TRANSADELAIDE DISABILITY ACTION PLAN (2007 - 2009) Issue Date: TARDIS-#43719 V4 - 17 October 2007 INTRODUCTION The objectives and the strategies detailed in this Disability Action Plan are expected to build on the work already being achieved throughout the whole of government Promoting Independence: Disability Action Plans for South Australia Strategy for ensuring that the public sector progressively becomes more accessible and inclusive for people with disabilities. The strategies identified aim to eliminate discriminatory policies and practices that result in people with disabilities being treated less favourably than those without a disability. The Plan covers both strategic and operational requirements in outlining the journey from where we are now to where we want to be and the steps we need to take to get there. TransAdelaide is challenged and committed to securing a modern, efficient and accessible rail system that allows all members of the community to access employment, cultural and leisure opportunities. TRANSADELAIDE TransAdelaide was established under the TransAdelaide (Corporate Structure) Act 1998 to operate train and tram passenger services within the Adelaide Metropolitan area. These services are provided under contract to the Passenger Transport Division (PTD) of the Department of Transport, Energy & Infrastructure (DTEI). We are aware that transport is vital for members of the community to access services and employment opportunities and provide independent mobility. With over 360,000 people with a disability in South Australia, it is important to enhance accessibility. The purpose of the Plan is to provide direction for TransAdelaide in developing strategies and actions to remove practices which discriminate against people with disabilities including its own staff. Actions within this Plan will occur at all levels to assist with the delivery of this outcome. This will include specific initiatives at a business unit level, as well as service provision and local strategies which improve and include decision making processes and planning of services. In South Australia, the PTD has the overall responsibility for developing a state wide public transport Disability Action Plan. TransAdelaide is working with DTEI to ensure integrated service provision across the transport portfolio. TransAdelaide's Disability Action Plan embraces; existing Australian Standards as appropriate, the Disability Discrimination Act (1992) (DDA), the South Australian Equal Opportunities Act (1984)(EOA), South Australian State Strategic Plan and the Disability Standards for Accessible Public Transport (2002) (DSAPT). The DSAPT is a legislated Standard which was enacted by the Federal Government on 23 October 2002 and applies to all operators and the conveyances they use to provide public transport services including supporting premises and infrastructure. The Standard prescribes what must be achieved to satisfy established compliance timeframes. This Plan has been developed to satisfy TransAdelaide's contractual obligations with the PTD, legal obligations with respect to the DDA and moral obligations to the community. Full implementation of all initiatives will depend upon the availability of funds from Government to meet the necessary costs. SETTING THE SCENE An accessible transport network is fundamental to creating opportunities and choices for the community. The policies contained in the Promoting Independence Strategy apply to all public sector services and programs of the South Australian Government and their funded agencies. The focus is on ensuring that mainstream services are accessible to people with disabilities and that all practices within those services that unlawfully discriminate against people with disabilities are eliminated. In 2003, the Australian Bureau of Statistics Survey of Disability, Ageing and Carers (ABS) estimated that one in five Australians have a disability or 20% of the population (3,958,300). The survey recorded 362,100 (23.9%) South Australians with disabilities. South Australia's greater representation of aged persons contributes to this statistic. The DDA provides a definition of the term 'disability' which is far broader than the ABS definition or the categories of persons with disabilities covered under the South Australian Disability Services Act (1993) or the EOA (1984). For the purposes of this Plan, and to ensure its alignment to the Promoting Independence Strategy, the DDA definition of disability has been used to promote consistency with the objects of the DDA as well as to support participation and independence. The Act requires employers and service providers to make whatever adjustments are necessary and reasonable to allow people with disabilities to use those services - irrespective of whether these services are provided by Government agencies, community organisations or business enterprises. WHERE ARE WE NOW? Since the introduction of the DSAPT there has been a great deal of work in this area to enable access to services for the widest range of people with disabilities, including people who use a wheelchair and people with sensory impairments. These improvements are developed to make it easier for people with disabilities to travel on all modes of public transport and access the services, job opportunities and entertainment venues that many take for granted. TransAdelaide recognises that people with disabilities have the right to challenge transport operators directly to improve the services they offer and encourages contact and comment from members of the community around issues relating to disability discrimination. TransAdelaide is aware that operators should not: * Discriminate against people with disabilities - for example by refusing someone to board a vehicle simply because they have a disability, even though the vehicle might be accessible to them; * Treat people with a disability less favourably; or * Fail to make a reasonable adjustment to the way they provide a service, when such a failure results in a person with a disability being unable to continue using the transport service - for example by failing to inform a blind person when they reach their destination or the failure to deploy a ramp for a person using a wheelchair. The DDA sets the framework for the development of Action Plans. The Objects of the DDA are to: a) eliminate, as far as possible, discrimination against persons on the grounds of disability in the areas of; * work, accommodation, education, access to premises, clubs and sport; * the provision of goods, facilities, services and land; * existing laws; and * the administration of Commonwealth laws and programs; b) ensure that people with disabilities have a right to equal treatment before the law; and c) promote community understanding that people with disabilities have the same fundamental rights as the rest of the community. The DDA contains five strategies for achieving these Objects: * discrimination on the basis of a disability is made unlawful; * independent investigation and conciliation or determination of complaints about discrimination; * development of Disability Standards; * development of Disability Action Plans; and * review of discriminatory laws by the Human Rights and Equal Opportunity Commission. THE AIMS AND OBJECTIVES TransAdelaide recognises that this is the very start of the process and major challenges remain ahead when developing and implementing a Disability Action Plan. The Plan addresses the six key outcome areas of the Promoting Independence: Disability Action Plans for SA and will report on how TransAdelaide will ensure: * Access to building, facilities and services; * Information and communication is accessible and inclusive; * Disability awareness and discrimination training of staff; * Consultation and complaints processes are in place; * Compliance with the DDA (1992) and the EOA (SA) (1984); and * Increased rate of employment of people with a disability. The Action Plan actions set out the key activities which are undertaken and are the result of: * Priorities identified by people with a disability through involvement in the production of this Action Plan; * The organisation's strategic objectives; * TransAdelaide's legal obligations under the DDA and the DSAPT; * Contractual obligations with the Department for Transport, Energy and Infrastructure, Passenger Transport Division; * TransAdelaide's commitment to specific targets within South Australia's Strategic Plan; * Auditing or assessment of services, facilities and practices to identify the shortfalls in areas that could give rise to claims of potential direct or indirect discrimination; * Resources available to undertake these tasks; * Monitoring and evaluating progress against the Action Plan; * Limitations identified in other areas of infrastructure provision, for example, roads, private property, other buildings and services that are not controlled/owned by TransAdelaide but which facilitate access to our services; * Legal obligations under the Rail Safety Act 1996 and Occupational Health, Safety and Welfare Act 1986. PRINCIPLES OF APPROACH TransAdelaide recognises the importance of involving people with disabilities in the formulation of policies, procedures and strategic planning that might affect them. The Plan requires us to formalise this process and we have ensured the inclusion of people with disabilities in the development of this Plan. Their involvement has been fundamental to the development of all aspects of this Plan, from identifying what extent the existing policies meet the needs of the people with disabilities to understanding the barriers and where outcomes have been unsatisfactory. Specifically we have: * Developed a high level steering group (Disability Action Plan Implementation Committee), involving representatives from across the organisation's business units * Developed a Disability Consultative Committee consisting of representatives from the disability sector. Liaison with these working groups will continue throughout the development and implementation of the actions/strategies within the Plan. As the plan progresses, consultation will be conducted with a wide range of people with disabilities, covering a variety of geographical areas, topics and types of disability. The establishment of such groups and consultation processes will ensure that people with disabilities are involved in all aspects of the organisation's business activities from planning to implementation. REPORTING Progress towards this Plan will be reported annually through the 'whole of government' Promoting Independence: Disability Action Plans for South Australia reporting process and through the TransAdelaide annual report. Implementation Table 1. ACCESS TO SERVICES OUTCOME Ensure access to buildings, facilities and services for people with disabilities STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET COMPLETION DATEACTION TO DATE / MILESTONES1 Improve accessibility of rail infrastructureInfrastructure / Trams 1.1 Access audits/assessments of physical features, waiting areas and facilities, layout and signage: Ongoing Training for internal TA staff sourced 1.1.1 Corridor Infrastructure External Audit conducted 2005 1.1.2 Adelaide Railway Station External Audit conducted 2005 1.1.3 Internal Business areas 1.2 Annual station upgrading program Ongoing Ongoing work program in place 1.3 Infrastructure program developed incorporating implementation priorities, funding required and timeframes Ongoing Info & data collation commenced 1.4 Implement infrastructure program in line with Disability Standards for Accessible Public Transport to ensure the increased number of accessible railway stations/facilities Ongoing Continuous Improvements being made 1.5 Increased use of the rail network by people with disabilities (South Australian Strategic Plan) Ongoing 2 Improve accessibility of train and tram vehiclesInfrastructure / Trams2.1 Undertake an audit/assessment of rolling stock Ongoing Internal train and tram audit/assessment program underway 2.2 Train program developed incorporating implementation priorities, funding availability and timeframes Ongoing Info & data collection commenced 2.3 Tram program developed incorporating implementation priorities, funding availability and timeframes Ongoing Info & data collection commenced 2.4 Train vehicle modification program developed, incorporating the implementation priorities, budget requirements and timeframes Ongoing 2.5 Implement vehicle modification program in line with Disability Standards for Accessible Public Transport Ongoing Info & data collation commenced 2.6 Improved accessibility of rail vehicle fleet resulting in the rising levels of patronage for people with disabilities (South Australian Strategic Plan Target) OngoingContinuous Improvements being made 2. INFORMATION & COMMUNICATION IS ACCESSIBLE AND INCLUSIVE OUTCOME Ensure that information and communication about services and programs are inclusive of people with disabilities STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET DATEACTION TO DATE / MILESTONES3 Review internal policies and procedures to ensure equitable access for people with disabilities to information and communicationOrganisation Development / Planning & Development 3.1 Process developed and implemented that ensures the inclusion of customer support, information dissemination, and alternative format/communications for people with disabilities has been developed and implemented across the organisationAug 2008 Dec 2008 Implementation4 Develop and execute communication strategy to inform target audiencePlanning & Development 4.1 Target audience informed and aware of changes Ongoing 1 4.2 Review TransAdelaide publications to ensure their availability to people with disabilities Ongoing Incorporated as publications are produced or re-issued 1 4.3 As an outcome of information policy/guidelines development - include a process to monitor the level of demand for alternative formats and information, together with comments and feedback has been developed February 2008 5 All electronic information and communication provision to be accessible to people with a range of disabilitiesPlanning & Development 5.1 All TransAdelaide websites (internet/Intranet) have been audited against their compliance with the W3C (World Wide Web Consortium) guidelines July 2008 Intranet review commenced 5.2 Website guidelines (internal and external) will be a key outcome of the Online Redevelopment project July 2008 5.3 People with a disability can use the National Relay Service or a TTY (TeleTYpe) number to contact the organisation Ongoing 5.4 Web Developers use up to date web design standards, software developments and equipment requirements for people with disabilities Web Developers receiving E-Accessibility training 3. DISABILITY AWARENESS AND DISCRIMINATION TRAINING OF STAFF OUTCOME Deliver advice or services to people with disabilities with awareness and understanding of issues and needs STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET DATEACTION TO DATE / MILESTONES6 Develop an Access, Equity & Diversity PolicyOrganisation Development6.1 Access, Equity & Diversity policy to be developed and promoted across the organisation as part of the Integrated Management SystemDec 2007 Developed April 2008 Promoted June 2008 Implemented7 Review training programs and modules to ensure their coverage of disability awareness and discrimination and access provisionOrganisation Development7.1 Existing training programs have been reviewed to ensure components on DDA obligations and understanding of people with disabilities and their needs, e.g. induction programs, customer service training, RTO courses Dec 2007 Customer service training manual reviewed Induction program currently under review RTO review is linked to the development and policy reviews 7.2 Disability Awareness & Discrimination Training schedule developed and implementation commenced, with a target that 20% of staff receive training per year Ongoing Staff training programme developed 7.3 Targeted training for key personnel has been developed and implemented; e.g. * Access Assessment training * Front line staff; * Client information management; * Line managers; * HR/Employment Ongoing This is separate to general Disability Awareness Training and will be monitored 7.4 All staff have received a copy of a Disability Awareness leaflet which highlights TransAdelaide's commitment to improving services to people with a disabilityDec 2007 4. CONSULTATION AND COMPLAINTS PROCESSES OUTCOME Provide opportunities for consultation with people with disabilities on service delivery, complaints and quality assurance mechanisms STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET DATEACTION TO DATE / MILESTONES8 Establish a Disability Consultative CommitteeCorporate Services 8.1 Group established and used for consultation by all Business UnitsAug 07Group established August 2007 9 Ensure effective, transparent mechanism for involving people with disabilities in all aspects of policy to inform setting of DDA priorities and business planningCorporate Services9.1 People with disabilities assist in setting DDA agenda and priorities for the organisationOngoingDisability Consultative Committee established August 200710 Review mechanisms for gathering appropriate information and whether these provide an appropriate evidence base for planning and decision making Planning & Development10.1 Appropriate community consultation mechanisms with people with disabilities have been established July 2008 6 10.2 Higher quality and relevance of information requested and received through consultation/complaints mechanisms July 2008 11 Develop an internal complaints handling proceduresPlanning & Development 11.1 TransAdelaide promotes the use of accessible and participatory complaints procedures for people with disabilities as part of the existing complaints handling processes Ongoing Complaints database in useOrganisation Development 11.2 All staff have been informed of the relevant policies and complaints handling processes for people with disabilities and their associates/advocates July 2008 Organisation Development 11.3 Complaints procedures have been incorporated into the induction training for all new staff Ongoing 5. COMPLIANCE WITH THE DISABILITY DISCRIMINATION ACT (1992), SOUTH AUSTRALIAN EQUAL OPPORTUNITIES ACT (1984) OUTCOME Ensure that TransAdelaide has met the requirements of the Disability Discrimination Act (1992) and the Equal Opportunity Act (1994) STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET DATEACTION TO DATE / MILESTONES12 Establish a TransAdelaide Disability Action Plan Implementation CommitteeCorporate Services12.1 Group established with an ongoing role to oversee the TransAdelaide Disability Action Plan May 2007Group established and meeting regularly13 Publish and monitor the ongoing implementation of the Disability Action Plan and report on implementationCorporate Services 13.1 TransAdelaide's Disability Action Plan Implementation Committee monitors progress against the Disability Action Plan Ongoing Group identified priority areas 6 13.2 Annual reports to highlight DDA related achievements Aug 2007 (2006/07 reporting) Report finalised 6 13.3 People with disabilities are involved, through consultation, in identifying barriers, improving outcomes, setting priorities and assisting planning activities Ongoing Disability Consultative Committee involvement 6 13.4 The Disability Consultative Committee monitor the Disability Action Plan implementation Ongoing Group established 14 Monitor the inclusion of the Disability Action Plan objectives in the departmental strategic planning processCorporate Services 14.1 Disability Action Plan objectives have been included in the TransAdelaide Business PlanJuly 2007Part of Governance section of Strategic Plan15 Project specification & tender documents to ensure compliance with the DDA 1992Infrastructure15.1 Project specifications and tender documents include detail on compliance with DDA (1992), EOA (1984) and the Disability Standards for Accessible Public Transport (2002)Ongoing16 Terms & Conditions of Contract, where appropriate, to ensure compliance with the DDA 1992 Corporate Services 16.1 Terms and Conditions of Contracts to include standard clause on legislative requirements.Ongoing 6. EMPLOYMENT AND HUMAN RESOURCE PRACTICES OUTCOME Increased rate of employment of people with disabilities to meet the South Australian Strategic Plan Target (T6.22) "to double the number of people with disabilities employed in the public sector by 2014" STRATEGYRESPONSIBILITYMEASURABLE OUTPUT/OUTCOMETARGET DATEACTION TO DATE / MILESTONES17 Assess HR policies and procedures for equity of employment of people with disabilitiesOrganisation Development17.1 HR policies have been assessed and necessary actions implementedOngoingProcedure checklist developed to assist the review 18 Ensure that people with a disability are provided with equal opportunities to employment Organisation Development 18.1 Workforce profile information/staff questionnaire conducted Dec 2008 Staff survey completed (2006), but used Office for Public Employment definition. New survey to capture DDA definition 6 18.2 Take account of specific employment support requirements, ensuring development plans for people who have identified as having a disability Ongoing 6 18.3 Procurement of workplace modifications and universal design for staff with disabilities Ongoing 6 18.4 Enhanced work opportunities within TransAdelaide for people with disabilities Ongoing 19 Monitoring of the recruitment strategy to ensure it promotes awareness and equity in the employment of people with disabilities to eliminate direct/indirect discriminationOrganisation Development 19.1 Access, Equity & Diversity policy is implemented and utilised June 2008 Policy in draft form 19.2 Essential and minimum requirements within job and person specifications to ensure they do not discriminate against people with a disability Ongoing Guidance to be included within the recruitment selection process (June 2008) Training for managers CONTACT DETAILS If you have any comments or questions in relation to TransAdelaide's Disability Action Plan please contact: TransAdelaide Adelaide Railway Station GPO Box 2351 Adelaide SA 5001 Phone: (08) 8218 2422 Fax: (08) 8218 2206 Email: accessible@transadelaide.sa.gov.au This document can be made available in an alternative format on request. DEFINITIONS Accessible Vehicle Generally, an accessible vehicle is considered to be a vehicle that can provide public transport for people with disabilities. In particular, an accessible vehicle will have an allocated space for passengers using a wheelchair and may have a ramp, or similar device that facilitates unassisted access into the public transport vehicle. Alternative Format Alternative format refers to information that is presented in a different format other than standard print form. Alternative formats can include presenting information in Braille, on audiotape / CD, large print or in electronic format. DDA The DDA refers to the Commonwealth Disability Discrimination Act 1992 DSAPT (Disability Standard) The Disability Standards for Accessible Public Transport are National Standards that have been developed to enable public transport operators to minimise the impact of discrimination in the provision of public transport services. These Standards prescribe how public transport is to be made accessible and are to be issued in conjunction with the Disability Discrimination Act 1992 (DDA). Disability The definition of disability covers a range of disabilities, which are physical, intellectual, psychiatric, sensory and neurological. A disability can affect a person's ability to communicate, interact with others, learn or get about independently. It covers disfigurement and the presence in the body of an organism capable of causing disease. It is usually permanent or it may be episodic. DTEI DTEI refers to the South Australian Government, Department of Transport, Energy and Infrastructure. DTEI has diverse responsibilities in relation to transport system and services, energy policy and regulation, and infrastructure planning for South Australia. EOA The EOA refers to the Equal Opportunities Act 1984 HREOC Human Rights and Equal Opportunity Commission (HREOC) was established under the Human Rights and Equal Opportunity Commission Act 1986. HREOC administers Commonwealth legislation in the areas of human rights, anti-discrimination, social justice and privacy issues. The Commission deals with complaints arising from the Act either through conciliation or subsequently through hearings. Infrastructure Infrastructure refers to all buildings and facilities required by TransAdelaide to operate its public transport services. Without being limited this includes: * Rail/tram depots and associated offices * Railway stations/interchanges, platforms and station buildings * Bridges, walkways, pedestrian crossings; and * Signalling systems, including level crossings in the rail and tram right-of-way, and on other TransAdelaide owned/leased property. Interchanges An interchange is a transportation complex where passengers can transfer from between modes of transport. This may include any combination of 'kiss and ride', 'park and ride', bus to bus, and bus to rail interchange. Interchanges in some cases have toilets, ticket vending machines/facilities, security phones and timetable information. PTD The Passenger Transport Division (PTD) is a division within the Department of Transport, Energy and Infrastructure (DTEI). The PTD, on behalf of the Minister for Transport, administers public transport service contracts made under the Passenger Transport Act 1994. Rollingstock Rollingstock refers to the railcars and trams operated by TransAdelaide. Service Providers A service provider is any person, organisation, government department or agency, which provides goods, services or facilities to the public, free or at a cost. Page 14