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Disabled Accessibility Document - Draft

Premier League Disability Advisory Group


Disabled Accessibility Document - Draft

 

Contents

 

1.             Introduction

2.             Legislation

3.             Stadium Capacity and Minimum Accessible Requirements

4.             Communication and Reporting requirements

5.             Wheelchair Spectators

6.             Ambulant Spectators – Amenity easy access seats

7.             Partially sighted and blind spectators

8.             Hard of hearing and deaf spectators

9.             Learning or intellectually disabled spectators

10.        Spectators with mental health conditions

11.        Assistance and guide dogs

12.        Spectator accommodation – standing

13.        Toilet facilities

14.        Changing Places

15.        Sensory room

16.        Other facilities –

      Sale of refreshments, Retail accessibility, Betting stations …

17.        Emergency and exceptional egress - disabled spectators

18.        Stewarding

19.        Additional topics for discussion and possible inclusion

                  Personal Assistants, What do we mean by disability and a disabled
                  person? Ticketing …

 

Extracts from Guide to Safety at Sports Grounds – Sixth Edition and Accessible Stadia Supplementary guidance August 2015 are by kind permission of Sports Ground Safety Authority.  Extracts from Premier League Ticketing and Matchday Guidance by kind permission of the Premier League


 

 

1.       Introduction

 

It is now more than twenty years since the first guidance documents detailing the provision of facilities for spectators with disabilities were published, and twelve years since Accessible Stadia was produced. Much has happened since then in terms of culture change, legislation and demographics, but what remains the same is that sports grounds should be inclusive and accessible to all spectators. Attending sporting activities is an integral and vital part of our culture and tradition, and no one should be excluded on grounds of disability.

 

Above is the original introductory text from the publication “Accessible Stadia Supplementary Guidance August 2015” stating an objective, which we wholeheartedly endorse, of endeavouring to deliver to disabled spectators, high quality facilities and services that are accessible, inclusive and welcoming for all.

 

The information contained in this publication is intended to bring together the disability related components from a number of documents - “Guide to Safety at Sports Grounds – Sixth Edition” , “Accessible Stadia - Supplementary guidance August 2015” and the Premier League “Ticketing and Matchday Guidance 2018” - and offer suggestions as to how to further improve, clarify and enhance the current guidance for the benefit of both home and away disabled spectators.

 

The invaluable knowledge and experience of the Chairs of sixteen Disability Supporters Associations, who comprise the Premier League Disability Advisory Group, has been embodied in this document.  

 

This Group, who directly represents a large proportion of disabled football spectators who attend Premier League matches, feel that greater scrutiny of current ASG implementation is essential.

 

The Equality Act 2010 places an evolving and anticipatory duty on service providers and, given an aging population, a renewed emphasis is crucial to more fully support and embrace the widest spectrum of disability in the future.

 

The document is primarily aimed at football stadia but we believe that much of the changes and improvements suggested could equally be advantageously applied to other sports stadia.

 

 

David J Butler FCA MBE

Chairman - Premier League Disability Advisory Group

 

NB: Suggested modifications, additional text and comments are highlighted in Red throughout.

2.       Legislation

 

The whole of this section has been reproduced without alteration from the “Accessible Stadia - Supplementary guidance August 2015”

 

The Equality Act 2010 (the Act) consolidated and replaced the previous discrimination legislation for England, Scotland and Wales. The Act covers discrimination on grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. These categories are known in the Act as ‘protected characteristics’. As well as consolidating existing law, the Act makes discrimination unlawful in circumstances not covered previously. Different areas of activity are covered under different parts of the Act. Part 3 of the Act deals with discrimination in the provision of services.

 

The Equality Act says that treatment of a disabled person amounts to discrimination where:

• a service provider treats the disabled person unfavourably;

• this treatment is because of something arising in consequence of the disabled
  person’s disability; and

• the service provider cannot show that this treatment is a proportionate means of
  achieving a legitimate aim, unless the service provider does not know, and could
  not reasonably be expected to know, that the person has the disability.

 

For discrimination arising from disability to occur, a disabled person must have been treated ‘unfavourably’. This means that he or she must be put at a disadvantage. Often the disadvantage will be obvious and it will be clear that the treatment has been unfavourable: for example, a person may have been denied a service or given a poorer service.

Being denied a choice or excluded from an opportunity is also likely to be unfavourable treatment.

 

Sometimes the unfavourable treatment may be less obvious. Even if a service provider thinks that they are acting in the best interests of a disabled person, they may still treat that person unfavourably.

 

Service providers can often prevent unfavourable treatment which would amount to discrimination arising from disability by taking prompt action to identify and implement reasonable adjustments. The duty to make reasonable adjustments requires service providers to take positive steps to ensure that disabled people can access services. It requires service providers to anticipate the needs of potential disabled customers for reasonable adjustments.

 

For service providers, the requirements to make reasonable adjustments comprise:

• where a provision, criterion or practice puts disabled people at a substantial disadvantage compared with those who are not disabled, to take reasonable steps to avoid that disadvantage;

 

• where a physical feature puts disabled people at a substantial disadvantage compared with people who are not disabled to avoid that disadvantage or adopt a reasonable alternative method of providing the service or exercising the function; and

 

• where not providing an auxiliary aid puts disabled people at a substantial disadvantage compared with people who are not disabled, to provide that auxiliary aid.

 

All sports grounds, new and existing, must comply with this legislation.

 

The Equality and Human Rights Commission monitors the application of the Act, and legal action can be taken by an individual who may feel that they have been discriminated against. Beyond the world of sport, there are a number of high profile cases that have set a legal precedent for service providers and the need to provide reasonable adjustments to their premises.

 

The Equality Act places an evolving and anticipatory duty on service providers (i.e. sports clubs, stadia management etc.) and sports grounds should ensure that access audits to assess their facilities and services are undertaken by competent parties on a continuing basis in order to ensure current and future compliance with the Act. For all premises, old and new, existing and proposed, management should be developing, or have developed, an “access plan or strategy”. This is best done through a thorough access audit by a competent person.

 

It is important that where football matches and sporting events require segregation of supporters, disabled people should have the choice to be accommodated within their own fan base. Therefore viewing areas should be provided with their fellow fans.


 

3.        Stadium Capacity and Minimum Accessible Requirements

 

Segregation (6th Edition extract 9.3h)

At grounds where areas of viewing accommodation are segregated, and where concourses are also segregated, sufficient amenities should be provided to service each part of the concourse.

Segregation (6th Edition extract 3.26)

Management should ensure that each segregated area offers full access to sufficient toilet and catering facilities. It should not be necessary for spectators in segregated areas to have to cross barriers or seek special permission to use such facilities (see also Chapter 9).

Management should also ensure that wherever possible sufficient viewing accommodation and facilities are provided in each segregated area for disabled spectators.

 

Each segregated area must have its own independent means of egress or evacuation.

 

Where Stadiums segregate home and away fans, the calculations below are to be applied to ensure that the guideline requirements are achieved for each set of spectators  i.e. compliance to be achieved as if each sector represented a standalone stadium.

The calculation below must be applied to each of these disabled categories:   

 

1)       Wheelchair positions

2) Amenity or easy access seating

 

(Accessible Stadia – Supplementary guidance extract - 1. Amenity and easy access seating)

 

Under 10,000             Minimum of 6 or 1 in 100 of seated capacity

(Whichever is greater)

 

10,000 to 20,000                 100 plus 5 per 1,000 above 10,000

20,000 to 40,000                 150 plus 3 per 1,000 above 20,000

40,000 or more                              210 plus 2 per 1,000 above 40,000

 

There should be an accessible toilet within 40m of any wheelchair position and amenity or easy access seating, with one accessible toilet provided for every 15 disabled spectator seats.

 

Disabled people should be provided with a choice of accessible viewing areas. In addition, it is important that family members and friends are able to sit alongside disabled spectators who require amenity or easy access seating and ticket office staff should be able to provide information about all amenity and easy access seating areas within the stadium.

 

No more than 25% of both wheelchair spaces and ambulant seating should be situated pitch side.

 

Elevated requirement

 

(6th Edition - Sightlines for wheelchair users – extract 12.4)   

“It is recommended that there should be a minimum elevated position, as illustrated in Diagram 12.3 which allows a person in a wheelchair to see the playing surface over any people standing in the row directly or diagonally in front. Spectators in wheelchairs must have a clear view of the whole pitch at all times, especially when seated spectators directly or diagonally in front stand up.”

The maximum limit pitch side is 25% the remaining 75% must be elevated.  This requirement applies for both wheelchair positions and ambulant spectators.

An Accessible Stadia Guideline qualifying “elevated” position is characterised by the raising of the disabled spectator to a height where their view is unobstructed.

Pitch side positions must be elevated where views are obstructed.  It is not acceptable to view between gaps in hoardings.

Passing movement in front of these positions should be minimised.

See diagrams in Section 5 and 6.

 

 

VIP and hospitality suites (Accessible Stadia Supplementary guidance August 2015 extract Section 4)

All areas of the stadium, including the VIP and directors’ boxes and corporate and hospitality suites, should be accessible to disabled people, along with any adjoining facilities and amenities. As such, inclusive design principles should be used in these areas and improvements should be made where required to ensure equal access.

 

Wheelchair user spaces and amenity and easy access seating located in hospitality areas should not be included in the quota for general seating areas but should be provided additionally.

 

 (6th Edition Segregation extract 3.26) 

It is further recommended that provision is made for visiting disabled supporters to sit within areas allocated to visiting supporters (that is, they should not have to sit amongst home supporters).

 

Moreover, where possible, spaces for visiting supporters who are wheelchair users, and their companions, should be provided in areas of standing accommodation allocated to visiting supporters.

 

Standing accommodation and disabled spectators (6th Edition – extract 13.22)

Disabled spectators are entitled to gain access to standing areas in existing or new sports grounds. The issues in respect of numbers, location and sightlines within standing areas are the same as those within seated areas (see Section 12.4).

 

Comment:

Providing access within standing areas for both ambulant and wheelchair users may prove impractical and potentially unsafe!

                                  

Also wherever possible, access routes for visiting disabled supporters should not pass through, or in front of areas reserved for home supporters.

 

 

Definition and categories of barriers and separating elements (Sixth Edition extract 11.1)

 

Comment:

 

There is no provision for safety barriers behind and / or around wheelchair and ambulant spectator areas offering protection from crowd surge or incursions into these areas by non-ambulant spectators.

 


 

 

4.        Communication and Reporting requirements

Communication

The Club’s Access Statement, in addition to providing the detailed information listed below for its home disabled spectators, must include a detailed description and a diagram of the away section of the stadium illustrating, as a minimum, the following :-

Disabled entrances with gate numbers

Location and numbered wheelchair positions

Lift locations and any weight restrictions

Position of drop down kerbs

Location and numbered ambulant seating illustrating position and number of

       steps encountered and handrail availability

Location, number and distance from accessible toilets,

Location of refreshments, betting stations with drop down counters

Ticket Office position and extent of disabled access

Identify hearing loops

Headset availability for the visually impaired

 

Accommodating visiting spectators (Sixth edition extract 3.25)

At all grounds there is a likelihood that spectators who are unfamiliar with the ground will be in attendance, particularly special events. However, grounds where supporters of visiting clubs attend it is recommended that advanced planning takes place between the ground management, the visiting clubs and/or the supporters’ groups, and the police, to ensure that visiting supporters, including those who are disabled or at risk, are:

 

a.         directed and welcome to the ground

b.        directed to the appropriate entrances

c.         accommodated safely

d.        always kept clearly informed of any special arrangements made for them inside
       the ground and on their departure.

 

Liaison between management and police and may be necessary to ensure that the likely number of visiting supporters is known. In consultation with the police, management should also determine clear policies on the accommodation of visiting supporters and on appropriate ticketing arrangements. Debriefing meetings should be held to evaluate these arrangements and, if necessary, formulate changes for future events.

 

When large numbers of spectators are expected from a non-English speaking country, management should provide verbal and written information in the language of the visiting spectator.

 

Reporting

The Accessible Stadia Guidelines are a minimum requirement, therefore reporting upon the utilisation of disabled spectators’ facilities and the existence and magnitude of waiting lists, will illustrate the degree to which demand is being satisfied.

Reporting structure example:

Qualifying and Audit

The accurate identification of qualifying wheelchair and ambulant positions against the minimum calculated requirement will facilitate ease of auditing.

5.        Wheelchair Spectators

Sightlines for wheelchair users (Sixth Edition extract 12.4)

 

Wherever practicable, disabled people should be offered the same opportunity as other spectators to view an event from any tier, or level of an area of the seated accommodation. Indeed, disabled access to all levels of a newly constructed, non-domestic building is a requirement of the relevant British Standard and Building Regulations.

 

Because wheelchair users are not always able to stand up, the spaces allocated to them and their companions must be located and designed in such a way that if spectators or other personnel stand up or walking front of their sightlines will not be obstructed.

 

The recommended method of achieving this is the construction of a riser of an increased height, or “super riser”, as illustrated in Figure 24.

 

The construction of a “super riser” might also be necessary for wheelchair user spaces in areas of seated accommodation that are located behind areas of standing accommodation.

 

Where a “super riser” is not in place, for example at pitch level, it is equally important that sightlines for wheelchair users are not obstructed by advertising hoardings and that all movements of personnel in front of this area are kept to a minimum.

 

This applies also to spaces allocated to wheelchair users positioned immediately behind lateral gangways.

 

It should be further recognised that some wheelchair users are unable to turn their heads, or to lean forwards or sideways, and that therefore their preferred location within a sports ground will be an elevated, corner position.

 

 

Finally, it is equally important that the sightlines of other spectators behind, and to the side of the spaces allocated to wheelchair users, are considered in the design process, to ensure that their sightlines are not unduly affected


 

Figure 24 Sightlines for wheelchair users (Sixth Edition extract 12.4)

 

Accessible Stadia Guidelines 2003 – extract 2.18  -

 

Sightlines from pitch level viewing areas

 

Where it is not practical to prevent frequent passage or personnel stationed in front of these spectators, a walkway behind these seats should be considered.

 

Design and location of wheelchair user spaces (Sixth Edition extract 12.17 and 12.18)

 

A wheelchair user space should meet the following requirements:

 

a.         Wheelchair users should be able to manoeuvre easily to a space that allows them a clear view of the event (see Sections 12.1 and 12.4)

 

b.        Wheelchair users should be provided with a choice of sitting next to either a disabled or a non-disabled companion.

 

c.         Some seats should be located so that an assistant/guide dog can accompany its owner and rest in front of, or under, the seat.

 

Although an individual wheelchair place can be provided by a clear space with a width of at least 900mm and a depth of at least 1400mm, it is recommended that each designated place should ideally 1400mm x 1400mm in depth to allow space for one helper per wheelchair space to sit alongside in a fixed or removable seat.

 

It is further recommended that management considers carefully the location of wheelchair user spaces in relation to other areas of viewing accommodation. For example, by locating spaces for wheelchair users immediately behind a family section this will enable additional companions to be closer to hand. Equally it allows any unused seats for companions to be occupied by family members.

 

 

Provision for cover (Sixth Edition extract 12.7)

b. Cover for wheelchair user spaces

 

For the amenity and safety of disabled spectators it is essential that areas designated for wheelchair users are adequately sheltered. If the designated area is separate from other areas of viewing accommodation and has its own roof, the design of this roof should not restrict the views of other spectators, but should still be of sufficient height to allow companions, stewards and other personnel to enter and move around freely inside.

 

 

Elevation of wheelchair viewing areas

 

One of the principal requirements of the relevant British Standard is that disabled people should have access to any storey of a new non-domestic building. In the context of sports grounds, this means that spectators with disabilities should gain a far greater choice of viewing location.


 

 

Concourses – design - amenities (6th Edition extract 9.3c)

 

When planning concourse amenities, designers and ground management should be aware of the needs of spectators with disabilities, for example when designing counter heights for catering outlets.

 

Attention should also be given to the positioning of toilets for disabled spectators, so that access to them is not impeded by queues for other facilities within the concourse.

 

 


 

 

6.        Ambulant Spectators

 

Spectator accommodation - seating  (Sixth Edition extract 12.1)

 

The provision of seated accommodation

New and existing seated areas will need to provide accessible viewing areas for disabled spectators, including ambulant disabled spectators. These areas must be located around the ground in adequate numbers and must be of appropriate viewing quality, to give all spectators a suitable range of viewing options. Provision and standards should be reviewed by management, in consultation with disabled supporters and local disability groups, on a regular basis.

 

Prefabricated or demountable stands need to satisfy the same criteria for numbers, dispersal and viewing quality for disabled spectators as those required in conventional construction.

 

Management should also consider the provision of amenity, or easy access seats for spectators with particular requirements. See section 12.18.

 

Amenity and easy access seats (Accessible Stadia Supplementary guidance August 2015 - extract)

 

In addition to the provision of wheelchair user accommodation all stadia should provide an equitable number of amenity and easy access seats for spectators who may require more space. Amenity seats should provide seating with extra leg room and it is helpful to provide some with armrests, although these should be removable. Amenity and easy-access seats should also have backrests.

 

People with limited mobility may need more room to access their seat using a walking aid or crutches, hence the need for extra leg room. They may be unable to stand easily or for long periods or easily change position.

 

Therefore, amenity seating should provide a reasonable sightline from a seated position that is not obstructed by another spectator standing in front or to the side.

 

The importance of dimensions (Sixth Edition extract 12.11)

Seating row depths and seat dimensions (Sixth Edition extract 12.12)

 

In addition, the safety, comfort and amenity of spectators will be determined by the amount of space provided for each individual seat.

 

Existing construction:

The minimum space allotted to each seated person should be:

Seat width (W):               460 mm measured between seat centres

Seating row depths (T):   610 mm where bench seating in place

                                         660 mm for all other types of seating

 

New construction:

The minimum space allotted to each seated person should be:

Seat width (W):                500 mm measured between seat centres

Seating row depths (T):   700 mm (however 800 mm is preferred)

 

Seat heights

The height of the seat (H) measured from the seating trade to the upper surface of the seat, should be a minimum of 400 mm, and the recommended height of 450 mm.

Seat depths

Seat depths (SD) seat depths include the thickness of the seat back, should be a minimum depth of 350 mm and a recommended depth of 400 mm.

 

Amenity (or easy access) seats (Sixth Edition 12.18 extract)

Amenity, or easy access seats, is seats provided for spectators who may require more space and/or who have limited mobility. Such seat should meet the following requirements.

 

a.         They should be located:

i.    in easily accessible locations and require the use of only one or two steps

ii.   at the end of rows and close to exits

iii.  ideally in stands no steeper than 20 degrees

iv.  within 40m of accessible toilets

v.   under cover.

 

b.   They should also:

i.    have backrests (that is, benches or bucket seats are unacceptable)

ii.   if provided with armrests, these should ideally be removable.

 

iii.  provide hand or “P” rails where ever steps are encountered to comply with the recommendations 8.10 - Handrails for stairway and ramps.


c   Radial gangways leading to amenity seats should be fitted with suitable means of support, such as handholds, grab rails or central hand rails.

 

d. As spectators with limited mobility may be unable to bend the knees or may need more room to access their seat, for example using a walking aid or crutches, amenity seats should conform to the minimum recommended seat width of 500 mm, and seat row depths of 800 mm.

 

e. As spectators with limited mobility may be unable to stand easily, or stand for long periods, or easily changed position, amenity seats should offer adequate sightlines and be located in areas where spectators in front, or to the side, are less likely to stand up and where other personnel passing in front will not block the views.

 

f. Where required, space should be available to accommodate an assistance dog.

 

g. Where appropriate, spectators requiring amenity seats should be able to sit with supporters of the own team in a range of viewing areas and ticket categories, including hospitality, VIP and directors’ boxes

 

h. Where required, management should make provision for the safe storage of mobility scooters for those spectators who wish to transfer to seats.

 

Suggested changes:-

 

i)          As disabled spectators may be unable to stand easily or change position comfortably, sufficient row depth should be provided to enable other spectators to move past the seated disabled spectator without the need to stand and be disturbed.

 

          Recommended row depth to be 1,000mm.   See diagram below.

 

ii)       Because ambulant spectators are not always able to stand up, the seats allocated to them and that of their companion, must be located and designed in such a way that if spectators or other personnel, in front or on either side, stand up or walk in front of them the sightlines will not be obstructed.

 

To be included as a qualifying ambulant seat for calculating the minimum requirement under the Accessible Stadia Guidelines, both i) and ii) must be met.

 

Where an ambulant disabled supporter has provided evidence of their disability and confirmed that they require the support of a PA, provision should be made for the PA to be seated alongside.

 

Current recommendations –

 

Seating row depths and seat dimensions (Sixth Edition extract 12.12)

 

Seating row depth (T) :  700mm (however 800mm is preferred)

Seat width (W):              500mm measured between seats centred

Seat depth (SD):             minimum depth of 350mm and a recommended depth of 400mm

Seat height (H)               minimum 400mm and a recommended height of 450mm

 

Recommended dimensions to facilitate the non-disturbance of ambulant spectators – seat depth 400mm – distance from seat edge to forward barrier 600mm. 

 

See Diagram below.


 

 

Sightlines and leg room dimensions for ambulant spectators–

New modified diagram

 

 

 

Sightlines for ambulant spectators from pitch level viewing areas.

 

Re-instate - Accessible Stadia Guidelines 2003 – extract 2.18

 

Diagram modified for ambulant spectator example.

 

Where it is not practical to prevent frequent passage or personnel stationed in front of these spectators, a walkway behind these seats should be considered.

 

Guide Dogs

A disabled spectator accompanied by an assistance or guide dog may also require extra space for the dog to lie in front of or under their seat.

 

Comment:  The revised leg room dimensions would improve the guide dog provision.

 

They too should be provided with a choice of amenity and easy access seating.

 

(Accessible Stadia Supplementary guidance August 2015 extract Section 1)

 

Amenity and easy access seats should be provided in easily accessible areas, such as at the end of rows, where steps are minimised to accommodate spectators with limited mobility. Spectators requiring amenity or easy access seats should be able to sit with supporters of their own team in a variety of viewing areas and ticket categories, including hospitality, VIP and directors’ boxes. Such seating should also be located close to toilets and other facilities.

 

The table (in Section 3) shows the minimum standards for amenity and easy access seating, established by the European Commission and UEFA and Centre for Access to Football in Europe (CAFE) Guide to Creating an Accessible Stadium and Matchday Experience - Access for All. These are minimum numbers only but are based on experience and good practice concerning the number of disabled people likely to want to attend a match or other stadium event.

 

Additional amenity seating should always be provided in hospitality and VIP areas (not included in the quota for general seating areas).

 

Seats incorporating barriers (Sixth Edition extract 12.21)

 

i.          Provision for disabled spectators

 

Disabled spectators are entitled to gain access to all areas in existing or new sports grounds. Therefore the recommendations and guidance in respect of spaces for wheelchair users and for ambulant disabled spectators are the same for areas where seats incorporating barriers are installed as they are for all other areas of seated accommodation.

 

 

 


 

Consideration for a wide range of disabilities

 

 

 7.  Partially sighted and blind spectators (Accessible Stadia Supplementary guidance August 2015 extract Section 3)

 

Recognition is made of the need to present visual information (such as signage, tickets, maps, display boards and safety related documentation), in a form that should not be misunderstood by people with colour vision deficiency or colour blindness. A new online Annex C offers further guidance.

 

Individuals who are blind or partially sighted require clear pathways and signage including tactile surfaces, colour contrasts and non-reflective surfaces, as well as alternative information formats such as Braille, large print, audio recordings and audio-descriptive commentaries. Partially sighted and blind people may be limited by sensory, physical and/or attitudinal barriers.

 

Re-instate (Accessible Stadia Supplementary guidance 2003 extract Section 2.2)

 

Visually impaired spectators may wish to be located at pitch level to experience the sounds of play and activity on the pitch. Proximity to the pitch will also benefit spectators with limited vision.

 

Supplying Match Commentaries to Viewing Areas

 

2.25 It is recommended that a match commentary be provided for spectators with visual impairments with sufficient provision for headphones

 

Consideration should also be given to the provision of radio or audio, induction equipment to relay commentary to any person equipped with a necessary earpiece or receiver. It is also recommended that professional commentators are used rather than volunteers.

 

 

Signs – inclusion issues (Sixth Edition extract 16.31)

 

When drawing up a signage strategy it is vital to incorporate inclusive design principles so that the ground will be accessible to as wide a range of visitors as possible. In order to achieve this it is important to note that:

 

a.         People who are deaf or hard of hearing, or are blind or partially sighted, tend to have a greater reliance on easy wayfinding and clear signage.

 

b.        Only a minority of the general population has perfect vision.

 

c.         A significant proportion of the population is affected by colour blindness and therefore experiences difficulty in reading or interpreting signs with certain colour combinations – see online Annex C

 

d.        When positioning signs in crowded areas, such as concourses, consideration should be given as to whether they will be visible to children, wheelchair users or people of shorter statue, and with additional signs may be needed at a higher level.

 

e.         Signs supplemented with tactile text and or Braille will only be of assistance if provided at the appropriate height, but are not generally appropriate for directional signs in large open spaces.

 

f.          Inclusive signage design principles should be applied not only in areas occupied by the public but also in all other areas of the ground where staff and others might gather all work.

 

 

Signage (6th Edition extract 6.3 e)

 

Circulation routes should be identified by clear signs, illuminated where necessary.

 

Consideration should also be given to the avoidance of colours and or colour combinations on signs and their backgrounds but might be difficult for people with colour blindness to read or interpret.  Note: see online Annex C.

 

 


 

 

8.-  Hard of hearing and deaf spectators

 

Accessible services, such as British Sign Language (BSL) interpretation and captioning for hard of hearing and deaf spectators and audio descriptive commentary for partially sighted and blind spectators, are integral to providing fully accessible sporting events.

(Accessible Stadia Supplementary guidance August 2015 extract Section 3)

 

Individuals who are deaf or hard of hearing may use other forms of communication such as sign language or lip reading and require services such as interpreters and dedicated text-to-voice telephone relay services. However, many have some hearing and may use assistive hearing devices such as hearing aids and may benefit from induction (hearing) loop and passive infrared systems and visual alarm systems. Hard of hearing and deaf people may be limited by sensory and/or attitudinal barriers.

 

Re-instate (Accessible Stadia Supplementary guidance 2003 extract Section 2.2)

 

The Green Guide (Chapter 13) identifies the importance of: audible public address systems, visual information on electronic scoreboards, audio induction loops in areas of spectator accommodation and in ticket offices, good lighting at turnstiles and counters (for lip readers), and staff/steward training. People with poor hearing may hear public announcements provided they are clear and succinct.

 

The DRC Code sets out the range of auxiliary aids or services, which it might be ‘reasonable’ (within the meaning of the Act) to provide. They include one or more of the following:

 

_ Written information (leaflets or guides).

_ A facility for exchanging written notes.

_ Verbatim speech-to-text transcription service.

_ Induction loop systems.

_ Subtitles.       

_ Videos with BSL interpretation.

_ Information displayed on a computer screen.

_ Accessible websites.

_ Textphones, telephone amplifiers and inductive couplers.

 


 

 

9. Learning or intellectually disabled spectators (Accessible Stadia Supplementary guidance August 2015  extract Section 3)

 

Learning disabled spectators may require accessible services including information in plain language or easy-to-read documents and websites and clear wayfinding with logical stadium layouts. In addition, stadium staff and stewards need to be sensitive to and aware of their needs, particularly in connection with communication, wayfinding and event day routines. For example, a person with autism may have a preferred event day routine or behaviour that is important to their sense of well-being which can be easily accommodated. Learning disabled people may require a personal assistant or companion and some may request a designated quieter area of the stadium. Learning disabled people may be limited by intellectual and/or attitudinal barriers.

 

 

10. Spectators with mental health conditions (Accessible Stadia Supplementary guidance August 2015  extract Section 3)

 

The needs of spectators with mental health conditions on event day should be considered and may include a request for a seat in a designated quiet area of the stadium and /or to be accompanied by a personal assistant.

 

One in four people will experience mental ill health during their lifetime and attitudinal barriers may limit spectators with mental health conditions.

 

 

11. Assistance and guide dogs (Accessible Stadia Supplementary guidance August 2015 extract Section 3)

 

An increasing number of disabled people use assistance dogs to assist in their daily living. Partially sighted and blind people may use an assistance or guide dog to help with wayfinding but increasingly assistance dogs are being used to support other disabled people such as dogs that provide early detection of a seizure (for a person with epilepsy) or a hyperglycaemic episode (for a person with diabetes).

 

Assistance dogs are fully trained to support the disabled person and their life style, which may include attending a live sporting event. As such, disabled spectators with assistance dogs should be welcomed at sporting venues with designated dog relieving stations and easy access seats.

 

Guidance can be found at www.guidedogs.org.uk/media/1488953/Access_sports_08-08-04.pdf

 


 

 

12. Spectator accommodation – standing (Sixth Edition extract 13.4)

Provision for wheelchair users

 

Disabled spectators should have the same opportunity to view an event from a standing terrace, if that is their preference. This applies particularly at sports grounds with visiting supporters are allocated areas of standing accommodation only, and where, as a result, those visiting supporters who use wheelchairs are expected to spectate from areas reserved for home supporters.

 

Each space for a wheelchair user on a standing terrace should be designed:

 

a.         to accommodate a minimum of one helper standing alongside

 

b.        to accommodate a range of wheelchair designs, including powered wheelchairs
       and mobility scooters.

 

c.         to allow for its use by able-bodied spectators if not required by a wheelchair
       user

 

d.        to provide sightlines for wheelchair users that meet the minimum requirements
       set out in section 12.4

 

Comment:

 

Is this a practical and safe proposition for disabled spectators to be situated in a standing area?

 

How can sightlines be maintained in such an area?

 

No mention of ambulant spectators!

How will this be applied safely to ambulant spectators?

 

 


 

 

 

13. Toilet facilities

 

Re-instate Accessible Stadia Guidance 2003 – extract 2.28

 

Disabled people should be able to find and use appropriate sanitary accommodation as easily as non-disabled people. See BS 8300 para 12.4 and Part M, Section 5 for the recommended standards of provision.

 

It may be necessary to prevent use of disabled facilities by non-disabled spectators and other stadium personnel.

 

The Royal Association for Disability and Rehabilitation (RADAR) operates a National Key Scheme, which offers a potential solution to this issue but this may restrict access to facilities for disabled spectators without keys.

 

Stewards should have access to RADAR KEYS.

 

2.28 Toilets for Ambulant Disabled Spectators

 

At least one WC compartment designed for ambulant disabled people should be provided within each single-sex toilet area. The compartment should be fitted with support rails and be of sufficient space to accommodate people who use crutches or otherwise have impaired leg movements.

 

Urinals have appropriate support rails and adequate space.

 

Dimensions for toilets for ambulant disabled people are illustrated in BS 8300 figure 60. Management should consider measures to prevent inappropriate use of such facilities by non-disabled spectators.

 

For toilets serving seating areas the use of tactile signage (male/female symbols in relief) will assist blind and partially sighted spectators.

 

2.29 Toilets in First Aid Posts

 

Toilets which are incorporated in the design of new first aid posts should be accessible to disabled people independently and should not conflict with the function of the unit.

 

Where existing first aid posts are being modernised and upgraded, a suitable toilet should be provided either within or close to the first aid room.

 

 


 

 

14. Changing Places

(Accessible Stadia Supplementary guidance August 2015 extract Section 2)

 

Some sports grounds have more recently installed Changing Places or peninsular toilets.

A Changing Places toilet offers a larger space with special lifting equipment that can be used by disabled people with complex and multiple needs often requiring the help of up to two assistants.

 

Installing a Changing Places toilet may enable a disabled person to attend an event who might otherwise be unable to without their assistant having to resort to using the toilet floor for changing purposes.

 

Changing Places toilets are usually fitted with a fixed, tracked or mobile hoist system so that assistants can fit the user’s sling to the hoist and move the person to the various items in the facility. There is also an extended space to accommodate disabled people who may use large, complex wheelchairs such as those with elevated leg rests, a reclining facility or integral oxygen cylinders.

 

A changing bench should be installed to provide a stable platform that is suitable for changing adults and children. It should ideally be height-adjustable, but can be manually or electrically operated and wall-mounted or freestanding.

It should be possible to fix any height-adjustable changing bench at an appropriate, safe working height for assistants, to reduce the strain on their backs.

 

Such facilities are not designed for independent wheelchair users, and should not replace existing accessible toilets, but enable disabled people with complex needs to attend and enjoy events. As such, clubs should, wherever possible, consider installing a Changing Places or peninsular toilet at their stadium.

  

 

 

 

15. Sensory room

 

Sensory room     specification to be added

 

 

16. Other facilities:

 

Sale of refreshments (6th Edition - extract)

 

The design of refreshment facilities, including self service outlets, should be such that they are accessible to disabled spectators with counters in areas positioned to ensure that general circulation routes are not impeded by any resultant queues.

 

Counters designed for wheelchair users should not be more than 850 mm above floor level, with a clear space beneath the counter measuring at least 700 mm in height above floor level, and 300 mm deep as recommended by BS8300: Design of an accessible and inclusive built environment.

 

Retail outlets and other commercial activities,

 

Stadium retail outlets, betting stations, museums and other areas of commercial activity should have step free access with aisles suitable for wheelchair access.

 

Retail counters designed for wheelchair users should not be more than 850 mm above floor level, with a clear space beneath the counter measuring at least 700 mm in height above floor level, and 300 mm deep as recommended by BS8300: Design of an accessible and inclusive built environment.

 

Counters in any of these enterprises should comply with above design.

 

These facilities should have accessible toilets available within in minimum of 40metres.

 

An appropriate number of hearing loops should be installed.

 

 

 


 

17.  Emergency and exceptional egress - disabled spectators (6th Edition extract 10.15)

Disabled spectators must be accommodated without prejudicing their safety or the safety of others. At the same time, safety measures and contingency plans for their emergency egress should not be drawn up in such a way as to place undue restrictions on disabled spectators.

 

Ideally, separate emergency exit routes should be provided for disabled spectators, thereby allowing for all spectators to be evacuated or moved at the same time.

 

If, for practical reasons, separate emergency exit routes to disabled spectators cannot be provided, contingency plans (See Section 3.15) need to consider how else disabled spectators might be evacuated or moved in an emergency, and whether those plans might affect the egress of other spectators. 

 

In all instances, designated egress routes for disabled spectators should be clearly signposted and should lead to a place of safety, or to refuge.

 

Management should pay particular attention to the following matters.

 

a.Information and warning systems

 

Information and warning systems are required to help all spectators, in particular those who are blind or partially sighted, colour blind, or deaf or hard of hearing, find their way in an unfamiliar environment. Those with restricted mobility should have a choice of more than one means of ingress and egress. For guidance on how warning systems should be designed to accommodate the needs of disabled spectators see Section 15.22

 

b.Refuges

 

Refuge is an area where, in the event of an evacuation, disabled spectators can be accommodated temporarily before their subsequent onward movement by means of suitable lifts (See section 10.15d) or by other forms of assistance via protected stairs, or by external escape routes, to a place of safety.

 

If the refuges form part of the management’s contingency plans for emergency egress the proposed procedures must be agreed with the local authority and fire services. For example, an emergency egress procedure, as agreed with the local authority and fire services, might allow for stewards to begin moving disabled spectators to refuges from which they can be subsequently moved, either by evacuation lifts or by manual assistance, to a place of safety.

 

A refuge for use under emergency conditions should:

 

i.          be protected from the effects of fire and smoke for a period of time equal to the period of fire resistance of the building and in no case less than 30 minutes.

 

ii.        be large enough to accommodate the maximum number of disabled people and their companions likely to be in need of a refuge

 

iii.     be linked to exit routes that are themselves large enough and suitable for the onward egress of those temporarily accommodated in the refuge

 

iv.     have a communication link with the ground’s control room

 

v.        be clearly signposted.

 

c.Stairways

 

The preferred method of escape by most wheelchair users is:

 

i.          if horizontally, to another fire compartment or to outside the building, or

 

ii.        If vertically, by use of an evacuation or fire-fighting lift.

 

If those options are not available or not in operation, it may be necessary to carry a person up or down an escape stair.

 

d. Evacuation lifts

 

A lift provided for passenger use in the normal operation of the sports ground may only be used for emergency egress if it meets the requirements of an evacuation lift, as specified by the relevant British standard.

 

While there is no requirement to provide evacuation lifts and sports grounds, such lifts reduce the need to evacuate disabled spectators down staircases. Also, evacuation lifts should be able to continue to operate with a reasonable degree of safety when there is a fire in the building.

 

Where the evacuation of wheelchair users is via a lift, the Fire safety plan (See section 15.26) should consider the loading and returning times of lifts.

 

However a lift can still fail. It is crucial; therefore, that having reached a refuge serving an evacuation lift, a disabled person can gain access to an adjacent suitable stairway should the conditions in the refuge become unacceptable. Contingency plans should therefore also allow for the careful carrying disabled spectators down stairs without their wheelchairs, should the wheelchair be too large or heavy.

 

The location of evacuation lifts should be clearly indicated signs on every floor level.

 

 

e. Fire-fighting lifts

 

A firefighting lift is essentially an evacuation lift that is provided principally for the use of the fire service and which meets the requirements of the current, relevant British Standard. Such a lift may, however, be used for the evacuation of disabled people.

 

Liaison with the relevant Fire authority to coordinate procedures for the use of the firefighting lift for evacuation purposes is essential.

 

f. Wheelchair stairlifts

 

Wheelchair stairlifts should not be used for emergency egress. Nor should any part of a stairlift or its mechanism reduce the width of any stairway or escape route below the required minimum.

 

g. Ramps

Where ramps are necessary for the evacuation of wheelchair users they should preferably be no steeper than 1 in 20 and have signs identifying changes of level.

 

 

Design and management of entry points and ingress routes (6th Edition extract 7.8 e)

Turnstiles are not suitable entry points for wheelchair users, for people who are blind or partially sighted and or accompanied by assistance dogs.

 

For those individuals, the most practical design solution is to provide level access via a staffed gate or door – fitted with an appropriate vision panel – which provides access into a control lobby.

 

Passenger Lifts (6th Edition extract 8.13)

a.         Wheelchair users and spectators with limited mobility need sufficient time and space to manoeuvre into the lift, and should be able to reach both the lift controls on the landing, and those inside the lift itself.

 

b.        Sufficient space should be provided in front of lifts so that people waiting for them will not obstruct crowd flows.

 

     f.   For the use of people who are blind or partially sighted, information signs and lift controls should be supplemented with tactile text and/or Braille, at the appropriate height and in colours that contrast with the background.

 

Escalators . (6th Edition extract 8.14)

 

Where escalators are installed and because people with impaired mobility may prefer not to use escalators, passenger lifts should be provided in addition, with clear signposting at the foot and head of each escalator pointing to the location of the nearest lifts.

 

18.   Stewarding

 

The need for stewards (6th edition Partial extract 4.1)

 

Safety at sports grounds relies to a great extent upon the deployment of an appropriate number of well trained and suitably equipped individuals whose role is to provide a safe, secure and welcoming environment.

 

In carrying out their duties stewards should also, always, be aware of, and ensure the care, comfort and well-being of all categories of spectators.

 

Indeed, in many circumstances it should be remembered that stewards may be the only service personnel representing the management with whom spectators have any contact during the course of an event.

 

Stewarding Plan – roles and numbers

 

Specialist Stewards (6th edition Partial extract 4.12):

For example fire stewards, stewards trained in conflict resolution, and stewards deployed in areas used by children or disabled people.

 

Note that where radar locks fitted to accessible toilets, stewards should be provided with the keys.

 

Continuity

 

It is considered important that wherever possible there is continuity of stewarding in disabled spectator areas.  This will provide familiarity and an understanding of individual capabilities and shortcomings of incumbents that may be significant in regard to risk assessment in the event of an incident or stadium evacuation.

 

Extraction, applied to a wide variety of disability conditions, presents different risks to disabled spectators and those around them.

 

Detailed knowledge by consistent stewarding should minimise such risks.

 


19.      Additional topics for possible inclusion

Premier League 2018 - Ticketing and Matchday Guidance – Extract

 

19a.   Personal Assistants

19b.   What do we mean by disability and a disabled person?

19c.   Ticketing

 

19a. Personal Assistants (PAs)

 

Not all disabled supporters will require a PA, and clubs are entitled to ask for confirmation and evidence that a disabled person requires a PA in order to support them at matches (see above).  However, clubs should be careful not to apply overly stringent requirements or criteria when considering whether a disabled person reasonably requires the support of a PA. 

 

If a disabled supporter has provided evidence of their disability and confirmed that they require the support of a PA – particularly where they are in receipt of a disability benefit which indicates the need for extra help (see Annex 2) - clubs should proceed on the basis that the supporter has a legitimate need for such support.  

 

Where a disabled person requires the support of a PA, the Premier League recommends that clubs should admit the PA free of charge.  Whilst it may be possible for clubs to meet their legal obligations in other ways (e.g. by offering the services of a member of staff, who is capable of providing the necessary support to the disabled person, and in effect acting as their PA at the stadium), this is a straightforward adjustment that clubs can make to their standard ticketing policy, in order to assist disabled supporters.

 

Where a disabled person requires significant support and a club seeks to charge their PA for entry (contrary to the Premier League’s recommendation), if the disabled person and the PA refuse to make that payment (with the consequence that the PA is refused entry), then the club will be required to implement other measures to support the disabled person (e.g. by providing a member of staff to act as a PA).

 

Although they do not have to, a club may admit both the disabled supporter and their PA without charge or at a price less than the cost of one ticket.  

 

Clubs cannot require disabled supporters to be accompanied by a PA (and as noted above, many disabled supporters will not need to be accompanied by a PA), but they may encourage this where appropriate – e.g. by making disabled supporters aware of the free PA ticket policy. 

 

It is sometimes proposed by disabled people that children act as a PA.  Providing that the child is indeed giving assistance to the disabled person to allow them to attend, and is capable of fulfilling the role and responsibilities of a PA, the club should permit the child to act as a PA.  Accordingly, clubs should not seek to impose a minimum age for PAs, but rather should treat each situation on its own merits.  In addition, other disabled people may potentially act as PAs for disabled supporters.

 

Where the disabled supporter is a young child, it may not be necessary for clubs to allow the child’s PA (who may be a parent or other responsible adult) to attend for free, if the club requires all children (whether or not they are disabled) to be accompanied by a paying adult. 

 

However, when formulating their ticketing policies, clubs may wish to give consideration to the socio-economic difficulties that may disproportionately be experienced by families with disabled children.

 

Factors to be taken into account by clubs in determining the suitability of a disabled person’s (DP) personal assistant (PA),

 

A variety of criteria may be applied but of course, each PA need not have to be able
          to perform all of the tasks, it would depend on the particular needs of the DP.

 

•             Assist the DP in travelling to and within the stadium and/or from his/her
               car to the stadium.

 

•             Enter the ground and sit with the DP

•             Assist the DP with putting on and taking off coats, etc.

•             Assist the DP with toileting.

•             Provide medication or similar treatment to the DP.

•             Fetch food/drink from a concession and/or feed the DP.

•             Supervise, interpret for or reassure the DP.

•             Assist the DP in toileting/watering his/her guide dog.

•             Assist with evacuation or other emergencies (beyond that which would
              be ordinarily expected from stewards and other stadium staff).

•             Communicate effectively with stewards and other staff.

 

 

Where an ambulant disabled supporter has provided evidence of their disability and confirmed that they require the support of a PA, provision should be made for the PA to be seated alongside.

 


 

 

19b. What do we mean by disability and a disabled person?

 

The Act sets out a definition of disability which is different from other legal definitions (for example those relating to certain disability-related benefits).  Section 6 (1) of the Act provides that a person has a disability if:

 

(a)  the person has a physical or mental impairment, and

(b)  the impairment has a substantial and long-term adverse effect on the person’s ability
           to carry out normal day-to-day activities.   

 

An effect will be regarded as “substantial” if it is more than minor or trivial; accordingly, this is a relatively low threshold.  Furthermore, in considering what the effects of an impairment are (on a person’s ability to carry out normal day-to-day activities), the effect of measures being taken to treat or correct that impairment – e.g. medical treatment, or the use of prosthesis (such as artificial limbs) or other aid (other than spectacles or contact lenses) – must be disregarded.   

 

A substantial adverse effect will be regarded as “long term” if:

(a)  it has lasted for at least 12 months,

(b)  it is likely to last for at least 12 months, or

(c)  it is likely to last for the rest of the person’s life.  

 

In accordance with the common approach of the British disability movement, the word “impairment” is used to connote a medical or quasi-medical condition and the term “disabled people” is used to connote the experience of being disadvantaged by society as a consequence of having an impairment. However, some disabled people prefer the term “people with disabilities”.

 

With regard to the meaning of the word “likely”, the courts have interpreted this to mean “could well happen”.  Furthermore, if an impairment ceases to have a substantial adverse effect on a person’s ability to carry out normal day-to-day activities, it shall nevertheless be treated as continuing to have that effect if that effect is likely to recur. 

 

Some conditions are automatically regarded by the Act as constituting a disability – these are outlined in Annex 1.

  

When clubs are preparing disability policies and implementing those policies in practice, it is important to remember that the Act covers a wide range of physical and mental conditions, and that individual disabled people will each have their own specific needs and requirements, which must be properly considered and accommodated.  This is particularly important when considering the issue of what reasonable adjustments it may be necessary to make for a particular disabled person(s). In many cases, those requirements may be obvious – such as the need for a wheelchair user to have access to a wheelchair space in the stadium – but in other cases, it may be less clear and/or more complex.  If in doubt, further advice should be sought including from the disabled person him or herself. 

 

Where a person states that they require the club to provide them with an adjustment or additional support owing to the effects of an impairment, such as a free or discounted ticket for a personal assistant (PA), it will usually be legitimate for the club to request supporting evidence of the person’s need for that adjustment or support.  There are a variety of legitimate sources of evidence which a club might reasonably rely on, when considering an individual’s needs and requirements.  These are likely to include (but are not limited to):

 

•     Evidence of receipt of relevant state benefits, i.e. Attendance Allowance (AA), Disability Living Allowance (DLA) or Personal Independence Payments (PIP).  (Note that there are other benefits available to disabled people, including War Disablement Pension, Employment and Support Allowance and Industrial Injuries Benefits, but people in receipt of these are likely to also receive AA, DLA or PIP).

 

Further information on AA, DLA and PIP can be found in Annex 2.

 

•     Holding a disabled driver’s Blue Badge, as evidence of significant mobility difficulties.*

 

•     A letter of confirmation from the Local Authority Social Services Department that the person is in receipt of relevant support services.

 

•     A letter from the person’s doctor (or other medical practitioner) confirming that they are a disabled person in need of extra help or adjustments.

 

As an individual’s circumstances may change, in some cases it may be appropriate for a club to request up to date supporting evidence regarding their ongoing need for a particular adjustment(s) (e.g. on an annual basis, at the time when season tickets are renewed, or when parking permits are reissued).   

 

Individual clubs, through practical experience, may impose their own qualifying conditions or interpretations as to the supporting evidence required

 

* Example – “Please Note: Receipt of a Blue Badge or incapacity benefit will not be considered sufficient to enable you to purchase tickets.”

 


 

19c. Ticketing

 

Ticketing Policy

Any ticketing policy developed by clubs should have regard to the Premier League’s general rules on ticketing, currently set out in Section R of the Premier League Handbook.  Although there is no legal requirement under the Act to have a written policy on ticketing, this is helpful for clarifying arrangements for disabled people and is also likely to be an important consideration should it be necessary to resolve any claim of discrimination. 

 

The disabled persons ticketing policy should incorporate the club’s disability access statement required under rule 2 of Section R.  The policy must also comply with rule 9 of Section R, in relation to the provision of a percentage of the accessible wheelchair spaces to visiting disabled supporters.  Currently, the rule requires that 10% of the accessible spaces in the stadium must be allocated to visiting disabled supporters.

 

A club’s policy in relation to ticketing arrangements for disabled supporters should seek to identify: (a) particular difficulties that may be encountered by disabled supporters, and (b) practical measures which can be implemented in order to avoid or overcome those disadvantages, and to ensure that those supporters benefit from at least as good a level of access and service as non-disabled supporters. 

 

Ticket Eligibility

 

For most clubs, there will be times when the demand for seats is greater than the supply.  When allocating accessible wheelchair user spaces or other seating for disabled supporters, this should be done on an equitable and transparent basis, having regard to the duty to make reasonable adjustments for disabled people.  As noted above, clubs should ensure that their ticketing policy is clearly set out in advance, in writing.

 

If a club sets aside a number of wheelchair user spaces for season ticket holders, it is likely to be reasonable to allocate these on the same basis as it allocates other season ticket seats (such as by giving the existing ticket holder an option to renew their season ticket and prioritising the allocation of any available seats to persons who have signed up to a waiting list, etc).

 

In circumstances where a non-disabled season ticket holder becomes disabled and wishes to change from a general access seat to, say, a wheelchair user space, a club should seek to accommodate that request.  If all of the wheelchair user spaces are already allocated, it may not be possible to arrange this immediately and the disabled person could be placed on a waiting list until a suitable seat becomes available.  However, where a club knows that the demand for wheelchair user spaces is (or is likely to be) greater than the number of available spaces, it should investigate the feasibility of increasing the capacity of such spaces within the stadium (as this may be a reasonable adjustment). 

 

One issue that has been raised by a number of clubs is who should be responsible for determining eligibility for concessionary disabled seating.  Given clubs’ duties under the Act, the Premier League recommends that eligibility for concessions for disabled people should be determined by the club and not delegated to, say, a supporters group.

 

Clubs should encourage disabled persons who require support and assistance to make this clear to them as soon as possible.  If a disabled person arrives at the stadium without appropriate support, giving rise to genuine health and safety concerns, it may be legitimate for a club to refuse to admit entry to the disabled person.  However, this should only occur if there are sufficient health and safety risks and it is not possible for the club to make the necessary adjustments, in order to support the disabled person, at short notice.  It is anticipated that this will be a very rare situation, and clubs should take all reasonable steps to ensure that disabled persons are able to attend and enjoy matches, whether on their own or accompanied. 

 

Ticket Administration and Purchasing

 

This is a key area in which the duty to make reasonable adjustments is likely to have a day to day effect on clubs.  There are a number of different ways that fans can purchase tickets and clubs will need to ensure that disabled supporters can use the same, or equivalent, methods for purchasing tickets.

 

Wherever supporters can buy tickets in person, clubs should endeavour to make those locations fully accessible to all supporters.  Reasonable adjustments might include ramps or other assistance for external access; an induction loop for those with hearing impairments; and lowered counters for wheelchair users. 

 

Equally, where supporters can use other methods for purchasing tickets, clubs should seek to ensure that these are accessible as well.  For example, where non-disabled fans can purchase tickets over the phone or on the internet, it is likely to be reasonable to provide textphone services and accessible internet pages to allow supporters with certain impairments to use their phones and computers to purchase tickets.  Where paper applications (such as forms applying for season tickets) are ordinarily required, clubs should ensure that there are suitable alternatives available for disabled supporters who cannot use this method, or who find it more difficult to do so. 

 

Staff training

 

Staff training has always been an important aspect of understanding the rights of disabled people, and how to comply with obligations under the Act, including the duty to make reasonable adjustments.  It remains important that all staff and managers who are likely to deal with customers should receive disability equality and awareness training, which should include clear guidance on: (a) legal obligations under the Act; and (b) the club’s policies and procedures on supporting disabled people.  This will help to ensure that principles of good practice are familiar to staff members and are implemented by them on a day-to-day basis.

 

Some clubs have a named individual as the principal point of contact for dealing with all disability access ticketing issues.  This can be beneficial, as the staff member will develop a deep knowledge and understanding of the issues affecting disabled people in relation to ticketing issues.  However, clubs should not rely exclusively on that person as a source of information or support for disabled supporters, in relation to those issues.

 

 

Ticket pricing

 

Some clubs offer concessionary prices for disabled supporters.  Subject to the points set out below, this is permitted under the Act (as it constitutes more, rather than less, favourable treatment).  However, it is not required by the Act, and clubs may charge these supporters the applicable full price, should they wish to do so.  That being said (and as discussed further below), it may be a reasonable adjustment to provide free tickets for personal assistants (PAs) of disabled supporters, in order to ensure that they are able to access and enjoy the match day experience.

 

Concessions for disabled supporters should be clearly set out in the club’s ticketing policy.  Where a club has a policy to offer reduced price tickets to disabled supporters, it should not differentiate between different types of disabilities. 

 

Where children are entitled to receive a concession (for example a half-price ticket), disabled children should benefit from: (a) the same concession as applies to non-disabled children; or (b) the concessionary price for an adult disabled supporter, whichever is the cheaper.

 

Clubs may also have arrangements for providing free tickets to various groups (such as schools or local community associations) as part of their ticketing policy. 

 

Disabled people should be included in this provision and where a disabled person(s) wishes to attend the match, where possible that should be accommodated.  Depending on the circumstances, it may also be reasonable, for example, to arrange for the other school children attending the match to sit near the disabled student (where, for example, the disabled student requires a wheelchair user space), so that s/he is not isolated from his/her schoolmates.  

 

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