Reply To: Regulation 503

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Stephen Ryan


Thanks for your comments. Yes this is a more complex topic than it first seems. Reg’s 503, 608 & 1011 all have this same approach and same problem.

Robbo reminded me (see above) that the wording changed in 1999 (I think) from “substantially adversely affected” to “make reasonable provision for” ….

Both these phrases are broad & non-definitive but it was to give us all some room to move with existing buildings. The words are there to allow partial compliance or allow existing buildings to remain as constructed without being upgraded but mainly where the works are relatively minor.

The trouble in my opinion is that “access” was mot included in that 1999 amendment and nor has it been added in any amendment since. It was not included when 116 was added and to me that would have been the time to address the matter if the legislators wanted to.

This is a challenging topic, I don’t believe any of us as BS’s / certifiers of any application are in a position to really approve “partial” access compliance. Access either complies or it does not in my opinion. Identify the issues and have someone determine the appropriateness.

What to do if you are confronted with a 503 / 608 or 1011 application where a ramp is installed that is 1:12 as they once were or one of the old accessible toilets that clearly don’t meet current standards.

In my case the building is 80-100 years old, 2 storey, the stair may not comply let alone access at the front door or to the upper level.

VBA need to take the lead and issue Practice Notes that address the issue, are work-able and reasonable.

Cheers, Steve.