Senedd Cymru | Welsh Parliament
Bil Aelod Arfaethedig – Mark Isherwood AS | Proposed Member Bill - Mark Isherwood MS
Datblygu'r Bil Iaith Arwyddion Prydain (BSL) (Cymru) | Development of the British Sign Language (BSL) (Wales) Bill
Ymateb gan: Y Sefydliad Safonau Prydeinig | Evidence from: British Standards Institution (BSI)
1. Introduction
BSI is pleased to take the opportunity to make a submission to your British Sign Language (BSL) Bill consultation and offer the information on existing standards that will support its implementation. We ask that you consider these are part of the process.
You will recall you worked with BSI following our publication of BS 25700 “Organisational approaches to Modern Slavery”i and took great interest in our societal standards work that intends to have a positive impact on Welsh and UK society. We very much welcomed your support for BS 25700, raising the standard in the Senedd and encouraging Welsh Government to make a statement on Modern Slavery in Wales that highlighted its use.
Your Bill seeks to promote and facilitate the use of BSL; improve access to education, health and public services in BSL, and support the removal of barriers that exist for deaf people and their families in education, health, public services, support services, and in the workplace. In doing so, it is important to remember the need for appropriate building inclusivity, whilst having access to BSL services and facilitating their use, the physical facilities also need to provide an inclusive environment.
In this submission we will highlight some of the standards that are available that promote inclusivity for deaf people in the built environment which in turn facilitates use of BSL. We would welcome your support in raising the profile of these standards by referencing them as part of the public debate across your discussions in relation to the Bill in the Senedd. We would be pleased to provide further help with any implementation and advice on our standards in support of your work.
2. About BSI
BSI is the National Standards Body for the whole of the UK. We are responsible independently for preparing British Standards and for coordinating the input of UK experts to European and international standards committees.
BSI represents the UK view on standards in Europe via the European Standards Organizations CEN and CENELEC and internationally via ISO and IEC. BSI is a member of ETSI (The European Telecommunications Standards Institute) and provides support to government through their membership of ITU (the International Telecommunication Union).
In its role as the UK’s National Standards Body, BSI provides the infrastructure for over 13,000 experts, who are the voice of UK economic and social interests, to be influential in the international standards organisations. BSI has a public interest responsibility to develop and maintain the standards infrastructure to support UK emerging industries at home and internationally.
BSI have a well-developed and wide suite of relevant standards in relation to health, safety and wellbeing, HR, governance, ageing, diversity and inclusion, and building designs. BSI also manages committees of experienced stakeholders, active at a national and international level, that are currently working to shape new standards in these important policy areas – some of which have been supported and adopted in Wales.
3. The role of standards in support of legislation and regulation
To recognise your ambition to bring forward potential legislation to improve the lives and access for deaf people in Wales, we wanted to take the opportunity to explain how standards can support legislation and regulation. Depending on the progress of your Bill, some of this information may be helpful and we would be pleased to support you further.
Standards are widely used to underpin and support regulation, or and as an alternative to regulation. Voluntary multi-stakeholder standards are already helping to deliver policy across a wide range of areas, including technical product safety, good governance, climate change, energy, fair markets, and public confidence.
Regulation can be appropriate when bringing about change, for example, to address market failures or set minimum requirements. But it can also be inflexible and expensive to develop and enforce; and if not sufficiently pragmatic and proportionate, can be intrusive to business and restrict innovation.
Using standards can ease pressure on the legislative process and reduce costs for government, and because they are transparent and independent, standards have the necessary legitimacy and degree of market acceptance to be used as tools for policy delivery.
Standards can support outcomes-based regulation by providing information to help target government intervention where it is most needed. For example, where standards are developed through usual BSI processes, and the relevant standards are then “designated” by government and listed on government websites in support of regulation.
4. Standards that support deaf & neurodiverse people in Wales
As part of the development of your Bill, we would advise you consider BS 8300 and PAS 6467 to support the implementation of the Bill. These standards are particularly relevant to your ambitions to improve the use of BSL when accessing public buildings in Wales.
We note your intention to have the new Commissioner to improve standards – we would welcome the opportunity to provide more insight in how standards can support legislation should the new Commissioner be established.
BS 8300ii
BS 8300 ‘Design of an accessible and inclusive built environment’ is in place to ensure that a built environment is developed with all levels of ability in mind. All users should be able to enter, use, and exit a building easily, comfortably, and independently – particularly the disabled, less abled, or elderly.
In addition, BS 8300 conforming buildings contribute towards social inclusion and reduce the risk of physical harm to those using the facility. BS 8300 was most recently updated in 2018 when the document was expanded into two parts. Part 1 focuses on building exteriors and approaches, while Part 2 remains focused on building interiors. We should point out that the standard is now due for further review and has committee representation from Wales. BSI will continue to monitor the progress of the Bill to ensure alignment where possible; we would welcome updates on the progress of your work.
Previous versions of the British Standard have focused on the provision of accessibility solutions specifically for the disabled. The most recent version, BS 8300-2:2018, however, goes into greater detail on how developers can build inclusive environments for all people, right from the beginning of a project. This ensures that the whole environment is accessible, rather than the topic of accessibility becoming a latter thought within a project.
BS 8300-2:2018 is the first standard to specifically address the needs of neurodivergent people. Another major addition is guidance on design strategy and the integration of design principles into the development process, which features in both parts. BS 8300-2 also does mention specifically about designing spaces to allow for a sign language interpreter to operate effectively. For example, ensuring they are suitably lit when low lighting is used for a performance.
BS 8300’s guidelines are wide-ranging, covering almost every aspect of building design you can think of that might impact accessibility. Key aspects of accessible design addressed include the following:
• Entrances
• Door fittings
• Steps, stairs, and ramps
• WCs
• Corridors and passageways
• Surface finishes
• Visual signs
• Lighting
The key element of the revision to BS 8300 is to offer "equal access to services and buildings". As an example, this includes hearing aid wearers no longer only having access to only one designated interaction point – such as a bank counter or checkout, they now can use as they all offer induction loop systems or other alternative assistive hearing systems.
Given the progress of innovation and planning, individuals should never again be excluded due to their disability and should be incorporated into the environment in a fully inclusive manner. Your Bill seeks to promote and facilitate BSL – but it is important to consider the physical surroundings – such as lighting in buildings are part of this process.
PAS 6463 - Neurodiversity (and inclusive building standards)
PAS 6463 Design for the mind – Neurodiversity and the built environment – Guide (can be downloaded here) provides guidance to the built environment on how to accommodate for neurodiverse needs, including incorporating suitable lighting when designing for people with dementia, autism and learning difficulties. It makes suggestions on lighting features such as glare, shadow, reflection, and flicker that can have an impact on a person’s wellbeing. The guidance cross-references other standards, including the BS EN 12464 series (for indoor and outdoor workplaces), and BS EN 17037 (daylight in buildings). Clause 11.10 of the guidance covers the benefits of adaptational (circadian) lighting for therapeutic benefits.
PAS 6463 also addresses acoustics and noise management, in terms of zoning and layout, background noise, room acoustics, and controls. The guidelines make a reference to BS ISO 22955, which covers acoustic quality in open offices.
Within BSI’s catalogue there are other accessible inclusive building standards that also foster good access and make provision for disabilities which can be deployed to complement your Bill.
5. Case study of the impact of societal standards in Wales
In 2023, Wales demonstrated the value of societal standards when the Welsh Senedd adopted BS 30416 “Menstruation, Menstrual Health and Menopause in the workplace” standard.
As an organization, the Senedd Commission, which provides the property, staff and resources to support the Welsh Parliament, wanted to attract and retain the most talented and skilled employees. As a result of the raised awareness and expectation about wellbeing at work, the Senedd Commission recognized the need to address menstruation, menstrual health and peri/menopause to be considered as an employer of choice.
In response, the Senedd Commission became the first organization in Wales to adopt BS 30416:2023 Menstruation, menstrual health and menopause in the workplace – Guide. The organization’s first step was to compare its existing policy to the standard. This identified areas where it was already meeting the recommendations, such as its staff and security uniforms using natural fibres to provide comfort, in addition to areas that needed improvement. For these areas, the Senedd Commission used the standard to make quick changes to its policy to support its employees.
In addition to these quick actions, the Senedd Commission is using the practical tools offered by the standard to identify and develop long-term changes. This currently includes reviewing its procurement requirements to ensure menstrual and peri/menopausal health training provision is inclusive of a diverse range of people and implementing inclusion/workplace adjustment passports.
By accessing an established framework for updating its policy, the Senedd Commission could easily explain the requirements for change to its organization’s leaders. The topic of menstruation, menstrual health, and menopause was instantly brought into focus and critical conversations could be facilitated across the workplace. The Senedd Commission is now more confident in its organizational provision, has the support to make improvements where required and can upskill, empower, support, and attract employees moving forward.
These include:
• Revising its existing policy to reflect current terminology; highlighting its legal duty; providing information on menstrual and peri/menopausal health cycles; and providing practical advice. The policy evolved into more than just an instruction of what to do, it became a handy self-help tool for people.
• Upgrading its hot desk booking system so staff could manage their symptoms better by booking desks based on their proximity to air conditioning vents, open windows, radiators, kitchens or toilets etc.
• Updating its Intranet to make it easier for people to find the types of support available. Its gender and mental health networks held a joint menstrual and peri/ menopausal health event around World Menopause Day.
• We were delighted by the positive response to the standard in Wales and the adoption of the standard by The Senedd on World Menopause Day in October 2023.iii
We believe that this example shows how Wales is at the forefront of demonstrating the impact of standards and their social value. We hope this submission will be helpful for your consideration for the Bill and how the built environment can facilitate inclusive access for BSL users.