Outcome of Queensland Rail consultations on TGSIs
On 11 February 2002 the Human Rights and Equal Opportunity Commission decided to grant a temporary exemption to Queensland Rail (QR) under section 55 of the Disability Discrimination Act (DDA). The exemption was for a period of 6 months, from the provisions of sections 23 and 24 of the DDA, in so far as they require installation of tactile ground surface indicators.
That exemption has now expired. QR and other operators remain free to apply for further exemption if they consider this is necessary. HREOC's understanding is that QR has not sought a further exemption because it will instead be managing issues in this area by implementing (initially on a trial basis) an agreed approach as detailed below.
The exemption was granted to allow consultation on means of balancing safety requirements for passengers with vision impairments, passengers with other disabilities and other passengers. The exemption was on condition that
- QR consult with interested parties and report to HREOC within four months on the approach which Queensland Rail will adopt to use of TGSIs
- This consultation include requesting the chair of the Rail Modal Group of the Accessible Transport Standards Consultative Committee to convene a meeting no later than March 2002 of that group together with representatives of the National Transport Secretariat, Blind Citizens Australia (BCA), the Physical Disability Council of Australia (PDCA) and the relevant Standards Australia committee with a view to identifying if possible an appropriate uniform approach to use of TGSIs for rail operators nationally
- QR agree to apply TGSIs in accordance with the outcome of these consultations
to any stations upgraded by them during the period of the exemption,
within a further twelve months.
Following this decision consultations including two national meetings were conducted by QR involving the parties identified in HREOC's decision. Those meetings enabled very useful discussions between rail operators, blind and physical disability community representatives and experts from Standards Australia.
Participants discussed the desirability of uniform approaches to TGSI installation as far as possible, given the need for TGSIs to give a clear and consistent indication of distance from the hazard presented by platform edges.
Four options for approaches to installation of TGSIs on rail platforms
were discussed:
1. TGSIs to be set back a minimum of 600 mm from edge, but width of TGSI
strip to be reduced to 400mm wide (rather than 600mm as recommended in
Australian Standard 1428.4) to allow 1200mm wide access path clear of
TGSIs on platforms with 2200mm or more available width;
2. TGSIs to be set back a minimum 600mm from edge, with 600mm width except
reduced to 400 where required to provide 1200 mm clear access path past
obstacles
3. Setback from edge to be reduced to 400mm with 600 mm wide TSGI strip
4. Setback from edge of a minimum of 600mm, width 600 mm, with intrusion
into access path having to be accepted, leaving 1000mm clear with total
available platform width of 2200mm.
Discussions eliminated options 1 and 3 on safety grounds.
TGSI strips 400mm wide (option 1) were not regarded as wide enough to be reliably detected if approached at right angles. 400mm setback (option 3) was not regarded as giving sufficient safety margin in a rail environment.
Other participants requested BCA and PDCA to discuss the choice between options 2 and 4.
HREOC has now been advised that the preferred approach is for implementation of option 4, on the understanding that non significant structures will be moved to create a clear 1.2 m wide path of travel and that BCA and PDCA will be involved in trialling at difficult stations (including Bowen Hills and Corinda).
BCA and PDCA have also offered to work on a case by case basis to identify
suitable approaches at other difficult stations.
In addition to issues of placement of TGSIs, the exemption application
raised issues of contrast between TGSIs and adjoining surfaces for people
with limited vision. Participants in discussions raised concerns about
a need for simple and affordable methods for ensuring sufficient luminance
contrast in the field. HREOC understands that QR will be including this
issue in its trials and will seek to involve Standards Australia and other
interested and expert parties. In particular QR will seek recommendations
on colours from Standards Australia, so that QR can incorporate selected
the nominated colours into the trials.
Commencement of QR's commitment, under the third of the exemption conditions listed above, to apply within twelve months the results of consultative processes to any stations upgraded during the period in which the exemption was operative, is clearly dependent on sufficiently clear results emerging from those processes, and thus now depends on the trials to be conducted by QR.
