Submission to the Retirement Commission. March 2005.

Low vision in NZ

The 2001 New Zealand Disability Survey undertaken by Statistics New Zealand estimates that there are over 90,000 New Zealanders who have significantly impaired vision. Based on survey respondents who identified themselves as having a sight limitation, in 2001 some 81,500 New Zealand adults were blind or had a sight limitation that could not be corrected by glasses or contact lenses. Approximately 7,800 of these adults were completely blind. The rest had some level of sight impairment that made it difficult for them to see ordinary newspaper print, or see the face of someone across the room (even when using glasses or contact lenses if they usually wear them). 

The ageing population means that New Zealand faces a low vision "epidemic" over the coming years.

On behalf of its membership the Foundation welcomes the Draft Code and is especially pleased that it makes provision for people who experience difficulty in accessing and communicating information.

Training

Subject to individual financial circumstances and lifestyle preferences, people who are blind, vision impaired, or deafblind should have the same freedom as others to choose to live in a retirement village and receive the same level of competent service other residents expect.

The ability to discern and respond to the needs of people who are blind, vision-impaired or deafblind should be a specific competency requirement for those working with retirement village residents. Such knowledge is required to ensure that staff are confident and skilled in assisting people who have a vision impairment to be safe and as independent as possible.

Examples: Appropriately trained staff will be aware of obstacles in the environment which are in fact dangerous hazards for people who cannot see clearly, will ensure that essential security information is communicated in an accessible way, and will be able to guide a blind person in the event of an emergency evacuation.

Safe and secure facilities

It would be helpful to include specific reference to New Zealand Standards 4121:2001 (Design for access and mobility) and 4102:1996 (Safer house design) and amendments to ensure that operators provide an environment appropriate for the "physical safety and security of all Residents (including those with Disabilities)".

Further, legislative provision for access routes, buildings, and facilities that do not exclude disabled people is contained in the Building Act 2004 (see sections 117-120), the New Zealand Building Code, and Fire Safety and Evacuation of Buildings Regulations 1992.

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, using 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. Deafblind people have unique needs, as they are less able to use their hearing to detect information about their environment.

Lighting must be established and maintained to the standards contained in NZS 4121 and NZS 4102.

Evacuation procedure

It is essential that the review of "safety and security of Residents (including those with Disabilities)" is based on accepted national standards and legislation. It is therefore appropriate that the Draft Code cites the Fire Safety and Evacuation of Buildings Regulations 1992.

Retirement village operators should be required to demonstrate that their emergency response procedures adequately cater for the needs of blind, vision-impaired, and deafblind residents. These people cannot see their environment clearly at any time; an emergency poses additional stress and danger. Blind and vision-impaired residents are likely to become disoriented, 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.

Examples of successful strategies: keep a register of residents who are vision impaired, make emergency plans and other information available in accessible formats, train staff in non-visual communication skills, organise a buddy system so that in an emergency a blind person has someone to team up with, and determine a specific evacuation point that a blind person can locate reliably.

The ability to make all residents aware of safety and security policies requires operators to ensure that policies and written procedures can be made available in accessible formats (such as the spoken word, electronic text, large print, recorded audio, or braille). Consistent with 10.1 in the Draft Code, operators should not pass on to residents any cost associated with making this information accessible.

Meetings

Meeting procedures will be significantly enhanced by training which enables staff to communicate with people who cannot rely on visual cues and clues. Awareness training and some straightforward facilitation strategies will ensure the active participation of blind, vision-impaired, and deafblind people in meetings and social activities.

Accounts

The ability to provide invoices and similar information in accessible formats (as required) ensures that people who cannot read standard print are not discriminated against.

Alteration of residential units for people with disabilities

Anecdotal evidence from the Retirement village sector does not detract from the need for commercial facilities made available to the public to have provision for disabled people who may wish to pay to use those facilities. The review of the Building Code embarked on by the Department of Building and Housing will, among other matters, "take into account people's expectations that buildings enable people with disabilities to be independent."

The Foundation supports the Draft Code requirement (8.5) that operators developing new residential units, facilities and common areas must fully comply with all applicable building standards (including the Building Code), but believes that allowing the operator to judge who "would be typically likely to reside in the Retirement village" will have the effect of restricting the choices available to disabled people. Would-be residents with a disability could be denied a place in a particular village on the grounds that its design is non-inclusive.

Similarly, any resident's circumstances can change over time - as eyesight deteriorates or another impairment presents, the resident who might otherwise be able to continue residing in his or her unit might find it difficult to do so because the unit was designed and constructed on the basis of the operator's profile of the typical resident. New Zealand is set to experience an epidemic of low vision as the population changes.

Universal design

The Code of Practice should endorse the principle of inclusive or "universal" design. It is worthy of reiteration that potentially any resident can experience short-term special needs. Dwellings designed and constructed to achieve universal usability increase the opportunity for someone recovering from a fall, injury or illness to recuperate in his or her own home.

Constructing facilities and common areas for the use of everyone including disabled people is in any case necessary so that residents can be visited by families, guests, and professional contacts who happen to have a disability.

Moreover, the Code of Practice must be precise enough to prevent discrimination against residents with an existing disability or who acquire temporary or permanent disability. They should have the same choice to spend their money on lifestyle options as other citizens, and should not have to spend substantially more for the same standard of living.

Residential units must be designed and constructed so as to maximise their flexibility and minimise the cost of modifying them to meet an individual's requirements or changing needs.

Communication

The Foundation warmly endorses the equitable approach to ensuring that there is effective communication between the operator and residents.

It is essential that all residents, whether or not they are able to read standard print, can access the information which pertains to them. Information made accessible is read by blind and vision-impaired people in various ways, and the method(s) will vary from individual to individual. Accessible formats include large print, audio, braille, and, for those who have computers, electronic text. Some people who have impaired vision use a magnifier to read print. Print should stand out clearly from the background colours, be printed on paper that is non-glossy, and should not be effaced or obscured by graphics.

Deafblind people (who frequently have some limited ability to see and/or hear) may use accessible formats such as the above, and/or may need the services of a specialist interpreter. The Foundation's expertise is available to help the Retirement village sector meet is obligations to clients who need information in accessible form.

Conclusion

The Foundation is hopeful that the finalised Code of Practice will:

• Require blindness, vision impairment, and deafblindness awareness training for retirement village staff.
• Require specific standards for inclusive design and construction to ensure that disabled people are not excluded from retirement villages on the grounds of their disability.
• Require operators to demonstrate that their emergency response procedures cater for people with sensory disabilities.
• Retain and make specific the requirement for accessible information and communication.