Disability Discrimination Act 1995 (DDA)
How may Fire detection and alarm systems be affected?
FD&A systems are likely to be affected where they interface with the public, that is:
- The provision and sighting of manual call points
- The methods by which an alarm is annunciated
- Features that may be controlled by the fire system along escape routes such as automatic door closers or route signage
Manual call points are not specifically mentioned in the act, but guidance is given in section 20 of BS 5839-1 where a significant proportion of the occupants have limited mobility. In particular clauses 20.2(e) and 20.2(h) refer to area where a reduction in travel distance and a small reduction in mounting height to help the disabled, where mobility may be reduced. In the majority of public areas there is unlikely to be a need to deviate from the normal distribution of call points as there will be able bodied people who can operate a call point and assist those less mobile. However the requirements of 20.2(h) to mount the call point in well illuminated positions on a contrasting background should be headed to assist the partially sighted. Similar consideration may be required for green call points used to release electrically locked doors.
Alarm sounders are specifically mentioned in the DDA and examples are given where audible alarms should be supplemented by visuals. This is reinforced by Approved Document M that states:
4.24 Sleeping accommodation will satisfy Requirement M1 if:
18.104.22.168.1. e) all bedrooms have a visual fire alarm signal, in addition to the requirements of Part B
5.4 Sanitary Accommodation will satisfy Requirement M1 or M3 if:
(22.214.171.124.2. g). Any fire alarm emits a visual and audible signal to warn occupants with hearing or visual impairments;
(Note: M1 = Access and Use, M2 = Access to Extensions to buildings other than Dwellings, M3 = Sanitary Conveniences in Extensions to Buildings other than dwellings.)
BS 8300 Design of buildings and their approaches to meet the needs of disabled people. Code of practice, was used as the base standard for many of the requirements in Approved Document M and states:
“Consideration should be given to the installation of alarm/alerting systems for people with impaired hearing, such as flashing visual devices and vibrating devices, for use in conjunction with proprietary or conventional systems.
Note 1: These devices can take the form of wearable paging units, pillow vibrating units or under mattress pads designed to wake a person from sleep.
Note 2: Certain frequencies in flashing/stroboscopic light systems can cause confusion, disorientation, and in some people epileptic fits.”
The standard goes on to specifically recommend that the fire alarm systems should be both visual and audible in kitchens, sanitary facilities and bedrooms.
BS5839-1 section 18 specifically deals with “Fire alarm warnings alarms for people with impaired hearing”, while section 17 covers the use of “Visual alarm signals”.
Although visual alarm devices are mentioned they are not the only alarm devices that may be employed. BS 5839-1 18.2.1 allows for tactile alarms whether fixed moveable or portable. Portable devices are those that may be carried on the person and can use radio, induction loop or infrared technology. They should however be considered as a supplement to the primary means of giving an alarm. Where visual alarm devices are installed in sleeping accommodation they should not be considered the primary method of waking sleeping persons the other devices described above should be used.
Fire Doors, not mentioned in the DDA, but are covered in Approved document M 3.10 Internal doors will satisfy requirement M1 or M2 if:
k) fire doors, particularly those in corridors, are held open with an electro-magnetic device, but self-close: when:
- activated by smoke detectors linked to the door individually, or to a main fire/smoke alarm system;
- the power supply fails;
- activated by a hand-operated switch;
Frequently asked Questions
What devices can be installed to meet the requirements of the DDA?
The DDA itself requires that reasonable adjustments are made to accommodate disable persons. How this is achieved will depend on the type of building and its use. Approved document M states that the requirements can be met by installing additional visual alarms in bedrooms and sanitary accommodation. BS 8300 recommends the use of additional flashing visual devices and vibrating devices.
Currently the additional visual devices can either be a separate visual device, or a combined sounder/visual device which some manufacturers supply.
Should visual devices be installed throughout the premises?
As mentioned earlier as the DDA itself requires “reasonable adjustments” and BS 8300 and AD M only specify that additional visual devices be installed in kitchens, toilets and bedrooms, there is no set requirement to install them throughout a premises. The decision to do so should be taken after a risk assessment is carried or at the request of the client.
What spacings should be used when installing the additional visual devices?
In the absence of any UK standards we suggest you seek the advice of the manufacturer. However as a rule of thumb the following spacing for visual devices can be considered:
- For large public areas one visual device for every 3 detectors/sounder i.e. about 1 every 30m.
- In small sanitary facilities and bedrooms one device should be sufficient.
- For large rooms similar spacings to public areas should be considered.
How bright should the additional devices be?
At present there is very little experience or guidance in the UK on the required light output of the visual devices to alert deaf persons. There has been a great deal of work done on this in the US and NFPA 72 goes into great detail in deciding what should be specified depending on room size and geometry but this may not directly translate to UK experience. BS 5446-3 the product standard for alarm devices for Deaf person in residential premises specifies a light level but the devices incorporate a vibrating device as well as the flashing visual device. The colour of the light is also important. We recognise that the light output of the device is related to the power required to drive the visual device, the brighter the light the greater the power required. If very bright visual devices are required this will have an effect on the design of fire alarm system in the UK. BFPSA is currently discussing the light output of visual devices with BSI and ODPM. It is hoped that ODPM will support a research project to determine the light output of visual devices.
Visual devices in sleeping accommodation
ODPM have confirmed that it was never the intent of the UK Regulations that visual devices in bedrooms should be the primary means of waking a sleeping person. It is recommended that the visual device in bedrooms should be supplemented by an additional means of waking the persons with reduced hearing abilities, such as a vibrating device.
- Disabilities Discrimination Act 1995
- Discrimination (employment) Regulations 1996
- Disability Discrimination act 1995 Code of Practice Rights of Access Goods, Facilities, Services and Premises. Disability Rights Commission 2002
- Approved Document M Access and facilities for disabled people
- Building Standards (Scotland) Regulations
- BS5839-1 2002. Fire detection and Alarm systems for buildings – Part 1: Code of practice for design, installation, commissioning and maintenance
- BS8300: 2001. Design of buildings and their approaches to meet the needs of disabled people. Code of practice to make reasonable adjustments.
- BS 5446-3. Fire detection and fire alarm devices for dwellings. Specification for smoke alarm kits for deaf and hard of hearing people
- NFPA 72. National Fire Alarm Code