Site navigation

Change font size: SmallerLargerReload

navigation Disability Rights

Use of Tactile Ground Surface Indicators at Kerb Ramps

Dr Sev Ozdowski OAM
Acting Disability Discrimination Commissioner
June 2005

Over the past few months I have received a number of inquiries concerning the use of Tactile Ground Surface Indicators (TGSI) at kerb ramps. These inquiries have come from Councils, access consultants and regulatory authorities who are trying to provide consistent advice to those responsible for constructing and maintaining kerb ramps.

The major concern appears to be about whether TGSI should be used at kerb ramps and if so where should they be placed.

I am aware that the issue of the use of TGSI has been the subject of much debate over the years in Australia and overseas and that there are a number of conflicting views on their use at kerb ramps.

Some advocate that they should be placed 300mm back from the actual beginning of the road which would put them on the down slope of the ramp, others say they should be placed on the pathway 300mm back from the beginning of the down slope of the ramp and others say they should not be placed anywhere.

I have been asked to give my view on three issues:

What do the Transport Standards say about the use of TGSI at kerb ramps?

There is no case law on interpretation of the Transport Standards in the area of use of TGSI at kerb ramps so the views expressed here are my interpretation following discussion with a number of people involved in the development of the Standards.

There are   three   relevant sections in the Transport Standards:

Part 2  - ' Access Paths'

This part provides an overall description of unhindered passage and a definition of a continuous accessible path of travel. Clause 2.1 (2) says that an access path must comply with AS 1428.2 (1992) Clause 8.1 which in turn references AS 1428.1 (1993) for the details on placement and construction of ramps.

The only reference in AS 1428.1 (1993) to TGSI is a note (2) attached to the Figure 8 (Kerb ramps and step ramps) which says that a 'tactile indicator' as specified in AS 1428.4 (1992) should be integrated into the design.

If we then go to AS 1428.4 (1992) the only references in that Standard to the placement of TGSI are in:

•  Clause 6.1 (c) which says that TGSI ".shall be set back from the hazard a distance of 300 ± 10 mm."; and

•  Clause 6.3 Figure 5 which clearly shows the position of TGSI extending 600mm starting 300mm back from the road edge.

In other words if you track the references under Part 2 of the Transport Standards you could interpret there to be a requirement for TGSI to be placed on the slope of the kerb ramp 300mm back from the road edge.

Part 6 - Ramps

If, however, we look at Part 6 'Ramps'   of the Transport Standards,   we see that this requires that any ramp on an accessible path of travel must comply with AS1428.2 (1992) Clause 8 . The Transport Standards use of the word ramp in this section does not distinguish between a ramp, step ramp or kerb ramp as Australian Standards do, but I believe it is reasonable to read the Transport Standards as applying to all of   these, including kerb ramps,   where they appear on a path of travel. 

As this Part references the whole of Clause 8 of the Australian Standard, this includes Clause 8.4.6 which states: 'Tactile warnings - Warning strips shall be provided at the top of the ramp, in accordance with Clause 18.1"

This Clause 8.4.6 is being interpreted by some as prohibiting TGSI on the down slope of the ramp as 'at the top of the ramp' is seen as being behind the ramp as is the case with ordinary (1 in 14) ramps.

Part 18 - Tactile Ground Surface Indicators

Part 18 'Tactile Ground Surface Indicators' of the Transport Standards references AS 1428.2 (1992) Clause 18.1 which is concerned with the general location of TGSI at stairways, ramps and platform edges but gives no reference to the actual installation of the TGSI. Part 18 also requires that the style and dimensions of TGSI must comply with AS 1428.4 (1992).

Depending on your point of view it would appear then that there is a possible contradiction between Parts 2/18 and Part 6 of the Transport Standards.

After discussions with some of the people involved in developing the Transport Standards, I am of the view that the intent of the Committee was to reference the most relevant, up to date best practice available in the Australian Standards suite of standards at that time.

In general terms, when it came to the application and installation of TGSI the Committee's intention was to refer organisations to AS 1428.4 in its broadest sense. This view is supported by Clause 18.1 of the Disability Standards for Accessible Public Transport Guidelines 2004 (No.3) (the 'Transport Guidelines') which indicates that the dimensions of the TGSI on an access path are detailed in AS 1428.4 (1992).

Following this line of argument I would suggest the appropriate interpretation of the Transport Standards to be that TGSI on kerb ramps should be located as described in Clause 6.1 (c) and Figure 5 of AS 1428.4, that is 300mm back from the road edge, and not 300mm back from the start of the down slope of the kerb ramp.

Having said that, the question remains as to whether that is appropriate given changes to the Australian Standards that have occurred over the past few years.

As the Transport Standards will be subject to a five year review in accordance with Part 34 of those Standards, it may be appropriate to consider this issue at that time and I intend to raise this issue with the review body for their action.

Should the requirements of the Transport Standards extend to the use of TGSI at kerb ramps in the broader built environment?

The Transport Standards apply to a limited set of circumstances. Clause 1.4(2) states that the Transport Standards apply to all operators of public transport services and the conveyances they use, and any supporting premises and infrastructure. In relation to kerb ramps, the scope of the Transport Standards is limited to infrastructure which is defined in Clause 1.18 as:

(1) Infrastructure is any structure or facility that is used by passengers in conjunction with travelling on a public transport service.

(2) Infrastructure does not include any area beyond immediate boarding points (for example, bus stops, wharves, ranks, rail stations, terminals).

In relation to kerb ramps therefore, I would suggest that the Transport Standards are not applicable to those kerb ramps found generally throughout the pedestrian pathways. The standard is limited to those kerb ramps that are found directly related to transport services such as at bus stops or at bus interchanges where transport service users might need to cross from one set of stops to another.

Having said that I believe it is appropriate to seek consistency between the different elements of the built environment that people with disabilities use.

When the Commission issued its Advisory Notes on Access to Premises in 1997 it contained a reference to the use of TGSI in the infrastructure (public pathways) and advised people to refer to AS 1428.4 (1992) in the same way that I believe the Transport Standards do.

This is because, at that time, AS 1428.4 (1992) was the most authoritative technical reference point available. The Commission has not revised the Advisory Notes since 1999 as we have been awaiting the outcome of negotiations on the development of a Disability Standards for Access to Premises (Premises Standards).

(In this context it should be noted that the current Building Code of Australia (BCA) and the draft Premises Standards specifically exclude the use of TGSI on kerb ramps and step ramps where they exist in a building subject to BCA requirements. However, this exclusion within buildings does not necessarily mean that TGSI should not be used on kerb cuts in the public pathways as there is arguably a greater danger of accident if warnings are not given).

As the Commission is not an expert body in relation to technical specifications such as this I am likely to continue to refer organisations to the best practice developed by bodies such as Standards Australia where we believe they represent a consensus view.

So while I believe the Transport Standard requirements in relation to TGSI at kerb ramps do not extend into the broader built environment I do believe we should be trying to achieve consistency in their use.

Proposed changes to AS 1428.4 and a new AS 1428.4.1

The current edition of AS 1428.4 (2002) is very different from that referenced in the Transport Standards.

From feedback I have received from various sectors, including a number of Local Councils and access experts, however, I believe there is still considerable confusion about how to apply the current AS 1428.4 (2002). For example, I have received reports from engineers who have to implement the Australian Standards that they are finding it difficult to apply them. I have also received reports from others involved in providing training on the use of the Australian Standard who advise that, once understood, the Australian Standard can be effectively applied.

Currently a new draft AS 1428.4.1 is under consideration for adoption by Standards Australia and I intend to base this discussion on that draft.

In relation to kerb ramps the draft AS 1428.4.1 states under section C2 that an alternative point of entry to the roadway should be established adjacent to the kerb ramp and within the confines of the path of travel. They should be positioned 300mm back from the edge of the road.

The draft goes on to identify an exception and provides a number of diagrams C2 through to C11 showing the different ways this may be engineered.

The exception is that TGSI are not required on a kerb ramp if:

Essentially my reading of the diagrams (C2 to C11) that show how to install TGSI when they are required, is that TGSI should be either:

I understand that the new draft has been developed through negotiation and has included the views of both people with mobility disabilities and blind people, but I have also been advised that those responsible for implementing the standard have continuing concerns about its application.

I am not in a position to say whether or not the new revised AS 1428.4.1 will overcome the concerns that have been expressed to me, so at this stage I am not willing to express a view on whether or not the current AS 1428.4 (2002) or the proposed draft should be considered as best practice by those responsible for construction of kerb ramps.

In order to try and resolve this issue I have written to Standards Australia with a request that they urgently consider a special meeting be convened to undertake a final assessment of the draft before publication.

I appreciate that this will take some time, but believe that the most sensible course of action is to seek guidance from Standards Australia as that is the organisation best suited to deliver a consistent set of specifications.

In the meantime, my view would be that any court dealing with a discrimination case in relation to this issue would likely consider a Council was acting reasonably if it followed the most authoritative advice available at the time, that being AS 1428.4 (2002).