Visual emergency warning systems

Visual emergency warning systems for people who are deaf or hearing impaired

The Disability Discrimination Act 1992 (DDA) makes it unlawful to discriminate against any person, or their associates, on the grounds of disability, in a broad range of areas.

Section 23 of the DDA relates to access to, and use of, premises that the public has reason to enter or use. It states that failure to provide equitable access is unlawful, unless to do so would impose 'unjustifiable hardship' as defined in Section 11 of the DDA.

Principles

Equity in the provision of services requires that people with disabilities should be provided with the same level of protection as other premises users or building occupants. If there are legislative provisions to provide particular facilities, such as fire alarms, then those facilities must be accessible to all.

Background

Currently there is no requirement in the Building Code of Australia to provide visual warning devices for people with hearing impairment. The only requirement is to provide sound signals. People who are deaf or have hearing impairment cannot hear those audible signals.

Buildings designed to the minimum BCA deemed-to-satisfy provisions, therefore, do not offer a sufficiently safe environment for people who are deaf or have hearing impairment.

Insufficient information, such as the lack of appropriate emergency warning, may result in restricted independence or even reduced level of safety. For example, due to safety concerns it is not unusual for deaf staff not to be allowed to remain in the workplace out of office hours unless a hearing colleague is present.

Current provisions and guidelines

The following documents contain current provisions for occupant-warning systems and/or visual warning devices. Please refer to the latest edition of the codes and standards which may contain revised or updated provisions.

A. Required by any jurisdiction enforcing the BCA (mandatory)

Where there is a fire-detection system – such as smoke detectors or a sprinkler system – the following provisions are required:

• An occupant-warning system for buildings less than 25m in height
• An early warning and intercommunication system (EWIS) for buildings over 25m in height

The current BCA deemed-to-satisfy provisions reference AS 1670.4 and AS 4428.4, neither of which address other than sound systems.

B. Specified by the Disability Standards for Accessible Public Transport (DSAPT)

Applicable to premises used to deliver public-transport services – airports, bus stations and the like. (The DSAPT is a Disability Standard under the DDA. It is unlawful to contravene a Disability Standard, but compliance may be achieved by (a) meeting the specification or (b) providing an 'equivalent service'. The requirement is enforced by application of the complaint procedure of the DDA.)

DSAPT Section 19.1 requires, if an emergency-warning system is installed, both audible and visual alarms, by reference to AS 1428.2-1992 Clauses 18.2.1, 18.2.2 and 18.2.3.

C. Other references (compliance with these criteria is recommended for best practice in any building with an emergency-warning system)

• AS 1428.5-2010 section 6 Requirements for Warning and Alerting Systems

Every emergency-warning system (EWIS) provided in public places, private offices, toilets and the like, shall be accessible to all people with hearing loss by visual or tactile information and assistive-listening system (ALS) where provided:

– EWIS generating audible alert and evacuation alarms, and/or verbal output, shall also provide the same information through visible signals, ie flashing amber lights for alert and flashing red lights for evacuation as required by the relevant Australian standards.

– Audible, visual and pulsing vibration alert for the purpose of waking people in the event of an emergency shall be provided in hotels, motels, guesthouses and the like.

– The audible portion of emergency warning signals shall also be transmitted through the ALS where provided.

– Recorded evacuation message where used in the emergency warning system (EWS) shall also be provided through the ALS.

– Smoke detectors should be fitted with a remote pulsing vibration alert.

• AS 1670.1-2004 Clause 3.22 Occupant Warning

Additional visual and tactile signals shall be provided to augment the audible emergency evacuation signal if the averaged A-weighted sound pressure level of the background noise is higher than 95dB. The temporal pattern described in ISO 8201 shall be imposed on the visual and tactile emergency evacuation signals.

• AS 1670.4-2004 Clause 4.3.7 Visual warning devices and tactile warning devices

In areas of high ambient noise levels, the audible warning system shall be reinforced by a system of visual warning devices or other devices, to provide sensory stimulation adequate for the needs of the person at risk. The temporal pattern described in ISO 8201 shall be imposed on the visual and tactile evacuation signals.

Visual warning devices shall be installed in areas where the background A-weighted ambient noise level exceeds 95 dB(A) or where the wearing of hearing protection devices is required (see AS 1269), or where required by the BCA for hearing impaired persons.

• AS 1670.6-1997 Clause 2.2.2 Visual alarm signals

Visual alarm signals shall be installed where it is required to alert persons who are hearing impaired or in areas of high ambient noise levels.

• Deafness Forum of Australia Position Statements

Regardless of whether or not particular legislative requirements exist, appropriate means should be provided to ensure that all users who are deaf or hearing impaired will be alerted to any danger (eg fire, bomb threat) and to any evacuation drill or system test within the premises at the same time as all other users. Appropriate means for emergency or fire alerts might be alarms with flashing lights and portable vibration pagers.

• The Victorian Deaf Society recommends the following alerting systems:

– Class 1b, 3, 9a, & 9c building: Personal Information System (involving a number of hearing people responsible of informing the deaf person in case of emergency), flashing lights, and/or vibration system.

– Class 5 & 9a building: Personal Information System, flashing lights, pager system, telephone or computer emergency warning system.

– Class 5 (small business) building: Personal Information System, flashing lights.

– Class 9a & 9c facilities for the Deaf: A system with different light colours to signify different emergency situations, ie orange to identify an alert, red to designate an evacuation.

Design recommendations

Consider providing visual and/or tactile emergency warning devices for people who are deaf or hearing impaired in accordance with the relevant Australian Standards and the recommendations of Deafness Forum of Australia and the Victoria Deaf Society, regardless of the fact that it is currently not a requirement under the provisions of the BCA.

Compliance with the recommendations is likely to minimise the likelihood of complaint under the provisions of DDA92.

Audible alarms should be supplemented with visible signals of flashing amber lights for alert and flashing red lights for evacuation:

• Visual warning indicators with adequate light output should be provided at least in the isolated areas, such as all toilet and shower areas, where people with hearing impairment might find themselves alone and unaware that an emergency alarm has been sounded.
• Rotating beacons may be needed in large areas such as general office areas and classrooms in a school for the deaf or in open work spaces.
• Text messaging onto screens should be provided where possible, such as in airports, bus and railway stations, schools and sporting venues. It is an effective means of alerting the public who has the tendency to ignore emergency warning unless it is obvious and easily understood.
• In smaller facilities consideration should be given to providing personal vibrating pagers linked to the alarm system.

Recommended alerting systems include personal information system, flashing amber and red lights, pulsing vibration systems, telephone or computer emergency warning system, depending on the function and size of the building.

References

A full copy of the act which prohibits the discrimination against people with a disability is available from

https://www.legislation.gov.au/Details/C2018C00125

The Disability (Access to Premises – Buildings) Standards 2010 is available for downloading from

https://www.legislation.gov.au/Details/F2011C00214

Advisory Notes on Access to Premises, issued by Human Rights & Equal Opportunity Commission, is available for downloading from https://www.hreoc.gov.au/disability_rights/standards/Access_to_premises/premises_advisory.html#update

Evaluating the Regulation of Alerting Systems to Facilitate the Evacuation of the Deaf in Australia , by Heather A Burkart, Laurie J Carpenter, Nicole A Keenan, and Vicente F Nogarotto, 2 May 2005.