Draft Disabled People's Protection Policies (DPPPs)

prepared during autumn 2002

Executive summary
1. Introduction
2. General Comments
3. Statement of Policy (Section 6 of the Guidance)
4. Detailed Arrangements (Section 7 of the Guidance)
5. Communication of DPPP (Section 8 of the Guidance)
6. Management Arrangements (Section 9 of the Guidance)

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Executive Summary

The Disabled Persons Transport Advisory Committee (DPTAC) is disappointed by the overall industry response in updating their Disabled Persons Protection Policies (DPPPs - hereinafter called 'Policies').

The updating was required to bring them in line with the revised Strategic Rail Authority (SRA) Code of Practice on Train and Station Services for Disabled Passengers (the Code) published in February 2002 and the SRA Guidance on Disabled Persons Protection Policies (the Guidance) published in April 2002. The revised Policies were due for completion in December 2002.

We reviewed drafts received from operators against the SRA Guidance and this report is a summary of our conclusions. It should be noted that in preparing this report, we have found it extremely difficult as:

• some operators have been reluctant to consult DPTAC on draft DPPPs. At the time of drafting this report we had not received all the drafts, making comparisons difficult.
• the SRA Guidance on format and structure has not always been adhered to. This has greatly lengthened the time required to identify issues within draft policies.

We have identified issues where we believe the review process could and should be improved. We have also sought to highlight examples of good practice that would be useful for other operators.

Our objective in producing this report is to assist operators in revising their draft Policies to meet the spirit of the SRA Code and Guidance.

We hope this will feed into the final Policies considered by the Strategic Rail Authority in December 2002.

The process

The SRA have the power^[1] to require operators to produce Policies. However, they do not appear to have the requisite power to enforce their implementation.

The Strategic Rail Authority is required to provide leadership to the railway industry and ensure the industry works together for common goals. One of these common goals for the industry is to improve the accessibility of the railway for disabled people.

In order to provide leadership on this issue we believe the SRA should also have the power to require publication and implementation of Policies.

This is essential to enable the SRA to ensure the integration of Policies in business planning and operation of the rail network. We believe progress towards access for disabled people should be a key service principle the SRA is seeking from operators.

The short length of remaining franchise and lack of available resources have been suggested as reasons for limited commitments to the implementation of the SRA Code in some drafts. We do not accept them as valid excuses for poor quality or inadequate Policies.

With respect to the short period of franchises, DPTAC would have expected operators to set out their strategic direction and commitment in working towards an inclusive railway and what can reasonably be achieved within the remaining period of their franchise. Many of the requirements relate to management procedures rather than physical changes to the infrastructure.

We are concerned that some in the industry do not recognise access for disabled people as an integral part of running a modern railway. This does not mean all stations need to comply with the letter of the Code but it should mean all operators are complying with the spirit of the Disability Discrimination Act 1995 by working towards the removal of barriers for disabled people.

Examples of good practice

Overall the drafts have been weak in meeting the expectation by DPTAC that the industry would work towards the SRA Code and Guidance. This is particularly disappointing given the positive messages on access for disabled people given in the SRA Strategic Plan in January 2002.

It is unacceptable that some operators have simply updated their existing policies without reference to the SRA Code or Guidance.

However, there are examples of good practice in both the overall quality of some Policies and elements within others. We have sought to highlight these in the body of this report.

Recommendations

• Power to implement - The SRA should be able to require operators not only to prepare but to demonstrate implementation of their Policy.
• Requirement for consistent format - The SRA should require Policies to be produced in a consistent format.
• Coverage of all items in guidance - Operators should also be required to cover all items in the Guidance to demonstrate they have considered the SRA advice.
• Enforcement powers - Disabled people need to be confident that these Policies will be enforced and will influence the provision of inclusive rail services.

Published: 17 February 2003

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