‘access for all’ action plan - city of unley · this city of unley “access for all” action...

‘Access for All’

Action Plan 2011-2016

In Response to the Commonwealth Disability

Discrimination Act (1992)

Adopted (insert date)

1. Introduction We recognize that members of the City of Unley community come in all shapes and sizes. This City of Unley “Access for All” Action Plan is a response to ensure that our services are accessible for all members of the community. The Plan aligns with the Commonwealth Disability Discrimination Act 1992 (DDA); and has been developed in consultation with the community, including people with disabilities, service providers, Council officers and volunteers. The City of Unley is located in Adelaide, South Australia 4 km south east from the CBD. It is a compact municipality comprising an area of 14.4 square km with a population of approximately 38 000 people.

The City of Unley is made up of the suburbs of Everard Park, Wayville, Goodwood, Unley, Parkside, Fullarton, Myrtle Bank, Highgate, Malvern, Unley Park, Kings Park, Clarence Park, Black Forest, Millswood, Hyde Park, and Forestville and is bounded by Greenhill Road and the parklands to the north, Anzac Highway and South Road to the west, Cross Road to the south and Glen Osmond Road to the east. The City of Unley's boundaries stretch over a total area of 14 square kilometres.

2. Legislative Requirements Access for people with a disability is a legislative requirement under the national Disability Discrimination Act 1992 (DDA) in regard to the following areas:

Education Access to premises Goods, services and facilities Accommodation and land Sports, clubs and all recreation and cultural events Employment Commonwealth programs and law Requests for Information

Council’s obligation to reduce and eliminate, as far as possible, discrimination on the basis of disability, and have some level of defense against a complaint, requires monitoring of actions, appropriate resourcing and evaluation of performance. The “Access for All” Plan 2011/16 will be used to inform Annual Business Plans across the organisation for the next seven financial years. Projects will be referred to Council for funding each year.

Projects contained within the Plan will be allocated to responsible officers via the Annual Business Plans of each Council department. In addition, the Plan will be evaluated through the following processes: Every three months, Managers and Team Leaders will report on the

outcomes of actions against the Plan’s performance indicators to the DDA Action Plan Steering Committee.

Community members throughout the term of the Plan can lodge comments

to the Council about its progress. The overall “Access for All” Plan will be reviewed after five years to ensure that legislative intent and statutory requirements are being satisfied Relevant Federal and State legislation is outlined below, but is not limited to: Commonwealth Government Disability Discrimination Act (DDA) 1992 The Federal Disability Discrimination Act 1992 came into effect on 1 March 1993. It provides uniform protection against unfair or unfavorable treatment for people with disabilities in Australia, and seeks to fill the gaps in State and Territory legislation. Its objectives are to:

eliminate, as far as possible, discrimination against persons on the grounds of disability;

ensure, as far as practicable, that people with disabilities have the same rights to equality before the law as the rest of the community, and

to promote recognition and acceptance within the community of the principles that people with a disability have the same fundamental rights as the rest of the community.

Disability Services Act 1986 Acknowledges the rights of people with a disability to access services and to be treated with dignity. Building Code of Australia The Building Code of Australia, (BCA) in conjunction with the DDA, applies to new buildings undergoing significant refurbishment or alteration. The BCA is a comprehensive statement of the technical requirements relevant to the design and construction of buildings and other related structures. AS 1428.1 (Australian Standards) is directly referenced under the BCA. Compliance with a range of access provision is required.

Australian Standard 1428 – Design for Access and Mobility AS 1428 (Parts 1 to 4) is an important reference standard which prescribes the basic requirements for physical access which must be adhered to in the planning, development and construction of all buildings and facilities. Other Australian and International Standards (AS and ISO) Various Standards set out requirements that must be referred to when making decisions that impact on people with disabilities. The Australian Human Rights Commission The Australian Human Rights Commission Act 1986 (formerly called the Human Rights and Equal Opportunity Commission Act 1986) established the Human Rights and Equal Opportunity Commission (now known as the Australian Human Rights Commission) and gives it functions in relation to the following international instruments:

International Covenant on Civil and Political Rights (ICCPR) Convention Concerning Discrimination in Respect of Employment and

Occupation Convention on the Rights of Persons with Disabilities Convention on the Rights of the Child Declaration of the Rights of the Child Declaration on the Rights of Disabled Persons Declaration on the Rights of Mentally Retarded Persons, and Declaration on the Elimination of All Forms of Intolerance and of

Discrimination Based on Religion or Belief.

In addition, the Aboriginal and Torres Strait Islander Social Justice Commissioner has specific functions under the AHRC Act and the Native Title Act, 1993 to monitor the human rights of Indigenous people.

The AHRC is responsible for administering the following Federal laws:

Age Discrimination Act 2004 Disability Discrimination Act 1992 Australian Human Rights Commission Act 1986 Sex Discrimination Act 1984 Racial Discrimination Act 1975 Native Title Act 1993 Workplace Relations Act 1996

The Commission has developed notes and guidelines on Access to Premises. South Australian State Government Local Government Act 1999

The Act details the statutory obligations of Local Government in relation to its role, functions and objectives, Chap 1 Sec 3, Chap 2, Sect 6 and 7. Equal Opportunity Act 1984 The purpose of the Equal Opportunity Act 1984 (SA) is to promote equality of opportunity for all South Australians. It aims to prevent discrimination against people and to give them a fair chance to take part in economic and community life. Disability Services Act, 1993 This Act provides the principles that are to be applied to the funding and provision services for people with disabilities. Development Act 1993 Part 1 Sec 3 (f) (g) regulates the design and construction of buildings. Mental Health Act 2009 An Act which provides for the treatment, care and rehabilitation of people with serious mental illness, with the goal of bringing about their recovery as far as is possible; to confer powers to make orders for community treatment, or detention and treatment of such people where required; to provide protections of the freedom and legal rights of mentally ill people. Carers Recognition Act 2005 (South Australia) The Act states that certain organisations must ensure that the organisation itself, and those who work for it, take action to reflect the principles of the Carers’ Charter in their provision of services to carers and the people for whom they care. It also requires that certain organisations must, where there is relevance to carers or the people for whom they care, consult carers or bodies that represent carers in:

Development of policies or programs Strategic or operational planning.

Organisations must report on the actions taken in relation to these matters. Children’s Protection Act 1993 The objects of this Act are to ensure that all children are safe from harm; and as far as practicable that all children are cared for in a way that allows them to reach their full potential; and to promote caring attitudes and responses towards children among all sections of the community so that the need for appropriate nurture, care and protection (including protection of the child's cultural identity) is understood, risks to a child's wellbeing are quickly

identified and any necessary support, protection or care is promptly provided; to recognise the family as the primary means of providing for the nurture, care and protection of children and to accord a high priority to supporting and assisting the family to carry out its responsibilities to children. Volunteers Protection Act 2001 This Act aims to encourage people to volunteer by protecting them from personal liability while they are doing authorised volunteering duties on behalf of an incorporated organisation. Recreation Services (Limit of Liability) Act 2002 This Act applies to organisations involved in sporting, leisure or recreational activities and their participants. Essentially it is a useful risk management tool and was prompted by the need to reduce the cost of public liability insurance for organisations involved in sport and recreation.

3. Strategic Context The City of Unley Community Plan 2015 outlines the vision for the City:

‘The City of Unley is recognised for its community spirit, natural and built environment, business strength and innovative leadership’.

The three key directions to achieve this vision are:

1. Community Spirit 2. Economic Strength 3. Natural and Built Environment.

International, National and State Strategic Context The Australian Government signed and ratified the United Nations Convention on the Rights of Persons with Disabilities in 2007. The purpose of the Convention is to:

promote, protect and ensure the full and equal enjoyment of all human rights and fundamental freedoms by all persons with disabilities, and to promote respect for their inherent dignity.

In 2009 the Australian Government produced The Way Forward – A New Disability Framework for Australia which makes a range of recommendations aimed at increasing private support for disability services. It also recommends:

that regulations for accessible and adaptable housing standards be strengthened to facilitate ageing in place; and as a first step, a set of no-cost and low-cost requirements be mandatory in all new residential buildings.

The new national Disability (Access to Premises – Buildings) Standards (Premises Standards) will be applicable from 1 May 2011. They will lead to improvements in the level of access required in new buildings and existing buildings undergoing renovation. The following framework provides a summary of the key current documents that assist in understanding disability access in the National, State and Council context.

Summary Framework: Understanding Disability Access in the National, State and Council Context

National

State

City of Unley

Acts

Disability Discrimination Act 1992 Equal Opportunity Act 1984 Disability Services Act 1993 Development Act (Building

Rules) (SA) 1993 Mental Health Act 2009 Local Government Act 1999 Carers Recognition Act 2005

Policy and Strategy

The Way Forward – A New Disability Framework for Australia

South Australia’s Strategic Plan

Strategic Infrastructure Plan for South Australia

Promoting Independence Strategy

Community Plan 2015 (amended 2009) City of Unley Annual Business Plan Eastern Region Alliance Ageing Strategy and

City of Unley Ageing Strategy (under development)

Moveable Signs By-Law Outdoor Dining Policy Fair Treatment Policy Home and Community Care Policies and

Procedures Consultation Policy Code of Practice for Access to Council

Meetings and Documents Building Inspection Policy Asset Management Policy Community Transport Policy Strategic Building Review

Plans

Promoting Independence Disability Action Plans for South Australia

30-Year Plan for Greater Adelaide

City of Unley ‘Access for All’ Action Plan 2011-2016

City of Unley Development Plan – consolidated 4 December 2008

Environment Sustainability Plan 2010-2013 Open Space Recreation Strategy 2004-2014 Economic Development Strategy 2010-2013

Standards

Disability Standards for Accessible Public Transport and Australian Standards 1428.1,2,3&4; 2353; 1735.12; 2899.1

Home and Community Care National Service Standards

Guidelines

Disability Standards for Accessible Public Transport Guidelines

Access to Buildings and Services – Guidelines and Information

Guide to Traffic Engineering Practice Pt 13- Pedestrians

Home and Community Care National Standards Instrument and Guidelines

Disability (Access to Premises – Buildings) Standards applicable from 1 May 2011

Community Transport Procedures Complaint Handling Procedures Community Consultation Guidelines

Codes Building Code of Australia

4. Developing the ‘Access for All’ Action Plan

In 1997, the inaugural City of Unley “Access for All” DDA Action Plan was developed and lodged with the Human Rights and Equal Opportunity Commission. Since this time the City of Unley has responded to the DDA legislative requirements through projects such as ongoing upgrades to Council owned and leased buildings and footpaths. In addition to this, DDA compliant bus stop and bus shelter projects were completed, incorporating tactile and directional paving at bus stops. Signage was also upgraded to include tactile and Braille indicators at toilets in parks and reserves and other public spaces. Community engagement into the development of the Action Plan took place between March and May 2010. Consultation techniques included workshops with Council staff, community focus groups, a community survey, and a community consultation workshop. A total of 53 responses to the survey were received. 5. Objectives The five Objectives of the City of Unley “Access for All” Plan 2011/16 are: 1. People with disabilities will have equal physical access to the City of Unley 2. Information about Council and services will be made widely available in accessible formats 3. People with disabilities will have equal opportunities to participate in community life 4. People with disabilities will be engaged in planning to assist Council to deliver high quality outcomes 5. Positive and inclusive images of people with a disability will be promoted. These objectives are supported by a range of strategies and actions with specific timeframes.

6. Acronyms and Definitions EEO Equal Employment Opportunity ABS Australian Bureau of Statistics AHRC Australian Human Rights Commission AUSLN Australian Sign Language BCA Building Code of Australia CALD People from Culturally and Linguistically Diverse backgrounds. DDA Disability Discrimination Act 1992 DES Domiciliary Equipment Services DFC Department for Families and Communities TTY Teletypewriter HACC Home and Community Care HREOC Australian Human Rights and Equal Opportunity Commission ISO International Standards Organisation IT Information Technology TGSIs Tactile Ground Surface Indicators OFTA Office For the Ageing RSB Royal Society for the Blind W3C World Wide Web Consortium JAWS Job Access With Speech (a text-to-speech software program) Disability The Disability Discrimination Act (1992) applies to any person, adult or child, who has any type and/or level of

disability including the following broadly categorised disability groups:

Psychiatric – e.g. people with mental illness such as depression Physical – e.g. someone who uses a wheelchair, stick or walking frame; uses a scooter; a person with

amputation or cerebral palsy Sensory – e.g. people who have difficulty with vision and hearing loss/deafness or blind Intellectual – e.g. someone with Down’s Syndrome

Learning – e.g. problems with literacy such as dyslexia Neurological – e.g. multiple sclerosis and motor neuron disease Disease processes – e.g. Hep. B or C, Diabetes, HIV/AIDS

The DDA covers a disability which a person has now, had in the past (e.g. a past episode of mental illness), may have in the future (e.g. a disability that may develop due inherited factors) or are believed to have (e.g. if it is believed that a person is HIV-positive). Associates of people with disability are also protected against discrimination. Associates refer to work colleagues, family members, personal attendants and/or carers.

Direct Discrimination

Direct discrimination occurs when a person with a disability receives less favourable treatment than a person without a disability would receive in the same or similar circumstances

Indirect Discrimination

Indirect discrimination occurs when there is a requirement, condition or practice in force that applies to everyone but unfairly excludes or disadvantages people with a disability because they are unable, or find it difficult, to comply with the requirement, condition or practice due to their disability.

Access Action Plan 2011-2016

Objective 1: People with disabilities will have equal physical access to the City of Unley Strategies Actions Resources Timeframe Responsible Manager

Undertake DDA access compliance audit of all Council owned buildings and facilities to ensure compliance with the BCA, new AS1428 and DDA obligations. Prioritize identified works within the Council’s Asset Management budget, based on building utilisation statistics and risk hierarchy.

Subject to budget bid

June 2014 Manager Assets and Sustainable Landscape

Investigate the potential to use The iSWEAR Program (an audit process which links sustainability with accessibility in one audit process) as part of DDA access compliance audit of all Council owned buildings.


June 2014 Manager Community Development

Conduct Council building audits to ensure compliance in emergency evacuation, stair treads, circulation space and lift compliance, particularly at customer contact sites.

Staff time Ongoing Manager Assets and Sustainable Landscape

Revise current procedures and evacuation plans to ensure that people with a disability are considered in Council-wide emergency plans.

Staff time June 2013 Organisational Development Manager

1. Meet standards for access into and within buildings Review policies on leases of Council premises to ensure

accessibility features are part of lease conditions. Staff time


Review infrastructure surrounding council facilities to identify and address specific barriers to access including signposting in accordance Australian Standards.



Identify deficiencies in compliance in kerb ramps, tactile ground surface indicators (TGSIs), continuous path of travel and audio traffic signals.


Continue program of accessible kerb upgrades in line with audits.


Audit street signs to identify non-compliant signage and include recommendations in scheduled program of works.



Reduce obstructions on footpaths by developing a Safe Street Furniture Policy.

Staff time June 2013 Manager Economic Development

Develop Policy to deal with footpath encroachment from significant trees.

Staff time June 2013 Manager Development & Building

Review Outdoor Dining Policy for compliance with the DDA and ensure that minimum width of accessible footpath space of 1.8 metres is enforced.

Staff time June 2014

Manager Traffic & Transport Manager Community Services

Review By-Laws, policies and procedures relating to “A” frame advertising sign placement to ensure consistency with the DDA (next By-Law review due for completion by 2015)


Manager Governance & Strategic Projects

2. Provide accessible paths of travel into and within Council owned facilities

Require evidence from all contractors undertaking works for Council, that they understand their DDA obligations.

Staff time Ongoing Contracts Engineering & Administration

Continue to increase percentage of compliant (Disability Standards for Accessible Public Transport) bus stops through existing program of works.

Within capital budget

Ongoing

Manager Traffic & Transport

Investigate the Transport SA funding opportunity for Councils to upgrade bus stops and shelters, and make application for funding as appropriate.


3. Accessible public and community transport

Consider opportunities to improve wheelchair lifters and fixing points for electric wheelchairs during scheduled process to replace community buses.

Included in replacement budget

June 2013 Manager Community Services

Develop an internal process that ensures the implementation of new car parking bays for people with disabilities, both on Council land or private property, adheres to Australian Standards AS 1428 (Access to premises).

Staff time June 2013 Manager Development & Building

4. Provide accessible parking

Develop a plan to upgrade non-compliant car parking bays on Council land for people with disabilities.



Develop a new policy on the safe use of electric wheelchairs and scooters in Council facilities.

Staff time June 2012 Manager Community Projects

5. Enable safe use of self-propelled wheelchairs (electric mobility scooters)

Train staff in a new Electric Wheelchair (Gopher) Policy of Council.


6. Provide adequate seats and resting points for people moving within and across the Council area

Increase number of seats at bus stops in areas of high pedestrian activity or need.


Ongoing Manager Assets and Sustainable Landscape


Objective 2: Information about Council and services will be made widely available in accessible formats Strategies Actions Resources Timeframe Responsible Manager

Review Council’s customer complaint process to determine if enhancements are required to enable residents and staff with a disability to place a complaint for action.


Make hearing assistance technology available at Civic Centre Customer Service Centre.


June 2012 Organisational Development Manager

Investigate “touch screens” at Council service areas which incorporate an easy reference to all Council facilities, activities and services.



Investigate providing key Council information in large print and/or symbols (Federal funding for this may be available through the RSB SA).

Staff time June 2013 Manager Governance & Strategic Projects

Train staff in use of TTY service (textphone for people with hearing impairment provided through the National Relay Service).


1. Provide accessible high quality customer service

Develop a register of available Auslan interpreters to enable people with hearing difficulties and Council


officers to communicate together.

Review Council’s Visual Style Guide regarding font size, colour suggestions, and use of visual symbols on Council publications.


Develop a waste collection assistance agreement with contractors, for people with disabilities.

Staff time June 2014 Manager Community Services

Ensure payment options and processes are accessible by linking with IT strategy to maintain “up-to-date” alternative methods of on-line payment.

Within operational budget

Ongoing Manager IT Services

Review Council’s Website to ensure compliance with latest W3C guidelines on Web accessibility.

Staff time June 2013 Manager IT Services

Investigate screen reader programs such as JAWS and IBM Homepage reader.


June 2013 Manager IT Services

Speech-enable Council’s Web Site with BrowseAloud service.


June 2012 Manager IT Services

Provide access to a register of community services available in the community (including a disability specific section) via Council’s web site.


2. Develop a Council website that is accessible to everyone

Provide ‘Unley Life’ magazine to be read on Radio RPH 5 and ensure this audio is accessible on the City of Unley web site for people with vision impairment.


Ongoing Manager Governance & Strategic Projects

3. Provide an accessible Mobility Map that includes information about the

Consult with users on content and use, update the map as required, and make it available in a range of formats.

Initial project subject to


location of accessible toilets, playgrounds, services.

budget bid


Objective 3: People with disabilities will have equal opportunities to participate in community life Strategies Actions Resources Timeframe Responsible Manager

Design Council run recreation, arts and cultural activities, programs and events to encourage and involve people with a disability.

Staff time Ongoing Manager Community Development

Promote the Companion Card to the community and the facilities which accept the Companion Card.

Staff time June 2012 and ongoing

Manager Community Projects

Review Council Grant funding guidelines and consider inclusion of a requirement to demonstrate DDA access compliance.

Staff time June 2013 Manager Community Development

Conduct a community survey, as part of a review of the Open Space and Recreational Strategy, relating to recreation planning for the City of Unley, to identify recreational needs of people with disabilities.



1. Provide equal access to recreation, arts, and culture through activities and events

Ensure that open space redevelopments, upgrades and maintenance follow Australian Standards and include accessibility requirements in design briefs.

Staff time Ongoing Manager Community Development and Manager Assets and Sustainable Landscape

Ensure toilets are regularly cleaned and maintained, including lighting and sharps disposal units.


Develop an access checklist to assist in planning all events.


Provide training to local sporting groups on attracting and supporting people with disabilities.



Encourage, develop and support activities at community centres that are accessible for people with disabilities.

Staff time Ongoing Manager Community Development

Review of recruitment and induction processes to include analysis of practices in relation to equal access to employment opportunities for people with disabilities.


Review the current Fair Treatment Policy to ensure inclusion of EEO considerations (as per section 35 of the Act).


Refer to the Australian Local Government Association publication “Accessible workplaces: best practice for the employment of people with disabilities in Local Government” as a guide to improving existing Council systems.

Staff time Ongoing Organisational Development Manager

Include disability as component of Council’s Workplace Diversity Action Plan.


2. Provide equal access to employment Educate local business associations and businesses on

the benefits of inclusive employment practices and the Subject to budget bid

June 2016 Manager Economic Development

benefits of being accessible businesses. Provide opportunities for people with a disability to volunteer at Council.

Staff time Ongoing Manager Community Services

Review volunteer induction processes and include information and awareness on DDA and working with customers with a disability where appropriate.


3. Provide equal access to volunteering

Ensure that coordinators of Council programs utilizing volunteers are able to provide appropriate level of support, including support related to disability.


Frail and aged residents will have access to a range of community services including the Home and Community Care (HACC) Program.

Within existing budget

Ongoing Manager Community Services

Provide home library service to people who are unable to visit the library due to a disability.

Within existing program

Ongoing Library Manager

Provide large print items and audio books in the libraries.

Within existing program


4. Provide equal access to community support

Investigate adaptive technology that increases access to the internet at libraries.




Objective 4: People with disabilities will be engaged in planning to assist Council to deliver high quality outcomes Strategies Actions Resources Timeframe Responsible Manager

Ensure that Council’s Development Plan promotes accessible and equitable development when planning for the community into the future.

Staff time Link to scheduled Development Plan reviews

Principal Policy Planner

Ensure that Council’s risks and obligations under Section 25 (2)d of the DDA are considered when assessing relevant development applications.

Staff time Ongoing Manager Development & Building

Ensure Council planning staff members are aware of universal and adaptable access standards for buildings and particularly for housing; enabling people to remain in their homes longer.

Staff time Ongoing Manager Development & Building

Expand the Home and Community Care Reference Group to include representation from the disability sector. Rename the group ‘Ageing and Disability Advisory Group’, schedule quarterly meetings, and consult with members of this group as required.

Staff time Completed and ongoing

Manager Community Services Manager Community Projects

1. Engage people living with a disability in Council planning Develop a process to encourage young people with a Staff time June 2013 Manager Community

disability to be more involved in Council governance through a Youth Advisory Committee or similar.

Development

Develop an Access and Inclusion Policy.


Review Council’s Community Consultation Policy to more effectively reflect Council’s obligations pursuant to the DDA.


Review Council’s Community Plan 2015 to determine changes required to reflect Council’s Commitment to the principles of the Disability Discrimination Act.


2. Train Council staff to be aware of legislative requirements and Council plans

Provide general training for staff on disability awareness; and specific training on the new Access to Premises – Buildings Standards for relevant staff.

Within staff training budget


3. Monitor and implement the Access Action Plan

Report on the outcomes of actions against the Plan’s performance indicators to the DDA Action Plan Steering Committee on a quarterly basis.

Staff time Ongoing Manager Community Projects


Objective 5: Positive and inclusive images of people with a disability will be promoted Strategies Actions Resources Timeframe Responsible Manager

Investigate opportunities to acknowledge the contribution made by carers.


Develop a process and criteria to recognise and reward businesses and services that are accessible and promote inclusive practices.

Staff time June 2015 Manager Economic Development

Work with the media to showcase achievements and promote positive stories and images of people with a disability.

Staff time Ongoing Manager Governance & Strategic Projects

Include a regular feature in the Unley Life publication to promote new and existing initiatives for people with a disability.

Staff time Ongoing Manager Governance & Strategic Projects

1. Promote community understanding of disability issues

Consider engaging one of the many motivational speakers with a disability to speak at Council events as required.


Ongoing Manager Community Projects