Education Buildings & ‘Educational Facilities Standards and Guidelines’ (EFSG)
Ensuring accessibility within education grounds, facilities and building is key to the provision of educational institutions which are inclusive and welcoming to all students. At MGAC, we have a proud history of involvement across countless projects in the Education sector, from small additions to primary schools, through to major multiple building developments at university campuses.
In our latest blog, Access Consultant John Ward takes a closer look at the Educational Facilities Standards and Guidelines (EFSG), and how MGAC works with them.
What are the Educational Facilities Standards and Guidelines (EFSG)?
The EFSG is a set of documents maintained by the NSW Department of Education (DoE). In their words, the EFSG “are intended to assist those responsible for the management, planning, design, construction and maintenance of new and refurbished school facilities”.
In regards to disability access, the EFSG repeats the mandatory requirements under the National Construction Code (NCC) and the Disability (Access to Premises – Buildings) Standards. It also contains measurable and specific requirements which are above minimum compliance, such as 1350mm minimum width path of travel. Our consultants routinely encounter the EFSG in educational settings, for example in New South Wales primary and secondary school spaces (including SSPs, or ‘Schools for Specific Purposes’).
Despite our regular contact with the EFSG, the documents can still cause much confusion. For example, the following statement in the EFSG Design Guide is a source of constant consternation for design professionals in the field:
“Generally AS 1428.1 is the minimum design standard for access and mobility. However, it is DoE’s policy that any enhanced requirements noted in AS 1428.2 be incorporated in any new design”.
Regrettably, the EFSG does not specify these ‘enhanced requirements’ – it is such an open-ended statement. As a consequence, it is left to the interpretation of all involved. More often than not, this lack of clarity can lead to difficult discussions late in a project, especially if there is a difference of opinion between consultants or project managers.
It is worth noting that no two architects or two project managers will have exactly the same opinion on most subjects.
How MGAC contends with the EFSG
Every MGAC consultant always strives to clarify our position on the EFSG requirement for the benefit of our clients, design professionals, and construction contractors we work with.
For us, the key wording from the EFSG is ‘enhanced requirements’. AS 1428.2-1992 is titled ‘enhanced AND additional requirements’. In this case, the content of AS 1428.2 falls into one of two categories as described in the preface to the document as follows:
“The purpose of this Standard is twofold. First, it covers items which are not covered in AS 1428.1, Design for access and mobility, Part 1: General requirements for access – Buildings, and second it gives enhanced requirements for access, for reference by authorities and other users who wish to provide a greater level of accessibility than the minimum requirements of Part 1.”
Breaking this down a bit more, this means that for something to be an ‘enhanced requirement’, as required of EFSG, it must firstly have coverage in AS 1428.1, and the corresponding section of AS 1428.2 must describe a higher level of access.
An analysis of AS 1428.2 reveals that a large amount of the content falls into the ‘additional’ category and includes:
· Urinals and baths
· Signage location and illumination
· Emergency warning systems
· Lighting and sound levels
· Hearing augmentation
· Reach ranges and window controls
· Furniture and fitments
· Viewing ranges
· Podiums and stage areas
· Street furniture
· Drinking fountains and water coolers
· Gateways and checkouts
· Vending machines
· Post boxes
· Time delay for lights at pedestrian crossings
In MGAC’s opinion, it is not the intent of EFSG to require such a large number of ‘additional’ – and sometimes onerous – requirements. This is supported by the choice of the word “enhanced” in the EFSG Design Guide.
Analysis of the remaining items in AS 1428.2 reveals that the ‘enhanced’ requirements include:
· Continuous accessible path of travel
· Walkways ramps landings stairs
· Ground and floor surfaces
· Handrails and grabrails
· Sanitary facilities
· Symbols, signs and TGSIs
It must also be noted that given AS 1428.2 has not been updated since 1992, many of the ‘enhanced’ requirements relate to a comparison with the version of AS 1428.1 at the time. AS 1428.1, which is the referenced mandated standard under the National Construction Code (NCC) and the Disability (Access to Premises – Buildings) Standards, now dates from 2009 – and in some areas the requirements match AS 1428.2-1992.
A clear example of this is the WC circulation size of 2300mm x 1900mm, which is identical in both standards. 30 years ago, it was considered an ‘enhanced’ requirement. Nowadays, it is the minimum standard.
Working with MGAC
MGAC always advocates for best practice accessibility in all building types and in all public domain spaces. We proudly provide this advice and actively encourage clients to integrate accessibility initiatives and expertise at the earliest possible stage of any project.
As the complications with the EFSG demonstrates, early involvement of a disability access consultant can save a lot of headaches down the line for project managers and architects alike. Aside from review of minimum mandatory compliance under the BCA/NCC and Premises Standards, it is also important to establish minimum compliance of any relevant design guideline, such as a Development Control Plan or the EFSG.
Our consultants always advise clients to go above and beyond their minimum obligations under the BCA/NCC. Instead, we encourage all our clients to continue raising the bar for improved accessibility outcomes through respectful collaborative dialogue – all the things MGAC is renowned for.