Submissions

To: Ministry of Business, Innovation & Employment
Date: December 2024

Purpose

This submission’s primary purpose is to highlight the disproportionately higher risk of serious injury or death from fires that disabled people face. DPA advocates for a systemic approach to fire safety, emphasising the crucial need for improved accessibility, mandating visual fire alarms in all public buildings, and fostering co-design partnerships with disabled people in the development of fire safety regulations and evacuation procedures.

Summary of DPA submission

DPA expresses deep concern that disabled people are at a disproportionately higher risk of serious injury or death from fires. This vulnerability stems from various factors, including barriers to evacuation, inability to perceive alarms, poor building design, and a lack of support for evacuation. DPA cites research showing that 45% of fire-related deaths between 2007 and 2014 involved individuals with pre-existing disabilities or health conditions. The tragic Loafers Lodge fire in 2023, which disproportionately affected low-income and homeless individuals (likely including many disabled people), further underscores these concerns.

DPA highlights that disabled and D/deaf individuals face significant obstacles to safe evacuation, such as the necessity for visual fire alarms, clearly audible alarms, timely and safe evacuation processes, and the presence of physical barriers.

DPA is concerned that the review focuses solely on fire safety, advocating instead for a more comprehensive review of both fire safety and broader accessibility components within the Building Act and Building Code simultaneously. DPA firmly believes that for any house, public building, or occupiable structure to be truly safe and accessible for everyone, including disabled people, it must be considered in its entirety, not just one isolated aspect like fire safety.

A key recommendation from DPA is to make visual fire alarms mandatory in all public buildings. They recall a 2014 petition by Deaf community representatives and subsequent parliamentary endorsement of this call, noting its benefits for D/deaf, hard of hearing, autistic, and neurodiverse people, as well as anyone wearing noise-cancelling headphones.

DPA also advocates for the enactment of enforceable accessibility legislation that would provide a comprehensive framework for reviewing building design, construction, and safety issues, rather than relying on fragmented reviews.

DPA expresses disappointment regarding the lack of pre-consultation with Disabled Persons Organisations (DPOs) like DPA for this review. They recommend a systemic approach to fire safety accessibility, implemented as a co-design partnership between MBIE, Fire and Emergency New Zealand (FENZ), and disabled people. Furthermore, DPA urges prioritizing the safest and most effective fire-safe building materials and standards, investigating cost reductions for such products (e.g., lift curtains), and reviewing the interface between current FENZ evacuation practices and Building Code standards to enhance protection for disabled individuals during emergencies.

Key Recommendation/Finding:

DPA recommends that the NZ Building Code is amended to require the mandatory installation of visual fire alarms in all public buildings (including supported housing for disabled people and rest homes) by a specified date.

Supporting Statement 1:

"However, many of these buildings do not have visual fire alarms meaning that D/deaf and hard of hearing people are at greater risk in fires."

Supporting Statement 2:

"In 2014, a petition was presented to Parliament by D/deaf community representatives from Deaf Action New Zealand calling for visual fire alarms to be installed in all public buildings."