by Adeline Bisson
Transport Standards purpose
The Disability Standards for Accessible Public Transport (DSAPT / Transport Standards) was formulated under section 31 of the Disability Discrimination Act and took effect on 23 October 2002. These Transport Standards establish minimum accessibility requirements to be met by providers and operators of public transport conveyances, infrastructure, and premises. They consider the range of disabilities covered by the DDA and apply to most public transport services (including air, water and land-based services carrying passengers).
The Transport Standards were developed to address the barriers faced by individuals with disabilities accessing public transport. They set out a series of requirements for transport providers to follow, aiming to create an environment where everyone, regardless of physical or cognitive abilities, can travel safely and comfortably, on an equitable basis and without discrimination.
Transport Standards structure
The Transport Standards comprise 34 parts, with the following structure:
- Part 1: Definitions and Standards reference.
- Parts 2 to 31: Specific requirements for each component or service part of public transport infrastructure, premises, and conveyances.
- Parts 32 to 34: Details on the exemption application process, equivalent access and direct assistance
- Schedule 1: Compliance target dates.
Table 1: DSAPT parts 2-31
- Access Paths
- Manoeuvring areas
- Passing areas
- Resting points
- Ramps
- Waiting areas
- Boarding
- Allocated space
- Surfaces
- Handrails ad grabrails
- Doorways and doors
- Lifts
- Stairs
- Toilets
- Symbols
- Signs
- Tactile ground surface indicators
- Alarms
- Lighting
- Controls
- Furniture and fitments
- Street furniture
- Gateways
- Payment of fares
- Hearing augmentation
- Information
- Booked services
- Food and drink services
- Belongings
- Priority
Each part is subdivided into sections, providing detailed requirements or referencing a specific clause from the Australian Standards, to provide quantifiable criteria to assess compliance. Each section also identifies to which transport facility (Conveyances/Premises/Infrastructure) the requirement applies.
Figure 1: Extract from DSAPT Section 9.1 showing section applicable to Conveyances, Premises and Infrastructure
It is important to note that if a DSAPT clause clearly mandates a specific value for an accessibility requirement, this would take precedence over any requirements specified in the AS Standards that might differ from the DSAPT requirement. A common example of this hierarchy would be the minimum access path width specified as 1200mm for Premises and Infrastructure, whereas AS1428.1 only requires a minimum access path width of 1000mm.
By adhering to DSAPT requirements, we can generate objective and consistent data points. These data points are invaluable for comparing the performance of Public Transport Operators in terms of the accessibility of their infrastructure and conveyances. This not only promotes compliance but also drives improvements in accessibility across the transport sector.
Limitations
While the Transport Standards set out the accessibility expectations for owners and operators, they also help transport providers establish their level of compliance and design strategies for improvements to their existing assets,
However, their application can be problematic with some key limitations.
- The Transport Standards often reference very specific versions and published dates for the Australian Standards and do not recognise later versions of these Standards. This can cause issues when newer versions of those standards are used in construction, potentially leading to non-compliance with DSAPT.
For example, a Unisex Accessible toilet must comply with AS1428.1(2001) according to DSAPT Part 15.1. Strict application of this clause could result in an undersized cubicle compared to an accessible toilet built to the newer 2009 or 2021 versions of AS1428.1. The larger cubicle defined by the newer standards would certainly provide customers with a better outcome and more functional toilet facilities.
- Some parts of the standards are general and lack specification, resulting in interpretation when assessing compliance.|
For example, DSAPT Part 27.1 – Information “general information about transport services must be accessible to all passengers” does not provide any details to quantify or qualify the compliance criteria.
- There are very limited requirements specifying wayfinding solutions to help those with disabilities navigate through Public Transport precincts when commuting between transport modes (for example there is no mandated requirement associated with directional ground surface indicators or other cues)
- No requirements for the provision of accessible parking bays (except for premises where the Premises Standards apply)
The Transport Standards are currently undergoing a major upgrade, and significant revisions are planned for release, which will address some of the current limitations (refer to article published in ACA e-Access Insight Winter 2024, ‘Enhancing Accessibility: The 2022 reform of Australia’s Transport Accessibility Standards’).
Audit tools
Notwithstanding the limitations mentioned above, the Transport Standards provide robust guidelines to assist Access Consultants with auditing Transport Facilities consistently and systematically. Each DSAPT part can be used as a base checklist to assess all elements of accessible transport services.
This method not only helps in maintaining baseline compliance data but also allows for meaningful comparisons of accessibility levels across different transport facilities. Additionally, it aids Transport Operators in benchmarking their compliance levels and identifying areas for improvement to enhance overall accessibility.
Going above and beyond
Access consultants, designers and other building certifiers should recognise that the Transport Standards specify only the minimum requirements to eliminate discrimination and provide accessible and inclusive Public Transport Systems. When designing or upgrading transport facilities or conveyances, access consultants should leverage their understanding of universal design principles and their knowledge of the accessibility standards to go above and beyond the strict minimum DSAPT requirements. Relying solely on DSAPT requirements when developing accessible solutions for public transport upgrade projects may result in missed opportunities to create optimal design outcomes with equitable and inclusive access.
AUTHOR BIO: Adeline Bisson
Adeline Bisson is a chartered civil engineer from the UK Institute of Civil Engineers and an ACA-accredited Access Consultant. She leads the universal access division at Sterling Advisory, a role she has held for over 10 years. During this time, Adeline has been instrumental in auditing Public Transport infrastructure in Victoria and New South Wales, assisting Public Transport Operators with building accessibility compliance databases. Her work enables them to prioritise upgrade works and develop long-term strategies to improve accessibility and remove discrimination in Public Transport Systems.