Ensuring accessibility within education grounds, facilities, and buildings is key to inclusive educational institutions that are welcoming to all students. The Jensen Hughes team has a proud history of involvement in countless projects in the education sector, from small additions and primary schools to multiple major building developments at university campuses.
The Educational Facilities Standards and Guidelines (EFSG) is a set of documents maintained by the NSW Department of Education (DoE) ‘intended to assist those responsible for the management, planning, design, construction and maintenance of new and refurbished school facilities.’ This article looks closer at the EFSG and how we work with the guidelines to create accessible spaces.
What are the Educational Facilities Standards and Guidelines (EFSG)?
Regarding disability access, the EFSG repeats the mandatory requirements under the National Construction Code (NCC) and the Disability (Access to Premises – Buildings) Standards. It also contains measurable and specific requirements above minimum compliance, such as a 1350mm minimum width path of travel. Our consultants routinely encounter the EFSG in such educational settings as New South Wales primary and secondary school spaces, including Schools for Specific Purposes (SSPs).
Despite our regular contact with the EFSG, the documents still cause much confusion. For example, the following statement in the EFSG Design Guide is a source of constant consternation for design professionals in the field:
‘Generally, AS 1428.1 is the minimum design standard for access and mobility. However, it is DoE’s policy that any enhanced requirements noted in AS 1428.2 be incorporated in any new design’.
Regrettably, the EFSG does not specify these ‘enhanced requirements’. As a consequence, it is left to the interpretation of all involved. More often than not, this lack of clarity can lead to difficult discussions late in a project, especially if there is a difference of opinion between consultants or project managers. It is worth noting that no two architects or project managers will have the same opinion on most subjects.
How our team contends with the EFSG
We always strive to clarify our position on the EFSG requirement for our clients, design professionals and construction contractors we work with. For us, the key wording from the EFSG is ‘enhanced requirements’. AS 1428.2-1992 is titled ‘enhanced AND additional requirements’. In this case, the content of AS 1428.2 falls into one of two categories as described in the preface to the document as follows:
‘The purpose of this Standard is twofold. First, it covers items which are not covered in AS 1428.1, Design for access and mobility, Part 1: General requirements for access – Buildings, and second, it gives enhanced requirements for access for reference by authorities and other users who wish to provide a greater level of accessibility than the minimum requirements of Part 1’.
This means that for something to be an ‘enhanced requirement’, as required by EFSG, it must first be covered in AS 1428.1, and the corresponding section of AS 1428.2 must describe a higher level of access. An analysis of AS 1428.2 reveals that a large amount of the content falls into the ‘additional’ category and includes:
- Lifts
- Carparking
- Urinals and baths
- Signage location and illumination
- Emergency warning systems
- Lighting and sound levels
- Hearing augmentation
- Reach ranges and window controls
- Furniture and fitments
- Viewing ranges
- Podiums and stage areas
- Street furniture
- Drinking fountains and water coolers
- Gateways and checkouts
- Vending machines
- Telephones
- Postboxes
- Time delay for lights at pedestrian crossings
We believe it is not the intent of the EFSG to require such a large number of ‘additional’ and sometimes onerous requirements. This is supported by the choice of the word ‘enhanced’ in the EFSG Design Guide. Analysis of the remaining items in AS 1428.2 reveals that the ‘enhanced’ requirements include:
- Circulation
- Continuous accessible path of travel
- Walkways, ramps, landings and stairs
- Ground and floor surfaces
- Handrails and grabrails
- Sanitary facilities
- Symbols, signs and TGSIs
Given that AS 1428.2 has not been updated since 1992, it must also be noted that many of the ‘enhanced’ requirements relate to a comparison with the version of AS 1428.1 at that time. AS 1428.1, which is the referenced mandated standard under the National Construction Code (NCC) and the Disability (Access to Premises—Buildings) Standards, now dates from 2009. In some areas, the requirements match AS 1428.2-1992.
A clear example is the WC circulation size of 2300mm by 1900mm, which is identical in both standards. Thirty years ago, it was considered an ‘enhanced’ requirement. Nowadays, it is the minimum standard.
Involving a disability access consultant
Our team always advocates for best-practice accessibility in all building types and public domain spaces. We proudly provide this advice and actively encourage clients to integrate accessibility initiatives and expertise at the earliest possible stage of any project.
As complications with the EFSG demonstrate, early involvement of a disability access consultant can save a lot of headaches for project managers and architects alike. Aside from a review of minimum mandatory compliance under the BCA/NCC and Premises Standards, it is also important to establish minimum compliance for any relevant design guideline, such as a Development Control Plan or the EFSG.
Through respectful, collaborative dialogue, our consultants encourage our clients to go above and beyond their minimum obligations under the BCA/NCC and continue raising the bar for improved accessibility outcomes.
