Personal Provision in Public Places

Howard Brayton and his wife My wife and I being retired, are fortunate to be able to take mini-breaks, when we please, visiting places we haven’t seen before, or places we have previously enjoyed and which we wish to revisit. Now I should point out that my wife is wheelchair dependent, but with her expertise on the computer, she is able to book accommodation in advance, which offers ‘facilities for the disabled’, even if those facilities aren’t actual spelled out; but I’ll come to that shortly. In 2015 we made several such jaunts, and became something of amateur experts on such ‘facilities’ as disabled parking, wheelchair access, disabled toilets and wet-rooms.

But before we proceed, may I make a plea for the right use of the English language? When I was a Local Education Authority advisor/inspector, I spent a considerable amount of effort trying to get schools to stop referring to ‘special needs kids’, but to call them children with special needs; they are after all children first, who happen to have a special educational need. The same should be applied to people who have a disability; not ‘the disabled’, they are people first. But of course we all want the quick shorthand phrase. So we have ‘disabled access’ and ‘disabled toilets’; which of course, strictly speaking, indicates that the access and the toilets are disabled, hence unusable, not the people for whom they are provided.

Having got that off my chest, let me resume by telling you something of our experiences. We arrived at one of Brecon’s top hotels, The Castle of Brecon Hotel, where my wife had booked a wet-room. The Castle of Brecon Hotel Parking for the disabled was right next to the entrance, the access was easy, the reception was bright and friendly, but I was surprised to see a sticker, indicating that their Food Hygiene Rating was just 2 out of five. In the event, the food was good, well prepared and presented. Our room was large enough to facilitate easy wheelchair movement, although a bit shabby, lacking general information and no Wifi. Then we opened the door to the wet-room (outwards of course); it took our breath away, that is the room not the door. It was state-of-the-art; big enough to take a double bed; tiled from floor to ceiling in beige ochre tiles, which were replicated on the floor. The Castle of Brecon Hotel The LED lighting  embedded in the ceiling, was subtle and seductive. The problem was the sink; it was immediately inside the door at right angles, which meant it was virtually impossible to turn the wheelchair to face it. The toilet was immediately adjacent, (which is recommended, so that hands can be washed before rising) but having only one drop-down rail, rising from the toilet was impossible without my help. The shower had its own problems. When wet the floor was lethal; a towel had to be laid down to stand on. Although there was a seat attached to the wall, the two vertical grab rails, were so far removed from the seat, as to be rendered useless; I remained on hand to assist.

So, one has to ask, who designed the room? Did a builder merely seek general advice from the internet? Was an Occupational Therapist (OT) asked for advice? Crucially, was a person using a wheelchair invited to say what was needed and where? Clearly not.

Estuary Lodge From Brecon we drove to Harlech, where we stayed in Estuary Lodge, an American-style motel chalet, which was superb. Designated parking immediately outside the chalet, level access, a beautifully appointed room, with every conceivable luxury, and a sliding door opening to the wet-room, which clearly had been designed with the help and advice of someone who uses a wheelchair.

I will break cover, and name two hotels where the wet-rooms were superb; access, size, anti-slip floor, the layout and the number, choice and positioning of grab and drop down rails. We have visited Premier Inns in Cornwall and Kingston-upon-Thames, and cannot praise them highly enough. But these were new builds, not conversions. They place provision for people with disabilities, very highly on their list of specifications. (Google Premiere Inns, click on Disabled Access, and read their statement and future intentions, you too will be impressed.)

Estuary Lodge Between our overnight stays we toured, stopping at attractions, pubs, hotels, and restaurants for meals. Now the Equality Act 2010, ‘requires … those that provide services to the public, to make reasonable adjustments to those physical features of a building, which place a disabled person at a substantial disadvantage, compared with people who are not disabled.’  The key work here is ‘reasonable’. For example, our ‘local’ is very old. The toilets are up two steps and it would be impossible to create a ramp. It is clear that every place we stopped at, had made an effort to comply with the Act, but with varying success, dependent on the space available. One of the problems in some places is that available space allows the wheelchair user access to the room, but doesn’t allow for the carer. An assortment of grab and drop-down rails were in evidence, but not necessarily in the correct positions to be useful. Space in other rooms is limited by baby-changing facilities. Estuary Lodge Others are used as general storage of buckets and boxes. Some required a Radar key, one indeed, a hotel on the square in Caernarvon, required a member of staff to unlock it, and remove the general detritus, including high-chairs. One prestigious hotel in Padstow, (a different holiday!) required us to go down to the lower ground floor in order to access the only toilet for people with a disability. The two Wetherspoon’s pubs which we visited (Bridgnorth and Witney), even provide open individual lifts so that those in wheelchairs can navigate the different levels.

Armed with this practical evidence, we were curious to know, who inspects the facilities in public buildings for people with a disability? An internet search and subsequent discussion with a friend who is an architect, led us to The Building Regulations Act 2010 Part M: Access to and use of buildings, volume 2, Buildings other than dwellings. Click to download pdf. Sections M1 to M8 deal with access, ramps, handrails, corridors, lifts, toilets, showers and so on. There are in fact 72 pages of technical information, with diagrams for suggested layouts, size of rooms, height of toilets, hand-basins, rails and supports …

Confused? You should be. I certainly was, so I set out to find help. ‘The Regulations are administered and controlled by the Building Control Department officers, and it is their role to check all submitted plans for compliance with the regulations’. So I contacted my Local District Council by ‘phone and asked for the name of someone I could meet to discuss my concerns. I was told that as the Building Regulations Department was a team, I should email my request for a meeting, to the team as a whole. This I did. 17 days later, having received no response, I sent another email. Now after nearly five weeks of being ignored I have given up; just as they had hoped I would, I suppose.

So I am left with my quest for information.

  1. As every ‘facility’ and location is different, is approval given purely based on the Regulation’s guidelines, or is advice sort for others e.g. OTs and someone who uses a wheelchair?
  2. Are the needs of the carer taken into account?
  3. Are carers actually invited to give their opinion?
  4. Once installed, are the facilities regularly inspected?
  5. How can people with a disability and/or their carer make their voice heard?

You can add your own list of questions, based on your own experiences. I hope you have more success than I have had eliciting answers from your Local District Council.

Just before I leave you, I’d like to return to the hotel in Brecon with the Food Hygiene rating of just 2, although the food was good. Perhaps ‘facilities’ should be inspected annually, and a Facilities for People with Disabilities Rating, given and the certificate displayed. The least we can do, which I already do, is leave comments about the ‘facilities’ on TripAdvisor or Facebook. Maybe we should offer our services as amateur experts, to trial and test local ‘facilities’.

Don’t just sit there, let’s do something.

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Howard Brayton

Retired education advisor, inspector, consultant & lecturer

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