PERFORMANCE

SOLUTION
REPORT
AMG Performance Centre
Cnr of Ninth Street & Qantas Drive ACCESS
Mascot, NSW
Report Prepared for: M Projects, Marcello Tuteri
Report Prepared by: Philip Chun, Lee Wilson

Our Ref: AN17-208387

Date: 24 October 2017
CONTENTS
1. INTRODUCTION ........................................................................................................................................... 3
2. REVIEWED DOCUMENTATION .................................................................................................................. 4
3. APPLICABLE LEGISLATION ...................................................................................................................... 4
4. PROPOSED PERFORMANCE SOLUTION ................................................................................................. 5
5. LEGISLATIVE REQUIREMENTS ................................................................................................................. 6
6. ASSESSMENT METHOD ............................................................................................................................. 6
7. PERFORMANCE REQUIREMENTS ............................................................................................................ 8
8. DEEMED-TO-SATISFY DEPARTURE ......................................................................................................... 8
9. ASSESSMENT .............................................................................................................................................. 9
10. CONDITIONS .............................................................................................................................................. 12
11. CONCLUSION ............................................................................................................................................ 12
APPENDIX A: CV AND QUALIFICATIONS OF THE AUTHOR .......................................................................... 13

DOCUMENT ACCEPTANCE

Name Signed Date

Prepared by Lee Wilson 24 October 2017

Senior Access Consultant
ACAA Accredited Member No. 236

Reviewed by David Choe 24 October 2017

Access Consultant
ACAA Affiliate Member No. 574

REVISION HISTORY

Revision No. Prepared by Description Date

00 Lee Wilson Report issued 24 October 2017

The information provided within this report is relevant to this project and the documentation referenced. As such
the information provided may not be transferred to other projects. This report must not be issued for public
comment or be used for any other purpose without prior permission from Philip Chun Access.

This determination is made at the request of the applicant and does not absolve the applicant and owner of the
requirements pursuant to the Disability Discrimination Act 1992 (Cth).

Philip Chun Access accepts no responsibility for any loss suffered as a result of any reliance upon such
assessment or report other than to verify the Performance Requirements of the BCA have been met to the
degree necessary.

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1. INTRODUCTION

The project includes internal alterations and additions to the existing building located on the corner of
Ninth Street & Qantas Drive, Mascot, NSW. The building is identified in the extract of the Site Plan
below.

The building is of two-storey construction and has been classified by the Building Certifier as a Class 6
building being an AMG showroom and associated workshop.

Mercedes-AMG GmbH, commonly known as AMG, is the high-performance division of Mercedes-Benz.

AMG independently hires engineers, manufactures and customizes Mercedes-Benz AMG vehicles.

Figure 1: Extract of Site Plan

During their assessment of the design, the building certifier has identified the following departure from
the Deemed-to-Satisfy (DtS) provisions of the Building Code of Australia 2016 (BCA).

This is addressed in this report:

Description of identified accessibility issues DtS provision Performance

Requirement

The two fully glazed sliding entry doors do not have a D3.1 DP1
50mm band around the door opening that provides a D3.2(b)
minimum of 30% luminance contrast as prescribed in AS
1428.1(2009), Clause 13.1.

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2. REVIEWED DOCUMENTATION

This report is based upon the following relevant Construction Issue architectural documentations
produced by Turner Studio and the Amended Building Permit produced by Department of Infrastructure
and Regional Development Airport Environment Protection and Building Control Office for Philip Chun
Access review:

Architectural
Drawing Number Revision Date
A-110-001 15 18/10/17
A-250-001 15 18/10/17
A-561-001 04 01/05/17
Other
Document Number Revision Date
17_729 N/A Amended 20/10/17
Amended Building Permit
Condition 29

Figure 2: Project Documentation List Table

Additionally, this report has been prepared with regard to the previous report prepared by Philip Chun
Access (Ref: AN17-208387 20170215 LTR_LP, dated 24 February 2017) discussing exemptions to
workshop areas.

3. APPLICABLE LEGISLATION

This report references the following applicable legislation:

Condition 29 of Amended Building Permit (Ref. No. 17_729)

Disability Discrimination Act 1992 (Cth) (the DDA)
Disability (Access to Premises Buildings) Standards 2010 (the Premises Standards)
Building Code of Australia 2016 (BCA)
AS 1428.1 (2009) Design for access and mobility, Part 1: General requirements for access
New building work

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4. PROPOSED PERFORMANCE SOLUTION

The proposed Performance Solution includes acceptance of the design of two fully glazed sliding doors
that have a reduced level of luminance contrast around the glass sliding doorway, as prescribed in AS
1428.1(2009), Clause 13.1.

The design solution relies on:

Automation of the doors on approach from both sides;

Audible cues when approaching an open doorway (i.e. how sound changes);
Other visual/wayfinding cues when approaching each door;
A contrast between each entire window/door frame assembly and adjoining soffit/walls; and
A compliant horizontal glazing visual indicator band across the entire width of each window/door
frame assembly.

The location of the two entry doors is identified in the Figure below:

Figure 3: Extract of Floor Plan A-110-001 (rev.15)

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5. LEGISLATIVE REQUIREMENTS

There are a number of Performance Requirements outlined in the BCA to which any Performance
Solution must comply, in order to meet the relevant functional statements and objectives. Compliance
with these Performance Requirements is mandatory whereas there is no obligation for a design to adopt
the Deemed-to-Satisfy provisions, either in part or in full.

Clause A0.2 of the BCA states:

The Performance Requirements can only be satisfied by a

(a) Performance Solution; or

(b) Deemed-to-Satisfy Solution; or
(c) A combination of (a) and (b).

Clause A0.3 of the BCA states:

(a) A Performance Solution must

(i) comply with the Performance Requirements; or
(ii) be at least equivalent to the Deemed-to-Satisfy Provisions

(b) A Performance Solution will only comply with the NCC When the Assessment Methods
used satisfactorily demonstrate compliance with the Performance Requirements.

In addition, this performance based solution report is required by Condition 29 of Amended Building
Permit (Ref. No. 17_729), which states the following:

29) In accordance with Clause 13.1 of AS1428.1-2009, all doorways shall have a minimum
luminance contrast of 30% provided between
(a) door leaf and door jamb;
(b) door leaf and adjacent wall;
(c) architrave and wall;
(d) door leaf and architrave; or
(e) door jamb and adjacent wall.
The minimum width of the area of luminance contrast shall be 50mm.
Prior to the issue of the Certificate of Compliance an alternative solution access report from an
appropriately qualified access consultant is to be submitted to address the glazed entry doors
where the adjacent wall is also glazed.

6. ASSESSMENT METHOD

According to Clause A0.5 of the BCA, the following assessment methods when used individually or in
combination, enable a determination that a Performance Solution complies with the relevant
Performance Requirements:

(a) Evidence to support that the use of a material, form of construction or design meets a
Performance Requirement or a Deemed-to-Satisfy Provision as described in A2.2.
(b) Verification Methods such as
(i) the Verification Methods in the BCA; or
(ii) such other Verification Methods as the appropriate authority accepts for
determining compliance with the Performance Requirements.
(c) Expert Judgement.
(d) Comparison with the Deemed-to-Satisfy Provisions.

In this instance, Philip Chun Access proposes a Performance Solution based on a combination of
Clause A0.5(c) Expert Judgement and Clause A0.5(d) comparison with the Deemed-to-Satisfy
provisions.

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 It should also be noted that throughout this report it identifies clauses from BCA 2016 and referenced
Australian Standards and not the Commonwealth Premises Standards. However, as the BCA access
provisions discussed within this report are essentially mirrored into Schedule 1 (Access Code) of the
Premises Standards, if the reference is made to the BCA, in this case, it is also consistent with the
provisions of the Premises Standards.

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7. PERFORMANCE REQUIREMENTS

As per BCA Clause A0.5, the Performance Solution will be assessed with consideration to the Deemed-
to-Satisfy clauses and objectives of the Performance Requirements as listed below.

Class of Building: Class 6

Deemed-to-Satisfy Clause: D3.1
Performance Requirement: DP1

These Performance Requirements state the following:

DP1 Access must be provided, to the degree necessary, to enable

(a) people to
i. approach the building from the road boundary and any accessible car
parking spaces associated with the building; and
ii. approach the building from any accessible associated building; and
iii. access work and public spaces, accommodation and facilities for personal
hygiene; and
(b) identification of accessways at appropriate locations which are easy to find.

The applicable section of DP1 to be considered in this report is DP1(a)(iii) access work and public
spaces, accommodation and facilities for personal hygiene.

8. DEEMED-TO-SATISFY DEPARTURE

The two fully glazed sliding doors do not have a minimum of 30% luminance contrast around each
doorway opening, as prescribed in AS 1428.1(2009), Clause 13.1.

Photo 1: Glazed Entry Doors Photo 2: Glazed Entry Doors

This requirement can be achieved by providing a 50mm wide band with a minimum luminance contrast
of 30% provided between at least one of the following:

door leaf and door jamb;

door leaf and adjacent wall;
architrave and wall;
door leaf and architrave; or
door jamb and adjacent wall.

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 These departures from the prescriptive requirements are evident in Photo 1 and 2 above shows the
design of the window and entry door arrangement.

9. ASSESSMENT

The proposed design is a departure from the applicable Deemed-to-Satisfy access provisions, and as
such, is it is important to understand the intent of these access provisions and determine any impact to
users of the building.

Intent of Access Provisions

The requirement to provide a 30% luminance contrast around a doorway is so that people with reduced
vision are able to identify a doorway.

People with a number of eye conditions benefit from a well-defined doorway, clearly identifiable as they
approach the doorway. These include the following common eye conditions where residual eye-sight or
vision loss is experienced:

Diabetic retinopathy: Reduced night vision, sensitivity to glare and patchy vision loss.
Macular degeneration: Resulting in a difficulty to focus, with the central vision blurred.
Retinitis pigmentosa: Reduced night vision, and extreme tunnel vision.
Cataracts: Where eyesight is cloudy causing blurred vision and a sensitivity to glare.
Glaucoma: Damaged optic nerves causing tunnel vision and blurred objects.

To meet the Deemed-to-Satisfy door access provisions the doorway requires a 50mm wide contrasting
band around each side of the doorway.

General Occupant Characteristics

An important factor in determining the suitability of the proposed Performance Solution is to consider the
typical occupant characteristics within these types of buildings. Under BCA Clause D3.1 and Table D3.1,
the building technically requires access to and within all areas normally used by the occupants, including
the entry doors.

For the purposes of assessing the design for compliance with the BCA, the building is a Class 6 in
accordance with BCA Part A3.

When determining the suitability of the proposed design we can consider the typical building occupant
characteristics within any Class 6 building.

Australia has approximately 1 in 5 people with disability, and the Australian Network on Disability
provides the following statistics:

Over 4 million people in Australia have some form of disability.

Over 300,000 Australians are blind or have low vision (being eyesight that cannot be corrected
through wearing glasses).
19% of men and 18% of women have a disability.
43% of people over 55 years have one or more disabilities.
2.2 million Australians of working age (15 64 years) have a disability.

One can, therefore, assume that there is the potential for a person with a disability to be employed within
the building or a person visiting the building, who could have a vision impairment and these user groups
are obviously the most affected by the door arrangement.

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 Consideration of Employee Occupant Characteristics

Notwithstanding the above, it is also worth considering the use of the building and roles of staff
employed in the building.

Whilst there is expected to be a number of staff with administrative roles, there will also be sales staff
and workshop staff who would not generally be vision impaired due to the nature of their employment.

In the Philip Chun Access report, reference AN17-208387 20170215 LTR_LP, dated 24 February 2017,
this aspect was discussed and a determination made regarding exemption provisions under Clause D3.4
of the BCA:

i) The work activities as described and understood would make it difficult for a person with permanent
or temporary disabilities to carry out the roles required in the Workshop; and
ii) Applying Clause D3.4 of the BCA / Premises Standards is applicable in this instance and that
access for people with disabilities has been provided to the degree necessary given the function of
the Workshop area.

The report found that the type of duties that would be conducted by the workshop staff includes basic
repairs and service works to Mercedes-Benz passenger vehicles as per the provided job description,
which would require a degree of mobility and is not considered suitable for people with disabilities. This
would therefore naturally extend to consideration of a person with vision loss working in a workshop
environment.

Similarly, it would be reasonable for sales staff to be fully sighted, given their requirement to drive
vehicles within the building and during test drives.

Consideration of Members of the Public and other Visitors

It is important to consider how the proposed design will impact on members of the public and other
visitors to the building.

As discussed in this report, the two fully glazed sliding doors do not have a minimum of 30% luminance
contrast around each doorway opening, as prescribed in AS 1428.1(2009), Clause 13.1 and identified by
the red lines below.

Photo 3: Glazed Entry Doors Photo 4: Glazed Entry Doors

Deemed-to-Satisfy Luminance Contrasting Area Deemed-to-Satisfy Luminance Contrasting Area

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 Even though the design will not directly provide 30% contrasting band around the door opening as
shown in the areas of Photo 3 and Photo 4 below, the design does provide the following accessible
features when compared to the minimum Deemed-to-Satisfy (DtS) requirements:
Accessible Feature
50mm wide 30% luminance
contrasting band around
door opening/doorway.
Automation of the doors on
approach from both sides.
Audible cues when
approaching an open
doorway (i.e. how sound
changes).
Other visual/wayfinding
cues when approaching
each door.
A contrast between the
entire window/door frame
assembly and adjoining
soffit/walls.
A compliant horizontal
glazing visual indicator
band across the entire
width of each window/door
frame assembly.
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DtS Proposed Design
provision
achieved?
The glass fixed sidelight panels on each side of the
No
door and each sliding glass door leaf will be fully
glazed without the 50mm band provided around the
doorway.
Yes Exceeds the DtS requirements, there is no
requirement to automate doors.
This greatly benefits all people entering the building
and is considered a universal design concept.
Yes There is no DtS requirement in terms of audible
sounds.
The design will provide an audible sensory cue to all
people with vision loss when:
Entering the building (i.e. the sound from inside
the building); and
When leaving (i.e. the sound outside the building
such as vehicle noise)
Yes There is no DtS requirement in terms wayfinding on
approach to the entry doors.
When leaving, staff would likely assist and supervise
any person with obvious vision loss if they are not
accompanied by a person.
As discussed above, there will be audible cues in
addition.
Yes There is no DtS requirement in terms of a 50mm
luminance contrasting band around the entire glazed
window/door frame.
In this case, there is expected to be a level of contrast
provided between the aluminium frame and the
adjoining walls and soffit ceilings.
Yes Meets the DtS requirements.
Each window and door frame assembly requires a
horizontal visual indicator decal band/strip that is a
solid/opaque continuous strip of minimum 75mm
width along the entire width of glazed doors and
adjacent panels.
Each band is to be located 900mm-1000mm AFFL
and to achieve minimum 30% luminance contrast
against the background surfaces within 2m on both
sides of glazing.
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 Summary of Access Arrangements

When considering these issues discussed within the assessment above we believe that the design is
comparable to the Deemed-to-Satisfy provisions and provides a reasonable level of accessibility.

As highlighted in this report, the use of the building is an important factor, in that it is highly likely that a
person with vision loss would not be visiting the AMG premises unless accompanied by another person
(given the products and services offered). Additionally, if a person with low vision were employed in the
building they would be orientated and inducted and then have learned familiarity after the initial
commencement of their employment.

10. CONDITIONS

This assessment is deemed to be acceptable based on the following conditions:

10.1 In all other respects, the project works shall achieve the requirements of BCA Part D3 and
AS1428.1 (2009) to the satisfaction of the relevant building certifier.
10.2 If there is any change of circumstances associated with the occupation and use of the building,
the Performance Solution outlined within this report may no longer be valid. Consequently,
access requirements consistent with the Premises Standards and the current BCA may need to
be implemented if there is any such change of circumstances.
10.3 A compliant horizontal glazing visual indicator band must be provided across the entire width of
each window/door frame assembly in accordance with AS 1428.1 Clause 6.6.

11. CONCLUSION

The proposed door arrangements discussed within this report will satisfy the requirements of
Performance Requirement DP1 by providing access to the degree necessary that is safe, equitable and
dignified appropriate to the use of the building.

This determination has been made at the request of the applicant and does not absolve the applicant
and owner of the requirements pursuant to the Disability Discrimination Act 1992 (Cth) (DDA). It should
be noted that Philip Chun Access has been engaged to provide a professional opinion relating to the
access issues presented in Section 1 of this report and have not been involved in any further aspects of
the project.

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 APPENDIX A: CV AND QUALIFICATIONS OF THE AUTHOR

Key professional experience

Lee Wilson has extensive experience in various facets of construction, property management, workplace health
and safety, risk management, project management and building compliance. For many years he has
specialised in the area of access for people with disability and universal design. Recent projects have included
aged care, educational, healthcare, hospitality, transport, accommodation and mixed-use developments. Lee is
an Accredited Member of the Association of Consultants in Access, Australia.

With an intimate knowledge of the construction industry and a broad range of experience across legislation,
including performance-based building codes, Lee is able to take a practical approach to compliance, whilst
ensuring the needs of all occupants, including those with disability have been met. Lee is passionate about
promoting access and is an active campaigner for Changing Places toilets and for the adoption of universal
design principals.

Qualifications
- Master of Project Management, 2014
- Diploma of Building and Construction (Management), 2012
- Bachelor of Technology (Building Surveying), 2011
- Graduate Certificate in Performance Based Building and Fire Codes, 2008
- Advanced Diploma of Building Surveying, 2008
- Certificate IV in Security and Risk Management, 2008
- Certificate in Access Appraisals Buildings, 2008
- Diploma of Building Surveying, 2007

Memberships and registrations

- Accredited Member of the Association of Consultants in Access Australia (ACAA)
- Chartered Member of the Chartered Association of Building Engineers (MCABE C.Build E)
- Member of Australian Institute of Project Management (MAIPM)
- Member of World Organization of Building Officials (MWOBO)
- Member of the International Association of Fire Safety Science
- Member of The Society of Professional Engineers (PEng (UK) MSPE)
- Member of ME-064-02 Standards Australia Technical Committee
- Livable Housing Australia Registered Assessor

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