Personal Submission to House of Lord’s Select Committee on Equality and Disability

1.        Executive Summary, Recommendations and Questions for the Select Committee

  • I welcome this opportunity to provide comments to the House of Lords Select Committee into the Equality Act 2010 and disability. This submission is focusing on transport and related issues. These are personal comments. Details of my background and experience are here.
  • https://clivedurdle.wordpress.com/about/

Clive Durdle

4 Toronto Road

Ilford Essex IG1 4RB

clivedurdle@mac.com

2.        Any journey is only as good as its weakest link

  • I understand that “any journey is only as good as its weakest link.” A core concept of the disability world is the idea of barriers. These may be physical, institutional and attitudinal. The idea of an equality impact assessment is to think through clearly what issues someone might face and what physical, legal and behavioural changes may be appropriate.
  • Thinking carefully about someone over their life cycle and on a day to day basis, and looking carefully at what happens, how and why, and how it may be different is very valuable.
  • My experience is like the curate’s egg. There are parts of the movement and transport systems that are impressive; other parts are in a backwater. It is not obvious that all the players have even received the message that “Houston, we have a problem”.

 

 

3.          The Equality Act

  • The Equality Act uses “boxes” of protected groups and defined “places”.
  • What effects might liminal matters that don’t quite fit into neat and tidy boxes be having? The latter part of this submission looks at some of these extremely complex issues.
  • Is the idea of groups of people and objects helping or hindering resolving very complex issues of institutionalization and discrimination? What other tools may help?
  • Should the categories of the Equality Act be more around power relationships and equality impact?
  • It is a duty to ‘have due regard’, not to take steps or to achieve equality. Is this an attempt to incorporate a deliberative, reflexive approach to achieving equality, recognizing that a straightforward command and control approach might encounter unproductive resistance? Or does it reflect a fundamental ambivalence as to the importance of equality issues?”
  • I understand that the Equality Act, by not being accessible itself and sufficiently enabling of change, is at least indirectly institutionalized and discriminatory.

 

4.        Professional Practice

  • I understand that there are real continuing complexities and confusions introduced by professional and legal practice and education.
  • The Cabinet Office is looking at these issues from a built environment perspective.
  • It is unclear that the issues being discussed and resolved there are transferring equally to the worlds of getting around.
  • It is not obvious that the excellent possibilities of sustainability and inclusive design are being progressed that effectively.
  • The meaning of the term “access” is precisely about this. This seems to be causing various professionals to think they are meeting legal and professional standards when in fact and law they are not.
  • The two main ways seem to cohere around the concepts of “access for all” and “vehicular access”

5.        Participation

  • I formally ask that looking carefully at how things are done elsewhere, experimentation and participation become key ways of working.
  • The definitions of the common wealth and what is private are causing continuing complexities and discrimination.
  • The phrase “nothing about us without us” is precisely about this.
  • Should properly recorded and designed experimentation be understood as a key part of enabling relevant authorities to show they have properly consulted and enabled participation?
  • There does not seem generally enough willingness to search out possible solutions, discuss carefully matters, learn and implement in a timely way changes that do make very significant differences.
  • There is evidence of both extreme risk averseness and ignoring of risks. These types of behavior are well – defined symptoms of institutionalization.

6.        Statistics and measuring equality

  • I understand there is a critical general issue about the quality of statistics.
  • The numbers of issues and barriers faced daily by disabled and other people is not being recorded properly, although bodies are experiencing high levels of claims for slips trips and falls, but this is not being understood as key equality indicator.

7.        Commonwealth and Cooperation

 

  • I understand this principle of all the various parties working together to think through carefully all the issues and propose solutions is critical to actually implementing the Public Equality Duty.
  • This duty must explicitly apply to all contractors carrying out public services.

8.        Lenin

  • Paraphrasing Lenin, there is a job to be done.
  • A major issue is that there seems to be a general ignorance of the poor state of infrastructure from the perspective of access for all, and that this is also institutionalized discrimination.
  • The costs of change are probably not that significant if tools of high quality design, thought and participation are used that create sustainable and inclusive long lasting infrastructure.
  • But first the detailed issues must be defined clearly.

9.        Conclusion of Executive Summary

  • This submission discusses the general issues and then illustrates them. There are specific issues in various areas that are highlighted in the main body of this evidence.

10.    Barriers

  • A core concept of the disability world is the idea of barriers.
  • These may be physical, institutional and attitudinal.
  • Comprehensive Equality Impact Assessments aim to think through clearly what issues someone might face and what physical, legal and behavioural changes may be appropriate.
  • Thinking carefully about someone over their life cycle and on a day to day basis, and looking carefully at what happens, how and why, and how it may be different is very valuable.
  • My experience is like the curate’s egg. There are parts that are impressive; other parts are in a backwater. It is not obvious that all the players have even received the message that “Houston, we have a problem”.

12.    Institutional Barriers

12.1.           I understand there may be two interrelated issues that may be due to the wording of the Equality Act, and that make implementation of its objectives extremely complex.

12.2.           The first is the list of “protected groups”. Is this a complete list? Should for example, pedestrians, cyclists, rowers, sailors and cyclists (users of human powered vehicles?) be protected groups?

12.3.           Secondly, is there a complete list of “places”, are ‘work, school, transport and housing’ complete?

12.4.           Where do roads, footpaths, cycleways, bridalways fit? Is “transport” the correct legal term? Where does the concept of the transport hierarchy fit with ideas of and law about equality?

12.5.           What effects might liminal matters that don’t quite fit into neat and tidy boxes be having?

12.6.           Is the idea of groups of people and objects helping or hindering resolving very complex issues of direct and indirect discrimination, what other tools may help?

12.7.           Should the questions to resolve these issues be more around power relationships and equality impact assessments?

12.8.           There is in East London a footbridge over the River Roding that is currently closed for repairs. No one can work out whose responsibility it is! Options include the City of London, London Borough of Redbridge, London Borough of Newham and probably other parties. There is then a question about which department of these organisations has responsibility – parks, highways….

12.9.           This is obviously a barrier but it is not clear what actions anyone should take to resolve it! The Equality Act looks like it is relevant, but how would it be used, where?


 

13.    The Public Sector Equality Duty

  1. Sandra Fredman Oxford University, has written:

14.1.           A key advance of the Equality Act 2010 is its introduction of a single equality duty. The new ‘public sector equality duty’ harmonises the earlier duties and extends its coverage to include other protected characteristics.

14.2.          In addition, the statutory aims have been deepened to reflect a substantive conception of equality. However, the core of the duty is unchanged. It is a duty to ‘have due regard’, not to take steps or to achieve equality.

14.3.           Is this an attempt to incorporate a deliberative, reflexive approach to achieving equality, recognising that a straightforward command and control approach might encounter unproductive resistance?

14.4.           Or does it reflect a fundamental ambivalence as to the importance of equality issues? (Is) the statutory provision is an example of reflexive law(?)

14.5.           Particular attention is paid to the spate of judicial review cases relying on the equality duty to challenge a range of budget cuts. It is argued that courts have struggled to deal with the regulatory challenges presented by the equality duties.

14.6.           Nor is it clear that a reflexive approach is appropriate to achieve substantive equality.”

15.    The European Transport Ministers

  • The European Transport Ministers have written:
  • “Obvious though it may seem, it is worthwhile stressing that any journey is only as good as its weakest link. There should, therefore, be a conscious effort on the part of government, local and central, to ensure that accessible transport services link together.
  • The physical process of making a journey should mirror the “chaine signalétique” approach advocated by COLIAC (formerly COLITRAH)6 for information; a carefully planned sequence without breaks or interruptions.
  • Until comparatively recently such an approach would have seemed unrealistic, even irrelevant, because so much needed to be done to make any single link in the transport chain accessible. This is changing, rapidly so in some countries, but the full value of accessible links will not be realized unless journeys are considered as a whole, rather than as a series of discrete movements. …..
  • In other words, the physical chain of accessible transport has to be paralleled by an administrative chain.
  • In further developing their policies for improving access to all modes of transport, government should not lose sight of the over- arching need to provide seamless transport for disabled travellers, and to achieve it by a combination of appropriate regulations and encouragement for collaboration between all the organisations concerned. (International Transport Forum n.d.)
  1. It is not obvious to me that accessible tools are available to resolve these complexities quickly. The Equality Act, by not being accessible, is, I understand, at least indirectly discriminatory.
  2. A related issue is possibly the history of Transport, Railway and related Acts. It is not obvious that these assist enabling equality and the view of the European Transport Ministers that “any journey is only as good as its weakest link.”
  3. The 1949 Transport Act, as well as establishing the legal basis of motorways, also formalized the road split between national and local authorities, with local authorities becoming responsible for footpaths, cycleways and local roads.
  4. This means that there is in existing transport and highways law basic assumptions that contradict completely the concept of the road hierarchy.
  5. Similar issues exist in the Highway Code, which contains discriminatory philosophies dating back to the 1930’s. There is a continual assumption that powered vehicles have priority, when actually the concept of the Queens Highway is the converse, that everyone is free to use it. America, with the pejorative term “jay walker” is the classic example of this. Should there not be a right to roam everywhere, including roads? Should 30 be the normal speed in built up areas?
  6. There is a classic science fiction novel that I strongly recommend that illustrates this, The Revolt of the Pedestrians (Keller 1928).
  7. 1n 1959 there were nine million cyclists on Britain’s roads.
  8. We do not now have public and private realms that achieve “any journey is only as good as its weakest link.”. To do this includes all parts of all journeys, including getting out of bed, going to and using bathrooms and toilets, getting around a home including up and down various levels, getting out of a front or back door, and using pavements. It includes all public transport being fully accessible and able to carry all types of mobility equipment, including cargo trikes and mobility scooters.
  9. The Equality Act has not enabled the full review and reassessment of all practices and professional thinking that I understand to be basic to taking equality seriously. There are not only physical and administrative barriers but also historical, legal, professional and intellectual barriers.
  10. The following sections illustrate some of these issues.

26.    Access

  • As well as these real complexities of who is responsible, I understand there are real continuing complexities and confusions introduced by professional and legal practice.
  • The meaning of the term “access” is precisely about this. This seems to be causing various professionals to think they are meeting legal and professional standards when in fact they are not.
  • The two main ways seem to cohere around “access for all” and “vehicular access”
  • The term “design and access statement” may have different meanings to various professionals, leading to further inadvertent indirect discrimination.
  • A mission to Mars failed catastrophically because different contractors were using different measurement languages.

27.    Campaign for Better Transport

  • Stephen Joseph, Chief Executive of Campaign for Better Transport has commented to me personally in an email correspondence:
  • “There are two main uses of the term “access” among transport professionals:
  • Access for people with disabilities. Access strategies here involve making transport networks and infrastructure accessible to people with all kinds of disabilities. This has involved, for example, a programme of dropped kerbs, of step free buses, and of moves towards making railways accessible through an “access for all” programme.
  • Access to key facilities and services, which involves mapping people’s travel patterns and needs and seeking to provide services to meet those needs.
  • This kind of access came to prominence with a report by the Government’s Social Exclusion Unit in 2003 which suggested accessibility strategies by local authorities, and resulted in these being required through Local Transport Plans.
  • Access in this context is sometime contrasted with “mobility” – in other words, trying to move the focus from simply promoting movement – more miles by more people and vehicles – to promoting access to key facilities and people, as the main aim of transport.
  • As Campaign for Better Transport, we’ve been involved in both these forms of access strategies.
  • On the first, we’ve worked with disability groups like Transport for All to promote disability access to transport.

28.    Vehicular Access and Access for All

  • The website of a major transport consultancy comments below about “access” to a site that includes a school and a retirement home, using a clear vehicular access model, which is arguably discriminatory as there is no evidence at all of any consideration of issues of access for all.
  • This is only one example of a probably very common discriminatory practice and leads to asking basic questions about do professionals understand their legal responsibilities, and why are they thinking in these ways?
  • “PJA was appointed to provide transportation and highways advice for the development, and to prepare a Transport Assessment to accompany a planning application. Barteak Developments entered into an agreement with the Malvern Preparatory School to redevelop a large part of their site for housing, including a retirement home. Forming a suitable access into the new site that would meet the approval of the local highway authority was difficult and a number of options were considered. Visibility splay requirements were assessed in detail using vehicle speed surveys. The final option selected involved the partial demolition of the boundary wall to the site, which was considered by the planning authority to be of local importance. Nevertheless, it was accepted as the least intrusive access solution.(Jones n.d.)
  • Similar limited use of the term “access” also occurs here:
  • “The designation of the new city of Craigavon in 1965 envisaged the development of a substantial new commercial area between the existing town centres of Portadown and Lurgan. This was to be the principal focus for the new city of 180,000 inhabitants but its failure to grow to anything like its projected population has meant that the new town centre at Rushmere is relatively small in floorspace terms. However, its ability to meet modern retailer requirements in terms of unconstrained greenfield sites, floorplates, mall type environment, convenient car based access and parking together with its role as a shared place has made it much more successful in attracting investment from the high street multiples. PJA was appointed as subconsultant to Tribal Urban Studio to develop a Commercially-led vision for the three centres, with each developing a distinct role. Central to this was the identification of redevelopment sites, mainly in the ownership of the public sector. PJA was required to establish an overall transport vision for the town centres and to specify access requirements” (Jones n.d.)

29.    Experimentation, modeling and participation

  • There is a related issue here that must also be tackled. Many professionals now use very powerful computer models and have rules that have evolved possibly over decades (more than a century in the case of the railways, since the 1930’s for the Highway Code) that may be leading to ways of working that do not actually enable solutions and may be indirectly and directly discriminatory.
  • I formally ask that looking carefully at how things are done elsewhere, experimentation and participation become key ways of working.
  • This has immediate effects, the models have something to test against, if something doesn’t work, it can be removed quickly, if it does work it can be honed and implemented generally quickly.
  • There does not seem generally enough willingness to search out possible solutions, discuss carefully matters, learn and implement changes that do make very significant differences. The transport professions feel as if they are fashion led.
  • For example, road closures and road changes can be trialed with plastic and wooden equipment to see what happens to road use patterns, instead of what tends to happen currently is that something is extensively modeled and then implemented permanently.
  • Should properly recorded and designed experimentation be understood as a key part of enabling relevant authorities to show they have properly consulted and met their Public Equality Duties?
  • There are bits of this in law, but something happens in the implementation. It may be related to misunderstanding hazard and risk.
  • I am aware of extensive transport changes happening near me in Waltham Forest but I am unclear of how equality issues have impacted these proposals.

30.    Risks, Hazards and Near Misses

  • A major guide by TFL about cycling “International Cycling Infrastructure Best Practice Study” (Dales & Jones 2014) writes:
  • “As regards concerns about possible ‘dooring’, where cars are parked facing the direction of travel on that side of the street, it is only the passenger doors that would open into a nearside cycle lane/track.
  • Passenger doors usually open less often than the driver’s door, because every car has a driver. Additionally, if a dooring does occur, cyclists would be thrown into the adjacent footway, not the carriageway. “
  • This comment is of note compared with the attitude of the Health and Safety Executive about workplaces, and I must formally ask why are there different standards for workplaces and streets and might this be discriminatory?
  • The Health and Safety Executive (Slips and trips team – HSE 2009) writes:

More: Near-miss reporting

A simple, and potentially anonymous, system for reporting near-miss incidents is a very important way of identifying problem areas. This will help you highlight some of the less obvious hazards in a workplace, or identify areas where a problem is developing.

Some models suggest that for every accident there are approximately ninety near-misses.

If there is a good reporting system in place, the hazard could be dealt with before someone is injured.

It can be difficult to get staff to report near-misses or minor slip accidents, as they are often seen as funny or embarrassing occurrences (until someone is hurt).

It is important to create a culture which encourages reporting of these accidents.

  1. I understand the type of attitude reflected above (about dooring being part of the street scene) by transport professionals is symptomatic of a general issue about the quality of statistics, specifically the numbers of issues and barriers faced daily is not being recorded properly, although bodies are experiencing high levels of claims for slips trips and falls, but this is not being understood as a key equality indicator. Transport generally records deaths and serious injuries, when the reality is all incidents and near misses matter. There are excellent examples of how to do things from Denmark and the Netherlands, but somehow in Britain I feel we do not quite get to the crux of issues. Is “good enough” or “that will do” actually discriminatory?

32.    Commonwealth

  • I do not have the legal expertise to define this, but understands this is about duties to co-operate and learn together for the common wealth. There is a very extensive literature about this, including the legal concept of ecocide, and the authors Elenor Ostrom and Lewis Hyde.
  • The idea of nothing about us without us is precisely about this.
  • Citizen’s Advice writes: (Advice 2015) “The Equality Act tells some public bodies that they will have to think about what they can do to make their services more helpful to poorer people.

How this might work

A local council in charge of a town’s bus services checks to find out if buses meet the needs of local people. It finds that people in a poor part of town have more trouble than other people getting to the local hospital. The council finds this was because of 3 things.

  1. There are only a few buses to the hospital each day
  2. Most people do not have a car
  3. It costs a lot to park cars at the hospital.

The council works with the hospital to find ways to make it easier for people from the poorer parts of town to get to the hospital. They decide to pay for a free bus service from the town to the hospital.

  • I understand this principle of all the various parties working together to think through carefully all the issues and propose solutions is critical to actually implementing the Public Equality Duty.
  • This duty must explicitly apply to all contractors carrying out public services, who must not be allowed to use confidentiality clauses.

33.    Parking

  1. About parking, thinking here may be indirectly and directly discriminatory.
  1. ITDP writes “In the last few decades a growing number of European cities have led the world in changing the direction of parking policy. European citizens grew tired of having public spaces and footpaths occupied by surface parking. Each parking space consumes from 15 m2 to 30 m2, and the average motorist uses two to five different parking spaces every day. In dense European cities, a growing number of citizens began to question whether dedicating scarce public space to car parking was wise social policy, and whether encouraging new buildings to build parking spaces was a good idea. No matter how many new parking garages and motorways they built, the traffic congestion only grew worse, and as much as 50% of traffic congestion was caused by drivers cruising around in search of a cheaper parking space.
  2. In the cities reviewed here, parking policy has been reoriented around alternative social goals. Some recent parking reforms are driven by the need to comply with EU ambient air quality or national greenhouse gas targets. Other new parking policies are part of broader mobility targets encouraging reductions in the use of private motor vehicles. While London, Stockholm, and a few other European cities have managed to implement congestion charging to reduce motor vehicle use, more are turning to parking.

Every car trip begins and ends in a parking space, so parking regulation is one of the best ways to regulate car use. Vehicles cruising for parking often make up a significant share of total traffic. Other reasons for changing parking policies were driven by the desire to revitalize city centers and repurpose scarce road space for bike lanes or bike parking. (Kodransky & Hermann 2011)

37.    Street Scene

  • Henshaw (Henshaw 2011) has fascinating commentary about what happens when footpaths are poorly designed. Although writing primarily about cycling, the issues are identical for disabled people with mobility issues and are therefore a key example of what an Equality Act should be able to achieve. The numbers of slip trip and fall hazards and barriers illustrated is impressive, and these are actually very common street scenes. The changes of level, cambers and kerbs illustrated below are all extremely serious barriers for the “wobblies” and “stickies” of the world.
  • “One of the many excuses used by people who oppose protected cycling infrastructure is the ‘but we have driveways’ excuse. There are people who believe that cycling infrastructure, especially a separate protected cycle path, does not go together well with driveways.
  • But of course the two can be combined: as long as the design of both the cycle path and the driveways are well done and follow strict rules.
38.
39.     1. Driveways may not interrupt the sidewalk or cycle path.
40.
2. Driveways may not influence the level of the sidewalk or cycle path.
41.
3. Driveways may not have priority over pedestrians or cyclists.
  • When a drive way does not interrupt the sidewalk or the cycle path, when it does not change the level of either of those and when it is clear it has no priority over pedestrians or cyclists then such a driveway is no problem at all to separated cycling infrastructure.
42.

43.

44.     Driveways that do not interrupt cycle path nor sidewalk, have no influence on the level of either of those and clearly have no priority.

 

45.    Patient transport

  • Patient Transport is another example of a whole system transport problem, albeit moving complex, fragile subjects.
  • The agenda includes someone getting out of bed and moving them to an operating theatre or MRI scanner possibly in another hospital, transfers and admission processes to other hospitals and journeys to and from home at admission and discharge and for outpatients and all the stops, handovers and waiting in between.
  • It isn’t really only a health problem, nor a transport problem, and requires very careful thought and planning of all stages and issues.
  • Hospital trusts, care quality commissioners may be looking at the issues too simply and incorrectly using examples from other systems, like “departure lounges”. The term “medical model” possibly applies.
  • A major hospital trust has recently purchased patient wheelchairs that are commonly used by pulling patients backwards, not exactly a dignified way! This trust was not also able to manage a patient who was able to walk but had been instructed not to sit – ie either lie or stand.
  • Comments were made about how these types of issues are seen as marginal, cinderella services, when actually any look at systems theory shows they are critical.
  • This is a further example that the very complex problems actually need to be tackled.

46.    Wheelchair services

  • The recent launch of a campaign to improve wheelchair services is a further example of how interconnected and detailed issues are. The existing legal structures are discriminatory as they are not enabling matters like these to be resolved quickly and effectively. (Gani 2015)
  • “It is estimated that 2% of our population use wheelchairs to get to work, go to school, buy their groceries, look after their children, contribute to our society and achieve their goals. Sadly many of them don’t fulfil their aspirations because the current wheelchair services fail to meet their needs.
  • Currently we see great variation in ability to access assessment and obtain service provision, delays in repairs and equipment, poorly thought through provision plans and patient pathways, confusing information, restrictive and inflexible funding and minimal integration of services.
  • And throughout all of this are the service users struggling to carve out the kind of lives they would wish to lead.
  • As a group, the Wheelchair Leadership Alliance has committed to make the kind of changes that will truly improve the lives of these service users and their families.” (Wheelchair 2015)

47.    Autism

  • There are many conditions that are not obvious, but all of these require equal consideration. Transport for all writes:
  • I plan all my journeys very carefully. Because of my autism, any changes, no matter how small, causes anxiety and stress. The world is a very unpredictable and confusing place and so I prefer to have a fixed daily routine so that I know what is going to happen. This routine extends to always wanting to travel the same way to and from places. When there are diversions or journey restrictions or cancellations, it doesn’t just irritate me; it can feel like the end of the world. The London Bridge closure has caused me massive amounts of stress.
  • People with Autism may experience some form of sensory sensitivity which affects one of the five senses – sight, sound, smell, touch, taste. I have hypersensitivity to things such as noises (I am unable to cut out background noise), breezes, lights, movements and odours. I also have balance and vestibular difficulties, so I am unable to stand on moving things such as escalators and lifts without being supported, because of dizziness and disorientation. I am too scared to use night buses because of how fast they go. They make me feel very ill and anxious, I can’t use escalators, lifts, tunnels, stairs especially spiral staircases on my own.
  • I can’t just turn up and use any station, it may take up to twenty visits to a station before I can use it. Starting from just going to see the outside of the station to then walking inside, then another visit to go onto the platform. (Lindsay 2015)

Bibliography

Advice, C., 2015. Equality Act 2010 – spotting discrimination – chart – Citizens Advice. Citizens Advice. Available at: https://www.citizensadvice.org.uk/discrimination/about-discrimination/equality-act-2010-spotting-discrimination-chart/ [Accessed September 2, 2015].

Dales, J. & Jones, P., 2014. International Cycling Infrastructure. Available at: https://tfl.gov.uk/cdn/static/cms/documents/international-cycling-infrastructure-best-practice-study.pdf [Accessed September 2, 2015].

Gani, A., 2015. Wheelchair users to launch challenge to improve NHS service | Society | The Guardian. Guardian. Available at: http://www.theguardian.com/society/2015/jul/20/wheelchair-users-to-launch-challenge-to-improve-nhs-service [Accessed September 2, 2015].

Henshaw, D., 2011. A view from the cycle path: But we have driveways. Available at: http://www.aviewfromthecyclepath.com/2011/08/but-we-have-driveways.html [Accessed September 2, 2015].

International Transport Forum, Improving Transport Accessibility for All. Available at: http://internationaltransportforum.org/pub/pdf/06TPHguide.pdf [Accessed July 20, 2015].

Jones, P., Projects – Phil Jones. Available at: http://www.philjonesassociates.co.uk/projects.html#projectID24 [Accessed September 2, 2015].

Keller, D., 1928. Amazing Stories Volume 02 Number 11 : Gernsback, Hugo, 1884-1967 : Free Download & Streaming : Internet Archive. Amazing Stories Vol 2 no 11. Available at: https://archive.org/details/AmazingStoriesVolume02Number11 [Accessed September 2, 2015].

Kodransky, M. & Hermann, G., 2011. Europe’s Parking U-Turn. ITDP. Available at: http://www.itdp.org/wp-content/uploads/2014/07/Europes_Parking_U-Turn_ITDP.pdf [Accessed June 28, 2015].

Lindsay, C., 2015. Using the Tube as an autistic person › Transport for all › Accessible Transport in London. Transport for All. Available at: http://www.transportforall.org.uk/blog/using-the-tube-as-an-autistic-person [Accessed August 1, 2015].

Slips and trips team – HSE, H., 2009. More: Near-miss reporting. Available at: http://www.hse.gov.uk/SLIPS/step/general/advanced/8E7F777B-3B84-49FE-A3D6-D0324E25A801/HSLCourseTemplate/28531/slidetype2_174026.htm [Accessed September 2, 2015].

Wheelchair, R., 2015. Wheelchair Charter. Available at: http://www.rightwheelchair.org.uk/images/The_Wheelchair_Leadership_Alliance_Charter.pdf [Accessed August 2, 2015].

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