The new hospital plans were submitted to the Planning Department on 30 November 2021. From the perspective of disabled access, we were disappointed by a number of aspects of the plans and have responded to the request for public comments as follows:

As a charity involved in accessibility audits, we have been attending the Our Hospital public meetings and have raised the importance of accessibility on several occasions.

This is a brief response to the plans submitted. We have not had time to read and respond to the entire submission. The following is, therefore, a selection of concerns at a macro level that relate to Jersey’s approved technical guidance documents ‘Part 8: access to and use of buildings’.

Overview

Some consideration of people with disabilities is evident within the plans for the new hospital as the Design Disability Access Statement makes clear. Disappointingly, it falls short of the ‘world class’ facility that has been championed in the media in terms of consideration of people with disabilities. The statement makes it clear that the ethos is about complying with minimum standards rather than exceeding those standards to create a building that truly considers people with all sorts of disabilities.

Car parking

There are to be 550 parking spaces in the multi storey. From the plans, these all appear to be standard spaces.

There are a number of disabled parking spaces shown as follows: 2 x knowledge centre, 24 x main hospital, 8 x mental health centre; total of 34 designated disabled spaces.

There appear to be no enlarged parking spaces, no parent and child parking spaces, and no large designated accessible parking space (4.8m x 8m).

BS8300-1 part 7.2 recommends medical and health facilities should provide 6% of total parking spaces as designated disabled spaces and, in addition, 4% of total parking spaces as of enlarged spaces. This would be 35 designated disabled spaces (584 x 6% = 35) and 24 enlarged spaces (584 x 4% = 23.36).

Part 7.4.1 says: ‘Designated accessible parking spaces should be provided for all known users who are disabled motorists (driver or passenger) and for other disabled motorists visiting the building or location.

‘Spaces designated for known users who are disabled (e.g. staff whether paid or unpaid) should be differentiated from spaces designated for other users. In addition, a number of enlarged standard spaces of 3.6 m wide × 6 m long should be provided that could be adapted to be designated accessible parking spaces.

‘Where space permits, at least one large designated accessible parking space, 4.8 m wide × 8 m long, should be provided to cater for commercial vehicles converted for side or rear access using hoists or ramps.

‘Designated accessible parking spaces should be solely for the use of disabled people. If there is an evidenced need, parent and child parking spaces should be provided in addition to any other designated/assigned parking spaces.’

We are disappointed that:

• the provision of spaces does not meet BS8300-1 recommendations with the 4% of enlarged spaces seemingly not observed.
• the opportunity to provide the ‘nice to haves’ like the parent and child spaces and large designated space for commercial vehicles has not been taken.
• all the disabled parking spaces are open to the elements. Transferring from your car to a wheelchair in the driving rain will be very unpleasant.
• we were unable to find mention of electric charging points for all parking spaces including designated disabled ones.

Entrances

The use of sheet glass and metal frames is pervasive in modern public buildings and it causes problems for people with disabilities, particularly visual impairments. Finding a glass door in a wall of glass can be extremely difficult for some people. Anyone who has walked into a patio door thinking it was open will (painfully) testify to the problems of glass entrances. Glass reflects making it difficult to visualise what you are seeing beyond the door and, therefore, stepping into. Light bounces off glass making it glare on bright days.

We are disappointed to see the entrances of the main hospital, knowledge centre and mental health centre all follow this trend. From the artistic impressions in the submission, it is impossible to make out the doors on all three buildings from their surrounding glass windows – this gives the non-visually impaired person an idea of the difficulties we are describing.

The canopy over the main entrance to the hospital is shown in the artistic impressions as casting some strong criss-crossing shadows. These pools of shade cutting across the canopy pillars, forecourt and main entrance could be very difficult to negotiate for some people.

We would like to see the canopy re-considered to make its structure simpler and its shadow less confusing.

Foyer

The artistic impression of the main hospital foyer is a large open plan area that the user steps into. Having been ‘funnelled’ through the entrance, it suddenly opens up into what could, at times, be a bustling part of the hospital. This may simply be too much for users sensitive to stimulus or who have hearing loss; for other users finding the information desk with nothing to guide you there, such as a handrail, may be difficult.

There does not appear to be any quiet room attached to the reception help desk where someone who is struggling with the foyer environment can be assisted privately.

The seating in the foyer appears to largely be without arm rests. This is unhelpful to people with certain disabilities who require armrests to help them stand/sit.

Doors

There are a lot of doors in the plans. Doors are problematic for wheelchair users, people with diminished strength (of which their will be a number in a hospital), people with restricted mobility and others, particularly if they are made ‘heavier’ through the use of door closers.

Whilst we acknowledge that door closers are required for fire safety, we hope that they will not be used on every door, e.g. the bathroom doors within the single bed wards would be more accessible without door closers. We hope that the use of free swing door closers, which allow the door to behave as if there is no door closer in place, but are linked to the fire alarm system so will close in an emergency, would be used on doors, such as to the single bed wards, as this would allow patients with any level of strength/mobility to leave their room unaided. We hope that all doors in passageways will be automated, opening on approach, and not manual or push pad opening.

Please consider whether facilities for disabled users are set behind doors that make those facilities inaccessible, e.g. in the knowledge centre on the ground floor there is a disabled WC, which has an outwards opening door (without door closer, we assume) that allows a user to control it better, but it is set behind an inward opening door to the suite of toilets.

Where doors need to be locked and accessible to staff only, key fobs are better than key pads. These should be set at an accessible height and well back from the door they control, ideally on the natural approach route. Many wheelchair users cannot get into the corner by a door jamb because of the footplate of their chair, in order to operate a key fob lock sited there. Often, they also cannot get back into position to get through the door before it locks again.

Wayfinding

There is much that will be key for wayfinding in the choices of colours, fonts, pictures etc in the new hospital. The design of signage and information may be outside the brief of planning, but we highlight it whenever we have the opportunity as it will be critical in making the new hospital accessible.

Having undertaken an exercise in wayfinding in the current hospital with various impairments, we are aware of how crucial this is to a patient finding their appointment or giving up before they get there.

Building users must not be reliant on staffed information points for assistance. What if the staff are called away? Too busy to help? Or Jersey cannot recruit people to fill these admin roles? Users may not have the confidence to ask for help, may wish to be independent, or may get confused enroute and not be near an information point, so there must ways to help yourself that are accessible for all.

We would like to see the use of strong colours that start on the appointment letter and follow all the way through the site from entrance to department, similar to the London tube map and the tiles on the tube tunnel walls. Colours assist people with low vision and learning disabilities, amongst others.

Colours may also be used to denote functions of rooms behind a door, e.g. blue for cleaning cupboards, green for toilets, red for staff areas.

Pictograms are also useful for assisting people who do not have English as a first language and/or have learning disabilities. Again, these should be used on the initial appointment letter and follow through the site.

Signage that uses words should be standardised in style and positioning, large sans serif font, proper case (capital then lower case), avoid shiny surfaces, and avoid black writing on a white background whilst still having a strong contrast between the background and letters.

Braille signage should be included at consistent heights/positions around the site to assist users.

Audio information points/intercoms should include auditory couplers/hearing loops.

Some of the above points are acknowledged at a high level within the submission, but detail is lacking as to how it is intended to be implemented.

Single bed wards

There is debate within the health profession over the advantages/disadvantages of single bed wards. There are 75% single bed wards and 25% four bed wards within the designs. Maternity and obstetrics is going to be 100% single bed wards.

Whilst single bed wards may appeal to the public, who when fit and healthy place a premium on privacy, and in an age of COVID may seem like a way of controlling cross-infection, they can have disadvantages for people with disabilities:

• for patients who have hearing loss being able to know whether you have summoned help relies on being able to see a call light has been lit. If this is located on the outside of your single bed ward, you have no idea whether your call for help has worked.
• unlike in a Nightingale ward, staff cannot see all their patients at once, therefore patients who attempt to get out of bed and fall, or who have dementia and are prone to wander are not monitored.
• similarly, on a busy shift, patients who require turning or encouraging to drink may be neglected because they cannot be seen by staff.
• patients who have depression or may get depressed while recuperating may find a single room isolating and worsens their mental health leading to slower recovery times.
• there is no flexibility for patients who require extra space for additional equipment, such as hoists, larger beds/wheelchairs.
• for patients with limited mobility that means reaching a call button or pressing it is not possible a single bed ward could be a matter of life and death.

We would like every department within the hospital to have a choice of ward type in order that those who have additional needs may use a ward that gives them an environment that is better suited to them.

Other observations

The lecture theatre in the knowledge centre does not appear to have any provision for wheelchair users to attend a lecture as the first row of seats is up one step. The first row needs to start on floor level and have the ability to remove seats from the row so that a wheelchair user can join in the front row and not be stuck out in front of the audience on their own.

Lift design does not appear in the artistic impressions, however we have seen a number of lifts that have full length mirrors, reflective surfaces, gleaming metalwork etc. All these serve to disorientate some users. We also see lifts without tactile call/control buttons and with the emergency speaking port at standing level only and with no hearing loop.

Within the artistic impressions, there do not appear to be any pictures showing incidental seating enroute to departments. With a large building to navigate, a variety of seating must be provided for users at regular intervals in corridors, not just in waiting areas.

If you wish to view the plans or respond, the planning application can be viewed here:

https://www.gov.je/citizen/Planning/Pages/PlanningApplicationDetail.aspx?s=1&r=P/2021/1670