Accessibility to police station front offices by disabled members of the community

Report: 11
Date: 7 December 2004
By: Commissioner

Summary

This report sets out the status of front offices across the MPA estate (as at October 2004) to provide access to the disabled in accordance with the requirements of the Disability Discrimination Act (DDA) 1995 and outlines future works to further enhance accessibility.

A. Recommendation

That Members are asked to note:

1. The progress made by Property Services in providing access for the disabled to front offices.
2. The present status of accessibility as set out at Appendix 1.
3. The proposed future programme of works including the front office refurbishment programme as set out at Appendix 2.

B. Supporting information

1. Part III of the Disability Discrimination Act 1995, places duties upon those providing goods, services or facilities to the public, to deliver them in such a manner as to be non-discriminatory to the disabled.

The duties on Service Providers were introduced in three stages:

1. The act became effective on 2 December 1996, whereupon it was unlawful for Service Providers to treat disabled people less favourably for a reason related to their disabilities.
2. Since 1 October 1999, Service Providers were required to make “reasonable” adjustments for disabled people, such as providing extra help, providing auxiliary aids or making changes to the way they provide their services.
3. By I October 2004, Service Providers were required to have made “reasonable” adjustments to physical features of premises to overcome physical barriers to access.

2. By virtue of the service provided to the general public by the MPS through their front offices, it is deemed that the requirements of Part III of the DDA applies to these locations.

3. In preparation for maximum compliance with the requirements of the Act, consultants were appointed in 2000 to undertake access audits of all front offices, including ingress and egress arrangements.

4. Arising from the access audits an on-going programme of work to provide ramps, lifts, automatic doors, accessible counters, hearing impedance loops, modifications to lighting, decorations, floor finishes, notices, seating etc has been carried out across the estate. Progress with external works, particularly ramps and lifts, has been delayed because of the need to receive planning consent, in some instances listed building consent and licenses from local highway authorities. Indeed, in some instances, proposals have been thwarted by refusal of planning application.

5. In addition to these works, there has been a Capital Works programme of front office modification and upgrading to not only achieve compliance with all aspects of Part III of the Act, but to introduce corporate design standards and generally enhance the public interface of front offices. Progress is on target to deliver a minimum of two new compliant front offices per Borough, as set out in ‘Building Towards the Safest City’ and endorsed by MPA. This programme is on going, details of which are set out in Appendix 2.

6. In May 2004, an independent access consultant was appointed to undertake access compliance reviews of all front offices, to audit work already completed and to recommend work still to be undertaken.

7. The findings of this latest review are being used to prioritise future work programmes, to formulate Appendix 1 and to compile data for publication of accessibility to MPS front offices (as recommended by the Act) on the MPS internet site and in a pamphlet to be published in the new year for distribution to all relevant stakeholders.

8. In addition to the priority of addressing accessibility to front offices, work has also been undertaken to address accessibility in meeting rooms and other public interface locations. Designs are being perfected for accessible and DDA compliant custody suites and cells in preparation for further extension of the Act in January 2006 to include these areas.

C. Race and equality impact

The Disability Discrimination Act 1995 clearly sets out the requirements to be achieved. Under the Act, disability embraces both physical and mental impairment, including ambulatory and sensory such as sight, touch and hearing and other impairments including mental illness, mental health problems and learning disabilities. Wherever possible, work undertaken by Property Services has addressed the full range of disabilities, particularly in the front office refurbishment programme of works.

D. Financial implications

Since 1996, considerable expenditure has been made in achieving compliance. Exact expenditure is impossible to determine as wherever possible, modifications have been undertaken as part of routine maintenance and incorporated in major refurbishment programmes. However, it is estimated that expenditure on works directly related to accessibility has been in the order of £9.5 million.

Findings of the latest access review suggests there is still a need to spend a further £3.8 million. This is to fund additional ramps, lifts, automatic doors, hearing impedance loops and other modifications. Some of this will be picked up through the front office refurbishment programme. The two programmes of work will be co-ordinated to ensure best value of expenditure is achieved, whilst striving for earliest access compliance (where practicable) with minimum disruption to service provision.

E. Legal implications

The date for full compliance of part III of the act has past, being 1 October 2004. As can be seen from Appendix 1, there are still many buildings that do not provide unimpeded access to front offices. However, in defence of any challenge made, it would have to be recognised that much effort and expenditure has been made to achieve compliance. There is an on-going programme of works to enhance accessibility and in so doing compliance, and in many of the remaining buildings, the structural configuration and their likely future disposal makes it impractical and unreasonable to achieve full accessibility. In such circumstances, modifications to the method of service provision are being adopted by front office staff.

Whilst the foregoing does not preclude a challenge of non-compliance with the requirements of the Act, our specialist consultants and legal advisors advise that there is a sound case for defence.

F. Background papers

None

G. Contact details

Report author: Alan Croney, Director of Property Services, MPS

For information contact:

MPA general: 020 7202 0202
Media enquiries: 020 7202 0217/18

Appendix 1: Accessibility status of front offices

Appendix 2: Front office refurbishment programme

Already completed:

Colindale

Finchley

Kilburn

Wembley

Holborn

Southall

Havering

Rainham

Hayes

Hillingdon

Chiswick

Feltham

Islington

Kingston

Kennington

Wimbledon

Walworth

Included in present major works:

Acton

Dagenham

Provided by PFI:

Lewisham

Bromley

Sutton

Deptford

For completion by November 2004:

Croydon

For completion by February 2005:

Limehouse

Edmonton

Stoke Newington

West End Central

For completion by May 2005:

Plumstead

For completion by June 2005:

Twickenham

Kensington

Harrow

Hammersmith

Bethnal Green

Bexleyheath

For completion by October 2005:

Hornsey

Chingford

Lavender Hill

Kennington

Forest Gate

2006/7 Programme:

Charing Cross

Ilford

Teddington

Heathrow

Barkingside

Peckham

Walthamstow

Streatham

Golders Green

Kentish Town

Shoreditch

Ponders End

Stratford

South Norwood

Fulham

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