The new Part M of the Building regulations came into effect on 1 May 2004 introducing a revised set of rules relating to buildings other than dwellings. An amended Approved Document covering these changes suggests various ways of achieving compliance with the core requirements and in the majority of cases the designer will choose to accord with these recommendations or the similar guidance contained in the British Standard Code of Practice B.S.8300: 2001. This is not mandatory however as these documents only show one way in which to comply and there may be other equally satisfactory ways in which the requirements can be met. The new Part M also introduces the concept of an Access Statement.
Purpose of an Access Statement
Alternative solutions to access problems will vary depending on the intended use of a building and its size and location. The gradient of the plot will also have an influence. Changes of use and extensions to existing buildings can pose problems particularly if they are of architectural or historic importance. The purpose of an Access Statement is to allow a designer to outline their philosophy and approach to achieving a reasonable level of accessibility. In its simplest form this may be a confirmation that they intend to accord fully with the guidance contained in either Approved Document M or B.S.8300. In this case the specifications and drawings submitted with the Building Regulations application should demonstrate this.
Access Statements and Planning Applications
Ideally the designer should prepare a statement for submission with the Planning application and indeed the Office of the Deputy Prime Minister considers this good practice. It can then be developed further for the Building Regulations application and during the construction process. This will provide the building owner with a useful document when considering compliance with the Disability Discrimination Act. The early consideration of such matters is advantageous in that any potential problems can be considered and resolved before any detailed design work takes place. It also avoids the need to seek amendments to planning consents where such problems only come to light at the Building Regulations stage.
Non-conformity with Usual Design Guidance
For designs that deviate from the usual design guidance, the Access Statement provides an opportunity to bring the Building Control Surveyor’s attention to this fact and to explain and justify that reasonable provision for accessibility has been made in other ways. The designer may wish to adopt more innovative methods or it may be that the normal provisions are not feasible for reasons of security, safety or conservation. With existing buildings undergoing extension or change of use, there may be complications caused by the existing structure or a need to conserve important architectural features. In all the above cases the designer needs to demonstrate achievement a reasonable provision or an equivalent or better level.
Further guidance on Access Statements and related matters can be found in Approved Document M (Para 0.20) and on the Disability Rights Commission website at drc-gb.org.