Briefing on the Interim Changes to the Guidance on the Use of Tactile Paving Surfaces
Briefing on the “Interim changes to the Guidance on the use of Tactile Paving Surfaces”
Introduction
Tactile paving is vital tool used by blind and partially sighted people which enables them to navigate their environment. The Government are considering making changes to the national framework detailing how tactile paving is used and implemented. Some of these changes concern us.
The ‘Guidance on the use of tactile paving surfaces’ was originally published in 1998 following extensive research and consultation with organisations representing blind and partially sighted people.
Despite the thorough research and consultation that preceded the publication of the Guidance, it has not been universally followed by local authorities. On occasion this has been deliberate, but has often been due to a lack of understanding of the principles contained within it.
In 2012 a blind and partially sighted campaigner legally challenged the London Borough of Newham’s decision to depart from the Guidance. Newham proposed to only lay tactile paving at controlled crossings and that paving would be grey.
The Court decided that it was unlawful for Newham to have departed from the National Guidance without good reason (the Court found that they had none). The decision emphasised the need for uniformity in tactile paving across the country andthat the Guidance had been subject to extensive research and consultation prior to publication
However, since the Newham decision some authorities have continued to depart from the Guidance; in particular the use of grey tactile paving at controlled crossingsis becoming much more common. As street design has moved on with the increasing use of shared space, removal of railingsetc,the Department of Transport (DfT) has decided thatinterim changes to the Guidance are needed to ensure that it is fit for purpose.
RNIB agrees that the Guidance needs to be reviewed and updated to ensure that it is fit for purpose, and we have urged the Department to begin this process as a matter of urgency. We are concerned that piecemeal changes to the Guidance could lead to further departure from it, even where the Guidance remains relevant. However, we recognise that some of the proposed changes to the Guidance may be helpful.We are keen to hear from blind and partially sighted people, rehabilitation workers and those representing local authorities to understand whether the changes proposed are the right ones, and whether they should be made prior to a full review of the Guidance.
This briefing sets out the recommended changes to the Guidance and RNIB’s initial views on these changes.
Section 5
Relaxation of the requirement for the back edge of an area of blister paving to be perpendicular to the crossing direction with two options – straight or curved edge.
Where a crossing point is located near a curved section of pavement, there may be asignificant amount of blister paving which may be confusing for blind and partially sighted people and create other problems for those with mobility difficulties. This is because it has to have a minimum of 800mm between where it starts and the kerb, and it has to have a straight edge along its length.
The consultation suggests two alternatives. The first is that the tactile will follow the kerb edge at a depth of 800 or 1200mm depending on the type of crossing. The second option is a stepped approach which would mean that there was no longer one long straight back edge, but instead a series of shorter straight edges, while maintaining a consistent depth of at least 800mm.
RNIB’s initial view
RNIB is concerned about the loss of the long back straight edge. This was previously included so that blind and partially sighted people could align themselves correctly in the direction of the crossing. We are also concerned that the curved approach may be impractical because it will require those installing the tactile paving to have to cut many more tiles to achieve the correct shape. This will impact upon costs as well as the time it takes to lay the paving. If the paving is not installed correctly this could lead to increased trip hazards, and there may be maintenance issues. We are concerned that the stepped approach, although an improvement on the curved edgeproposal,could also cause confusion.
At present, our view is that this change should not be made and that further research and consultation needs to be undertaken to ensure that the changes are appropriate. However, we are keento hear from stakeholders particularly blind and partially sighted people before finalising our view.
Section 6
Replacement of the requirement for the blister paving at a controlled crossing to be red with a requirement for at least a 50% contrast ratio with the surrounding paving
The current Guidance requires that the blister paving at controlled crossings is red in order to assist partially sighted people to distinguish the presence of a controlled crossing. It was also thought to assist sighted pedestrians and drivers. Red does not have to be used in conservation areas.
The Department is concerned that as design preferences have changed the use of red no longer provides sufficient contrast. The proposal also seems to reflect existing practice amongst some local authorities.
The consultation document proposes that the presence of a controlled crossing should provide a contrast ratio of at least 50%to the surrounding paving, in both wet and dry daylight conditions, and when illuminated by street lighting at night.
RNIB’s initial view
RNIB recognises that the continued use of red may no longer provide sufficient contrast with the surrounding paving in order to be beneficial to partially sighted people. We also understand that providing a minimum level of contrast in dry and wet conditions is potentially more helpful. We acknowledge that grey and charcoal tactile is being used increasingly by authorities. We are however, concerned that the use of minimum contrast, rather than a specific colour, undermines the principle of uniformity (highlighted in the Newham case). We are also concerned that local authorities may not have resources or capacity to hold the range of colours of tactile paving necessary to achieve the contrast.
At present, on balance, our view is that this change should not be made and that further research and consultation needs to be undertaken to ensure that this is appropriate. However, we are keento hear from stakeholders particularly partially sighted people before finalising our view.
Section 7
Introduce a universal requirement for the boundary between carriageway and footway to be demarcated with tactile paving wherever they are at the same level.
The existing Guidance recommends that where an “extensive” section of carriageway has been raised, the tactile should be confined to the crossing point, and the remaining area should maintain a level difference of at least 25mm or have a continuous physical barrier e.g. planters or railing. Where an entire junction has been raised, the Guidance recommends the continuous use of a physical barrier e.g. guard railings.
The difficulty with the existing Guidance is that there is a movement in highway design to remove continuous barriers e.g. railings; but they have not been replacing these with an alternative barrier. Coupled with this is the increasing use of shared spaces and raised junctions. The use of 25 mm is unhelpful because there is research to suggest that 60mm is the minimum that can be reliably detected by blind and partially sighted people.
The consultation document does not propose what type of tactile paving should be used, it only suggests a minimum depth of 800mm. The Department has suggested that this will require further research and consultation as part of the larger research project.
RNIB’s view
RNIB opposes this change. We believe that the best way of differentiating between the carriageway and the pavement is through the use of a kerb. In accordance with the requirements of ‘Inclusive Mobility’, we believe that the kerb should be at least 125mm. We are concerned that this proposal gives the green light to the increasing use of flush surfaces.Highways departments should always seek to use a kerb unless there is very good reason not to, and they should always take professional advice from an access consultant and seek the views of blind and partially sighted people before removing a kerb.
Where a kerb is removed, we agree that it is essential that a barrier is maintained or tactile paving of at least 800mm is installed. However, we are concerned if no guidance is given on what paving should be provided, not only will there be a lack of consistency but also the potential for confusion(e.g. people might be expecting bicycles on the path and not realise they are on a road).
Rather than revising the guidance we would urge the Department to write to local authorities explaining the importance of kerbs and the potential discriminatory effect of removing them.
Section 8 - Suggestions for crossing improvements
These two linked recommendation are not directly related to tactile paving, but were raised at the DfT workshop which preceded the consultation. It was felt that they could improve some people’s experience when using pedestrian controlled crossings.
Push buttons on both sides of a controlled crossing with rotating cones.
At busy junctions people with sight loss are sometimes unable to reach the rotating cone which is always installed on the right. The proposal in the consultation is that where there are boxes on both sides each should have a cone.
RNIB’s view
This seems very sensible and will increase the chances of all people who rely on rotating cones to be able to use this feature. However, we would also stress the continuing requirement, when local authorities are installing and maintaining crossing to ensure that the ‘bleeps’ are switched on unless there is a nearby controlled crossing where the beeps would conflict and cause confusion.Inclusive Mobility states:-
“Tactile indicators should not be considered as a substitute for audible signals as they are required by different people, although some will benefit from both.”
Control boxes to have tactile arrows indicating the direction of crossing
It is proposed that tactile arrows are included on push-button boxes and would present a more effective way of indicating crossing direction than the back edge.
RNIB’s view
We believe that the inclusion of a tactile arrow would be helpful in providing additional directional information, but this should not be a replacement for a straight back edge at controlled crossings. In addition there may be maintenance issues to ensure that the arrow is always facing in the right direction.
How to respond
The consultation is open until 13 November 2015. If you would like to respond, or read more about the consultation visit the Government website.
The Department for Transport will be holding workshops in London, Bristol and Manchester where tactile models of the proposed changes will be available for users to try. We would urge as many people as possible to attend. The dates are as follows:-
- London: 29th October from 2.00pm to 4.00pm in Greenwich
- London: 2nd November 10.30am to 12.30pm in Great Minister House
- Bristol: 4th November 10.30am to 12.30pm (Venue TBC)
- Manchester: 5th November 10.30am to 12.30pm in Transport for Greater Manchester HQ
Please contact if you would like to attend or for further details.
23 September 2015
rnib.org.uk