In this second part of our interview with Colin Nessfield of the Mineral Products Association (MPA), we delve into the rules and regulations surrounding tactile paving and whether the clarity of the guidelines impacts the provision of the paving.
Read part one of the conversation between Mark King and Colin Nessfield.
Mark King (MK): Picking up where we left off from last time, I think it’s important to look at the requirements relating to tactile paving and the rules around blisters and profiling.
First of all, where can people find information about the design parameters that tactile paving should meet?
Colin Nessfield (CN): There’s actually very little in the way of statutory guidance regarding tactile paving, but the closest thing we have is part M of The Building Regulations. This outlines some of the legal requirements in relation to adhering to the Disability Discrimination Act (DDA).
More detailed information is available in the British Standards. Specifically, BS8300 covers the external environment (part 1) and access to buildings (part 2). Although they are not a formal part of The Building Regulations and do not directly relate to the DDA, it’s generally thought that meeting BS8300 standards fulfils the DDA’s requirements.
MK: There are a lot of similarities between Part M of the Building Regs and BS8300, but there are also some inconsistencies. With this in mind, which set of guidance should take precedence?
CN: BS8300 part 1 is the best for external steps, like nosings, because it provides specific detail; however, this is only published as guidance, so there’s no legal requirement to meet these standards.
In terms of a legal hierarchy, the DDA must be complied with, but it doesn’t explain how to comply. Next is the Building Regulations, part M and BS8300-1 and -2, although these are only codes of practice.
MK: In your experience, how well are the tactile paving recommendations followed in the UK?
CN: Things are improving, albeit slowly. Compliance is relatively high in transport (mainly railway stations). You rarely go to a train station and don’t see a strip of brightly coloured paint or contrasting tactile paving, but this is definitely one of the situations where compliance is crucial.
Compliance is sketchy across towns and cities in the UK. Casual observation suggests it’s optimistic to say we’re even halfway to properly meeting users’ accessibility needs.
MK: But it is improving?
CN: Slowly. Until there’s a firm legal obligation to ensure guidance is followed, it makes rules difficult to enforce, and it’s tricky to be 100% compliant when things are open to interpretation.
MK: Considering the potential lack of compliance, and other factors, what do you think are the main failings when it comes to tactile paving in the UK?
CN: The most common thing I see is areas where tactile paving should have been used, but it hasn’t. This is obviously a big failure, but it’s just as essential to ensure the correct profiling is used, too.
For example, a hazard warning flag at a crossing point gives the user a completely wrong impression of what they will face.
After this, the next problem is using colours that don’t contrast enough. Quite a considerable number of people who are registered blind are visually impaired, so they still have some residual vision. Contrasting colours can help people identify that they are approaching something and direct their attention to the object or hazard.
There is confusion over red-coloured products as well. These should only be used at a controlled crossing, but they’re frequently found at uncontrolled crossing points and for hazard warnings, which isn’t their purpose.
These are the four main areas where we encounter problems in the UK regarding current installation.
MK: In 2021 and 2022, respectively, the European and UK standards for tactile paving were published. How have these updated versions changed and evolved from older versions, i.e. those released in 2003 (BS7997) and 2008 (TS15209)?
CN: BS7997 (which was fairly simplistic compared to the standards we have now) was written as a British standard for the UK marketplace and those that deal with typical UK products. Despite being useful at the time, it ended up being withdrawn to avoid clashing with the TS15209, which was published in 2008.
TS15209 was developed at the European level, so it had to attempt to solve problems that were occurring all over Europe. Although it was well-intentioned, it offered up all of the options across the continent as solutions, which led designers to pick and choose what they wanted instead of creating a consistent standard.
MK: I was in Stockholm last year (2023) and noticed the huge profiles on the blister paving around uncontrolled traffic points. They’re really different from the type of profile we’d expect in the UK. Is that a result of what was in TS15209?
CN: Yes, it included an array of options without adequately defining what was appropriate. In addition to the six standard profiles we tend to use in the UK, there were another 18 to 20 options, so there was a lot of misplaced design.
Sometime after that, about five years later, I took over as the convener of the TC work group. As a team, we were presented with this pan-European specification and tasked with fixing it so that it would be fit for purpose.
We redrafted the standard to remove the available options and then allowed them to be re-added as part of the national annexes.
This meant that if you bought the UK version of the standard, you would only be presented with the six profiles that are commonly used here.
This allowed us to choose a 7th or 8th option at the UK level if we thought users would benefit from it, with no need to wait for the European TS to be published.
One noticeable addition we put into the 2022 version was addressing the need for contrast between areas to ensure the tactile paving stands out for those with some residual vision.
MK: BS8300 and Part M of The Building Regulations both address the contrasting strip required for steps and how these should contrast in terms of reflective values and what’s needed to create a suitable contrast. Having said this, they don’t offer much guidance about the corduroy hazard warning paving in terms of contrast, only that they should be present and set back 400mm and be 800mm in width.
Does TS15209 address that warning paving should obtain a degree of contrast with the surrounding paving before the users come to the steps?
CN Yes, it does. In BS8300 part 1, the design of steps, details of the strip and how it should go around the nose of the step are included. That’s a construction detail.
TS15209 includes information about the strip itself and measuring the product's light reflectance. Differences between areas are given in clauses 5.1 and 5.2, and the default reflectance values are featured, too, to provide you with some idea of the levels that should be achieved.
Let’s say you’re designing with a multi-coloured paver on the way up to a change in surface or some kind of hazard. TS15209 explains how to implement a strip of different-coloured material around the tactile paving to highlight the change and help draw attention to it.
MK: Is there anything else of value you wish to highlight relating to tactile paving, its design, use, and the guidance around it?
CN: It’s important to mention that other guidance does exist and that they vary from what we’ve discussed. In Scotland, for example, there are some slightly different requirements.
Information can also change depending on the local authority. For example, London transport guidance has slightly different requirements relating to slip-skid.
The Department of Transport’s Inclusive Mobility Guidance offers excellent guidance, and it’s a free download from the GOV.UK website. Likewise, charities and support groups for the visually impaired also provide advice on what we’ve discussed.
There’s a lot of information out there, but we have to remember that it’s only guidance. It’s not written in law.
If you want to request a CPD with our team, you can find the tactile paving topic in our CPD library.