12. Public Transport

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12.1. General.
12.2. Trains.
12.3. Buses.
12.4. Trams.
12.5. Small Public Service Vehicles (SPSVs).
12.6. Air Travel.
12.7. Ferries and Other Marine Transport.
12.8. Posters and Maps.
12.9. Accessible Digital Signage (ADS).

12.1. General.

12.1A. Timetables.
12.1B. Unplanned disruption to services.
12.1C. Accessible Buttons.
12.1D. Pre-booking Assistance.
12.1E. Public Information Systems.
12.1F. Signage, Posters, Maps, and Information Displays.
12.1G. Identification of Vehicle/Carriage.
12.1H. Training in Disability and Equality Awareness.
12.1I. Emergencies.

12.1A. Timetables.

All public transport operators must have accessible timetables equally available to all, and in so far as is practicable, at the same point an time for all.

It should be noted that there is a difference between real-time information and accessible timetables. Where printed fixed timetables exist, these full timetables must also be available in accessible digital formats (online and by app), as well as by phone at all times. In other words, visually impaired people should be able to go online or check an app to find out every remaining service from a particular provider for that particular day, or check out all other services from an individual operator on any given day.

This means that structurally, all timetables must be up-to-date and available to screenreader-users as well as visually impaired people who use different colour settings, e.g., invert colour or High Contrast.

As reasonable accommodation, braille and large print timetables should be available without undue delay, on request.

  • Because not all areas of the country have internet access, and for reasons of general accessibility, each service provider should have an accessible app which can be accessed by mobile devices (such as a smartphone). This means that saved information can be accessed in locations that do not have internet access, and it also means that if there is a diversion or cancellation, that it is more likely that such information can be accessed. Note that particular care should be taken in the production of accessible digital local/urban bus services, and VVI should be contacted for guidance in this regard (info@vvi.ie).

12.1B. Unplanned disruption to services.

12.1B1. Bus.
12.1B2. Rail and Tram.

12.1B1. Bus.

Bus services currently tend to rely on social media accounts, website updates, and apps, to notify passengers of scheduled or unscheduled disruption of services. However, such means of accessing information are not accessible to many visually impaired people.

Apart from the cold or rain, as well as the inconvenience in terms of meeting people at the journey’s end etc., visually impaired people can be preyed on by people with bad intentions if they are seen to be alone in the same spot for prolonged periods of time.

Currently, infrastructure has not been rolled out to urban/suburban or national bus stops to allow announcements to be made regarding planned or unplanned disruptions to services. But this is a matter of universal design that should be remedied. Options for audio notifications to be made at all bus stops in the country should be explored and implemented as a matter of urgency.

12.1B2. Rail and Tram.

Rail and tram services, on the other hand, do have such an announcement infrastructure for platforms. However, our members regularly experience the absence of such announcements, in particular while waiting for trams. Indeed, even where services have been down for a day, due to an incident or planned works, some of us have been left standing at tram platforms, none the wiser.

Where services are disrupted, announcements must be consistent and reliable. This includes regular announcements where services are down for several hours, or even a whole weekend, as in the case of train services, on occasions.

Where a service disruption is unexpected, where possible, company staff (customer service asistants) should be dispatched to stops to offer assistance to those, such as visually impaired people who may not be easily able to independently find an alternative at such short notice, and who therefore, may need assistance finding a taxi or appropriate bus stop etc.

12.1C. Accessible Buttons.

Information on the door-opening buttons and on the help buttons needs to be accessible so that visually impaired people know what such buttons are used for. This is achievable by the use of raised, high contrast (yellow on black at 32 pt. font), print lettering, as well as durable braille in Grade 1 Standard English Braille format. At this size, full words will not be possible, so we recommend the following abbreviations.

  • H = HELP
  • I = INFORMATION
  • O = OPEN
  • C = CLOSE
  • G = Ground Floor
  • B = Basement
  • 1 = first floor
  • 2 = second floor
  • [up arrow] = up
  • [down arrow] = down

Location of buttons must be consistent so that visually impaired people know where to find them.

12.1D. Pre-booking Assistance.

Some visually impaired people may need assistance on some journeys, especially when a journey is new or infrequent to them.

While customer services should be able to direct any caller to a direct line to those in the company providing the assistance, a direct number should be available which is specific such pre-booking (as a specialist assistance unit in the company).

The principle should always be to provide a direct line of contact between the actual person providing the assistance, and the person requesting the assistance, at the soonest possible time. There are several reasons for this, including possible delays for either person, cancellation due to unforeseen events, or problems with mutual real-time location.

12.1E. Public Information Systems.

12.1E1. Volume.
12.1E2. Priority Messaging.

12.1E1. Volume.

All audio public information systems (PISs) should be audible above ambient or environmental noise. In this, it should be noted that open windows on buses or trains can drown out the on-board PIS, so that it is inaudible. Volumes should be set to mitigate against such possibilities.

12.1E2. Priority Messaging.

The only absolutely essential information given by on-board audio announcements relate to stops (next stop (and where relevant, destination stop). Next-stop announcements should occur in a timely manner, giving vulnerable passengers time to organise themselves and find the exit. When the doors open, the or just before they open, the name of the stop should be heard once more (as with the Luas).

If non-stop-related public announcements are to be made on the public information systems, they should absolutely never interfere with stop announcements, because if they do, we are likely to miss our stop; and finding ourselves in a new environment at another stop, etc., can be dangerous.

The problem of the crowding out of stop announcements by other public announcements is particularly noticeable on urban bus services where the distance between stops can be relatively short – especially when traffic is quiet. In such cases, bilingual public announcements, especially when bunched together, can last for more than 40 seconds, and not allow time for the next stop announcement.

12.1F. Signage, Posters, Maps, and Information Displays

12.1F1. Introduction.
12.1F2. Electronic Displays.

12.1F1. Introduction.

The minimum standards, as a baseline, are to be found through the National Standards Authority of Ireland (NSAI), in terms of signage, generally, but (EU) 2019/2021 with regard to electronic signage and displays, in particular.

12.1F2. Electronic Displays.

In brief, we recommend static yellow writing on black background. Luminosity must be strong enough to be easily legible, where relevant, in contexts of high environmental brightness, such as direct sunlight.

Bearing in mind the size of the screen and the amount of information being displayed at any one time, and including adequate spacing between letters and words/numbers, text size should be as large as possible, with high resolution.

Higher-up display boards with timetables etc., should always be complemented by eye-level display boards which are more readily accessible to those of us with partial sight.

12.1G. Identification of Vehicle/Carriage.

12.1G1. Introduction.
12.1G2. Accessible Vehicle/Carriage ID (format).
12.1G3. Accessible Vehicle/Carriage ID (location).
12.1G4. Trains.
12.1G5. Small Public Service Vehicles (SPSVs).
12.1G6. Buses.
12.1G7. Trams.

12.1G1. Introduction.

If a visually impaired person has had a disabling experience in a public transport journey, it is very useful for the record (for both themselves and the service-provider), that such information be accurately logged and fixed.

Our fully sighted comparitor can read the vehicle or carriage identification number, which is placed in a prominent position, for such purposes. However, it is our experience that such identification is not available to many visually impaired people (and blind people in particular).

12.1G2. Accessible ID (Format).

Accessible ID numbers should be at eye-level, and consist of two formats:

  • raised print which is yellow on black, and which has a font of 64 pt.
  • Grade 1 Standard English Braille.

Regarding clarity of braille, we are very impressed with the definition of braille signage on the refurbished Die Dietrich Enterprise train between Belfast and Dublin (as of March, 2022).

12.1G3. Accessible Vehicle/Carriage ID (location).

It should not be a matter of chance that a passenger happens to be close to a vehicle or carriage ID. At a minimum, these accessible numbers should be available on the backs of seats – or in the case of a front seat, on the opposing panel and/or adjacent window pane or sill (depending on the space). Such information should also be adjacent to doors, for the use of standing passengers.

12.1G4. Trains.

On trains, the identification number for each respective carriage should be accessible on the back of every seat, beside every door, and on every toilet door.

12.1G5. Small Public Service Vehicles (SPSVs).

Strips with the same information should be accessible on the left side of the dashboard of small public service vehicles (SPSVs), such as taxis and cabs, as well as on the backs of all seats, where they can be legible by passengers. In the case of SPSVs, the information should contain the vehicle registration number and the SPSV registration number (as applicable) of the license-holder, as well as the name of the license-holder.

12.1G6. Buses.

On buses, ID numbers should be available on the back of every seat. Where a seat has no seat in front of it, the information should be accessible on the adjacent window pane (or sill if there is enough space), and on any nearby panel. Where possible, this information should also be available adjacent to doors.

12.1G7. Trams.

On trams (e.g., the Luas in Ireland), the carriage ID number should be available 1.2m from the floor to the right of every door.

12.1H. Training in Disability and Equality Awareness.

All front-of-house staff, and all management, should have training in disability and equality awareness. Such training gives staff and management a good grounding in the social model (rather than the medical) model of disability, and portrays passengers as equal rights-holders rather than unfortunate people in need of help.

12.1I. Emergencies.

Any or all information on emergency evacuation that is available in visual form on any transport mode, should also be available as an audio explanation in multiple formats. It is important that this is a matter of systems accessibility, and not just reasonable accommodation, given the nature of emergencies and the need for people to be able to access information as quickly as possible.

Emergency information should also be available on as many digital platforms as possible, including on the service provider’s website and app, in a prominent position, and audio on-board audio announcements should alert passengers to this availability.

12.2. Trains.

12.2A. Platform and In-station Announcements.
12.2B. Onboard Announcements.
12.2C. Accessible Buttons.
12.2D. Ad Hoc Assistance.

12.2A. Platform and In-station Announcements.

At main stations, as soon as an intercity train is awaiting passengers, this should be announced in the atrium and the relevant platform, with reminders every two minutes, where time permits.

Conditional on the implementation of 12.2B below, platform announcements should be otherwise confined to giving information on train delays and altered platforms or timetables, as well as appropriate advance notice of an incoming train before its arrival.

12.2B. Onboard Announcements.

Train doors should automatically open at each stop and the onboard announcements heard by people on the platform as well as on the train. This makes the doors easier to find for visually impaired people trying to get on board, as well as providing necessary accessible information. This should also involve speakers on the outside of the train, which would aid in the finding of the train door.

At the departure station, announcements of the final stop and all the enroute stops should be made every minute while a train is waiting to leave. This ensures that people do not get on the wrong train, and also makes the doors of the train easier to independently locate.

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

12.2C. Accessible Buttons.

While VVI recommends automatic opening of all train doors – which assists in the location of entry/exit points for visually impaired people, we realise that door-buttons also need to exist at these points (not least in case of emergencies), as well as on toilet doors.

12.2D. Ad Hoc Assistance.

Particularly in the larger stations, a visually impaired person should be able to access and exit a train (with assistance) without pre-booking. For example, a visually impaired person may be later than expected in arriving at a large railway station, but still require assistance, for example, in having a ramp so that their guide dog can comfortably walk on or off a train without falling through the gap.

12.3. Buses

12.3A. Stopping to Inform Visually Impaired People at a Bus Stop.
12.3B. Prioritisation of Vulnerable Passengers by drivers.
12.3C. On-board announcements.

12.3A. Stopping to Inform Visually Impaired People at a Bus Stop

Where it is clear that a visually impaired person is waiting at a bus-stop, the driver must stop and inform that person of the number of the bus and where it is going. Partly, this is because a visually impaired person may not be able to see an oncoming bus or its number in order to flag it down.

12.3B. Prioritisation of Vulnerable Passengers by drivers.

12.3B1. Boarding.
12.3B2. Alighting.

12.3B1. Boarding.

In some cases, a person’s balance is adversely affected by their visual impairment, and as such, the need to be seated when being transported. Moreover, they need to be seated in a familiar space, so that they know exactly what to do when alighting or otherwise needing to speak to the driver.

As such, pass-holders and others who are visually impaired should be invited by the driver to board a bus before all other passengers. This can be done by a general announcement to those waiting at a stop.

12.3B2. Alighting.

Drivers should try to remember their duty of care to vulnerable passengers, including in the following ways:

  • where public information systems are malfunctioning, to remember to ask a passenger for their destination stop, and to remember to inform them when this stop has been arrived at.
  • to remind other passengers to respect priority seating and seating in the disabled persons area of buses.
  • where a passenger requires a ramp or kneeling mechanism to board, to remember to use these mechanisms when the passenger is alighting. Not all who need such mechanisms are wheelchair-users.
  • always pull in as close to the kerb as possible. Otherwise, passengers are liable to fall and hurt themselves.
  • similarly, when pulling in, make sure that both doors are opening out onto the designated alighting area, and in particular, that no street furniture, such as a pole, is in the near vicinity of either door when the bus is pulled in.
  • It should also be remembered that while the boarding stop may have been higher (e.g., 160mm high), when a passenger boarded, the destination stop may be much lower, and in such cases, bus drivers should try to be mindful that a vulnerable passenger may need to use a kneeling mechanism or ramp at these lower levels where they did not need them at the higher levels. A passenger may alert the driver to such needs, and particular attention should be paid to such notices.
  • It should also be made clear to obviously vulnerable passengers, or those who identify as such (through use of JAM or sunflower cards), that they are entitled to alight at the front door if they prefer.
  • drivers should be keenly aware of ‘bunching’/’clustering’ of buses at stops, which makes it difficult or impossible for visually impaired people to safely find and board the bus they are looking for – and conversely, makes it just as difficult when they are alighting. While this is a planning issue caused with decisions made at a higher level, drivers should do what they can to ameliorate conditions for vulnerable passengers in such situations.

12.3C. On-board announcements

The next stop should be announced prior to each stop, and as the door is opening on arrival at that stop.

Other automatically generated announcements, such as GDPR information, should only happen where there is greatest distance between stops. This is because, during times of least traffic, a visually impaired person is liable to miss a stop because a GDPR announcement (in English and Irish, taking 40 seconds) has prevented the announcement of their destination stop. Such No announcements, including emergency health announcements, should ever interfere with the announcement of stops. Being left at the wrong stop can be highly dangerous for a visually impaired passenger.

If one company has one name for a bus stop, and another company has a different name for the same bus stop, this causes confusion, and can cause visually impaired passengers to miss their stop altogether. To avoid this confusion, the central list of stop-names, as compiled by the National Transport Authority, needs to be adopted by all bus companies.

12.4. Trams.

12.4A. Platform Announcements.
12.4B. On-board Announcements.
12.4C. Automatic Opening Doors.

12.4A. Platform Announcements.

At fork stops (i.e., those stations immediately before the forking or divergence of a tramline), the final destination of each tram approaching the fork should be announced (i.e., as platform announcements).

Delays or suspension of tram services should be frequently announced on platforms.

12.4B. On-board Announcements.

After leaving the stop two stops before a fork stop, an announcement should be made giving the final destination of the tram. Between the actual stop before the fork stop and the fork stop itself, the final destination should be mentioned twice (as currently happens between Abbey Street and Busaras).

12.4C. Automatic Opening Doors.

All trams should have automatically opening doors. This makes it possible for visually impaired people to independently locate the doors, which is otherwise next to impossible, particularly when trying to board (from the outside), but also from within the tram itself, when we are trying to get out.

12.5. Small Public Service Vehicles (SPSVs).

This category includes taxis, hackney cabs, minibuses, and limousines.

12.5A. Audible Taximeters.
12.5B. Tactile Card Terminals.

12.5A. Audible Taximeters.

While a fully sighted passenger can see the taximeter to verify their fare at the end of a journey, and even know how the meter is clocking up during a journey, at present, in Ireland, visually impaired people are not afforded this right.

It should become policy that a condition of an SPSV license is the installation of an audible taximeter on each vehicle (which are compulsory in several parts of the world, including areas of the USA and Canada).

12.5B. Tactile Card Terminals.

Less and less SPSV drivers are accepting cash payment of a fare, and use of debit/credit card to pay is becoming the norm. However, unless there is a tactile keypad on the card terminal, a visually impaired passenger is likely to find it impossible to key in their pin number in order to make the payment.

Note that because of security issues, as well as for reasons of equal rights, it is totally unacceptable that a visually impaired person be asked or expected to ask the driver, or any other third party, to key in their pin on their behalf. No-one else would give their card pin to a stranger, and neither should a visually impaired person.

12.6. Air Travel.

12.6A. General.
12.6B. At the Airport.
12.6C. During the Flight.

12.6A. General.

All frontline members of staff should have awareness and equality training regarding disability (see 12.1H, above)..

12.6B. At the Airport.

Airport buildings are generally large and open-plan, making it difficult or impossible for visually impaired people – and especially blind people – to independently navigate.

Whether outside or inside the airport buildings, airport staff (be it security or otherwise), should be able to observe whether someone is lost, and ask them if they need assistance. In terms of someone with a visual impairment, the degree to which this is observable varies, with one factor being the degree of visual impairment – although this is not the only factor.

Visually impaired passengers should be introduced to eh specialist assistance staff at the earliest possible time (including in assistance with queues and ticketing validation machines, etc.).

Note as very important that being visually impaired does not mean that we either need nor want the use of a wheelchair. People use wheelchairs because they need to use wheelchairs, not as a fashion statement. The safe, dignified, and appropriate way to guide a visually impaired person can be found in Section 4.5 and 4.6 of this document).

As a particular note to assistance personnel guiding visually impaired people: please be wary and careful of the immediate surrdounding of the person you are guiding. One of VVI’s tallest members received a serious head injury because the person guiding him presumed that he would see the top of the cabin door (which was lower than our member). While this would appear to be a matter of poor training, such incidents should never, occur for any reason.

12.6C. During the Flight.

12.6C1. Emergencies.
12.6C2. Accessible Comfort Needs.

12.6C1. Emergencies.

Visually impaired people may not be able to see the in-flight safety presentations. As such, as per 12.1I, above, emergency information must be available in a multiplicity of formats, and on as many digital platforms as possible, including apps.

It is important that flight attendants properly explain the relative location of all possible exit routes to visually impaired passengers. Where visibility is poor, such as where there is a lot of smoke, a visually impaired passenger may be at a relative advantage in advising other passengers.

12.6C2. Accessible Comfort Needs.

In-flight entertainment should have touchscreen controls accessible to visually impaired people. For example, this could involve a flight attendant activating the requisite onscreen button to enable this accessibility function.

All leaflets (including menus etc.) handed out during a flight, should be available in multiple formats (including digital), and visually impaired passengers should be informed of the availability of such alternative formats at the earliest possible stage.

Having said this, where the in-flight menu is limited (as is generally the case regarding in-flight dining), both the passenger and the flight attendant should find it much quicker for the attendant to just inform the passenger of the food and drink on offer.

12.7. Ferries and Other Marine Transport.

12.7A. General (Training).
12.7B. At the Terminus.
12.7C. The Voyage.

12.7A. General (Training).

All frontline staff should have training in awareness and equality regarding disability (see 12.1G, above).

12.7B. At the Terminus.

The quay or harbour area is invariably expansive and open plan, so that safe independent navigability by a visually impaired person is either extremely difficult or impossible, due to lack of universal design in the design of such areas. This is the case even where a terminus building has been built.

As such, visually impaired people, especially when travelling alone, need assistance in navigating such areas.

Whether in conjunction or not with the role of the harbour quartermaster, policies at ground level and on a higher level, need to be put in place to make sure that an eye is kept out for anyone who may seem lost – since this could beas a result of visual impairment not being compatible with non-universal design.

When it has been identified by any employee in the terminus area that a visually impaired person is present (whether they intendgetting a ferry or not), safe guidance should be available to that visually impaired person at all times (see Sections 4.5 and 4.6 of this document).

12.7C. The Voyage.

12.7C1. Emergencies.
12.7C2. Orientation on a Boat.
12.7C3. Keeping an Eye Out.

12.7C1. Emergencies.

All emergency information provided visually should be equally available in multiple other formats which are accessible to visually impaired people, and this information should be in multiple formats,including on a service-provider app.

12.7C2. Orientation on the Boat.

First and foremost, such accessible information should include a text-described and audio-described map of the boat. All distance dimensions should be given in such a description, so that we can tell relative distances. Terminology such as fore and aft or starboard prow/bow, or port and starboard, should either be initially clearly explained, or just be totally replaced by front, back, and left/right side in such descriptions.

Like any other passenger, a visually impaired passenger or employee may delight in exploring the boat by themselves, and we have equal right to such uninterfered-with pursuits, unless a member of the crew is aware of an imminent danger.

12.7C3. Keeping an Eye Out.

Unlike other passengers, a visually impaired passenger may be alone without wanting to be alone. For example, they may be lost, or may not know where there is seating; where there is food/drink service, etc. Part of the training of crew-members should be to ask if solitary people with obvious visual impairments would like assistance at any time during the voyage.

Crew should be trained to keep an eye out for vulnerable passengers, including visually impaired passengers, so that, for example, if the passenger is sea-sick, that they have an appropriate place to go.

12.8. Posters and Maps.

The following are some pointers to follow:

  • colourblind people cannot distinguish between red and green, and when they are side by side, many see the combination as black – making, for example, a black line symbolising a transit route, invisible where adjacent to green and red combinations.
  • stops and stations on maps should have large lettering, and be in high contrast to the background colour(s).
  • large thick black letters are not a good idea, since they can be relatively ill-defined.
  • italicised print should be ruled out
  • as with Tube maps, smaller circles for minor stations is a good idea.
  • high contrast means dark and bright, as much as it means different colours. For example, blue writing on a white background, or white writing on a grey background, is not high contrast, and can be impossible to see for partially sighted passengers.
  • the optimal high contrast is yellow or bright orange on a black or navy background.
  • London Underground (Tube) maps are a good model to follow.
  • where sea-coasts or rivers appear on maps, there should be a rich blue, or grey, if blue is already featuring in the main map.
  • consider what information is prioritised, or even necessary. For example, is north-south arrow indicator actually useful?
  • regarding paper timetables, there Need to be braille and large print versions (portable) With times written on other side of the map, and available at as many stations as possible. These should be free, and fold-up. Once again, the model is the Tube underground, London.
  • Where relevant, features such as buildings should be easily recognisable.
  • all posters, maps, etc., should be tested with regard to varying light conditions. For example, bright sunlight may actually make something more difficult to see. Once again, London Tube is best practice, in our experience, in this regard.

12.9. Accessible Digital Signage (ADS).

12.9A. Introduction.
12.9B. Example of Possible ADS on Trains.
12.9C. Potential ADS Use in Taxis.
12.9D. ADS on Buses.

12.9A. Introduction.

Without prejudice to any other measure indicated in this or other VVI
policy documents, statutory bodies should explore the use of
accessible digital signage with regard to all public service vehicles
and public transport hubs, closely consulting and actively involving
DPOs, including their prioritisation and distinction, in such
consultations.

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

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

12.9B. Example of Possible ADS on Trains.

Onboard tags could provide information on:

  • carriage numbers
  • seat-numbers and location of priority seating
  • information on stops
  • emergency information
  • the location of toilets
  • the location and use of buttons

In-station:

  • location of platforms and toilets
  • realtime updates on timetabling

12.9C. Potential ADS Use in Taxis.

  • An ADS tag on front and side windows of a taxi can let an ADS-user know that a free taxi is approaching or just waiting for a passenger in a stationary position.
  • use of ADS tags on the inside of the vehicle can be another format of information regarding the PSV license number and holder.

12.9D. ADS on Buses.

Use of ADS tags on buses allows for the presentation of information to ADS-users in the following ways:

  • the location of bus-stops
  • realtime information as to the next buses.
  • an alternative on-board format letting a passenger know what is the next stop etc.
  • outward facing tags at the front and front door of the bus allowing an ADS-user to know what the number of a bus is.

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