Submission to Standard New Zealand on Allied Health Services Sector Standard Draft DZ8171. March 2005.

Information barriers

On behalf of its membership the Foundation welcomes the draft standard and is pleased for the opportunity to comment upon it. The Foundation is drawing attention to the needs of blind and vision-impaired people because it is their common experience that accessing allied health services is difficult if one can neither read standard print nor follow other visual information and directions. Deafblind people experience additional difficulty in receiving information and directions.

Designing services to be inclusive for people who have vision impairment would enable Foundation members and the growing number of New Zealanders with some degree of vision limitation to access those services independently and safely.

Specific comments

1.1 page 12: Change the outcome statement to: "Consumers receive safe and reasonable services in a manner that is respectful of their rights, equitable for consumers with sensory disabilities, minimizes harm, and acknowledges their cultural and individual values and beliefs." This is consistent with the New Zealand Disability Strategy.

1.1.2: Changing "in a suitable format" to "in the consumer's preferred format" would encourage providers to ensure that the format provided is indeed suitable for the particular consumer.

Add: "Steps are taken to make reasonable modifications in procedures and policies to enable consumers to be accompanied by guide dogs." (See Dog Control Act 1996 s.75.)

2.3 page 15: Encourage services to have the capacity to employ disabled people, consistent with the view of a non-disabling society advanced in the New Zealand Disability Strategy. Add: "Reasonable accommodations are made to remove any barriers that disabled people might experience in accessing employment within the service."

2.3.8 page 16: 2.3.8 Add: "Ensuring that training locations are accessible and that all professional development materials are available to print-disabled persons in their preferred format."

2.5 page 17: Add: "Information about the service is made available in accessible formats."

Add: "Organisations provide staff with training in working with blind, deafblind and vision-impaired consumers."

Add: "Organisations train staff to communicate effectively with people who cannot access information presented in visual form."

Accessible formats

Accessible formats are a reasonable accommodation in line with the Human Rights Act 1993. They include audio, braille, electronic text, and large print. Accessible web pages must offer any downloadable documents in Word or text form as well as PDF because PDF files are not reliably accessible to people using adaptive technology such as talking screen readers. The Telephone Information Service operated by the Foundation is an excellent way to communicate essential information in audio form to blind people throughout New Zealand. Plain English versions of advertising and marketing material are likely to be appropriate for some audiences.

The spoken word is also an accessible format. Staff can read aloud to the consumer whatever sighted people can read for themselves, e.g. name badges, forms (e.g. registration, admission, consent) and invoices. Interpreters may be required for deafblind consumers. Staff can fill in forms for someone who cannot see to write, provide a signature guide so the consumer is able to sign a form, and assist with handling currency at the point of payment. Staff should accurately relay all pertinent information, for instance the location of telephones or the availability of taxis.

Awareness training

Staff who have received some training in blindness and deafblindness issues will be well placed to assist consumers effectively by guiding consumers safely and orienting them to the layout of waiting areas, clinics, and rest rooms. The Foundation can advise on and develop staff training programmes.

4.4  page 21: Add: "Interventions (including post-procedure support) are provided by staff who can guide a blind or vision-impaired consumer safely, and communicate directions and route information clearly and accurately."

Staff should work with consumers to ensure that, for example:

• The consumer can identify medication correctly and use it properly.
• The consumer can follow all explanations of procedure and instructions for treatment and care.
• Post-procedure support plans are customised to the consumer's lifestyle as someone who is blind, deafblind, or vision impaired.

Emergency procedures

6.1 page 27 Add: "Create emergency procedures for non-visual communication with blind, deafblind, and vision-impaired people, and train staff to communicate effectively with people who cannot see."

The way in which someone with a sensory disability can respond to an emergency may be very different from how others respond, particularly when the response is dependent upon information delivered and received under stress.

Among the many challenges facing blind and vision-impaired people is the problem of ensuring personal safety in an environment they cannot see clearly. Sighted people may encounter and sidestep obstacles; for a blind or vision-impaired person the unseen or unclear obstacle can become a hazard.

The environment can become even more unpredictable and disorienting when emergency conditions occur. This increases the likelihood of personal injury and/or trauma for blind and vision-impaired people. They may be separated from their mobility aids (e.g. a cane or guide dog), and cannot easily respond to instructions issued on the assumption that the hearer can see where to go or what to do.

Multi-storied buildings present a special challenge because there is often no indication of floor numbers and there is nothing to show how many flights of stairs there are between floors. Blind and vision-impaired people can get disoriented when using stairs in an emergency and inadvertently end up at a dead-end basement.

Deafblind people will have additional needs because sirens and much spoken communication will not reliably help them.

Policies and staff training procedures are therefore required to ensure that blind, deafblind and vision-impaired people are safe during emergencies. Procedures might including making emergency plans and other information available in accessible formats, training staff in non-visual communication skills, organising a buddy system so that in an emergency a blind, deafblind, or vision-impaired person (consumer or employee) has someone to team up with, and determining a specific evacuation point that a blind person can locate reliably. It is important to have emergency coordinators who possess some knowledge of blindness, "sighted guide" techniques, and how to communicate effectively with blind, deafblind, and vision-impaired consumers and employees.

Accessible facilities

6.4 page 28: Add: "Facilities accommodate the needs of disabled people."

See New Zealand Standard 4121:2001 Design for Access and Mobility, the Building Act 2004 and the Building Code, and the Fire Safety and Evacuation of Buildings Regulations 1992. Lighting must be established and maintained to the standards contained in NZS 4121.

6.4.7 page 28: Change to: "The internal environment and its access and egress routes must minimize risk of harm, promote safe mobility, and be appropriate to the needs of all potential consumers, including people with disabilities, and the service provider."

6.4.12 page 29: Change to: "There is sufficient well lit parking, including accessible parking, with safe footpath access and suitable arrangements for all consumers using the service, including people who are disabled or frail."

In the draft 6.4.7 notes floors, but the entire environment must promote safety. Again, NZS 4121 is key. Consideration must be given to the following areas, among others:

• Level paths that are clearly marked and protected from vehicles.
• Access routes free of protruding objects.
• Stairs that have uniform riser height and tread width, and handrails both sides.
• Lifts that have visible and audible information indicators and tactile controls.
• Wide doorways and doors that are safe for all consumers.
• Surface textures that are firm, stable, and slip resistant.
• Adequate and adjustable lighting.
• Elimination of interfering ambient sound.
• Furniture and fittings arranged to enable not prevent access.

6.4.9 page 29: Change to: "There is clear signage, provision for communicating directional information to people who cannot see or read signs, and where applicable there is information on how to obtain...."

Vision-impaired people may have more or less vision in particular environments. Usable vision can vary according to factors such as lighting, surface glare, and of course the person's own eye condition and field of vision. Deafblind people have unique needs, as they are less able to use their hearing to detect information about their environment.

Advice on accessible and inclusive facilities

The Foundation's specialist staff can advise on design features and techniques to ensure that buildings and access routes are safe for people who are blind and vision impaired. Inexpensive modifications include colour contrast around doors, windows, and light switches, introducing contrast to indicate the edges of stairs, labelling doors with large print and braille labels, and using various tactile markers to make an everyday environment more manageable. Any vending machines should be placed in well lit areas and have raised keypads and braille labels.

Conclusion: a barrier-free environment is good for all

Equitable access to places, goods and services is a human right. A barrier-free environment that is safe and useable for all ensures that people's life circumstances (the temporary and the lasting ones) are catered for. An environment that is designed to be barrier-free could produce economic growth because it reduces the cost of subsequent compliance with anti-discrimination requirements and may increase the pool of clients for the particular business or activity. Accommodating accessibility needs should not be perceived as a burden but as an opportunity to meet the needs of consumers and employees. Of course, the unique aspects of different services might mean that the accommodation offered by each health facility is specific to its field.