This page belongs to: Premises Standards Review 2021

International approaches

We conducted an international literature review to explore how other countries address access to premises. The literature review provides examples of alternative approaches to accessibility and how those could be adapted to an Australian context.

Examples and observations from the literature review are grouped with our key themes and recommendations.

Consistency and clarity

These examples provide a snapshot of how different countries address the theme of consistency and clarity. Other countries emphasise:

  • education about building requirements
  • appropriate consultation to ensure people with disability are heard.


Relevant, free and easily accessible education materials for building professionals, businesses, and disability stakeholders are critical to the successful implementation of legislation.

In Australia, Premises Standards resources predominately come from the AHRC and the Australian Building Code Office. However, other countries can teach us about delivery methods and ensuring the information is current and relevant.

In Canada, the Ontario Human Rights Commission provides free e-learning modules with quizzes. These let builders and other interested stakeholders check their understanding of:

  • relevant legislation and standards
  • the duty to accommodate
  • applying human rights principles
  • compliance and enforcement processes.

The United Kingdom’s National Disability Authority has a toolkit to help people make their services, buildings, information and websites more accessible. The ‘Consider accessibility when procuring’ resource outlines how the head of a public body can ensure the goods and services it procures are accessible to people with disabilities. The ‘Make your buildings more accessible’ resource recommends owners audit their buildings every 3 years. It also provides a template for an ‘access handbook’ outlining the features of a building that must be maintained to ensure access for everyone.

The UK Government sponsors an Inclusive Design Hub offering a free one-hour course on inclusive environments. The course outlines best-practice guidance for designing public buildings and outside spaces.

Consultation and appropriate representation

People living with disability, as well as access consultants, commented that access issues are best addressed in the design phase. A lack of appropriate consultation sometimes resulted in costly rectification work or a lack of accessibility for people living with disability.

In 2020, Ireland’s Department of Justice launched a Disability Participation and Consultation Network. The network aims to involve people living with disability in developing policy and legislation across the government. A member of the network is the Disabled Persons Organisation, which provides opinions on specific issues or projects, such as Ireland’s state report to the UN Committee on the Rights of Persons with a Disability.

The Canadian province of Newfoundland and Labrador has a Buildings Accessibility Advisory Board. The board is a public advisory body composed of a chairperson, representatives of persons with disabilities, and a representative of the responsible department for building policy.

The board’s objective is to advise the responsible minister on accessibility for:

  • buildings
  • associated entrances
  • parking spaces
  • grounds
  • walkways
  • other facilities.

Rating systems and mapping

People living with disability suggested that a star rating system can help people living with disability plan their journeys. For example, Western Australia has a rating system that provides information on accessibility at their train stations.

However, it can be difficult to combined data from the Australian Government, state and territory governments, and local councils. The United Kingdom’s Blue Badge Map may provide a solution to this problem.

When the UK’s local authorities stopped producing maps of accessible parking spaces, a member of the public started the crowd-sourced Blue Badge Map. As well as helping people with disability parking permits find carparks, the free online map provides location and accessibility information for:

  • petrol stations
  • railway stations
  • underground stations
  • taxi ranks
  • accessible beaches
  • public buildings of interest, like museums and hospitals.

Access and egress

Access and egress is a broad topic, which was reflected in the submissions received during the review.

There are many different approaches to access and egress issues around the world. The examples below illustrate just a few of the lessons and insights from international jurisdictions.

Wheelchair openings and thoroughfares

In our review, people living with disability and their advocates said that wheelchair openings and thoroughfares are not wide enough for larger wheelchairs or mobility scooters, which are becoming more common. Some of these stakeholders suggested that the National Disability Strategy and National Disability Insurance Scheme might have sped up this trend, by helping people with disability have access mobility aids that suit their needs, rather than settling for what was previously available.

In 2006, the Canadian Human Rights Commission reported on international examples of best practice in universal design. It noted dimensions for wheelchair openings and thoroughfares in different countries. The ideal width was found to be 1200 mm, or 1830 mm in high-traffic areas.

Emergency egress

Emergency egress was an issue raised by our stakeholders. Many respondents felt Australia was behind in this area due to our lack of high-density living compared to other countries. Recently released international disability standards have also further addressed emergency egress issues.

Canadian Standard B651-18 covers accessible design for the built environment. It says that if a building’s emergency evacuation route is different for people unable to evacuate independently, it must publicly display evacuation plan signs indicating an accessible egress route. The standards includes provision for individual evacuation plans for people with disabilities. 

The United States’ 2010 ADA standards for accessible design state that tactile signs must identify emergency exit doors. Fire alarm systems must also have permanently installed audible and visible alarms.

Accessible car parking

Accessible car parking has been a significant issue in both Premises Standards reviews. Car-parking ratios in other countries are often more generous than the 1 in 50 and 1 in 100 ratios of the Premises Standards.

Ireland’s Technical guidance document M – access and use (2010) states that at least 5% of spaces for public buildings should be designated accessible car parking spaces, with a minimum provision of one space. This is unless otherwise specified by local authorities.

The United States’ 2010 ADA standards for accessible design has compulsory requirements and extensive advisory information about car parking. For example, access aisles must be at the same level as the parking spaces they serve. Built-up curb ramps should not project into access aisles and parking spaces, because the slope would be too great for wheelchair transfer to and from vehicles.


Stakeholders in our review raised issues around lifts, especially where they intersect with public transport and premises. However, stakeholders stated the newer lift standards, such as Australian Standard 1735.12:2020, are a significant improvement to the 1999 version of the standard.

Ireland’s Technical guidance document M – access and use has specific requirements for accessible lifts. These include a diagram of dimensions and provisions for those with vision or hearing impairment.

For example, lift landing and lift car doors should contrast visually with adjoining walls. Lift floors must not be dark, to avoid creating the illusion of an open lift shaft. Emergency lift communication systems with push-button activation and inductive couplers should be included for people using hearing aids.

Heritage buildings

Many countries acknowledge that a proposed modification for equal access may undermine architectural, cultural or other qualities of historical buildings. Historical preservation preference should be given to preserving heritage aspects of the building.

Suggestions for addressing these issues include:

  • finding ways to avoid an obstacle instead of altering it (Ireland)
  • making the visitor experience more inclusive, such as through descriptions and visual displays (New Zealand).


Countries’ compliance regimes depend on enabling legislation and governance frameworks. These examples offer insights into how state and local jurisdictions undertake compliance activities. These requirements also generate data that is useful in:

  • future assessments
  • policy and legislative design
  • implementation.

In Ireland, local authorities are designated as building control authorities, giving them powers of inspection and enforcement for compliance. Prosecution of non-compliance in court can lead to fines or imprisonment.

When Ireland’s parliament changes public building accessibility requirements under its National Disability Inclusion Strategy, it triggers an access audit of specific public buildings. Local authorities must carry out this audit within 6 months.

In the United States, the Minnesota Council on Disability has developed standardised building access checklist to assess the accessibility of buildings, their internal spaces and the surrounding site.

Communication and wayfinding

The examples below highlight how supplementary material can guide best practices for building professionals and employers. Communication and wayfinding issues also intersect with emergency egress issues, as highlighted by the examples from the United States.

Improved guidance with standards

Ireland’s National Disability Authority provides signage design guidance to supplement their Technical guidance document M – access and use. Based on findings from the Centre for Excellence in Universal Design, the guidance covers:

  • text
  • symbols and arrows
  • colour and contrast
  • tactile features
  • positioning of signage.

The document also provides a rationale statement for specific requirements. For example, section says that tapered treads and open risers should not be used. The rationale is that they create a sense of insecurity for people with vision impairment.

Emergency egress

Under the United States’ 2010 ADA standards for accessible design, fire alarm systems must have permanently installed audible and visible alarms. This aids communication and wayfinding for people with vision and hearing impairment during emergencies.

Fixtures and fittings

Standardisation of certain fixtures and fittings, especially signage placement and switches, is an issue for people with vision or hearing impairments. The benefits of these standards were also noted by people with intellectual or cognitive impairment. Larger employers indicated a strong preference for standardisation to provide an accessible and inclusive work environment.

Other countries, such as Ireland, Canada and the United States, include fixtures and fittings in their standards for public building accessibility. The United States has requirements for building elements like light switches and lift controls, including providing access to those fixtures and fittings. For example, the standards specify reach ranges for both adults and children.

Toilet and change room provisions

Our stakeholders considered the inclusion of adult accessible change facilities in the NCC a significant achievement. Stakeholders indicated a need for more of these facilities, especially at major transport hubs. Stakeholders raised adult accessible change facilities as an issue that should be addressed in the future.

The UK’s building regulations mandate the standard provision of changing places toilets in 6 specific locations. These include:

  • hospitals
  • primary care centres
  • assembly, recreation and entertainment buildings with a capacity of 250 or more people.

In the United States, the City of Portland has developed a self-contained kiosk-style public toilet. The Portland Loo is smaller than a carpark space spacious enough for users with a pram, shopping trolley or wheelchair. It comes pre-assembled, requires minimal utilities and can be cleaned with a hose. This means it can be used in areas where traditional toilet blocks are not suitable.

Environmental sensitivities

A number of access and health issues are included under the theme of environmental sensitivities. Compared to the 2016 review, the 2021 review received more submissions that raised multiple chemical sensitivities.

New building materials were identified as a source of gases. Recent work in Australia has examined this issue. However, the scope of the Premises Standards does not cover building materials.

Canadian standard B651-18 mandates that construction, furnishing or decorative materials should not give off gases that affect air quality. It also requires adequate ventilation to dilute any contaminants.