reduced to a dollar figure, but should not be rendered invisible.
Australia needs to adopt a framework like “8 80 Cities”: a city design concept that puts people first. Cities designed for 8-year olds and 80-year olds are suitable for everyone. Housing design should adopt this approach. We must start building “8 80 homes”. Light switch heights positioned for an 8-year old to use also benefit people using wheelchairs. Step-free home access and hobless showers assist 80-year olds as much as parents with young children, or people recovering from injuries.
VCOSS consulted our members to develop this submission. It recommends changes to achieve accessible housing. VCOSS looks forward to engaging with the ABCB on the Accessible Housing Project as it progresses.
- Recognise and assess all social and economic benefits of minimum accessibility standards
Make accessible housing normal
- Include minimum standards in the National Construction Code
- Make Option 3 – Gold the new minimum standard
- Make all performance requirements meet the Livable Housing Australia Gold standard
- Make intercoms in apartment buildings suitable for people with a vision impairment
- Investigate backyard access requirements
- Include basic fixtures and fittings as a performance requirement
- Cease assessing clearly inadequate options for access standards
VCOSS advocates that any RIA includes assessing all social benefits of introducing minimum accessibility standards, including:
- allowing Australians to stay in their home as they age and prevent injuries
- reducing government expenditure on health services and home modifications for people with a disability
- assisting carers and reducing their likelihood of injury
- limiting the effects of loneliness and increasing social inclusion and productivity
- making life easier for families with young children
The number of Australians aged 65 and over is projected to more than double by 2054-55 to over 7 million people. Both the number and proportion of Australians aged 85 and over will also grow rapidly. The Australian Government’s health expenditure is projected to more than double over the next 40 years.
Many older Australians report a desire to age in place: a policy goal of successive Australian governments. In-home care delivers lower aged care and healthcare costs and reduces the costs of moving to other accommodation. People remain included within their community and connected to family and friends.
There are two types of people in Australia: People who have a disability and people who don’t have one yet.
People’s homes have always been places for the provision and care of children, and will increasingly become places for the provision of care for adults. By 2050, over 3.5 million Australians will access aged care each year, with around eighty per cent of services delivered in the community, including in people’s homes.
People are more likely to have a disability as they age. Over half of people aged over 64 have a disability, and over 85 per cent of people aged over 89. Every Australian is likely to acquire a disability at some point in their lives, usually mobility-related. Every person in Australia benefits now, or in the future, from minimum accessibility standards and more accessible housing.
Falls are the costliest injury category among older people. In the United States, the total health care cost of a fall was almost $US 20,000 each year. The costs are substantial and increase with fall frequency and severity.
A third of individuals aged over 64 fall in any given year, and up to 20% of older people experience related injuries from a fall. Almost 100,000 people aged over 64 were seriously injured from falls in 2012–13. The number of people injured has likely increased in the past five years. Between half and three-quarters of falls experienced by older people occurred because of the design or setup of their home.
A person’s risk of falling is determined by a combination of mobility issues, risk-taking behaviour, and the physical environment. Home modifications can reduce the likelihood of falls. Minimum accessibility standards reduce the risk of falls and subsequent costs to the public health system. They also prevent or delay older people’s need to enter out-of-home care, and allow them to stay in their homes for longer. The ABCB should consider and quantify the benefits of ageing in place.
Almost 4.5 million Australians live with a disability and over one in five Australians with a disability require assistance getting around. People with disability are more likely to live in poverty. They are less likely to own their home, or be able to afford expensive alterations to existing homes.
People with a disability are often excluded from participating in community life by building design that stops them leaving own home and visiting other people’s homes. The current voluntary building regulatory framework places the financial burden of home modifications on people who have the least capacity to pay.
Australia ranks 21 out of 29 OECD countries in terms of labour force participation for people with a disability. On average, a person with a disability earn a gross weekly income of $465, less than half for a person without a disability ($950). Changes to accessible housing standards will help people with a disability engage in work.
Minimum access standards deliver savings to governments for home modification programs, including modifications funded by the NDIS. These should be considered and quantified in the RIA. The costs to individuals forced to live in dwellings that do not meet their accessibility needs should also be quantified.
Informal primary carers help older people every day. The majority of carers provide older people with help to get around and for self-care, including bathing and showering. These activities would be made considerably easier – and safer – in an appropriately designed home.
Inaccessible housing, particularly inaccessible bathrooms, increases injury risks for people caring for someone with an illness or a disability. Over two-thirds of carers have a physical injury. Step-free home access and hobless showers reduce the physical burden of carers and minimise injury risks.
Australia has approximately 2.7 million informal carers. Carers’ health and safety improves if accessible housing becomes commonplace. Benefits to carers, including impacts on the health system due to injuries and reduced productivity due to avoidable injuries that are sustained while providing care, should be considered in the RIA.
Loneliness impacts on a person’s health and wellbeing. One in four adults are lonely and lonely Australians have significantly worse physical and mental health status than connected Australians. Social isolation is linked to lower immune system functionality, higher risk of heart disease or stroke, and early death.  Loneliness limits a person’s engagement with society and work.
Increasing accessible housing stock is a step towards strengthening social inclusion and reducing loneliness. Accessible housing lets people live in a house that is close to friends, family, work, school, services and to participate in that community. People can choose to stay within their community as their families’ needs change because their house can be adapted to meet their needs. People don’t just live in their houses, they visit and stay with other people and have other people visit and stay with them.
Minimum accessibility standards improve social inclusion and reduce loneliness in Australia by:
- giving people independence of movement.
- removing barriers to exclusion from social participation and work
- letting people live and participate in the community with dignity.
- providing the opportunity for people to make a stronger economic contribution through work.
The ABCB should consider how minimum accessibility standards impact upon loneliness and social inclusion as part of the RIA.
In 2016, over 370,000 Victorians were children aged between 0 and 4 years. Universal housing features such as a step-free pathway and entrance to the home, and wider doorways and corridors, make it much easier for parents with small children to get in, out of and around the house.
Children are less likely to suffer tripping injuries in houses with level entrances and hobless showers. ABCB should consider the additional safety benefits that minimum accessibility standards will introduce for families with young children, including reducing risk of falls, emergency department visits and time spent in hospital.
Human experience cannot, and should not, always be distilled into a dollar figure. Quantifying human experience limits an understanding of people and their place in the world. It does a disservice to people who may be living with a disability, experiencing isolation or facing barriers to accessibility that impact upon their lives in complex ways.
Accessibility is not a niche benefit. It should not be considered as a “fix” to a problem experienced by a specific cohort of people. Every Australian will feel the positive effects of minimum housing standards, particularly as the population ages. If nothing is done to deliver minimum accessibility standards in housing now, society will bear the negative effects well into the future.
In 2009, the National Dialogue on Universal Housing Design, a group made up of government, building industry and community sector members, was established to deliver a voluntary approach to minimum accessibility standards for new homes. The National Dialogue agreed on an “aspirational target that all new homes will be of an agreed Universal Housing Design standard by 2020 with interim targets to be set within that 10-year period”.
The target was endorsed by the Council of Australian Governments (COAG) as a key commitment in the 2010-2020 National Disability Strategy. However, none of the interim targets have been met, and there has been no response to this failure by government or the housing industry.
Just five per cent of all housing stock in Australia is accessible. The voluntary inclusion of accessibility features has failed to deliver homes suitable for people with mobility issues.
Homebuyers rarely purchase for their future needs, or those of future occupants. “Aspirational targets”, as endorsed by COAG, have not worked. Australia needs a regulated approach. National Construction Code (NCC) amendments are the only way to deliver accessible houses and apartments.
A regulatory approach is the only solution to deliver accessible homes.
VCOSS believes minimum accessibility for newly built homes must become the ‘new normal.’ New homes are being built that a growing proportion of people can’t access. Like new cars having seatbelts, or swimming pools having fencing, regulation sets a basic minimum for the benefit of the whole community. It is the only way to shift the existing standard of inaccessible house and apartment designs.
The ABCB Options Paper proposes three options to deliver minimum accessible housing standards.
ABCB Options for minimum standard
|Performance Requirement||Option 1
(Silver 5 Point)
(Silver 7 Point)
(Gold 12 Point)
|A step-free entrance to the home||Included||Included||Included|
|Wider internal corridors and doors||Included||Included||Included|
|An accessible toilet or bathroom on the ground floor or entrance level||Included||Included||Included|
|A bathroom and shower that is easier to access||Included||Included||Included|
|Grab rails installed in bathroom and toilet (or capacity to do so)||Included||Included||Included|
|A ramp of safe pathway to the front door or other entrance||Included||Included|
|Safer internal stairways and paths||Included||Included|
|More space in and around the kitchen, capable of being adapted||Included|
|More space in and around the laundry, capable of being adapted||Included|
|Ground (or entry) level bedroom||Included|
|Easy to reach light switches||Included|
|Doors that are easier to open and close||Included|
There are 12 essential performance requirements to deliver an adequate minimum standard of accessibility (Option 3). All 12 performance requirements should be included in the NCC. In addition, the NCC should deliver adequate step-free backyard access, and include door and tap hardware and intercom systems in apartment buildings useable by people with a vision impairment.
Two hundred millimetres of additional corridor width makes all the difference to the accessibility of a home.
The RIA should consider all performance requirements to meet the Livable Housing Australia Gold standard. This achieves a reasonable minimum level of accessibility for new homes. The technical difference between silver and gold performance requirements is the difference between a person with a mobility issue being able to navigate freely around the house, or being excluded from areas of their own home.
VCOSS members want the NCC to remove access barriers for people with disabilities that are not mobility-related. The NCC can be amended so people with a vision or hearing impairment can access apartment buildings.
The Disability (Access to Premises – Building) Standards 2010, and matching NCC provisions, require intercom systems in apartment buildings to be suitable for occupants who are deaf or hearing impaired. There is no requirement for intercom systems to be suitable for people with a vision impairment.
VCOSS members advise that people with a vision impairment face barriers to accessing apartment buildings from the point of entry, particularly when intercom systems are touch-screen based or lack tactile readability.
Almost ten per cent of Australians over the age of 55 have a vision impairment. Vision impairment is common among older people and risk increases rapidly with advancing age, especially for women. Minimum access standards must keep pace with Australia’s changing needs, including the higher prevalence of vision impairment as the population ages. The NCC should require intercom systems in apartment buildings be useable by people with a vision impairment.
Homes designed with backyards should include step-free access to it. There is little point having a backyard if people cannot use it.
The ABCB should require the RIA to assess step-free access to backyards as part of Option 3. This performance requirement may be achieved in many ways, for example, through a garage, or via a ramp.
The Livable Housing Design Guidelines includes a number of design elements that improve accessibility, appear to be low-cost and are easy to deliver but are not included for consideration in the Options Paper.
VCOSS members suggest that door and tap hardware should be included as a minimum accessibility standard. They are basic features that would improve accessibility for children, older people and people with a disability. ABCB should include door and tap hardware, installed at a Livable Housing Design Platinum Standard, as a performance requirement in the best option being considered (Option 3) and assess it as part of the RIA.
The ABCB is considering a limited number of performance requirements that do not meet an adequate minimum accessibility standard (such as Option 1). People with mobility challenges can only enter and exit their homes freely if they have ramped access to the front door from the street or parking area. The weakest option (Option 1) does not allow people to enter and leave their homes, so is clearly not an acceptable minimum standard and should not be assessed. For people with mobility issues, steps are the difference between safely and independently accessing a building and being completely locked out from it.
Ramped access reduces the risk of injury and inconvenience for older people and parents with young children who use prams. It allows people to live independently without relying on other people to help them get around.
Parallels can be drawn from other sectors. For instance, the attempt to deliver “accessibility” in the Melbourne bus system in Victoria is an example of how a well-intentioned design program can go wrong when it hasn’t been fully considered.
In 2009, the Victorian Government started replacing older model buses with low-floor buses for wheelchair access and upgrading bus stops to meet the requirements of the Disability Discrimination Act. At the time there were almost 200 high-use bus stops in the outer suburbs of Melbourne that didn’t connect to a footpath. The upgrade program did not include the construction of new footpaths. Any footpath upgrades only occurred if there is an existing footpath very close by to connect into. If not, the bus stop was upgraded in isolation, leaving an “accessible” bus stop and no way for people with mobility issues to access it.
Disability Discrimination Act-compliant bus stops were built unattached to footpaths, or were built on bus routes serviced only by high-floor buses. The “accessibility” improvements delivered by the upgrade didn’t consider what else existed in that location, or the needs of people with a disability. Users found that while they may be able to access a vehicle at the beginning of a journey they could not disembark the vehicle because there was no access at the end. This is not accessibility.
If a journey does not provide a continuously accessible path from beginning to end, then it cannot be used, regardless of how many pieces of compliant infrastructure exist along the way. The same is true of accessible housing.
Theoretical accessibility doesn’t help anyone. It creates additional cost without achieving useful results and requires additional modification to bring it up to a decent standard. Option 1 will deliver the same results in new homes as the so-called “accessible” bus stops provided. When a person can’t get to the front door of their house, then the building can’t be classified as accessible. Option 1 should be removed from consideration in the RIA.
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