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


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.

Newsletter Submissions & observations

Legal Opinion for VVI as a DPO – for all DPOs

Date: 27 July 2021

What constitutes a Disabled Persons Organisation under the United Nations Convention on the Rights of Persons with Disabilities.

To:  Voice of Vision Impairment (
From: Michael Lynn S.C. and Philip Reynor Solicitor: Eversheds Sutherland

  1. Background
  2. Summary
  3. VVI Concerns
  4. Ireland and the CRPD
  5. Optional Protocol to the CRPD
  6. Key provisions of the CRPD in respect of DPOs: Articles 4(3) and 35(4)
  7. What is a ‘Disabled Persons Organisation’?
  8. The scope of Article 4(3)
  9. Article 33
  10. Articles 4 and 33 as linked with other provisions of the CRPD
  11. Conclusion

I. Background

  1. Voice of Vision Impairment (‘VVI’) is a voluntary all-Ireland organisation established to campaign for the needs and rights of disabled people, with particular experience in, and focus on, the area of persons with a visual impairment (‘VIPs’). VVI was set up specifically as a national Disabled Persons Organisation (‘DPO’) in line with the Convention on the Rights of Persons with Disabilities (‘CRPD’) in July 2019.
  2. We use the phrase “disabled people” rather than “people with disabilities,” as the former reflects the ‘social model’ of disability rather than the so-called ‘medical model’. The social model has as its basis that disability is caused by the way society is organised, rather than by a person’s impairment or difference. It looks at ways of removing barriers that restrict life choices for disabled people, so enabling them to be independent and equal in society. The so-called medical model categorises people as disabled because they have an impairment or difference, which may or may not be receptive to medical or other treatment. Many disabled rights activists believe this medical model focuses on impairment rather than need, creating low expectations that impede the achievement of independence, choice and control.
  3. Ireland is due to publish its first State Report on its implementation of the CRPD this year. It published a draft report for the purpose of consultation on 3rd December 2020. Several organisations, including VVI, which describe themselves as national DPOs have come together to work as a coalition on a shadow report.
  4. VVI has raised a query in relation to what constitutes a DPO under the provisions of the CRPD, specifically with regard to the provision of services to disabled persons, and what role should a DPO play in policy making?
  5. VVI would like a legal opinion on the interpretation of a DPO under the CRPD.

II. Summary

  1. DPOs play a central role under the CRPD and, as the authority on disability, should be considered as the only representative organisations when it comes to disability.
  2. Organisations of disabled people (i.e. DPOs) can only be those that are led, directed and governed by disabled people. A clear majority of the membership of a DPO should be recruited from among disabled people themselves.
  3. The membership of a DPO must be open to anyone from their designated impairment grouping(s) and, importantly, at least half of a DPO’s employees should be disabled.
  4. The CRPD clearly establishes that DPOs must be afforded the opportunity to participate and, in that regard, should not only be closely consulted but must also be actively involved and prioritised by States parties as the only representative organisations.
  5. It is particularly important from the perspective of participation, that the term ‘representative organisation’ in the context of the CRPD is understood to mean a DPO and is not broadened in scope to include non-DPOs (such as service providers).
  6. The essence of a DPO is that it is composed of disabled persons, and led by them. It is to be distinguished from a service provider. Nor is it simply a campaign group. A DPO is an organisation owned and led by a clear majority of disabled persons, which thereby ensures their full participation, understanding and promotion of their interests.
  7. Under the CRPD, a DPO has an acknowledged role to play in public consultation and decision-making. This involvement extends to the negotiation, development, and drafting of policy and legislation by States parties. The pooled expertise and collective agency of disabled people is extremely important.
  8. States parties should systematically and openly approach, consult and involve, in a meaningful and timely manner, DPOs. This requires providing access to all relevant information, including the websites of public bodies, through accessible digital formats and reasonable accommodation when required, such as the provision of sign language interpreters, Easy Read text and plain language, Braille and tactile communication.
  9. Permanent consultation mechanisms with DPOs should be established, including round tables, participatory dialogues, public hearings, surveys and online consultations, respecting their diversity and autonomy.
  10. The Optional Protocol is a vital aspect of the CRPD as it provides an important advocacy tool for people concerned with violations of their rights. Despite the Department of Justice and Equality stating in 2015 that Ireland intends “to sign and ratify the Optional Protocol”, this has yet to occur.
  11. The failure of the Government to ratify the OP-CPRD places a significant barrier to disabled people who wish to complain to the UN if their rights are violated and weakens the effect of the CRPD in Ireland.

III. VVI Concerns

  1. VVI believes that rights-based organisations and service providers should be kept separate in order to remain objective and avoid conflicts of interest, particularly where there is State funding and/or consultation involved.
  2. VVI is concerned that the classification ‘DPO’ may be being wrongly extended to service providers who are not DPOs. This may have implications for which organisations should be prioritised by the State as DPOs for the purpose of compliance with the CRPD.
  3. VVI is concerned that it itself is not being adequately recognised, or appropriately prioritised, as a DPO. Under the CRPD, a DPO has an acknowledged role to play in public consultation and decision-making, so VVI should be facilitated in carrying out such functions. It has provided several examples of the obstacles it can face in contributing to public schemes which impact on VIPs, including the following three.
  4. (i) VVI was asked in November 2020 if it was interested in being consulted on the design for a new railway station in Waterford. It said that it was, but was then given no role as a service provider was preferred. (ii) VVI has raised five issues in respect of the National Transport Authority’s Bus Connects plan for a re-design of bus routes in the Greater Dublin Area but these, it says, are being ignored. (iii) The Public Participation Network (‘PPN’) is currently one of the few ways that DPOs have of engaging with local authorities. Current PPN guidelines provide that all members are equal which fails to recognise the special position of DPOs and the support they need. For example, requests to revert the PPN Handbook to original braille have, VVI says, been ignored with deference, instead, being given to the advice of a disability service-provider which claimed such provision was unnecessary.

IV. Ireland and the CRPD

  1. The CRPD is a landmark legal instrument aimed at ensuring the protection and vindication of the human rights and fundamental freedoms of disabled persons. It forms the cornerstone of an international framework established to guide national policy-making and legislation, and international cooperation, for building an inclusive society, and fostering disability-inclusive development. It has been described as bringing about a paradigm shift such that disabled persons are, as they should be, respected as active subjects with equal rights, capable of taking their own decisions and contributing to society, rather than objects of treatment, charity or other support.
  2. The aim of the CRPD is to guide and support State parties in the formulation and enforcement of their legislation, strategies, policies and programmes, so as to promote the full empowerment, equality, and inclusion of disabled persons.
  3. As expanded upon below, one of the principles at the centre of the CRPD is the fundamental role to be given to DPOs, in order to ensure the effective participation of disabled persons in public life. This participation includes not only the involvement of DPOs in the implementation and monitoring of the CRPD but also aims to guarantee that disabled persons are fully and decisively involved in the making of decisions that affect their lives and rights at local, national and international levels. This involvement extends to the negotiation, development, and drafting of policy and legislation by States parties. The pooled expertise and collective agency of disabled people is extremely important.
  4. The CRPD was adopted by the United Nations in 2006. The European Union acceded to the CRPD through Council Decision 2010/48/EC, formally adopted on 26 November 2009. The instrument of ratification on behalf of the EU was then deposited in December 2010. This was the first occasion that the EU became a party to an international human rights treaty.
  5. In 2007, Ireland signed the CRPD and shortly thereafter it declared that as a dualist state it was required to be in a position to meet the obligations assumed under the terms of an international agreement before bringing it into force domestically. This meant that in order to ratify the CRPD, Ireland would first have to amend a range of its legislation. With the exception of the passage of the Assisted Decision-Making (Capacity) Act 2015, which has still not been brought into force, little was done in this regard by the government from 2007 to 2018, with the dualist argument being employed to excuse the delay in ratification of the CRPD. In 2015 the Department of Justice and Equality published its ‘Roadmap to Ratification of the United Nations Convention on the Rights of Persons with Disabilities’. This document was produced eight years after the signing of the CRPD by Ireland and identified large volumes of legislative provisions as non- compliant with the CRPD. A Disability (Miscellaneous Provisions) Bill 2016 (‘the 2016 Bill’) was introduced with the purpose of amending a range of legislation so that Ireland could ratify the CRPD.
  6. On 20 March 2018 – with the vast majority of the required legislative amendments remaining outstanding – Ireland finally ratified the CRPD, even though the 2016 Bill has yet to be enacted. It was amended by the Select Committee on 30 January 2019 and lapsed with the dissolution of the Dáil and Seanad on 14 January 2020. In the Legislation Programme Autumn Session 2020, the status of the Bill was listed as follows: ‘Revised heads in preparation’.
  7. At long last, a timeline has now been published by the government for the commencement and implementation of another important piece of legislation, the Assisted Decision-Making (Capacity) Act 2015 (as amended), which should now be operational by June 2022.
  8. Having ratified the CRPD in 2018, Ireland has an obligation to report periodically to the UN on its implementation of the Convention. It must write a report for the CRPD Committee every four years, and answer questions raised by the Committee.
  9. The Government must also ensure there is an independent organisation to monitor how the CRPD is being put into practice across the country. This is being done by the Irish Human Rights and Equality Commission (‘IHREC’). This process is referred to in the CRPD as the ‘Independent Mechanism’.
  10. The purpose of the Independent Mechanism is to monitor the operation of the CRPD and write reports to the CRPD Committee. The CRPD provides that disabled people must be a part of this monitoring process as this ensures that a clear picture of the lives of disabled people is presented.

V. Optional Protocol to the CRPD

  1. The Optional Protocol to the CRPD (GA resolution A/RES/61/106) (‘OP- CRPD’) – which entered into force at the same time as the Convention – establishes two additional mandates for the CRPD Committee:
    (i) the receipt and examination of individual complaints; and
    (ii) the undertaking of inquiries in the case of reliable evidence of grave and systematic violations of the CRPD.
  2. This is a vital aspect of the CRPD as it provides an important advocacy tool for people concerned with violations of their rights.
  3. Complaints may only be communicated against a State party that has ratified or acceded to the OP-CRPD, and only upon the exhaustion of all available and effective domestic remedies. Ratification of the OP-CRPD by Ireland would allow the CRPD Committee to receive, consider and provide its views and recommendations in relation to alleged violations by Ireland of CRPD rights as communicated by disabled persons or those acting on their behalf.
  4. Despite the Department of Justice and Equality stating in 2015 that Ireland intends “to sign and ratify the Optional Protocol to the Convention on the Rights of Persons with Disabilities at the same time as the Convention itself is being ratified”, this did not occur upon ratification of the CRPD and Ireland has yet to ratify the OP-CRPD (see: ‘Roadmap to Ratification of the United Nations Convention on the Rights of Persons with Disabilities’; at p.13).
  5. In relation to the decision not to ratify the OP-CRPD, the Department of Justice and Equality stated:

“The matter of signing the optional protocol will be reviewed and further considered following completion of the first reporting cycle under the Convention. Due to the variability and uncertainty of the reporting cycle we are not in a position to give an exact date at this juncture.”

  1. That report was due to be published two years after the ratification of the CRPD by Ireland, i.e. on 20 April 2020, but remains outstanding to date. The failure of the Government to ratify the OP-CPRD places a significant barrier to disabled people who wish to complain to the UN if their rights are violated and weakens the effect of the CRPD in Ireland.
  2. Nevertheless, in addition to the Government, the Independent Mechanism and civil society organisations, disabled people and their representative organisations can send their own reports to the CRPD Committee. The CRPD Committee will then examine all these reports and revert to the Government in relation to how it can better protect the rights of disabled people.

VI. Key provisions of the CRPD in respect of DPOs: Articles 4(3) and 35(4)

  1. Article 4(3) of the CRPD, headed ‘General obligations’, states (emphasis added):

“In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, States parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.”

  1. What constitutes a “representative organization” for the purposes of the CRPD? In order to provide guidance for States, in 2018 the CRPD Committee published General Comment No.7 on the participation of disabled persons, including disabled children, through their representative organisations, in the implementation and monitoring of the Convention. From the outset, when discussing the definition of “representative organizations,” the wording of paragraph 10 of General Comment No.7 (as set out in full in paragraph 49 below) makes it clear that the phrase “representative organizations” is another expression which means “organizations of persons with disabilities” or DPOs. Indeed, this is made clear throughout General Comment No.7 (see, for example, paras. 5 to 12, and 16). By defining a representative organization specifically as a DPO, it clearly intended that DPOs are to be the only representative organisations for the purpose of disability. As such, service providers and other non-DPOs are not to be considered as “representative organizations” for the purposes of the CRPD.
  2. In addition to providing for consultation with disabled persons through their representative organisations, or DPOs, in the implementation of legislation and policies, Article 33(3) of the CRPD ‘National implementation and monitoring’ provides for participation in monitoring compliance with the CPRD (emphasis added):

“Civil society, in particular persons with disabilities and their representative organizations, shall be involved and participate fully in the monitoring process.”

  1. It is important to note that Article 33(3) refers to ‘participation’. Similarly, Article 4(3) states that disabled persons should not only be “closely consult[ed]” but also be “actively involve[d]” by States parties “through their representative organisations [i.e. DPOs]”. This implies that “active involvement” is a form of participation that is something more than mere consultation. In this respect and for the avoidance of any doubt, it should be noted that where the CPRD refers to ‘representative organisations’ it is referring to DPOs and not, for example, service providers or other non-DPOs. It is particularly important from the perspective of participation, that the term ‘representative organisation’ in the context of CPRD is understood to mean a DPO only and is not broadened in scope to include non- DPOs.
  2. Participation in public life, as both a principle and a human right, is well established in a number of international human rights treaties such as Article 21 of the Universal Declaration of Human Rights, Article 5(c) of the International Convention on the Elimination of All Forms of Racial Discrimination, Article 7 of the Convention on the Elimination of All Forms of Discrimination against Women, and Articles 12 and 23(1) of the Convention on the Rights of the Child.
  3. One of the purposes of General Comment No.7 is to “clarify States parties’ obligations under articles 4(3) and 33(3) and their implementation …”. It outlines in paragraph 7 some of the ways in which States parties can fulfil these obligations, by granting financial or other assistance to DPOs.
  4. Whilst a UN Committee’s General Comment is only of persuasive force in how one properly interprets the Convention article(s) to which it refers, General Comments are nevertheless of potential importance; a General Comment by the Committee on Economic, Social and Cultural Rights was cited by the Supreme Court in NHV v. Minister for Justice [2018] 1 I.R. 246 in its discussion on the right to seek work under the Constitution.
  5. The CRPD’s Committee’s General Comment No. 7 states that the “effective and meaningful participation of persons with disabilities, through their representative organizations, is … at the heart of the Convention.” It continues:

4. Often, persons with disabilities are not consulted in the decision-making about matters relating to or affecting their lives, with decisions continuing to be made on their behalf. Consultation with persons with disabilities has been acknowledged as important in the last few decades, thanks to the emergence of movements of persons with disabilities demanding recognition of their human rights and their role in determining those rights. The motto “nothing about us without us” resonates with the philosophy and history of the disability rights movement, which relies on the principle of meaningful participation.

5. Persons with disabilities still face significant attitudinal, physical, legal, economic, social and communication barriers to participate in public life. Before the entry into force of the Convention, the views of persons with disabilities were dismissed in favour of those of third-party representatives, such as organizations “for” persons with disabilities.

  1. Paragraphs 8 and 9 of the General Comment note the shortcomings in many States.

8. The Committee, however, continues to observe an important gap between the goals and the spirit of articles 4(3) and 33(3) and the degree to which they have been implemented. This is due, among other things, to the absence of meaningful consultation with and involvement of persons with disabilities, through their representative organizations, in the development and implementation of policies and programmes.

9. States parties should acknowledge the positive impact on decision-making processes and the necessity of involving and ensuring the participation of persons with disabilities, through their representative organizations, in such processes, notably because of their lived experiences and knowledge of the rights to be implemented. States parties should also consider the general principles of the Convention in all measures taken for its implementation and monitoring, and in advancing the 2030 Agenda for Sustainable Development and its goals.

  1. When Article 33(3) is read in conjunction with Article 4(3), it becomes clear that disabled people through DPOs must not only be involved in the monitoring framework of Article 33(2), but also the focal point and coordination mechanism of 33(1). In order to facilitate, and make effective, this intended involvement, the State may be obliged to work on building capacity within civil society to ensure that DPOs have the ability to participate meaningfully in the process of implementation and monitoring.
  2. In relation to the Government’s report to the CRPD Committee, it should involve disabled people through DPOs in assessing how it is carrying out its obligations under the CRPD (see Article 35(4) of the CRPD).
  3. Moreover, the central place given to DPOs by the CRPD implies that States parties need to be rigorous in determining what organisation is a DPO and what is not. Paragraph 10 of General Comment No. 7 confirms this, stating:

10. The involvement and participation of persons with disabilities through “representative organizations”, or organizations of persons with disabilities, is inherent in both articles 4(3) and 33(3). For proper implementation, it is important for States parties and the relevant stakeholders to define the scope of organizations of persons with disabilities and recognize the different types that often exist.

  1. In Ireland, the State’s primary response to Articles 4(3) and 33(3) appears to have been the Disability Participation and Consultation Network (‘DPCN’), which neither prioritises DPOs nor even distinguishes them from non-DPOs, and comprises a majority of service providers. This does not seem to give DPOs the sort of preferential position and role that is envisaged by the CRPD. The Committee on the Rights of Persons with Disabilities published its Initial Report under the Convention on the Rights of Persons with Disabilities (Ireland) (December, 2020) which states that “This [DPC] Network is comprised primarily of Disabled Persons Organisations”. While the DPCN does have some DPO members, it appears that a significant majority of its members, including its organising member, Inclusion Ireland, are service providers which would not qualify as DPOs for the purposes of the CRPD. Moreover, there are now over 70 members of the DPCN which renders “close consultation” with DPOs as mandated by Article 4.3 of the CRPD (see para. 57 below) impractical and doubtful.

VII. What is a ‘Disabled Persons Organisation’?

  1. The essence of a DPO is that it is composed of disabled persons, and led by them. It is to be distinguished from a service provider. Nor is it simply a campaign group. It is an organisation owned and led by disabled persons, which thereby ensures their full participation, understanding and promotion of their interests.
  2. A distinction is made between an ‘organisation of persons with disabilities’ (i.e. representative organisations or DPOs), and other ‘civil society organisations’ (‘CSO’) and ‘organisations “for” persons with disabilities’ (‘OFPD’).
  3. Paragraph 11 of General Comment No. 7 refers to some distinguishing characteristics of DPOs. It states (underlining added):

“The Committee considers that organizations of persons with disabilities should be rooted, committed to and fully respect the principles and rights recognized in the Convention. They can only be those that are led, directed and governed by persons with disabilities. A clear majority of their membership should be recruited among persons with disabilities themselves. Organizations of women with disabilities, children with disabilities and persons living with HIV/AIDS are organizations of persons with disabilities under the Convention. Organizations of persons with disabilities have certain characteristic aspects, including the fact that:

(a) They are established predominantly with the aim of collectively acting, expressing, promoting, pursuing and/or defending the rights of persons with disabilities and should be generally recognized as such;

(b) They employ, are represented by, entrust or specifically nominate/appoint persons with disabilities themselves;

(c) They are not affiliated, in the majority of cases, to any political party and are independent from public authorities and any other non-governmental organizations of which they might be part/members of;

(d) They may represent one or more constituencies based on actual or perceived impairment or can be open to membership of all persons with disabilities;

(e) They represent groups of persons with disabilities reflecting the diversity of their backgrounds (in terms of, for example, sex, gender, race, age, or migrant or refugee status). They can include constituencies based on transversal identities (for example, children, women or indigenous people with disabilities) and comprise members with various impairments;

(f) They can be local, national, regional or international in scope;

(g) They can operate as individual organizations, coalitions or cross-disability or umbrella organizations of persons with disabilities, seeking to provide a collaborative and coordinated voice for persons with disabilities in their interactions with, among others, public authorities, international organizations and private entities.

  1. The phrase “clear majority” in para. 11 implies something more substantial than a simple majority of 51:49. It suggests that a DPO should be structured in such a way that it is clearly led and governed by disabled people, not just technically so. So, the structure taken as a whole must ensure such leadership and governance.
  2. The CRPD Committee draws a very important distinction between DPOs and other civil society organisations, and emphasises strongly the special place of DPOs, and the priority they should be given in ensuring their participation in proposed legislation and initiatives aimed at assisting disabled persons (emphasis added).

13. Organizations of persons with disabilities should be distinguished from organizations “for” persons with disabilities, which provide services and/or advocate on behalf of persons with disabilities, which, in practice, may result in a conflict of interests in which such organizations prioritize their purpose as private entities over the rights of persons with disabilities. States parties should give particular importance to the views of persons with disabilities, through their representative organizations, support the capacity and empowerment of such organizations and ensure that priority is given to ascertaining their views in decision-making processes.

14. A distinction should also be made between organizations of persons with disabilities and civil society organizations. The term “civil society organization” comprises different kinds of organizations, including research organizations/institutes, organizations of service providers and other private stakeholders. Organizations of persons with disabilities are a specific type of civil society organization. They may be part of a mainstream umbrella civil society organization and/or coalitions that do not necessarily advocate specifically for the rights of persons with disabilities, but can support in mainstreaming their rights in the human rights agenda. In accordance with article 33(3), all civil society organizations, including organizations of persons with disabilities, have a role to play in monitoring the Convention. States parties should give priority to the views of organizations of persons with disabilities when addressing issues related to persons with disabilities, and develop frameworks to request civil society organizations and other stakeholders to consult and involve organizations of persons with disabilities in their work related to the rights enshrined in the Convention and other topics, such as non-discrimination, peace and environmental rights.

VIII. The scope of Article 4(3)

  1. Article 4(3) requires close consultation and active involvement with disabled persons, through their DPOs, in legal and regulatory frameworks and procedures across all levels and branches of Government. The involvement of DPOs should be a mandatory step prior to the approval of laws, regulations and policies, whether mainstream or disability specific. Therefore, consultations should begin in the early stages and provide an input to the final product in all decision-making processes. Consultations should include organizations representing the wide diversity of disabled persons, at the local, national, regional and international levels (para. 15, Gen. Comm. No. 7).
  2. The legal obligation of States parties to ensure consultations with DPOs encompasses access to public decision-making spaces and also other areas of research, universal design, partnerships, delegated power and citizen control (para. 17, Gen. Comm. No. 7).
  3. The phrase “concerning issues relating to persons with disabilities”, as referred to in Article 4(3), covers the full range of legislative, administrative and other measures that may directly or indirectly impact the rights of disabled persons. It includes decision-making processes, such as general laws and the public budget or disability-specific laws, which might have an impact on their lives (para. 18, Gen. Comm. No. 7). In cases of dispute about the direct or indirect impact of the measures under discussion, it falls to the public authorities of the States parties to prove that the issue under discussion would not have a disproportionate effect on disabled persons and, therefore, that no consultation is required (para. 19, Gen. Comm. No. 7).
  4. To “closely consult with and actively involve” disabled persons through DPOs is an obligation under international human rights law that requires the recognition of every person’s legal capacity to take part in decision-making processes based on their personal autonomy and self-determination (para. 21, Gen. Comm. No. 7). States parties should systematically and openly approach, consult and involve, in a meaningful and timely manner, DPOs. This requires providing access to all relevant information, including the websites of public bodies, through accessible digital formats and reasonable accommodation when required, such as the provision of sign language interpreters, Easy Read text and plain language, Braille and tactile communication. Open consultations provide disabled persons with access to all the spaces of public decision-making, on an equal basis with others, including national funds and all the relevant public decision-making bodies relevant to the implementation and monitoring of the CRPD (para. 22, Gen. Comm. No. 7; see, also, paras. 43, 45 and 46).
    Public authorities should give due consideration and priority to the opinions and views of DPOs when addressing issues directly related to disabled persons. Public authorities leading decision-making processes have a duty to inform DPOs of the outcomes of such processes, including an explicit explanation in an understandable format of the findings, considerations and reasoning of decisions on how their views were considered and why (para. 23, Gen. Comm. No. 7; see, also, paras. 47, 48 and 49).
  5. Public authorities should give due consideration and priority to the opinions and views of DPOs when addressing issues directly related to disabled persons. Public authorities leading decision-making processes have a duty to inform DPOs of the outcomes of such processes, including an explicit explanation in an understandable format of the findings, considerations and reasoning of decisions on how their views were considered and why (para. 23, Gen. Comm. No. 7; see, also, paras. 47, 48 and 49).
  6. “Full and effective participation”, as set out in Art. 3(c), requires that States parties facilitate participation and consult with disabled persons representing the wide diversity in impairments. By guaranteeing the participation of DPOs, disabled persons will be able to better identify and point out measures that could either advance or hinder their rights, which ultimately yields better outcomes for such decision-making processes. Full and effective participation should be understood as a process, not as an individual one-time event (para. 28, Gen. Comm. No. 7). Full and effective participation can also be a transformative tool for social change, and promote agency and empowerment of individuals. The involvement of DPOs in all forms of decision-making strengthens the ability of disabled persons to advocate and negotiate, and empowers them to more solidly express their views, realize their aspirations and reinforce their united and diverse voices. States parties should ensure the full and effective participation of disabled persons, through their DPOs, as a measure to achieve their inclusion in society and combat discrimination against them. States parties that ensure full and effective participation and engage with DPOs improve transparency and accountability, making them responsive to the requirements of such persons (para. 33, Gen. Comm. No. 7).1
  7. A range of obligations, such as the provision of funding for DPOs, the appointment of DPO members on representative bodies, and clear structures aimed at ensuring primacy for DPOs are also recommended by the General Comment No. 7 as arising from the CRPD: see paras. 42 to 66.

IX. Article 33

  1. Article 33 supplements Article 4(3). It requires the involvement of civil society in the monitoring of the State’s compliance with the CRPD and this should include DPOs, which should be heard and recognised through formal mechanisms.
  2. Article 33(3) implies that States parties should support and fund the strengthening of capacity within civil society, in particular DPOs, to ensure their effective participation in the processes of the independent monitoring frameworks. DPOs should have appropriate resources, including support through independent and self-managed funding, to take part in the independent monitoring frameworks and ensure that reasonable accommodation and accessibility requirements for its membership are met. The support and funding of DPOs in relation to Article 33(3) complements States parties’ obligations under Article 4(3) of the Convention and do not preclude them (para. 39, Gen. Comm. No. 7).

X. Articles 4 and 33 as linked with other provisions of the CRPD

  1. Articles 4(3) and 33(3) are important as instruments to achieve the obligations arising from other articles in the CRPD. For example, they are key to achieving equality and non-discrimination, as required by Article 5.
  2. Priority objectives for States parties in implementing the CRPD include the creation of an enabling environment for the establishment and functioning of DPOs, by adopting a policy framework favourable to their establishment and sustained operation. This includes guaranteeing their independence and autonomy from the State, the establishment, implementation of and access to adequate funding mechanisms, including public funding and international cooperation, and the provision of support, including technical assistance, for empowerment and capacity-building. Legislation and policies should be adopted that recognize the right to participation and involvement of DPOs and regulations that establish clear procedures for consultations at all levels of authority and decision-making. This legislative and policy framework should provide for the mandatory realization of public hearings prior to the adoption of decisions, and include provisions requiring clear time frames, accessibility of consultations and an obligation to provide reasonable accommodation and support. This can be done through clear references in laws and other forms of regulations to the participation and selection of representatives from DPOs. There should also be the establishment of permanent consultation mechanisms with DPOs, including round tables, participatory dialogues, public hearings, surveys and online consultations, respecting their diversity and autonomy (see para. 94(b), (e) and (f), Gen. Comm. No. 7).
  3. Notably, States parties should prohibit discriminatory and other practices by third parties, such as service providers, directly or indirectly interfering with the right of disabled persons, including their DPOs, to be closely consulted and actively involved in decision-making processes related to the Convention (para. 51, Gen Comm. No. 7). Also, States parties should put in place mechanisms to denounce the conflicts of interests of representatives of organizations of disabled people or other stakeholders, to prevent their negative impacts on the autonomy, will and preferences of disabled people (para. 52, Gen. Comm. No. 7). States parties should adopt provisions granting organizations of disabled people seats on, for example, standing committees and/or temporary task forces by giving them the right to nominate working members to these bodies (para. 53, Gen. Comm. No. 7).
  4. Access to information (Article 21 CRPD) is necessary for DPOs to be involved and to fully participate and freely express their opinions in the monitoring process. Such organizations need to receive the information in accessible formats, including digital formats, and technologies appropriate to all forms of disabilities, in a timely manner and without additional cost. This includes the use of sign languages, Easy Read, plain language and Braille, augmentative and alternative communication, and all other accessible means, modes and formats of communication of choice by disabled people in official interactions. Sufficiently prior to any consultation, all relevant information, including specific budgetary, statistical and other relevant information necessary for an informed opinion, should be made available (para. 84, Gen. Comm. No. 7).

XI. Conclusion

  1. It is clear that DPOs are fundamental to the proper implementation of the CRPD. The CRPD Committee has advised extensively on this – as summarised above. Unfortunately, Ireland’s very late ratification of the CRPD, and failure to ratify the Optional Protocol, suggest that the State has not properly addressed how it will introduce the mechanisms that are required to ensure that DPOs play the crucial role that is entrusted to them by the CRPD. It would appear to be an omission that now requires urgent attention in close consultation with VVI and other national DPOs.
  2. Should VVI have further questions, we will try our best to reply to them.


Have your say about disability rights in Ireland

We’d like to take this opportunity to remind anyone who is blind or partially sighted that they are welcome to become a member of Voice of Vision Impairment, simply by emailing with your name and local authority area (if you know it). Membership has no obligations, but lots of benefits.

VVI is a founding member of the DPO Coalition. The DPO Coalition is preparing its first ever Shadow Report to the UN Committee on the Convention on the Rights of Persons with Disabilities (CRPD).

The Coalition wants to know about your experiences and opinion on what you think of the Convention on the Rights of Persons with Disabilities (CRPD) and how it relates to your life. This survey is an opportunity for you to give feedback about your rights.

Your feedback will help the DPO Coalition write the report to the UN Committee about how well the Irish Government is implementing the Convention on the Rights of Persons with Disabilities (CRPD).

The survey is split into three sections. Section 1 is information about your profile, section 2 is about your experiences and section 3 is about what you think of the Convention on the Rights of Persons with Disabilities.

In section 2 Quality of Life the survey asks questions about different areas of life and experiences of discrimination and barriers to participation.

  • Discrimination
  • Supports
  • Healthcare
  • Education and Training
  • Work and Employment
  • Safety from abuse
  • Choosing where to live
  • Transport
  • Social participation
  • Participation in public and political life
  • Justice

The survey can be completed by clicking on the following link:

The deadline to finish the survey is 12.00pm on 8th April 2021.

FAQs on this type of survey

Do I have to fill in the whole survey?

No, you can pick the questions that are important to you. You can fill in as many questions as you want and you can skip ones that you do not want to answer by pressing the green “Next” button.

Can I add more information later?

Yes, for example, you can answer some questions one day and other questions the next day:

  • Start the survey and answer the questions you can finish on that day.
  • To save your answers on a page make sure you click the green “Next” button or your answers will not be saved.
  • You can close the survey on any page when you are ready to finish on that day.
  • You can use the same link you can open the survey again at a later time.
  • The survey will open on the last page you finished, and you can continue answering questions.