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SOLUTION
REPORT
AMG Performance Centre
Cnr of Ninth Street & Qantas Drive ACCESS
Mascot, NSW
Report Prepared for: M Projects, Marcello Tuteri
Report Prepared by: Philip Chun, Lee Wilson
DOCUMENT ACCEPTANCE
REVISION HISTORY
The information provided within this report is relevant to this project and the documentation referenced. As such
the information provided may not be transferred to other projects. This report must not be issued for public
comment or be used for any other purpose without prior permission from Philip Chun Access.
This determination is made at the request of the applicant and does not absolve the applicant and owner of the
requirements pursuant to the Disability Discrimination Act 1992 (Cth).
Philip Chun Access accepts no responsibility for any loss suffered as a result of any reliance upon such
assessment or report other than to verify the Performance Requirements of the BCA have been met to the
degree necessary.
The project includes internal alterations and additions to the existing building located on the corner of
Ninth Street & Qantas Drive, Mascot, NSW. The building is identified in the extract of the Site Plan
below.
The building is of two-storey construction and has been classified by the Building Certifier as a Class 6
building being an AMG showroom and associated workshop.
During their assessment of the design, the building certifier has identified the following departure from
the Deemed-to-Satisfy (DtS) provisions of the Building Code of Australia 2016 (BCA).
The two fully glazed sliding entry doors do not have a D3.1 DP1
50mm band around the door opening that provides a D3.2(b)
minimum of 30% luminance contrast as prescribed in AS
1428.1(2009), Clause 13.1.
This report is based upon the following relevant Construction Issue architectural documentations
produced by Turner Studio and the Amended Building Permit produced by Department of Infrastructure
and Regional Development Airport Environment Protection and Building Control Office for Philip Chun
Access review:
Architectural
Drawing Number Revision Date
A-110-001 15 18/10/17
A-250-001 15 18/10/17
A-561-001 04 01/05/17
Other
Document Number Revision Date
17_729 N/A Amended 20/10/17
Amended Building Permit
Condition 29
Additionally, this report has been prepared with regard to the previous report prepared by Philip Chun
Access (Ref: AN17-208387 20170215 LTR_LP, dated 24 February 2017) discussing exemptions to
workshop areas.
3. APPLICABLE LEGISLATION
The proposed Performance Solution includes acceptance of the design of two fully glazed sliding doors
that have a reduced level of luminance contrast around the glass sliding doorway, as prescribed in AS
1428.1(2009), Clause 13.1.
The location of the two entry doors is identified in the Figure below:
There are a number of Performance Requirements outlined in the BCA to which any Performance
Solution must comply, in order to meet the relevant functional statements and objectives. Compliance
with these Performance Requirements is mandatory whereas there is no obligation for a design to adopt
the Deemed-to-Satisfy provisions, either in part or in full.
(b) A Performance Solution will only comply with the NCC When the Assessment Methods
used satisfactorily demonstrate compliance with the Performance Requirements.
In addition, this performance based solution report is required by Condition 29 of Amended Building
Permit (Ref. No. 17_729), which states the following:
29) In accordance with Clause 13.1 of AS1428.1-2009, all doorways shall have a minimum
luminance contrast of 30% provided between
(a) door leaf and door jamb;
(b) door leaf and adjacent wall;
(c) architrave and wall;
(d) door leaf and architrave; or
(e) door jamb and adjacent wall.
The minimum width of the area of luminance contrast shall be 50mm.
Prior to the issue of the Certificate of Compliance an alternative solution access report from an
appropriately qualified access consultant is to be submitted to address the glazed entry doors
where the adjacent wall is also glazed.
6. ASSESSMENT METHOD
According to Clause A0.5 of the BCA, the following assessment methods when used individually or in
combination, enable a determination that a Performance Solution complies with the relevant
Performance Requirements:
(a) Evidence to support that the use of a material, form of construction or design meets a
Performance Requirement or a Deemed-to-Satisfy Provision as described in A2.2.
(b) Verification Methods such as
(i) the Verification Methods in the BCA; or
(ii) such other Verification Methods as the appropriate authority accepts for
determining compliance with the Performance Requirements.
(c) Expert Judgement.
(d) Comparison with the Deemed-to-Satisfy Provisions.
In this instance, Philip Chun Access proposes a Performance Solution based on a combination of
Clause A0.5(c) Expert Judgement and Clause A0.5(d) comparison with the Deemed-to-Satisfy
provisions.
As per BCA Clause A0.5, the Performance Solution will be assessed with consideration to the Deemed-
to-Satisfy clauses and objectives of the Performance Requirements as listed below.
The applicable section of DP1 to be considered in this report is DP1(a)(iii) access work and public
spaces, accommodation and facilities for personal hygiene.
8. DEEMED-TO-SATISFY DEPARTURE
The two fully glazed sliding doors do not have a minimum of 30% luminance contrast around each
doorway opening, as prescribed in AS 1428.1(2009), Clause 13.1.
This requirement can be achieved by providing a 50mm wide band with a minimum luminance contrast
of 30% provided between at least one of the following:
9. ASSESSMENT
The proposed design is a departure from the applicable Deemed-to-Satisfy access provisions, and as
such, is it is important to understand the intent of these access provisions and determine any impact to
users of the building.
The requirement to provide a 30% luminance contrast around a doorway is so that people with reduced
vision are able to identify a doorway.
People with a number of eye conditions benefit from a well-defined doorway, clearly identifiable as they
approach the doorway. These include the following common eye conditions where residual eye-sight or
vision loss is experienced:
Diabetic retinopathy: Reduced night vision, sensitivity to glare and patchy vision loss.
Macular degeneration: Resulting in a difficulty to focus, with the central vision blurred.
Retinitis pigmentosa: Reduced night vision, and extreme tunnel vision.
Cataracts: Where eyesight is cloudy causing blurred vision and a sensitivity to glare.
Glaucoma: Damaged optic nerves causing tunnel vision and blurred objects.
To meet the Deemed-to-Satisfy door access provisions the doorway requires a 50mm wide contrasting
band around each side of the doorway.
An important factor in determining the suitability of the proposed Performance Solution is to consider the
typical occupant characteristics within these types of buildings. Under BCA Clause D3.1 and Table D3.1,
the building technically requires access to and within all areas normally used by the occupants, including
the entry doors.
For the purposes of assessing the design for compliance with the BCA, the building is a Class 6 in
accordance with BCA Part A3.
When determining the suitability of the proposed design we can consider the typical building occupant
characteristics within any Class 6 building.
Australia has approximately 1 in 5 people with disability, and the Australian Network on Disability
provides the following statistics:
One can, therefore, assume that there is the potential for a person with a disability to be employed within
the building or a person visiting the building, who could have a vision impairment and these user groups
are obviously the most affected by the door arrangement.
Notwithstanding the above, it is also worth considering the use of the building and roles of staff
employed in the building.
Whilst there is expected to be a number of staff with administrative roles, there will also be sales staff
and workshop staff who would not generally be vision impaired due to the nature of their employment.
In the Philip Chun Access report, reference AN17-208387 20170215 LTR_LP, dated 24 February 2017,
this aspect was discussed and a determination made regarding exemption provisions under Clause D3.4
of the BCA:
i) The work activities as described and understood would make it difficult for a person with permanent
or temporary disabilities to carry out the roles required in the Workshop; and
ii) Applying Clause D3.4 of the BCA / Premises Standards is applicable in this instance and that
access for people with disabilities has been provided to the degree necessary given the function of
the Workshop area.
The report found that the type of duties that would be conducted by the workshop staff includes basic
repairs and service works to Mercedes-Benz passenger vehicles as per the provided job description,
which would require a degree of mobility and is not considered suitable for people with disabilities. This
would therefore naturally extend to consideration of a person with vision loss working in a workshop
environment.
Similarly, it would be reasonable for sales staff to be fully sighted, given their requirement to drive
vehicles within the building and during test drives.
It is important to consider how the proposed design will impact on members of the public and other
visitors to the building.
As discussed in this report, the two fully glazed sliding doors do not have a minimum of 30% luminance
contrast around each doorway opening, as prescribed in AS 1428.1(2009), Clause 13.1 and identified by
the red lines below.
50mm wide 30% luminance The glass fixed sidelight panels on each side of the
No
contrasting band around door and each sliding glass door leaf will be fully
door opening/doorway. glazed without the 50mm band provided around the
doorway.
Automation of the doors on Yes Exceeds the DtS requirements, there is no
approach from both sides. requirement to automate doors.
This greatly benefits all people entering the building
and is considered a universal design concept.
When considering these issues discussed within the assessment above we believe that the design is
comparable to the Deemed-to-Satisfy provisions and provides a reasonable level of accessibility.
As highlighted in this report, the use of the building is an important factor, in that it is highly likely that a
person with vision loss would not be visiting the AMG premises unless accompanied by another person
(given the products and services offered). Additionally, if a person with low vision were employed in the
building they would be orientated and inducted and then have learned familiarity after the initial
commencement of their employment.
10. CONDITIONS
10.1 In all other respects, the project works shall achieve the requirements of BCA Part D3 and
AS1428.1 (2009) to the satisfaction of the relevant building certifier.
10.2 If there is any change of circumstances associated with the occupation and use of the building,
the Performance Solution outlined within this report may no longer be valid. Consequently,
access requirements consistent with the Premises Standards and the current BCA may need to
be implemented if there is any such change of circumstances.
10.3 A compliant horizontal glazing visual indicator band must be provided across the entire width of
each window/door frame assembly in accordance with AS 1428.1 Clause 6.6.
11. CONCLUSION
The proposed door arrangements discussed within this report will satisfy the requirements of
Performance Requirement DP1 by providing access to the degree necessary that is safe, equitable and
dignified appropriate to the use of the building.
This determination has been made at the request of the applicant and does not absolve the applicant
and owner of the requirements pursuant to the Disability Discrimination Act 1992 (Cth) (DDA). It should
be noted that Philip Chun Access has been engaged to provide a professional opinion relating to the
access issues presented in Section 1 of this report and have not been involved in any further aspects of
the project.
Lee Wilson has extensive experience in various facets of construction, property management, workplace health
and safety, risk management, project management and building compliance. For many years he has
specialised in the area of access for people with disability and universal design. Recent projects have included
aged care, educational, healthcare, hospitality, transport, accommodation and mixed-use developments. Lee is
an Accredited Member of the Association of Consultants in Access, Australia.
With an intimate knowledge of the construction industry and a broad range of experience across legislation,
including performance-based building codes, Lee is able to take a practical approach to compliance, whilst
ensuring the needs of all occupants, including those with disability have been met. Lee is passionate about
promoting access and is an active campaigner for Changing Places toilets and for the adoption of universal
design principals.
Qualifications
- Master of Project Management, 2014
- Diploma of Building and Construction (Management), 2012
- Bachelor of Technology (Building Surveying), 2011
- Graduate Certificate in Performance Based Building and Fire Codes, 2008
- Advanced Diploma of Building Surveying, 2008
- Certificate IV in Security and Risk Management, 2008
- Certificate in Access Appraisals Buildings, 2008
- Diploma of Building Surveying, 2007