Frequently Asked Questions

The Disability Rights Commission (DRC) closed on September 2007. Its responsibility for helping secure civil rights for disabled people has now transferred to the new Equality and Human Rights Commission. The Disability Rights Commission had prepared a guide: ‘Access Statements: Achieving an inclusive environment by ensuring continuity throughout the planning, design and management of buildings and spaces’, which is still available on the DRC archived website.

Yes. In new build dwellings, particularly flats, planning for floor level gravity drainage requires recesses and connections in the floor which may prove unreasonably difficult to achieve. Shower waste pump kits can be fitted as an alternative when gravity drainage is not an option and it would be reasonable in these circumstances for the future level access shower provision to be designed to accept this arrangement. Drainage solutions that work using gravity drainage will perform and maintain better.

For purpose-built and purposed designed Category 3 dwellings it may be reasonable to expect a gravity drainage system from the outset.

A landing is defined in common usage as “a level area at the top of a staircase or ramp or between one flight of a stair or ramp and another” and it would be reasonable to expect these landings to have a gradient between 1:40 and 1:60.

It is possible that some ramped approaches may incorporate gradients of 1:12, but in general, a ramped approach should have gradients in accordance with lengths and rises shown in diagram 2.1.

This meets provision 2.22d where a door opens inward (shown dotted) to provide a leading edge.

Diagrams 2.5 and Diagram 3.10 each set out acceptable requirements for projection by a hand-rinse basin or wash hand basin into the WC access zone for each category. Typically this is up to 200mm and clear of the pedestal or trap beneath the wash hand basin, or 300mm for a wash hand basin adjacent to a WC. It would be reasonable for a hand rinse or hand wash basin to project up to 200mm into a turning circle (where necessary) providing this remains clear of pedestal or trap underneath the basin. For Category 2 a 450mm deep wash hand basin may extend its full depth adjacent to the tap end of the bath with the 1100mm clear access zone required beyond the basin.

A projecting corner is typically created by a wall projecting outwards beyond the plane of the door. It would be reasonable for door controls to be positioned at least 300mm from any corner or obstruction that would prevent a wheelchair user accessing the controls in the same way as is done with the 300mm nib required for doors.

Where the approach is head on, and where the double doors are not the principal or alternative entrance, it would be reasonable for at least one or both leaves to have individual clear opening widths of 750mm. Where both leaves of a double door can be operated with a single action, door leaves smaller than 750mm may be reasonable providing that the Building Control Body is satisfied that the doors in combination are reasonably accessible to a wheelchair user.

The term porch or lobby is intended here as a private and domestic front porch or lobby to a dwelling. Lobbies created in corridors or other circulation spaces elsewhere in the dwelling do not need to comply with requirements of 2.20i but should comply with requirements for hall and door widths in paragraph 2.22. Door swings into a private lobby or private porch should be designed so that a wheelchair user can practicably enter the private lobby and then turn to close the door.

The requirement for 1500mm between door swings should be measured with doors closed where one leaf opens into the lobby, and the other opens outwards but should be measured between open door swings where both doors open into the lobby. Door swings to a non-habitable room such as a WC or a store door opposite the front door would not require this 1500mm dimension.

Yes, for Category 2 where there is a need to insulate inhabited areas below a balcony or terrace a step-up of up to 225mm would be reasonable. This does not apply to Category 3.

A minimum of 1200mm should be maintained between fixed built in elements such as walls or kitchen cupboards. Loose furniture can encroach into the minimum clear access space of 1200mm set, whilst not a requirement it would be reasonable to expect a route at least 750mm clear to be maintained between any loose furniture and fixed units.

Paragraph 2.29 requires that an accessible bathroom is located on the same storey as the principal bedroom defined in paragraph 2.25b. In a dwelling where accommodation is set out over three storeys or more, it would be reasonable for a twin room, or a double bedroom (as an alternative to the principal bedroom) to be located on the same floor as the accessible bathroom required by paragraph 2.29 providing that the relevant requirements for circulation are demonstrated for that type of bedroom.

Diagram 2.4 shows 750mm width to the side of beds and 750mm at the foot of beds, with wardrobes or other furniture outside the access zone. Bedside furniture is permitted to sit to the side and at the head of the bed and up to a zone of 600mm away from the wall at the head of the bed. Furniture used to demonstrate compliance would reasonably be in accordance with the dimensions given in the furniture schedule in Appendix D.

Drop down rails to facilitate transfer to a WC are likely to be required to either side of the WC, whilst handrails and supports subject to a lower loading are likely to be required elsewhere. On that basis, it would be reasonable to expect the wall behind the WC to support a load of 1.5kn, but it may be reasonable for other walls to support a reduced load of 0.85kn. It would also be reasonable to design to meet these loads only in the zone where hand rails are likely to be fixed e.g. between 300-1500mm above finished floor level. Where boxing is not a reasonable fixing point, it may not need to be strengthened. Detail on location of wall strengthening can be discussed on a case by case basis with the Building Control Body.

For Category 2 M4(2) in every dwelling which has a principal double bedroom, it is deemed reasonable to require that the dwelling has a bathroom containing a WC, a basin and a bath as described in paragraph 2.29b. These requirements are assumed for properties with two or more occupants. For smaller one-person dwellings (for instance, a 1b1p as defined by the Nationally Described Space Standard) it may be reasonable for a shower to be provided instead of a bath as a permanent layout providing that the requirements of Diagram 2.5 for clear access zones continue to be met.

A 300mm nib is required for a head-on approach to a gate or door to ensure that the door can be approached and opened by a wheelchair user – the nib allows a wheelchair foot rest (or other mobility aid) to project beyond the line of the door frame, enabling a wheelchair user to reach the door handle.

When the internal approach is not head-on, a nib may not be required for all of the 1200mm (Cat 2)(2,20f) or 1800mm (Cat 3) (diagram 3.3 and 3.24f) distance as indicated, provided that the proposed layout creates the movement space for a wheelchair user to approach the door controls and use the door handles to open the door.

Diagrams 2.5 and Diagram 3.10 each set out acceptable requirements for projection by a hand-rinse basin or wash hand basin into the WC access zone for each category. Typically this is up to 200mm and clear of the pedestal or trap beneath the wash hand basin, or 300mm for a wash hand basin adjacent to a WC. It would be reasonable for a hand rinse or hand wash basin to project up to 200mm into a turning circle (where necessary) providing this remains clear of pedestal or trap underneath the basin. For Category 2 a 450mm deep wash hand basin may extend its full depth adjacent to the tap end of the bath with the 1100mm clear access zone required beyond the basin.

The change from 800mm to 950mm in the corrigenda was to provide the necessary distance between centre line of a WC pan and the centre line of a wash hand basin. This should not be understood as the requirement of space between a WC and the edge of a wet room shower.

Diagrams 3.10 and 3.11 show the maximum encroachment of basins into the WC access zone – the maximum penetration is typically 200mm, but 300mm adjacent to a WC. In wheelchair accessible layouts (diagram 3.11 and paragraph 3.36h) the intention is that there is a clear zone from the floor to the underside of /drainage/pipes/ services of between 400-600mm. This is to maximise ease of approach, whilst recognising that services have to be accommodated in some form. It is anticipated that pipes and drainage may need to be through-wall penetrations to achieve this result rather than running to the floor. Diagram 3.16A shows wash hand basin access zone encroaching by 200mm, in line with requirements set out in 3.11.

Category 3: Wheelchair user dwellings require that fully furnished layouts should be provided for both adaptable and accessible options in order to demonstrate compliance. These layouts should include all of the furniture set out in Annex D (other than coffee tables and occasional tables which are optional, and where included may sit within manoeuvring zones) which shows typical module sizes, the number of elements per room and per size of dwelling. Other than for Category 2 Bedroom layouts, and for sanitary accommodation, furnished layouts are not required to demonstrate compliance of Category 1 or 2 dwellings.

It would be reasonable for living rooms in an 8 person home to have 8 seats, not 1 as is currently shown in Appendix D: Furniture Schedule. The 8 seats in the living room can be distributed between combinations of 2 and 3 seat sofas and 1 seat armchairs, Furniture layouts are required to demonstrate compliance in a Category 3 layout.

As set out in the furniture schedule a 1200x600mm wardrobe is preferable to accommodate additional storage required for assistive aids, but where the circulation requirements cannot be met with the minimum bedroom area, a 600x600mm

No – this is an error. A ramped approach should have gradients in accordance with lengths and rise shown in diagram 3.1 and gradients of 1:12 are not permissible in approach routes to Category 3 dwellings.

Stacks and services should be located outside of the grey shaded clear access zones shown for both Category 2 and Category 3 bathrooms to ensure that a wheelchair is able to use the bathroom effectively. In Category 3 wheelchair accessible bathrooms and WC/ Cloakrooms, the access zone extends to the rear of the cistern to enable assistive devices to move up to the surface of the wall. Wheelchair adaptable layouts will need to be capable of simple alteration to also meet this requirement.

A planted door stop can be easily repositioned to allow a door which opens inwards to be re-hung outwards without the need to change the door frame as a whole. Category 3 Wheelchair adaptable dwellings can, therefore, have inward opening doors, but must be capable of easy adaptation to provide the outward opening door required for Category 3 Wheelchair accessible dwellings. Flats typically need outward opening doors on the entry-level accessible WC.

There is a risk that when a wheelchair user exits the lift they could manoeuvre dangerously close to the top step of a flight of stairs depending on the layout of the landing area. Consideration needs to be given to ensuring reasonable distance between the top step and the edge of the manoeuvering circle.

The underlying principle in Category 3 dwellings is that wheelchair adaptable dwellings should be capable of being simply adapted to meet the needs of a wheelchair user, or designed at the outset to do so. In demonstrating compliance for all M4(3) dwellings, a sensible approach would be to firstly design for a wheelchair accessible layout which complies in all aspects with requirements of M4(3) 2b including bathrooms, corridors, doors, bedrooms and kitchens. Designers can then modify that design utilising the greater flexibility provided by requirements for adaptable dwellings.

When considering alterations required to change an adaptable dwelling into an accessible wheelchair user dwelling it would be reasonable to allow for moving lightweight internal partitions and the associated making good works or moving local wall mounted services, sockets and plugs. Moving or modifying structural walls, block work walls, party walls or fire compartment walls, soil stacks, soil vent pipes and major building services may not be considered a reasonably simple alteration. Any change however simple should still comply with all of the relevant requirements of the building regulations.

Ideally, the storage and transfer space should be sited adjacent to the hallway or corridor of a dwelling and nearby the principal entrance. This arrangement should also comply with escape requirements set out in Approved Document B (Fire Safety) for that type of dwelling. To do so, in some circumstances it may be necessary for the wheelchair transfer and storage space to be located away from the entrance area but still on the same storey.

Furnished layouts for Category 3 housing are required and in those layouts, loose furniture can encroach into the 1500mm access zone required by paragraph 3.32b, though a clear route at least 750mm wide must be provided. 1500mm clear should be maintained between any fixed building elements or kitchen cabinets.

An adaptable kitchen must be capable of being easily adapted to provide an accessible layout. Concealed drainage such as inaccessible stacks or drainage behind boxing, walls or partitions should not need to be extensively modified to support an accessible layout. It would, however, be reasonable for easily accessible connections to stacks and surface mounted drainage inside cupboards, or services mounted against walls to be altered to meet an accessible layout.

The intent is that wheelchair users are able to approach and use the basin. Typically this requires some space at low level below the basin for an approach to be made and for full pedestal basins to be avoided. Semi pedestal basin types are permissible, and providing that it can be demonstrated that a wheelchair user can approach the basin, the lower extent of the basin may be lower than the typical range of 400-600mm above finished floor level.

Do WC pans need to pro-Diagrams 3.10 and 3.11 both state that the size of the sanitary units are given as minima in the furniture schedule in Appendix D. Using other sizes may affect the overall size of a bathroom or cloakroom. Using a larger unit than the 500x700mm WC + cistern given in the guidance may, therefore, impact on the overall clearances and room sizing needed to make a compliant bathroom, cloakroom or wet room. Larger units are permissible if the knock-on effect to overall room dimensions is factored into the sizing of a room’s layout. ject no less than 700mm in order to fit with the furniture schedule and also be clear of all boxing-in and pipework?

The requirement for M4(3)2a is for a bathroom that is capable of simple adaptation at a future date to become wheelchair accessible in compliance with M4(3)2b. It need not be completed and delivered as a wheelchair accessible bathroom, but does need to be equiped with suitable services and adequate overall dimensions. The simplest way to demonstrate compliance is to design an accessible bathroom, and then modify the layout to meet the more relaxed requirements for an adaptable bathroom.

It would be reasonable for wheelchair adaptable bathrooms to have either a level access shower or a level access shower with a bath fitted over at the point of completion. Wheelchair accessible bathrooms should have the level access shower available at point of completion. Where a bath is not provided in addition to the shower at completion there should be sufficient space above the level access shower for a bath to be fitted, whilst still being able to comply with the access zone requirements set out in diagram 3.11 once the bath is in place. These bathroom layouts should provide a turning circle of 1500mm when the door is closed as explained in paragraph 3.43e.

Wheelchair accessible properties must always provide an accessible shower as a minimum at the point that the properties are complete.

It is always preferable for a shower to be positioned in the corner of a bathroom, and this should be the case wherever possible. It would be reasonable for a shower to be away from the corner as shown in diagram 3.17, but only where both a bath and a shower are in the same room and the shower can be increased in area at a later date if necessary.

Category 3 Bathrooms should provide a 1500mm turning circle free of low-level obstruction that provides 360’ access and movement for a wheelchair user. Ellipses are not used to demonstrate compliance in bathroom, cloak room or wet rooms.

Category 3 bedrooms require that a 1200mm manoeuvring square is used to make reasonable provision for space around beds and between doors and other bedroom furniture.

In living areas / the lounge of a Category 3 dwelling, either a 1400×1700 ellipse or the 1500mm turning circle can be used to demonstrate a reasonable manoeuvring zone.

No. The storage space in the wheelchair standard should not include plant or equipment – the space is intended for storage of additional wheelchair or mobility/health equipment which typically exceeds requirements in other forms of housing.

Reasonable provision should be made in the layout and structure of dwelling to make it easy to fit these features later, to suit any specific needs of the householder, but these are not required at completion. Note that in buildings other than dwellings, Approved Document M (Access to and use of buildings) Volume 2: Buildings other than dwellings specifies where grab rails and drop down rails should be fitted that meet the most common needs of disabled people.

“Habitable rooms” are defined in Approved Document M: Volume 2 Buildings other than dwellings under paragraph 0.26 as “… for the purpose of defining the principal storey [habitable room] … a room used, or intended to be used, for dwelling purposes, including a kitchen but not a bathroom or a utility room.

Guidance in paragraph 2.29 of Category 2 asks for a bath, a washbasin and a WC to be provided. In some types of home or in certain circumstances it may be reasonable for the bathroom to be equipped with a shower instead of a bath, providing that;
there is sufficient room for a bath to be installed in place of the shower at a later date.
it can be demonstrated that the bathroom can still comply with the requirements for clear access zones in diagram 2.5 once a bath is installed.

Yes, to the extent possible within the constraints of the existing building, as set out in the Access Statement.

Approved Document M does not include guidance for handrails and guarding to external ramps, because this is covered in detail by Approved Document K clause 2.12 (page 20), where it states that in dwellings and for common access areas in buildings that contain flats: Provide all of the following:
a. For ramps that are less than 1000mm wide: provide a handrail on one or both sides.
b. For ramps that are 1000mm or more wide: provide a handrail on both sides.
c. For ramps that are 600mm or less in height: you do not need to provide handrails.
d. Position the top of the handrails at a height of 900mm to 1000mm above the surface of the ramp.
e. Choose handrails that give firm support and allow a firm grip.
f. The handrails may form the top of the guarding if you can match the heights.

An ambulant disabled person should be able to hold a handrail for support either before taking the first step up or down or after reaching the landing from the last step in a flight. That should normally be possible where the handrail continues around the central well of a stair without further extension onto the landing, particularly if the handrail continues in an unbroken radius.

Approved Document M “Access to and use of buildings” Volume 2: Buildings other than dwellings (ADM Vol.2) currently states: “Approved Documents are intended to provide guidance for some of the more common building situations. However, there may well be alternative ways of achieving compliance with the requirements. Thus there is no obligation to adopt any particular solution contained in an Approved Document if you prefer to meet the relevant requirement in some other way.

BS 8300:2001 ‘Design of buildings and their approaches to meet the needs of disabled people – Code of Practice’ supersedes BS 5619:1978 and BS 5810:1979. BS 8300 provides guidance on good practice in the design of domestic and non-domestic buildings and their approaches so that they are convenient to use by disabled people. The design recommendations are based on user trials and validated desk studies which formed part of a research project commissioned in 1997 and 2001 by DETR.

The guidance in Approved Document M is based on and is complementary to the BS, although the BS contains much additional material that is not apt for, or not considered appropriate for, inclusion in guidance accompanying regulation. Also, in a few cases, the guidance in AD M differs from the recommendation in BS 8300. Compliance with the recommendations in the BS, therefore, while ensuring good practice, is not necessarily equivalent to compliance with the guidance in ADM Vol.2.”

Where the recommendation in BS 8300 implies a higher standard than that recommended in ADM Vol.2, clearly that would be acceptable. Also, where the BS recommendations post-date the publication of AD M and are based on new or re-evaluated research, such as described below, those recommendations too may be considered acceptable alternatives to the guidance in ADM Vol.2.

The BSI committee responsible for BS 8300:2001 published a consolidated amendment (Amendment 1:2005) to the BS in June 2005, prior to commencing work on the major quinquennial review of BS 8300. This amendment addressed a number of issues, some of which relate only to BS 8300, and some common to BS 8300 and ADM Vol.2.

Two or three issues, in particular, are known to have caused some difficulty to industry and the design and building control professions. In order to assist in resolving these concerns, the BS committee has undertaken a review of the research on which the recommendations in both BS 8300 and ADM Vol.2 were based. Where appropriate, guidance based on consideration of the BS amendment is included in the FAQs below.

Contrasting material means material with a visual contrast.

The Design Considerations in Approved Document M: Volume 2 Buildings other than dwellings 3.17 make it clear that “…a passenger lift is the most suitable means of vertical access and should be provided wherever possible. However, given the space constraints in some buildings, it may not always be possible to install the type and size of passenger lift that would be suitable for use by all, and other options may need to be considered to provide for users with mobility impairments.”

Approved Document M: Volume 2 Buildings other than dwellings 3.21 and 3.22 add that “…For all buildings, a passenger lift is the most suitable form of access for people moving from one storey to another…” but emphasise that “…in exceptional circumstances for new developments with particular constraints (e.g. a listed building, or an infill site in a historic town centre), where a passenger lift cannot be accommodated, a vertical lifting platform (platform lift), although not equivalent to a passenger lift, may be considered as an alternative option to provide access for persons with impaired mobility.” The Provisions at Approved Document M: Volume 2 Buildings other than dwellings 3.24 state that “…The provision of lifting devices will satisfy Requirement M1 or M2 if … new developments have a passenger lift serving all storeys [or] new developments, where due to site constraints a passenger lift cannot be accommodated to provide access to persons with impaired mobility, have a lifting platform, of a type designed for the vertical height to be traveled”

The guidance is clear therefore that the normal expectation would be for a lift to be provided in new developments, with justifiable exceptions where a lifting platform may be acceptable. It should be noted that the situations mentioned (e.g. a listed building or an infill site in a historic town centre) are examples only. Each situation should be judged on its merits.

The aforesaid does not however mean that there will be no exceptions to these principles. The legal requirement of the Regulations is that there shall be reasonable provision for access. What is reasonable must be judged on the circumstances of the individual case, and there will almost certainly be cases where the provision of any kind of lifting device may be unreasonable.

The onus must, however, be on the applicant to justify such exceptions in an Access Statement. As an indication of the sort of factors that might be relevant to such a justification, applicants may wish to demonstrate for example that no members of the general public are accommodated, that all facilities are replicated on each floor, that the space demand of the lift and associated landings is disproportionate to the accommodation provided, that adequate provision is made for installation of a lift at a later date should it be required, and so forth.

It would not be reasonable to set out in guidance such as this exactly what combination of circumstances would justify omission of a lift, but nor would it be reasonable for a building control body to state in advance of consideration of an application that provision of a lift would not be required.

Sections 0.10 to 0.12 of Approved Document M: Volume 2 – Buildings other than dwellings, edition 2015 of the Building Regulations aims to define when a building undergoes a change of use. Not all the requirements in Approved Document M apply where there is a change of use of a building to flats.

The building work which is exempt from charges is:

• Any alteration to an existing public building or home occupied by a disabled person which is solely for the purpose of enabling a disabled person to get in or out, or to provide better facilities for a disabled person.
• The provision or extension of a room in a home where the sole use of the room will be
• To carry out medical treatment of a disabled person which cannot be carried out in another room, or
• To store medical equipment used by a disabled person, or
• To replace or adapt accommodation or a facility in a building which already existed but which a disabled person could not use without assistance.

The guidance that follows is based on consideration of Amendment 1:2005 to BS 8300:2001 (see BS 8300:2001). A handrail should be:
1. of an oval or circular profile;
2. finished so as to provide visual contrast with the surroundings against which it is seen;
3. easy and comfortable to grip with no sharp edges, smooth and not cold to the touch.

A circular handrail should have a diameter of at least 40 mm but not greater than 50 mm.

A handrail with an oval profile should have dimensions of 50 mm wide and 38 mm deep. The profile should have rounded edges with a radius of at least 15 mm.

There should be a clearance of between 50 mm and 60 mm between a handrail and any adjacent wall surface and any handrail support should meet the handrail, centrally, on its underside. The clearance between the bottom of the rail and any cranked support, or continuous balustrade should be at least 50 mm to minimize the risk of the handrail supports interrupting the smooth running of a person’s hand along the rail.

Localised obstructions means any element that might impede the ability of a wheelchair user or person using mobility aids to turn easily through a door opening or around a corner. Localised obstructions are fixed items such as a protruding radiator or a wall-mounted fire hydrant. Skirtings and architraves can be ignored when measuring clear widths.

The grey shaded areas in diagrams should be free of wall nibs, services or any protruding elements, however, a localised obstruction is only problematic if it is in the likely path of travel of someone entering or leaving a room or turning a corner. Where grey areas are indicated to both sides of a door this assumes that the door can be approached from two directions – if a door can only be approached from one direction then a clear zone on the other side of the door is not required (e.g. at the end of a corridor).