The NCBI Clear Our Paths Campaign (2022): a DPO Perspective

This week sees the NCBI’s (National Council for the Blind of Ireland) media “Clear Our Paths” campaign, and you may be wondering what VVI’s approach is to this issue and what differences, if any, are there between VVI and NCBI on it. Indeed, so dominant has the NCBI been in the advocacy space regarding visual impairment in Ireland, people might even be wondering why VVI should need to exist in the first place.

Unlike the NCBI, which is a disability service-provider, or “organisation for people with disabilities”, Voice of Vision Impairment is a ‘Disabled Persons Organisation’ (DPO), or “organisation of people with disabilities”, as defined by the UN Convention on the Rights of People with Disabilities (CRPD), which Ireland ratified in 2018.

This means that VVI is necessarily rooted in the CRPD, and that our core mission is the defence of and advocacy for Human Rights (of visually impaired people in our case), and that a clear majority of our members must be visually impaired. Note the difference between “members” and “service-users”. It also means that we must be led, directed, and solely run by visually impaired people. 

 According to the UN Committee on the CRPD, DPOs are the only representative organisations when it comes to anything to do with disability, and their opinions and views are to be prioritised in consultations regarding disability by the State, and ultimately by non-statutory bodies as well.

Legal Opininion Commissioned by VVI regarding DPOs (2021)

This exclusive representative role and prioritisation of DPOs is logical when one makes other comparisons: imagine Women’s Rights organisations being led by men, for example, or trades unions being led by employers, or Consumer Rights groups being led by retailers. This would clearly be unacceptable, and even scandalous, because of clear conflicts of interests. For the same reason, the disability industry, according to the CRPD, is not in a position to represent disabled people. This representative role, for obvious reasons, belongs to disabled people, themselves, through their DPOs.

While VVI depend on the lived experiences of our members to determine our detailed policies on issues, our general approach to issues, as a DPO, is necessarily determined by the CRPD, including adherence to the social model of disability (as opposed to the medical or charity model). The following is a brief explanation of how this works in practice, using the issue of clutter-free footways as an example.

Background to Clear Footway Campaigns.

“Make Way Day” began as a social media based campaign organised by the Disability Federation of Ireland (DFI) in September, 2017, and has become an annual event ever since. While the NCBI is a member of the DFI, it took a leaf from the DFI’s book, and began the annual “Clear Footpaths Campaign” as it was, back in November, 2017. Both media campaigns now appear to be a calendar fixture.

Charity PR versus DPO Rights.

Some might argue that at least these organisations are doing something about the issue, and something is better than nothing. However, there is no evidence that such campaigns have any lasting effects in terms of public behaviour; but it is very likely that they do have the longer-term effect of increasing brand-recognition of the DFI and NCBI, respectively, in the public’s mind. This explains the significant resources devoted to such major PR campaigns.

For example, the NCBI’s profile across the media over a full week, gives itself branding that advertising couldn’t buy, increases public donations, increases custom in its charity shops, and most importantly, increases its branding with decision-makers when it comes to State funding and the embedding of their consultative status in significant policy areas. 

The bins and dog-poo are just as likely to be a problem a day after the campaign, but the publicity is literally priceless. The “Clear Our Paths” campaign has the advantage of having the tried-and-tested branding technique of storytelling built into it in the simplest and most naturally understood way, and uses blind people themselves as an alibi in this branding masterclass.

Part of the branding is the perception that the NCBI is populated by members, and that it is a ‘representative’, or even, ‘the‘ representative organisation for visually impaired people in Ireland.  For example, when John Cooke, the interviewer on RTÉ’ Radio 1’s Drivetime, on August 15th, asks June Tinsley, Head of Communications at NCBI, “Has it been more challenging for your members and the people you represent…?”, she makes no effort to correct either trope (a stance which directly or indirectly undermines DPOs, and is thus in contempt of the CRPD (cf. General Comment 7, para. 51).

How the DPO Approach is Different.

VVI, as a DPO, is in its infancy, and Ireland has not yet acknowledged the superpowers bestowed on DPOs by the CRPD, as laid out by the UN Committee in General Comment 7.  These powers include the reversal of projects (plans or policies, etc.), that have not been disability-proofed by DPOs (General Comment 7, para. 66). 

These rights are only obtainable through DPOs – not disability service-providers – and in order to see them come to fruition, we must first ensure that the DPO space is not shut down through suffocation of the space by service-providers, and we must campaign for the full recognition of DPO rights – since the traditional vested interests in Ireland are more dedicated to a consolidation of the status quo than in any meaningful change.

And yet, as fledgling as we are, VVI is outperforming key disability service providers in terms of campaigning on accessible public spaces, as well as other areas. For example, one local authority (Dublin City Council), and one public transport provider (Irish Rail), have begun to put the obligation to prioritise the views and opinions of DPOs into practice, and are finding VVI’s website to be a useful resource as a baseline in Universal Design, as they closely consult with and actively involve us in their consultation processes.

With regard to clutter-freefootways etc., DPOs, being rooted in the social model of disability and in the principles of the CRPD, necessarily holds that safe travel in, and full access to, one’s own community is a Human Right that can only be realised by the adoption of Universal Design in planning and policies by public authorities. VVI’s solutions to most of the issues referred to in the DFI and NCBI campaigns can be found in our Manual of Accessible Planning for Pedestrians (MAPP), for example, in Section 13.

VVI MAPP – Parking of vehicles

Policies, such as our MAPP, are constantly under review in order to remain relevant, and as such, we depend on the individual experiences of our members and pooled expertise of our decision-making core (i.e., our representatives) to make sure they are kept up-to-date.

So, excellent PR campaigns by service-providers will come and go, but if you are visually impaired (that is blind or partially sighted), come and join VVI and add to our strength.  As a member, we will build your experiences on this or any other issue into our policy so that your individual difficulties can lead to permanent change for all.

Dr. Robert Sinnott,
Co-ordinator, Voice of Vision Impairment
T: 086-3989365


VVI promotional video

Dublin City PPN has put our Voice of Visual Impairment promotional video up on its website

The video is available on youtube

The video can also be accessed on the PPN website here:


The VVI is Ireland’s national representative organisation for visually impaired people, specifically focusing on our rights and needs from a visually impaired perspective. In this, we are part of a wider movement of what are known as Disabled Persons Organisations (DPOs).

All VVI members and representatives have a visual impairment, and since we are not a service-provider, we use our expertise to represent the interests and needs of all visually impaired service-users.

We also very much welcome members who have other impairments as well as being partially sighted or blind, and our policies are very much influenced by the particular needs arising from combinations of visual impairment with other impairments.

Video by Ernie Beggs and Paul Woodward

Music by Robbie Sinnott

Submissions & observations

Position Paper on Universal Design for New DART Fleet

Voice of Vision Impairment, JUN 2022


DART stands for Dublin Area Rapid Transit, and is the name given to overground urban and suburban rail service in the Greater Dublin Area.

VVI compiled this position paper in the Spring and early Summer of 2022 in response to Irish Rail’s consultation on a design for a new DART fleet.

This document is complementary to our other policy documents, in particular, our Accessible Communications Policy, and our Policy on Accessible Public Spaces

1. Interior

1.1. Consistency

There is a need for consistency from carriage to carriage. Also, there is a need for consistency vis-à-vis front and back carriages vs. the rest of the train. In other words, the layout should be identical in all carriages, no matter which way they are facing.

1.2. Priority Seating Signs

The current signage (embedded in the windows of commuter trains) announcing Priority seating for blind and pregnant people is very useful and needs to be replicated in the new fleet.

1.3. Handrails

Bright yellow handrails are essential – i.e., not green, blue, or any other colour. The standard on Dublin Bus, Luas, and currently on Irish Rail, is very good because yellow reflects light while also being very distinctive.

Yellow vertical handrails on Siemens 81xx Series Dart
Photo (above) of yellow vertical handrails on Siemens 81xx Series DART.
Yellow vertical and horizontal handrails on Tokyu Car 85xx Series Dart
Photo (above) of yellow vertical and horizontal handrails on Tokyu Car 85xx Series DART.

The vertical handrail from the floor to the ceiling when one boards the train is very useful. This is like the Luas or Iarnród Éireann Diesel Commuter trains and essential for people to maintain their balance when no seating is available, and need to be easily visible to visually impaired people who have some sight.

Yellow vertical and horizontal handrails on CAF 29xxx Series DMU.
Photo (above) of yellow vertical and horizontal handrails on CAF 29xxx Series DMU.
Yellow vertical and horizontal handrails on Siemens Berlin U-Bahn
Photo (above) of yellow vertical and horizontal handrails on Siemens Berlin U-Bahn train.
Yellow vertical handrails on an Alstom Luas tram
Photo (above) of yellow vertical handrails on an Alstom Luas tram.

Vertical handrail attached to the ‘wall’ on either side of the door: We are very impressed with this as there is currently nothing to hold onto when boarding or exiting trains in Ireland, so this is very welcome. Because there is nothing to hold onto, currently, passengers have to lean against the door-jam.

Handrails on seating

These are handy for shuffling around the corner to the aisle; and work well to assist a passenger standing; and, of course, for other passengers to hold onto for balance while walking through the train. The thinner version is easier to grip for those with less hand muscle or dexterity. Also, the rails should protrude less into the aisle, in case of passenger collision and should also be present at the top of seats, allowing more passengers (e.g., from behind the seat) to have the potential for easy-to-reach holding.

In general, the more opportunities for holding onto a rail etc., the better. A blind person cannot see where such rails are, and so it cannot be presumed that we will know where to reach. The more options we have in our close vicinity, the better.

Seating loop handrail & vertical handrail to ceiling CAF 29xxx Series DMU
Photo (above) of seating loop handrail & vertical handrail to ceiling CAF 29xxx Series DMU.

1.4. Accessible Door Buttons

The door buttons need to be accessible: including raised high contrast print, as well as durable Standard English Braille. Currently, the braille “c” and “o” on commuter train door buttons and raised door open/close arrows is good practice.

Accessible door open and close buttons on CAF 29xxx Series DMU
Photo (above) of accessible door open and close buttons on CAF 29xxx Series DMU.

Regarding clarity of braille, we are very impressed with the definition of braille signage on the refurbished De Dietrich Enterprise train between Belfast and Dublin.

Braille signage for ‘Dryer’ on Enterprise De Dietrich cross border carriage
Photo (above) of braille signage for ‘Dryer’ on Enterprise De Dietrich cross border carriage.
Braille signage for ‘emergency intercom’ to speak to train crew on Enterprise De Dietrich carriage
Photo (above) of braille signage for ‘emergency intercom’ on Enterprise De Dietrich carriage.

1.5. Accessible Help Buttons

Similarly, the help/intercom facility needs to have the same raised print and braille signage for visually impaired passengers.

An intercom with ‘SOS’ in raised print and braille on Iarnród Éireann/NI Railways Enterprise cross border refurbished De Dietrich carriage
Photo (above) of intercom with ‘SOS’ in raised print and braille on Iarnród Éireann/NI Railways Enterprise cross border refurbished De Dietrich carriage.

1.6. Accessible Carriage ID

On trains, the identification number for each respective carriage should be accessible on the back of every seat, beside every door, and on every toilet door. Accessible, in this respect, means raised print letters in high contrast, and Standard English Braille.

Dublin Bus stop #1417 with raised numbers in vertical format, braille and contrasting colours
Photo (above) of Dublin Bus stop #1417 with raised numbers, braille and contrasting colours.

1.7. Questioning the Concept of “Family Seating”

It is proposed that there be designated “family seating” areas on carriages. The practicality of such a feature as a designated family area is questionable. Rather than being in the best planning tradition of envisaging normal or worst-case scenarios, it appears to be based on someone’s imaging of an ideal journey, perhaps on a lovely sunny Sunday afternoon etc. Even then, the idea that there would only be space for one family per carriage (with two bicycles only), appears to be tokenistic, at best.

The more area designations in a carriage, the more confusing for passengers, and all designations are likely to be weakened as a result. In particular, we’d be worried that the unnecessary and impractical family designation would reduce the priority seating for vulnerable passengers, and weaken the acceptance of such designated areas by passengers more generally.

Keeping designations as simple as possible (i.e., priority seating and wheelchair areas closest to the doors) means that consistency (1.1 above) is much more achievable and adoptable.

Also, with a family designation area, as currently planned, when the carriage is reversed on a return journey, a visually impaired person will not necessarily know which side is family, and which side is general. There is no need for such confusion.

A realistic practice Family-friendly approach is currently operating with the use of opposing seating as currently in place on the Dart and used (with table) on intercity and commuter trains.

1.8. Airplane style seating

As with commuter trains and inter-city trains, a mixture of airplane-style seating and opposing seating would retain the family-friendly element, while meaning that there is more seating for all passengers.

There is currently a proposal for a small shelf beside the window on the new DART fleet. The curved edges are useful, but there is the possibility of snagging for those unfamiliar with its presence. As such, we would propose a flip-up version as one alternative, or else, as on one of the diesel commuter trains, which has a cup holder for 2 cups just under the window, which doesn’t take up as much space.

Otherwise, if airport-style seating is mixed in with the opposing seats (as on current inter-city and commuter trains), the flip-up shelves at the back of seats (as currently used) would be viable.

Many passengers like to be able to put their elbow against the frame of the window to rest on their journey, and we would suggest that this feature be retained in any new designs.

1.9. Tip-up seats

Two tip-up seats at the wheelchair space close to the door is also best practice. From a balance perspective, finding a seat as soon as possible when you board a Dart is critical in case you are thrown when the train starts moving. We realise that there are planned to be 2 tip-up seats at the wheelchair area and are supportive of this.

1.10. Wheelchair Spaces

On ICR trains, such as those operating to Galway, Tralee, Rosslare etc, one carriage on each 4 carriage set has room for 2 wheelchairs (one left and one right). We propose that this system be designed for every carriage in the new DART design.

While wall mounted signage should work for designation of wheelchair spaces, other passengers often do not or cannot read it, and either park themselves or their luggage there. Accordingly, use of the Dublin Bus standard floor signage of a white wheelchair on a blue background should also be used to help to prevent any confusion, albeit with the use of carpet rather than smooth flooring (with Dublin Bus using the latter).

Disability & wheelchair area on TFI Alexander Dennis (ADL) hybrid bus
Photo (above) of disability and wheelchair area on TFI Alexander Dennis (ADL) hybrid bus.

It appears that on the new DART fleet, Alstom have some concerns about passengers congregating in this area who are only travelling 2 or 3 stops and thus blocking the flow for a wheelchair passenger to board. A useful mediation for this is found on Luas trams, where an announcement of ‘passengers, please move down the tram to allow other passengers to board’ helps with the onboard dispersal of passengers.

1.11. bicycle storage

Transport For London (TFL) does not allow bicycles on its trains because of risk of self-combustion. Clearly, the combustibility of e-bikes and e-scooters needs to be investigated before they are allowed onto passenger-trains.

Also, having space for two bicycles for each carriage appears to be more trouble than it’s worth. It reduces seating space and consistency standards, while only appearing to be tokenistic in terms of “active modes”. A specific holding space for multiple bicycles (even if only a dedicated 6-m long carriage) would be practical for lone cyclists and not interfere with other passengers.

1.12. USB ports for charging

The 2 USB ports between the 2 seats is a good location and ensures no wires going across the other passenger as it currently the case on Intercity ICR and Mark4 trains where the usb ports are in the wall of the train. The metal trunking covering these will ensure they won’t get damaged.

We recommend under-seat, rather than shoulder-height, positioning of the USB ports because it is easier to access, especially when one is seated, and one is less likely to be annoying another passenger in plugging and unplugging etc.

USB and 3 pin plug charging point in wall on Rotem Hyundai 22xxx Series ICR.
Photo (above) of USB and 3 pin plug charging point in wall on Rotem Hyundai 22xxx Series ICR.

1.13. Space under Seating

We are very impressed with the proposed ample storage for bags etc under the seating, as per model we reviewed in March (2022), at the Irish Rail Works in Inchicore. Such space is also good space for a guide-dog. From a visually impaired perspective, it’s all about keeping the aisles clear for all passengers and ensuring no-one stands on the dog etc.

The regular priority seating on ICR trains backs onto a luggage rack and are certainly a tight fit for a guide dog. Indeed, this means the guide-dog has to rest in the middle of the aisle, where passengers, including visually impaired passengers can step on them or trip over them.

2. Doors

2.1. Automatic Door-opening

In order for visually impaired people to independently locate the doors from the inside or outside, there needs to be automatic door opening for doors on the alighting side. This best practice is currently operating in London (since the 1980s), and in Berlin (since the start of Covid. Opening of some doors will not suffice, as many visually impaired passengers will not know whether they are standing on the platform near the front or the rear of a stationary train, and those on the inside may not know on which side of the carriage to get off (i.e., find the door opening button).

An arguments that automatic door-opening may be uncomfortable for on-board passengers is relatively frivolous, especially when contrasted with the right of visually impaired people to independently board trains as per universal design. The principle of Human Rights being more important than aesthetic convenience is paramount.

2.2. High Contrast Doors

There is a need for high contrast colouring of doors. The current proposal of grey doors on a white train does not meet this need. Best practice can be seen on the current commuter fleet, where white doors are contrasted with a dark green carriage.

High contrast colouring of doors on CAF 29xxx series DMU.
Photo (above) of high contrast colouring of doors on CAF 29xxx series DMU.

2.3. Two-way bleeps, with distinctive closing sound

The proposed feature of bleeps to represent the open carriage door – and bleeps that can be heard from the outside and inside – is very welcome.

3. Miscellaneous

3.1. External Livery

The current external livery on commuter trains where the engine is yellow, and the train is dark green, is what we consider to be best practice.

High contrast yellow driver’s cab on Siemens 81xx and Tokyu Car 85xx series DART.
Photo (above) of yellow Driver’s cab on Siemens 81xx and Tokyu Car 85xx Series DART.

3.2. Visual Display of PIS Signage

Visual display of public announcement systems should be in accordance with all EU Regulations and Directives.

3.3. Audio Announcements

At en route stations, the next station should be announced prior to arriving at, and on arrival at, that station. When the door is open, announcement should be made of the next stop and the final stop, and this announcement should be two-way, audible from the platform as well as from the train.

3.4. Positioning of Speakers

We note that speakers are planned for the roof. However, speakers are needed closer to the ear-level of passengers. In terms of fleet consistency, these could be at a priority seating or flip-up seat adjacent to a wheelchair dock.

At least, there should be an intercom beside the door and under the horizontal handrail in the wheelchair area between the tip up seats, as proposed. Of course this is coach c or carriage 3 but having intercoms on the right side of the 4 doors in each carriage is a valuable safety net to contact the Driver in the event of the next stop audio announcement system not working etc.

Intercom to the right of door on a 5xxx Series Alstom Luas tram
Photo (above) of intercom to the right of door on a 5xxx Series Alstom Luas tram.

3.5. Accessible Digital Signage

Without prejudice to any other measure indicated in this or other VVI position documents, the relevant statutory bodies should explore the use of accessible digital signage with regard to the new DART design, closely consulting and actively engaging with DPO’s (including their prioritisation and distinguishing in such consultations).

There are various possible mechanisms for accessible digital signage, including Navilens, which is dependent on a smartphone camera being able to decode physical tags which are strategically placed and which can make detailed information, including real-time updates, accessible to visually impaired and other people.

Test Navilens tag on glass panel facing down CAF 29xxx Series DMU.
Photo (above) of test Navilens tag on glass panel facing down CAF 29xxx Series DMU.

Where relevant, the information provided by ADS must be realtime or otherwise adequately updated, as appropriate.

3.51. Example of Possible ADS on Trains

Onboard tags could provide information on:

  • Carriage numbers
  • Seat-numbers and location of priority seating
  • Information on stops
  • Emergency information
  • The location of toilets
  • The location and use of buttons

VVI Audit of Capel Street, Dublin, Highlights Hazzards of Outdoor Dining to Visually Impaired People

VVI Report Summary on Parliament Street

Inspected by Rosita and Robbie:

Inshore Furniture

Directly outside of establishments at the inshore, can be found tables, chairs, barrels, and small planters. This can occur even where the establishment has outdoor seating opposite on the new build-outs. Sometimes can be found tables with no chairs. It should be remembered that this furniture is unsegregated from the footway.

Obstacles on the footway
Photo showing barrels and other obstacles on the footway

Such inshore obstacles are:

  1. trip hazards.
  2. Snag-hazzards for long-cane users.
  3. Edges of tables are collision-hazzards at waist height.
  4. Familiar inshore landmarks are buried beneath an everchanging landscape of ad hoc furniture. If this inshore furniture has permission, how was such permission granted by Dublin City Council (DCC)? If it doesn’t have permission, why hasn’t DCC done anything about it?
  5. Where is the due regard to safety of vulnerable pedestrians obliged in the Planning Act, S254?

Regular ignoring of new outdoor seating areas

There are regular examples of furnigure (including tables) encroaching on the footway from the new outdoor seating areas, i.e., crossing well over the metal strip and well into the footway.

Metal strip obstacles on the footway
Photo of seating crossing the metal strip on the footway

Indeed, in some cases, the entire zones (including matting) cut well into the already-narrow footway space, and canopy anchors are also to be in the footway area (i.e.. This poses the same risks as mentioned in (1) above, edge of the pavement, I’d be liable to clip my hand on the edge of the table as they’re physically too close to the edge of the pavement. Where the kerb would have been previously).

Designated Outdoor Dining Areas too Cluttered

Quoting Rosita, a guide-dog owner and one of the VVI auditors, “there are too many seats within the area (especially the second area mentioned above) myself and a guide dog couldn’t navigate it safely and to complicate matters further because of layout, if I was sitting at a table closest to the planters, and other people decided to sit in the same row as me, I would be physically unable to pass them to head back to the pavement. They would be blocking the only route out from the seating area.”

There also seem to be no additional bins as there will be more food waste and packaging left behind after people have finished eating.”

Outdoor dining seats, barrels and large planters
Photo showing a large amount of outdoor dining seats, barrels and large planters

Hazzardous Canopy Anchor Cords (guy lines)

There are several instances of canopy anchor cords descending diagonally into the footway area, meaning that they are liable to snag a vulnerable pedestrian in the neck or face, or otherwise put them off balance.

No evidence of monitoring by DCC.

Canopy anchor cord crossing into the footway
Photo showing instance of a canopy anchor cord crossing into the footway

Inadequate Segregation

Quite often, we found no segregation at either end of the outdoor seating areas, meaning that a visually impaired person could inadvertently find themselves entangled in diners and furniture.

Overlapping with Bicycle Lane

At one point, some of an outdoor seating space is up on the kerb, while seating beside it is down off the kerb (on the road, and the space between them leads directly onto a bicycle lane.
This is unnecessarily putting the vulnerable diner in harm’s way.

Outdoor dining seating area too close to bike lanes
Photo showing outdoor dining seating area too close to bike lanes

Narrow footways

As mentioned earlier, in many places already narrow footways have been substantially constricted further, so that it is difficult to see how, in places, even a single power wheelchair could fit through (consultation with Physical Impairment Ireland needed on same).

Narrowing of the footway due to outdoor seating and other obstacles
Photo showing a narrowing of the footway due to outdoor seating and other obstacles

Hot Liquid Hazzard

The brand new hazard of footway pinch-points between pedestrians walking one way along a footway and others carrying hot liquids etc. in a perpendicular direction from the businesses to the outdoor seating, has yet to receive satisfactory attention by DCC.

Where does the insurance liability rest in the case of an accident occurring from this extra health and safety hazard?


There is no evidence of monitoring or policing of conditions by DCC. This means, effectively, that it is a free-for-all, and is likely to disimprove if left to its own devices.

As things stand, this ongoing situation disables pedestrians with visual impairments using Capel Street.

We have not, as yet, audited Parliament Street, but we have no reason to think that the results would be much different.

Note a photographic file of our audit has been made to back up our findings above.

Small planters and other small obstacles crossing the metal strip
Photo showing small planters and other small obstacles crossing the metal strip on the footway


Position paper on Home Support Services Standards

Voice of Vision Impairment, November 2021


Recently, VVI has been engaging with the health services regulator, HIQA, on optimal standards in home support services, including a focus group meeting on November 30th, 2021.

The following position paper comes from HIQA’s questions and the responses of our members, which was augmented by the focus group engagement.

This position paper is compiled by Gerry, Ed, Áine, and Robbie.

What works well?

1.1. Flexibility to Adapt to Clients’ Needs

In the HSE Home-help service the fact that the client is free to tell the home-help what needs to be done, and there isn’t a prescribed list is positive. In England for a while, in some local authority areas, home-helps were prohibited from reading printed material to visually impaired people or anyone who had problems reading print. The lack of such prescriptive requirements by the home-help service is a positive feature.

We do recognise, however. that this needs to be balanced with the benefits to clients, workers, and agencies, to have clear expectations of work.

1.2. Spot Checks

Occasional spot-checks by Health Nurses etc, are essential and welcome on the rare occasions when they happen, but but these need to be done properly and more often (see below).

What would make things better for people using home support services?

2.1 Disability awareness training for all Home Services staff

This training should include the workers themselves, as well as supervisors that are properly trained in how to run the home-help service.

2.1.1. Examples for workers regarding visual impairment

For example, Home-helps will often put away items when tidying, cleaning, or washing. Sometimes this makes such objects very difficult to find when they have been placed in unusual locations. For a visually impaired person, having things moved to a different location can mean that they can’t be found, or that they are knocked down because they are encountered unexpectedly, E.G. a toothbrush an toothpaste placed on a different area of a shelf or, on a different shelf. A cup that is placed just on the edge of a shelf in a press that falls out when the door is opened.

Similarly, where one worker may have the intuition to ask about an out-of-the-way object that is gathering dust, and the visually impaired client may have forgotten that they had such an object in their possession, others may not have such intuition. Perhaps such things cannot be taught, but awareness is a good thing.

For visually impaired clients, the home worker can be a useful pair of eyes. For example, someone had placed a grapefruit in an unusual place in the house of a VVI member, and not knowing this, our member was wondering where the smell of mould was coming from. A home services worker was able to correct the situation immediately on seeing the grapefruit.

Whereas, generally, problematic hoarding can be identified and diplomatically worked with by home support workers, including recommendations of getting appropriate referrals, and working with the client to clear spaces, this skillset takes on another dimension with visually impaired clients who may have a lot of paper clutter that may need disposing of. In such situations, of course, permissions must always be sought before such papers are gone through by the worker in consultation with the client.

2.1.2. Listening

As well as a more formal disability awareness training, there is a Need for workers to listen to the service-user on how they need things done. They are the experts in their needs. For example, homecare workers dealing with a visually impaired person need to leave everything back exactly where they found it, or if not, ask permission before moving an item to another place, explaining reason.

2.1.3. Time-keeping

Not specifically related to disability, but important nonetheless, is time-keeping. Workers should only ever show up at the appointed time, and not unexpectedly. If they are running late, they should first check with the client before arriving, and if something comes up for them unexpectedly, they need to inform the client as early as possible.

2.1.4. Hygiene and First Aid training

Workers should also be trained in safety hygiene and basic first aid training, including cardiac pulminory resuscitation (CPR).

2.2. Regulation and Regular Monitoring

2.2.1. Regulating the Sector

Currently, the home support sector has no independent regulation. This necessarily means that the standards of care on the ground are likely to be significantly varied. The well-being of service-users should not be a matter of luck or chance. Clients and their families need to know that they can depend on a certain standard of quality care with accountability and choice embedded in the system.

At the very least, there needs to be objective benchmarks or measurements for the purposes of assessment of standards.

In so far as is possible, such standards should also apply to family carers, at least in so far as the need to protect anyone from living in squalor and in an abusive situation, and the need to uphold the dignity and Human Rights of everyone in our society.

2.2.2. Matching Workers and Clients

There should be a practical acknowledgement of the Importance of flexibility regarding particular needs of clients and particular talents of workers. Such optimal matching of clients and workers could be bart of the disability awareness training in 2.1 above.

For example, a worker may have a particular gift at befriending, and certain clients would be likely to benefit more from such talents. Other clients, on the other hand, may prefer their own company and space, and just need practical assistance. Indeed, some clients may be neurodiverse, with particular boundary needs, that may suit the talents of other workers.

As part of the matching process, it might be a good idea to also factor in compatible interests or hobbies etc., further facilitating a mutually warm relationship between client and worker. Matching skills such as language proficiency would be of similar mutual benefit.

2.2.3. Direct Line between management and service-user

There should be a direct line of communication between the service provider and the service receiver in order that the service can be monitored regularly to ensure that a quality service is being given and the service recipient has the opportunity to inform the service provider that the individual employed by them is suitable for the provision of services for that particular service recipient.

2.2.4. Accessible Modes and Formats of Communication

The format of communication by the service provider with the service user must be in accessible format, with provision made for accessible communications in the opposite direction (cf. Disability Act, S28; CRPD, Art. 9; Equal Status Act (2000, Ss. 4, 5). Options may include large print, braille, but also include phone calls and other forms, such as constntual consultation visits,

2.2.5. Written Record

There are reports of home-helps who are supposed to provide an hour’s work but who only stay for half an hour, which is missed by management, since There is often no communication with the client by the home-help supervisors about the standard of the service”.

The staff member of the service provider should keep a diary of tasks completed at the dwelling of the service recipient, which can be periodically submitted to the contractor for review or checking.

a copy of the same journal should besigned off on, or given to the customer or close family member who is referenced as a close contact so that the service recipient can confirm same. Also, that in the event that the service person is not suitable, there should be the option of replacement by another staff member to provide the home care hours .

This does not negate the idea of a care plan, but means that flexibility can be built into care-plans where they exist.

2.2.6. Anti-Bullying Awareness by Management

It is also important that such a link is in place to ensure that bullying doesn’t take place. Bullying can be in different disguised forms: using the individuals credit card for purchasing goods other than the goods required by the service recipient, Acquiring possessions of the service recipient as they don’t appear to have a use for such goods, services in their present circumstances (see also 2.6 below).

2.2.7. A Red Flag Mechanism

As part of the regulatory system, there needs to be a mandatory mechanism whereby records of complaints against an individual worker are maintained, including across agencies. It should not be possible for workers who have been found to have been negligent on more than one occasion to simply be moved around or passed on to clients until ones are found that don’t complain. If a worker is negligent with one client, there is a high probability that that client is not the only one, and this should also be borne in mind when a worker has been found to have been negligent or unprofessional with one client.

2.2.8. External Reviews – Independent Monitoring of Standards

A VVI member reports that, “In our local area a survey was conducted to gauge client satisfaction. It was conducted by individuals who were not trained to carry out such work. The survey questions were put to the client in the presence of the home-help whose services were being assessed”.


Spot-checks by adequately trained personnel (independent or management), should occur at regular periods, e.g., at least once a year or on request, and not in the presence of the worker.

Obviously, all entry to the home by anyone involved in the service-provision or its monitoring, must be predicated on the consent of the service-user. This also presumes prior arrangement of a visit, and not someone just showing up at the door of a service-user, unexpectedly.

Unless a problem or problems are found, such spot-checks should be confidential (between management and the service-user).

2.2.9. Moving On

The service recipient should have the right to change their home assistant in the situation that they do not feel comfortable with the arrangement and communicating this to the service provider. There should be no stigma about either side wishing to move on to another worker/service-user.

2.3. Other Communications

2.3.1. Workers’ Holidays, Illness, replacements and trainees

To quote a VVI member, “In our area when a home-help goes on holiday there is rarely any cover. People are left without the service until the person returns from holiday. No official notification Is given about a home-help taking a holiday. it is left to the home-help to inform the client”. Similarly, a worker may have to take sick-leave or retire.

Our members report cases where such information has not been passed onto them at all, so that they expect a worker to arrive, and nothing happens for a fortnight or so, or even, a worker has taken sick-leave, has not been replaced, and the client has not been informed.

When people are being trained they are often sent out with an existing home-help to a client without the clients consent or knowledge that a trainee will be accompanying the home-help (see also 2.6 below).

When workers are changed the client is not necessarily officially notified, again, it is left to the existing home-help to inform their client.

2.3.2. Respecting Close Connections between Workers and Clients

One worker states that she can go to somebody as a home-help or carer, (she does both) and she may know that person for a number of years but isn’t always told when they have died. Often as a carer she is looking after somebody in their home and then they may go into hospital. She doesn’t get told if they die. Also, sometimes people are found dead int their homes and she still isn’t told even if she has been going to that person regularly. This happened recently and when she complained she was told that she shouldn’t get close to her clients.

If you have a situation where carers and home-helps are too afraid to get too close to their clients because of what may happen to them, then you essentially have a service without anyone who does care. These people are not taught how to distance themselves and neither incidentally are doctors and nurses. But if the people providing the care are not properly nurtured then they can’t provide an optimal caring service to their clients.

2.4. Insurance

There are reports of home-helps who frequently break crockery ETC. There appears to be no proper insurance in place to cover damages of clients’ property

2.5. Sufficient Time Guaranteed

The service recipient should be entitled to a sufficient quota of hours of service to ensure that a quality service is given, The allotted hours should not be reduced by the loss of hours due to staff having to reduce time due to travelling between clients or due to the case of a particular client requiring extra attention in a particular occasion.

2.6. Specific Designated Workers, and no-one else.

Staff service provider contracts should specify that the member of staff and they alone, should engage with the service receiver, thus eliminating any other personages from entering the dwelling of the service recipient such as other family members or friends of the service provider staff member unless with the explicit permission of the service receiver (see also 2.2.4, and 2.3.1, above).

2.7. Need for Comprehensive System

Our members perceive a need to co-ordinate or otherwise dovetail home help into personal assistance. For example, a person might like to go into town to shop for items in Dunnes etc., and have lunch there etc.

Similarly, while it is pointed out in the scoping document that certain medical services such as nurses, physiotherapists etc are not included, the individual may require management assistance of their circumstances due to incapacity caused by a long-term impairment or medical conditions which require ongoing treatment and which need organising on a local basis rather than having to travel extended journeys for minor pre op testing, i.e. individual from midlands has to travel to have procedure done in C.U.H. but is also required to attend appointment at C.U.H. at 8am on a Sunday prior to surgical procedure for Covet19 test. Logically, the individual could be tested locally and the results passed on to the Team in C.U.H. All the details involved in such arrangements could be managed in house so as to streamline service.

Remote PA systems such as AEIR should be supported by the HSE, or whichever statutory body is responsible for PA services.

The right to live independently in a community is universal. Among other things, this means that there should be no age cut-off points for the provision of personal assistance.

2.8. Customer Services Charter

That the service recipient be made aware of their customer rights and the content of a customer service charter which sets out the parameters of the quality of service the individual is entitled.

2.9. Better Pay and Conditions for Workers

2.9.1. General Pay and Conditions

Home service workers getting properly paid and most of the payment for their work not going to an agency would be very welcome. Poor wages and conditions inevitably leads to poor turnover and generally less quality of interactions.

2.9.2. Replacing the “Agency” Model

Workers should have the same employment rights as is normal in other sectors. The sharade that they are “self-employed” contractors with an agency needs to be ended once and for all, and for all such workers to be treated as employees of the agencies, i.e., how things are in to all intents and purposes. Happier workers make for happier clients.

2.9.3. Travel Costs.

Travel costs to and from clients, as well as any travel costs occurring during the official care time, need to be factored in as part of a worker’s remuneration. Such costs should never be borne personally by the worker.

Similarly, enough time should be given to workers between jobs for a break and for travel to the next job.

3. What are the important outcomes?

  • Most of all, the dignity of the service-user be always uppermost. They need respect from the system as well as from their individual carers.
  • The service-user lives in a safe home (e.g, clean and tidy).
  • Their well-being be maintained – e.g., depending on client, cooked dinners, walks, shopping, etc.
  • In so far as is possible, that the independent living of the client is supported
  • Clients should be included as part of the home help service rather than an appendage to it. Using the principle of “Nothing about us without us”, and the obligations on the State under the Convention on the Rights of People with Disabilities, disabled people, through their representative organisations (also known as Disabled Persons Organisations), should be prioritised in all consultations on standards and policies in this area.
  • Need for an Independent evaluation of privatisation, not just from a cost-effectiveness standpoint, but also recognising that such services as provision of care is qualitatively different from the production or processing of widgets, so sectoral profit-margins are not the bottom line. The outsourcing of State services in the past twenty years should be intrinsic to such a review, as well as the associated higher regulation costs when there are multitude of private players vs. an accountable service provided by the State (e.g., as with the equivalent provision by local authorities in Britain).

By Gerry, Ed, Áine and Robbie (21 Dec 2021)


No next stop audio announcements on 50% of the Dart fleet since 2017

Blind and partially sighted passengers rely on on-board audio announcements when travelling on trains, buses, and trams, etc., in order to know where we are, and in order to know what stop to get off at. Other passengers also find this useful, whether they are napping, reading an eBook, or new in town. However, if a visually impaired person gets off at the wrong stop, they are not only completely lost, but placed in a dangerous situation, literally with unexpected pitfalls and obstacles, and no knowledge of how to escape or find help. Even getting to the platform on the other side of the track in order to get the next train going in the other direction is extremely difficult to do if you are blind and unfamiliar with a station.

Many of us began noticing a high number of audio announcement faults on the Dart from 2017, and raised these with Iarnród Éireann, as well as the accessibility difficulties encountered in trying to identify the carriage vehicle id for subsequent investigation and repair.

The good news is that a new system will be installed by early 2023. The bad news is that it will have taken an incredible 6 years (2017-2023) to resolve.

VVI (Voice of Vision Impairment), is not only dismayed at the excessive delay in resolving the issue of no next stop announcements on 50% of the Dart fleet, but we also have serious concerns regarding the implications this has for other public transport modes, including bus and tram. There appears to be little regard for forward planning in terms of built-in obsolescence, future-proofing, and disability-proofing our public transport fleets so that they are safe and accessible for all passengers; but worst of all, there is no light at the end of the tunnel, in that such lack of foresight and planning appear to be endemic to the several statutory bodies dealing with Ireland’s public transport system.

Photo of Siemens (LHB) Dart and Toyyu Car Dart
Photo above of Siemens (LHB) Dart on the left and Toyyu Car Dart on the right.

To be or not to be, board the Siemens (LHB) Dart vehicle id 8115 on the left with audio announcements or the Tokyu Car Dart vehicle id 8621 on the right with no audio announcements.

Some background

The Dart is made up of 142 electrical multiple units (EMU), 74 of which were supplied by LHB in Germany, and went into service in 1984. The remainder were supplied by Tokyu Car in Japan, and went into service between 2001 and 2005.

The original German LHB Darts were subsequently refurbished by Siemens (which included a passenger information system) and went back to service in 2008/2009. The audio announcements on these units, thankfully, remain in working order.

However, the same cannot be said for the fleet of 68 Dart EMU ordered by Iarnród Éireann-Irish Rail from Tokyu car in Japan between 2000 and 2004. Divided into 3 classes (8500, 8510 and 8520), the bulk of these units entered service in 2004/2005, and these were the first Dart units to feature a passenger information system (PIS) with next stop audio announcements.

The passenger information system (PIS) equipment for the 8500 and 8510 class units was supplied by Vemisa, and the 8520 class units by Ikusi – both suppliers are still in business.

These systems were maintained by Quaestor in East Wall, Dublin.

Towards Replacement of passenger information system and manual announcements.

In 2019 – two years after the audio announcements began to disappear – Iarnród Éireann confirmed to VVI that it was seeking funding from the National Transport Authority (NTA) to replace the passenger information system on the 68 Tokyu Car Dart’s as they were life-expired and could not be repaired.

VVI suggested in the interim that Dart Drivers could make manual next stop and destination announcements until a new system was procured/installed.

Previously we highlighted Iarnród Éireann Drivers on the Cork to Cobh and Middleton lines making manual next stop announcements on their early 1990’s diesel commuter trains which don’t have an automated audio announcement system. We also highlighted Drivers on Intercity and commuter Trains making manual announcements when the audio announcement system was either out of order or when there were no Hosts or Customer Service Staff (CSO) on board.

Iarnród Éireann cited the significant number of stations on the Dart line (31 versus 11 on the Cork Commuter Routes), and mentioned the possibility of announcements only at hub stations, subject to agreement with Driver representatives. Two years later however, and four years since the audio announcements began to go quiet, no progress has been made.

Dept of Transport, Tourism & Sport Accessibility Consultative Committee Meetings.

The Department of Transport, Tourism & Sport (DTTAS) hold regular meetings of a “Accessibility Consultative Committee” and the minutes of these meetings are available online from 2018 to 2021.

While we don’t have access to the minutes from meetings in 2017, it is clear the Dart audio announcement (PIS) issue was on the agenda at previous meetings as early as 2017.

At the meeting on 28th of March, 2018, the accessibility update from the National Transport Authority refers to “Possible interim measures to address difficulties with audio/visual announcements on DART pending replacement of the existing system, e.g. an app – NTA to raise with Irish Rail.”

At a meeting on the 18th of September, 2019, the “DTTAS advised that 47% of the DART fleet requires an upgrade of its Passenger Information System and Irish Rail is developing a proposal on the necessary upgrade work for submission to the NTA for funding. Following a tender process, it is understood the work will take approximately 2 years to complete.”

At a meeting on the 22nd of Janury, 2020, “Dept of Transport, Tourism & Sport (DTTAS) Work Programme – Quarters 3 and 4 2019 (Action 8) DART Passenger Information System. Target is to award contract for 17×4 car sets in 2020, with a view to installation in 2021. This had previously been stated to be one of the key public transport projects for people with disabilities.”

Tender issued.

On March 15th, 2020, when funding was secured from the NTA, Iarnród Éireann issued a tender.

“…The existing 8500 EMU fleet are fitted with passenger information systems (PIS) equipment supplied by Vemisa (8500 and 8510) and Ikusi (8520). Both systems are now obsolescent and require to be replaced with modern, reliable and best in class systems. The new replacement systems will consistently and reliably provide accurate and timely information; provide good visibility/readability (displays) and deliver good intelligibility (audio)…”

Iarnród Éireann

Tender awarded.

On December 10th, 2020, Ikusi were awarded the contract to replace the passenger information system.

While the awarding of the contract is very welcome news, it was, however, long overdue, since 50% of the Dart fleet will have been operating with no audio announcement for 2017, 2018, 2019, 2020, 2021 and 2022 (6 years).

Questions that need to be Answered.

Why the excessive delay?

Could this happen again on a different fleet?

The LHB (Siemens) Darts, for example, use a passenger information system from Telvic.

Bus Éireann, Dublin Bus, Go-Ahead and Luas also have passenger information systems. Indeed, the original 3000 class Luas trams operating on the red line, for example, date back to 2003.

At least most of the equipment in Dublin Bus is 2014 and newer. The supplier, Innit, are pretty big in Germany, so hopefully they offer good support. But should we really be leaving such vital accessibility to chance?

We need to know if the audio announcement systems on any of these (LUAS, Dublin Bus, Bus Éireann, or other trains), are life-expired and if so, are there projects in place to replace them?

The current and urgent DART example shows up an issue whereby even if the NTA funded a replacement project tomorrow, between procurement, installation and commissioning, we are looking at a time frame of at least 2 years. How it has taken 6 years at Iarnród Éireann is an issue that needs to be investigated so that sucha delay does not happen again, with Iarnród Éireann, or with any other service-provider.

Where does the book stop? Was it an NTA funding issue?

Was it because the issue wasn’t one of the long term action minutes at the DTTAS Accessibility Consultative Committee meetings and therefore disappeared from scrutiny so to speak?

Either way, both the DTTAS and NTA were clearly aware of this and appear to have sat on it.

What we are requesting

  1. We would like some accountability in the form of an investigation to get to the bottom of this neglectful mess.
  2. We look for the assurance (with proof) that the same dangerous systematic situations are not about to befall other transport fleets.
  3. We look for an interim measure, such as manual driver announcements, even at hub stops, on the DART line until the broken half of the DART fleet is fixed in 2023.
  4. We request that certain low-tech fallback systems be introduced on fleets to mitigate against the loss of these essential audio announcement systems through fault or obsolescence, and we in VVI are here to fulfil our particular role as a DPO, under the Convention on the Rights of People with Disabilities, including our prioritisation in such consultations.
Photo of LHB Siemens Dart
Photo of LHB (Siemens) Dart EMU # 8140 with working audio announcement system
Audio announcements on Siemens (LHB) Dart journey from Pearse to Glenageary (3m24s.). 

Photo of Tokyu Car Dart
Photo of Tokyu Car Dart EMU # 8601 – audio announcement system not working (above).

No audio announcements on Tokyu Car Dart journey (8m24s).


What is inclusion?

In the video below listen to Robbie Sinnott from Voice of Vision Impairment answer questions as part of Dublin City Council’s Inclusion and Integration Week, 2021. We have also included the full transcript at the bottom of the page.

We are not born disabled.
Many of us have impairments,
And because of this, we are often disabled by society
We are being disabled by prejudice
We are being disabled by bad design
We are being disabled by bad planning

So, while diversity is cause for celebration,
Being disabled is not.
Make disability history.

Be aware.
Know your rights.
Join us in VVI

Full transcript

Dublin City Inclusion and Integration Week – Questions and Answers series

Inclusion and Integration Week, 2021

Question 1: What does integration mean for you?

Robbie: Integration is about being equal in humanity. Being disabled is not an identity. Being disabled is something that is done to a person by society, by attitudes, by design. So we really need to do away with disability because it is being disabled that causes disability is a social construct.

Question 2: What does social inclusion mean to you?

Robbie: Social inclusion means the disappearing of the barriers and obstacles that stop me from living exactly the same life as my sighted counterparts. Social inclusion would be good design, good planning. And it would be listening to the needs of people with a visual impairment through their DPO or through their representative organisation.

Question 3: What is the most positive aspect of inclusion and integration within Dublin City?

Robbie: There’s a great acceptance among most ordinary people of diversity and that’s not necessarily shared by the systems and institutions who like to box tick. But it’s certainly there among ordinary people, which is fantastic.

Question 4: How can Dublin improve its inclusion and integration in Dublin City?

Robbie: By basically doing what it’s told to; what Ireland has ratified; what it’s signed up to under the convention and the rights of people with disabilities. And by prioritising disabled persons organisations, representative organisations in their planning. And basically planners are there to plan not just for people like themselves. They’re there to plan for everybody. And my need to access my city is a human right to safely access the streets outside and around my home. That is a human right and it’s as equal as anybody else’s.

Question 5: Would you agree Dublin welcomes diversity? Why?

Robbie: Well I think Dubliners welcome diversity and their brilliant at it. Dublin City Council doesn’t necessarily welcome diversity. It has its own idea of diversity in a wallpaper sense. Yeah, it likes it, you know. In terms of colour or taste. Possibly. But when it comes to hard tax, when it comes to the things on the ground, for instance, making things accessible to disabled people, like accessible and safe streets for disabled people. They are not remotely interested in hearing us whatsoever. They have their own idea and it’s far from disability proofed and it’s far from safe. It’s very disabling. The attitude is disabling and their plans are disabling.


Describing How You Look at Meetings is a “waste of time”

Woman sitting in a seat wearing a blindfold

Last month (September, 2021), we in VVI were approached by a statutory body regarding a particular aspect of online meeting protocol apparently intended, in particular, for the benefit of visually impaired attendees.

This protocol involves each speaker, in their introduction, describing what they look like and what they are wearing. They even describe themselves as being “middle aged” etc.

We agreed to survey our members to see what they think of the practice, and not surprisingly to us, the unanimous verdict is strongly against the practice.

So if your organisation has already embraced such a practice, or if it is thinking of doing so, the following selection from our responses might cause you to reconsider:

“For me it is a waste of time.”


“Unless a description of something adds value, I see no point in it. In this case, I believe it would add no value.”


“I don’t see any great advantage to being told that the speaker is “grey haired, rotund and in his fifties” Concentration on descriptions should be more to do with the details contained within the speakers oration, documentation refs and description of other information details like images or illustrations or such material.”


“Personally I don’t really care, but I certainly wouldn’t be bothered if it didn’t happen, I don’t really care what people look like and I’m not sure how relevant it is to a meeting.”


“I am blind. Thereby my perception of what people are is generally based on non-visual criteria. The effectiveness of what people have to say incorporating their ability to be descriptive, credible and convincing is what matters to me not a visual description of the individual.”


“I largely agree with what David has said. Personally, I wouldn’t find a description of the physical features or dress of the speaker of interest or value… I would find it of no interest and perhaps a little uncomfortable if I was in the minority as a visually impaired person. I think they would be much better being asked to make sure they described their slides and read out information that they are talking about and pointing to.”


“not everyone would feel equally comfortable describing themselves, and indeed, a blind person would find it difficult to describe their own appearance, so in terms of equality, it mightn’t be as inclusive as it first seems.”



Difficulties boarding the Luas due to Covid-19 restrictions


Covid-19 has shown us that while public transport is operating at 100% capacity since September 1st, the situation is however very fluid with the possibility of capacity reductions and further lockdowns should there be a spike in Covid-19 cases. While no one could have foreseen the Covid-19 pandemic, we do however need to future-proof things.

Difficulties boarding the Luas

Locating the door and indeed the door open button on a Luas tram by passengers who are blind or partially sighted is like a needle in a haystack. Having to trail the tram to find an open door is not a pleasant experience on your knuckles and you certainly won’t have clean hands after it. You also risk catching your fingers when another passenger opens the door from the inside.

Picture showing a blind passenger trailing Luas stopped at a station in order to find open or closed door
Picture of blind passenger trailing Luas to find open or closed door

In contrast, locating the internal door open button is straight forward as it’s in a frame.

Photo of Luas internal door open button located within the interior door frame
Photo of Luas internal door open button in door frame

In 2012, Roger Flood from Dublin Bus Travel Assist gave me an excellent tip which was to go to the front of the Luas platform before it slopes and to stop there where the Luas Driver would open the front door for me, making it just as easy as boarding a bus. This had been a game-changer for hundreds of blind and partially sighted passengers who Roger had trained over the years.

In March 2020, to minimise the spread of Covid-19 by people touching door open buttons and to ensure proper ventilation, Luas Drivers were opening all doors.  In 2021, Drivers were no longer opening the single half-leaf door at the front of the tram and were telling me to walk down to the next door. You therefore have to trail the Luas as you will see in the following bodycam video.

The video below is a recording of the difficulties faced by blind passengers boarding the Luas

Blind person boarding the Luas tram

When VVI queried this at a Luas User Group meeting earlier this year as it was unlikely to have been a door fault on every occasion, we were told that the front door on the Luas is locked and the area behind the Driver is actually cordoned off so as to ensure social distancing. Blind and partially sighted passengers therefore need to trail the Luas in the hope of finding an already-opened door or rely on the kindness of a helpful member of the public which are not always around at lighter used stations like Museum. Another problem we have are some Luas Drivers driving off when blind and partially sighted passengers are trailing the Luas trying to find the seam for the door. I understand Drivers have discretion to wait for vulnerable users boarding.

Although the Drivers are allowed to open all doors ‘At a platform when identifying that a passenger has difficulty entering the tram (elderly, mobility impaired).’, both Transdev and TII have stated that passengers could fall out if they were leaning against the door and that this could be fatal in the event of Drivers opening doors on the wrong side in error.

Photo from the front of a train of the Siemens (LHB) Dart Drivers Cab with window
Photo of the Siemens (LHB) Dart Drivers Cab with window

Both Dublin Bus and Dart Drivers have a window in their cab which they can open for ventilation. The LUAS however does not hence the reason for chaining off the area behind the Drivers Cab and locking the single half-leaf door at the front.

Photo from the front of Luas Drivers Cab with no window
Photo of Luas Drivers Cab with no window

01.09.2021– Capacity was restored to 100% on public transport.

01.09.2021– Query send to Transdev and TII as Drivers are not opening the single leaf door at the front of the tram for blind and partially sighted passengers with a long cane or guide dog.

09.09.2021– Drivers are now opening the single leaf door at the front of the tram

Future proofing due to possible Reintroduction of capacity restrictions

This could be achieved by having:

  1. Tactile pavingfrom the lozenge tactile to the second door down or potentially every door so as to evenly distribute passengers throughout the tram.
  2. Future tram orders should add selective door openingto open the second door down. Future tram refurbishments could also have this added.
  3. Audible locator beacons (like they have on traffic lights) could be added to door open buttons.

Barry O’Donnell (VVI) 15.09.2021


VVI Pre-Budget Submission

28 AUG 2021

1. DPOs to be Funded

In line with the UN Convention on the Rights of People with Disabilities (e.g., General Comment 7, paras. 61, 62), the State is required to ring-fence core funding for Disabled Persons Organisations (also known as “Representative Organizations”), as well as providing project-related funding.

Note, DPOs are not disability service providers (DSPs) or advocacy organisations run for disabled people. In short, they are not the traditional brand-names of the “disability sector”.

2. Increase in Blind Persons Pension and Disability Allowance

According to the 2016 Census, at least 75% of those with a severe visual impairment in the relevant age-brackets are not in paid employment. Whereas Welfare payments are generally kept low as an incentive for the recipients to seek paid employment, the institutionalised and practical barriers are clearly too high for visually impaired people for this approach to be justifiable, generally, in their case. As equal Irish citizens, they deserve dignity of life and equal opportunity.

To mitigate against the current institutionalised disabling of people from their institutionalised unemployment and impoverishment, at the very least, the Blind Persons Pension and Disability Allowance need to be increased to meet the increased cost of living brought about by the disabling and impairments of their recipients.

For budgets to come, we would advise that universal basic income be considered for all people with a severe visual impairment for as long as the unemployment rates are so high (i.e., for as long as there is clear institutionalised biases and practical issues with blind and partially sighted people being employed).

Similarly, Blind Welfare Allowance would reflect the extra costs of living of independent visually impaired people, and be increased accordingly (cf. SVPJ report, 2017) which found that the extra costs due to visual impairment were around €70 per week, however, this is likely to be an underestimation given that the research relied on focus groups, which should be more biased towards the self-selection of relatively independent and mobile visually impaired people, and probably against those with most or recent sight-loss.

3. Equalisation of Blind Persons Pension with Disability Allowance

Currently, those on the Blind Persons Pension are at a disadvantage in several ways when compared with those on the Disability Allowance. For example:

  • Disability Allowance is payable from 16, but the Blind Persons Pension only from 18.
  • Capital disregard is €50,000 for the Disability Allowance, but only €20,000 for the Blind Persons Pension.
  • There are no disregards for partners or spouses on Blind Persons Pension, but some disregards for these regarding Disability Allowance
  • While on Disability Allowance, full Medical Card entitlements are allowable up to an income of €427 per week, but with the Blind Persons Pension, no extra earnings income is permitted for a recipient to retain their Medical Card benefits.

All of these anomalies are unjustifiable, and appeared to have accrued by neglect rather than design. The Blind Persons Pension should be put on a par with the Disability Allowance in all respects as soon as possible. Since there are only slightly more than a thousand people in receipt of the Blind Persons Pension, fixing these discrepancies should not be onerous, but it is the fair and right thing to do.

3. Visually Impaired Passengers

The EU Parking Permit scheme for disabled drivers and passengers means that blind passengers (along with severely physically impaired passengers/drivers) have disabled parking rights.

Visually impaired people have a comparatively restricted ability to engage in “active modes” of transport, and as such, it is an anomaly (and discrimination on the basis of disability) that they are not also eligible for the Disabled Drivers and Disabled Passengers Scheme, which provides a range of tax reliefs linked to the purchase and use of specially constructed or adapted vehicles by drivers and passengers with a disability. Visually impaired people may not need adapted vehicles, but the necessity of their being driven should be reflected in the same tax reliefs and toll exemptions, i.e., as set out in the Disabled Drivers and Disabled Passengers (Tax Concessions) Regulations 1994 (SI 353/1994) as amended.

5. Talking Books should be VAT-free

21% VAT needs to be removed from talking books (to match print book counterparts). This helps to address the difficulties in educational and cultural access experienced by blind people, especially having lost their sight later in life, and recognises the barrier to purchasing talking books caused by the systemic impoverishment of visually impaired people.

6. Removal of VAT on dog-food for guide-dogs.

A guide dog is an aid to VIPs both for independent living and mobility. As such, the costs of maintaining them should be vat exempted, as is the case for adaptive technology, which also can be seen as an aid to independent/living/mobility.

So, VAT should be removed from all purchases necessary for the maintenance of guide dogs, including dog-food.

7. TV license exemption to all visually impaired people – whether on welfare or not.

De facto this is the case anyway, since An Post has been thwarted in the Courts for trying to chase down blind people who had not officially been exempted. But visually impaired people should not have to worry about such things. This is a good time to remind the State that the vast majority of television programming in Ireland does not have Audio Description, and so is inadequately accessible to visually impaired viewers/audiences.

8. €2 tax on all Prescriptions for Medical Card Holders

When Fianna Fáil and the Green Party introduced this tax (€2.50 back then) in 2009, it was said to be a temporary measure necessary in the drastic economic circumstances that the State found itself in.

Eleven years on, and this regressive tax has only been reduced by 50c. Because this is a nasty little tax that hits the most vulnerable in society, it needs to be immediately removed, and removed completely. Many of our members are dependent on medicine related to their eye conditions, and this tax effectively taxes them on those eye conditions, or the prevention of those conditions getting any worse – which would be even more costly to the State.

As such, an affected person with a visual impairment on a social welfare payment will necessarily be poorer than their sighted comparitor as a result of this regressive tax. So, it is discriminatory as well as immoral.

9. VVI to be Closely Consulted

Apart from the above, no budget measures specifically relating to visually impaired people should be made without first closely consulting with Voice of Vision Impairment (as Ireland’s national DPO specifically focusing on visual impairment related issues).

Similarly, no budgetary changes should be made concerning disability in general without all national DPOs being closely consulted with.

10. Seed Funding for a National Universal Accessibility through Technology Scheme

As a basic step to using technology to empower visually impaired people in society, a national and universal scheme to provide access to all signage both digital and static, should be explored through consultations with VVI and other national DPOs. At last, technology has reached the point at which we can now implement affordably and easily those requirements, outlined in both the 2005 Disability Act (and the 2006 NDA Code of Practice), the Equal Status Acts, and most importantly of all, Article 9 of the CRPD.

Whereas, before, such technology may have seemed too expensive and not universal enough for widespread application, this landscape is rapidly changing, and Ireland should be at the forefront of utilising such technology to improve the lives of visually impaired people.

Possibilities include individual accessible technology grants from lottery funds, and a national assistive technology library where visually impaired people can test out devices.