Sg Blind Citizens Australia
Ph 1800 033 660 | E bca@bca.org.au | W bca.org.au | ABN 90 006 985
226
Response to Aviation Disability Standards Consultation Paper
Date: Friday 2 October 2026
Submitted via: AviationAccessibility@infrastructure.gov.au
Submitted by: Melanie Chafield, National Policy Officer
Contact: melanie.chatfield@bca.org.au
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Table of Contents
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Response to Aviation Disability Standards Consultation Paper
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5. Additional issue: orientation and wayfinding within the aircraft
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About Blind Citizens Australia
Blind Citizens Australia (BCA) is the national disability-led organisation representing
people who are blind or vision impaired. BCA advocates for the rights, independence
and full participation of people who are blind or vision impaired and brings lived
experience to national policy and systemic advocacy.
General comments
BCA welcomes the development of Aviation Disability Standards and supports the
objective of more consistent and enforceable accessibility across air travel. This
submission identifies where the proposed measures should be strengthened and
where additional requirements are needed to address barriers experienced by
people who are blind or vision impaired.
For people who are blind or vision impaired, accessibility depends on more than
assistance being theoretically available. Passengers need accessible information
and confidence that agreed assistance will be provided when and where it is needed.
When arrangements are unreliable, passengers may have to repeatedly explain their
requirements, correct assumptions about blindness and vision impairment, locate or
follow up assistance, and resolve problems as they arise. This places an
unnecessary burden on passengers, including experienced and independent
travellers.
A central principle of the Standards should be that independent travel does not mean
having no accessibility requirements. A person who is blind or vision impaired may
travel independently while requiring accessible information, guided or orientation
assistance at particular stages of the journey, particularly in unfamiliar environments
or when arrangements change.
BCA supports clear and enforceable minimum accessibility requirements that apply
across airlines, airports, contractors and stages of travel. Guidance can support
technical detail and implementation but should not substitute for essential
requirements. Where genuine technical, infrastructure or scale constraints exist,
proportionality should generally affect how or when an accessibility outcome is
achieved, rather than whether it is required.
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The Standards should provide greater certainty about what passengers can expect
and what airlines, airports and other providers must do. Accessibility should be
assessed by whether a passenger can use the service in practice, not simply
whether an accessibility feature is present or a technical requirement has been met.
This requires end-to-end usability, clear responsibility and continuity of assistance
and information across the journey, supported by accessible real-time escalation
when arrangements fail, appropriate review and redress, and reporting and oversight
capable of identifying systemic problems.
The experiences and examples in this submission reflect barriers reported by and
known to BCA through its work with people who are blind or vision impaired. Where
BCA identifies a required accessibility outcome without proposing detailed technical
specifications, implementation should be informed by people directly affected and
relevant technical, safety and accessibility expertise.
Response to consultation paper
- Whole of journey 1.1 Roles and responsibilities of airports and airlines Shared responsibility
BCA supports the proposed regulated shared responsibility model.
Accessibility assistance can fail when responsibility passes between airlines, airports
and contractors and it is unclear who is responsible for ensuring the passenger
reaches the next stage of their journey. This can be particularly significant for a
person who is blind or vision impaired navigating an unfamiliar airport or responding
to a disruption. For some passengers who are blind or vision impaired, guided
assistance at transition points such as kerbside to check-in, check-in to the boarding
gate, connections and arrival is what makes independent air travel practicable.
The Standards should require:
clear allocation of responsibility at each relevant stage of the journey;
mandatory coordination between airlines, airports and contractors;
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active handovers when responsibility transfers, with the transferring provider
remaining responsible until the passenger reaches the agreed destination for
that stage or the receiving provider assumes responsibility; and
an accessible real-time escalation mechanism where agreed assistance is not
provided or another accessibility barrier threatens the passenger’s ability to
complete their journey.
Airlines and airports should identify a designated accessibility contact who can be
reached during travel and has sufficient authority to coordinate and resolve
immediate assistance or accessibility failures.
Where a passenger has requested or is receiving disability-related assistance, the
Standards should also set a clear maximum period for leaving the passenger without
the agreed assistance or an effective means of obtaining help. As a baseline, a
passenger should not be left unattended for more than 30 minutes without their
explicit agreement. For a person who is blind or vision impaired, being left in an
unfamiliar location without accessible information or a reliable way to locate staff can
leave them effectively stranded even if they are physically able to move
Guided and orientation assistance The Standards should expressly recognise guided and orientation assistance as
forms of passenger assistance. Assistance should not default to wheelchair
assistance where this is neither requested nor appropriate. For people who are blind
or vision impaired, effective assistance may instead involve describing an unfamiliar
environment, identifying a changed route or explaining where a queue, gate, seat or
facility is located.
Where requested, reasonable assistance should also be available to identify and
retrieve checked baggage. Accessible information should identify the correct
baggage carousel and any subsequent changes.
Staff should communicate directly with the passenger when passports, boarding
passes or personal effects are taken and returned. A passenger who cannot visually
monitor what is happening needs to know what has been taken, why and when it has
been returned.
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1.2 Staff training BCA supports mandatory aviation-specific competency requirements for relevant
staff and contractors. Training should extend beyond general disability awareness,
mobility aids and physical transfers to include:
communicating appropriately with people who are blind or vision impaired;
providing guided assistance and useful orientation information;
appropriate interaction with white canes and dog guides;
communicating changes to routes, queues, gates and facilities; and
obtaining consent before providing physical assistance.
Staff providing practical assistance should receive role-specific practical instruction
and demonstrate relevant competency, rather than simply completing disability
awareness training. Training content should be developed with people with disability
and relevant disability representative organisations, including disability-specific
expertise where particular roles create predictable accessibility risks.
1.3 Disability engagement BCA supports a regulatory requirement for meaningful and timely engagement with
people with disability and disability representative organisations. The Standards do
not need to prescribe a particular reference-group model for every organisation,
provided engagement is proportionate, occurs early enough to influence decisions
and includes people with relevant lived experience and expertise.
Engagement should seek targeted disability-specific expertise where a general or
standing reference group does not adequately represent the people likely to be
affected. For example, where a proposal has particular implications for people who
are blind or vision impaired, relevant lived experience and blindness-specific
expertise should be included.
Engagement should apply particularly to the development or significant alteration of
passenger-facing systems, facilities, accessibility policies and processes that
materially affect accessibility.
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Smaller operators could use shared or proportionate engagement arrangements.
Passenger volume may appropriately affect how engagement is undertaken, but
should not provide an exemption from meaningful engagement.
1.4 Reporting BCA supports mandatory, standardised reporting on accessibility outcomes.
Reporting should measure whether accessibility arrangements work in practice and
identify the type of accessibility failure, rather than relying only on aggregate
disability complaints or activity measures such as the number of staff trained.
Common definitions, performance indicators and reporting methods should make
results comparable across providers and over time.
Relevant measures should include failures to provide agreed assistance,
inaccessible or delayed operational information, handover failures, security
screening accessibility failures, disability-aid incidents and accessibility complaints.
Data should, where practicable, be sufficiently disaggregated to identify recurring
barriers affecting particular disability groups, including the distinct information,
communication, orientation and wayfinding barriers experienced by people who are
blind or vision impaired.
Reporting requirements can be proportionate to operator size, but smaller operators
should not be exempt from identifying and reporting accessibility failures.
Government should collect, analyse and publish comparable sector-wide information
so systemic problems and implementation progress can be assessed. Reporting
should be supported by independent monitoring and effective enforcement;
compliance should not depend primarily on individual passengers pursuing
discrimination complaints after a failure has occurred.
- Planning and booking 2.1 Passenger assistance profiles BCA supports requiring airlines to offer voluntary passenger assistance profiles
based on functional access requirements rather than diagnosis. Profiles should allow
passengers to record relevant communication, guided or orientation assistance, dog
guide, disability-aid, seating and transfer requirements.
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Passengers should control their information, including the ability to access, correct
and delete it. Relevant information must reliably reach the staff and systems
responsible for delivering agreed assistance, with journey-specific requirements
confirmed where necessary.
Profiles must not become a prerequisite for assistance or require unnecessary
disability or medical information. Information sharing should be limited to what is
necessary and subject to appropriate privacy and consent safeguards.
2.2 Limits on passengers requiring assistance BCA supports regulation preventing arbitrary limits on passengers with disability or
passengers requiring assistance. Any restriction should relate to the assistance
actually required and be necessary and proportionate to a specific safety
requirement or unavoidable aircraft-specific operational constraint. Any applicable
limits, their basis and available alternatives should be published in accessible
formats for passengers to understand prior to booking.
A passenger who requires only guided or orientation assistance or accessible
information, for example, should not be counted towards a limit intended for
passengers requiring physical assistance to board, disembark or respond in an
emergency.
2.3 Advance notice BCA supports the proposed guarantee that accessibility services requested with at
least 48 hours’ notice will be provided, together with a requirement to make every
reasonable effort where less notice is provided.
The Standards should clarify which services genuinely require advance preparation.
Routine guided or orientation assistance, accessible communication and access to
boarding and disruption information should not be subject to a general 48-hour
requirement. A passenger who books on the day of travel should not, for example, be
unable to obtain guided assistance through an unfamiliar terminal solely because 48
hours’ notice was not possible. Routine accessibility should form part of ordinary
service capability.
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2.4 Equivalent fares BCA supports regulation ensuring people with disability have access to equivalent
fares and booking conditions across airline-controlled booking channels. Mainstream
online booking should itself be accessible and assisted booking should be available
as an alternative rather than a substitute for accessible mainstream systems.
Where an accessibility barrier requires a passenger to change booking channels, the
passenger should not incur additional fees or otherwise be financially disadvantaged.
This is particularly important where fares change dynamically. A passenger who
cannot complete an inaccessible online transaction and must contact the airline
should not lose the fare available when they attempted the transaction because
obtaining accessible assistance took additional time.
2.5 Assistance animals BCA supports nationally consistent and enforceable requirements for the approval
and carriage of assistance animals, provided they do not narrow existing protections
under the Disability Discrimination Act 1992. Aviation requirements should also align,
where appropriate, with the Australian Government’s broader work towards nationally
consistent regulation of assistance animals, to avoid creating a separate or
conflicting recognition and evidence regime for air travel.
Application and evidence requirements should be proportionate and avoid
unnecessary or repeated assessment. Where relevant circumstances have not
changed, passengers should not have to repeatedly establish the same information
for each journey.
BCA supports the deemed‑refusal rule, as it provides certainty and enables timely
complaint pathways. Where carriage is refused, passengers should receive the
specific reason and have access to a prompt review process, wherever practicable
before travel.
BCA supports requirements for safe in-cabin carriage with the handler. BCA defers to
dog guide handlers and organisations with specialist expertise, including Guide Dogs
and Dog Guide Handlers Australia, on detailed requirements concerning dog guide
accreditation, evidence, carriage, positioning, space, safety and animal welfare.
Protection of assistance animals
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The introduction of pets in aircraft cabins creates an additional consideration for the
safety of dog guides and other assistance animals. Where a handler and dog guide
have complied with applicable requirements, they should not bear additional risk
because an airline permits other animals to travel in the cabin. Airlines and airports
should have appropriate arrangements to prevent and manage interactions between
pets and assistance animals, including during boarding, security screening, use of
animal relief areas and other points where animals may come into proximity.
The regulatory framework should also clarify responsibility and appropriate remedies
where an assistance animal is injured or otherwise adversely affected because of
another animal or a failure to implement appropriate safety arrangements. This is
particularly important because injury to a working dog may affect the handler’s
mobility and independence beyond the immediate journey.
2.6 Dangerous-goods approval for disability aids BCA supports a nationally consistent process that provides clear, accessible
information about approval requirements, evidence requirements and reasons where
approval is refused. Information and decisions should be provided in a format usable
by a person who is blind or vision impaired, and decisions should be made within a
clear timeframe once complete information has been provided.
2.7 Carriage of disability aids BCA supports free carriage of disability aids and allowing aids required during the
journey to remain with the passenger wherever safe and practicable. Separation
from an essential disability aid can reduce a passenger’s ability to travel
independently.
The Standards should use a functional definition rather than an exhaustive product
list. For people who are blind or vision impaired, relevant aids include canes (e.g.
white cane, long cane, mobility cane, identification cane or support cane) and
assistive technology used for mobility, orientation, communication and access to
information.
Where an aid cannot remain with the passenger, requirements should cover safe
handling, prompt return and accessible pre-travel information about applicable
restrictions.
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2.8 Carers and companions BCA supports nationally consistent requirements limiting when an airline can require
a passenger to travel with a carer or companion. The onus should be on the airline to
demonstrate that a carer or companion is necessary because of a specific and
substantiated safety requirement that cannot reasonably be addressed through other
assistance or adjustments. The requirement should be based on the individual
passenger’s circumstances and the particular journey, not assumptions based on
disability.
Requiring guided or orientation assistance, accessible information or an accessible
safety briefing should not, by itself, be treated as evidence that a person who is blind
or vision impaired cannot travel independently.
Where an airline requires a carer or companion as a condition of carriage, the
passenger should not bear the additional airfare arising solely from that requirement.
2.9 Medical certificates BCA supports clear regulatory limits on medical-certificate requirements. Medical
evidence should only be required to address a specific medical or aviation-safety
issue. Evidence should not be repeatedly required where relevant circumstances
have not changed. If an airline requires additional medical assessment beyond the
evidence already required, it should generally meet the reasonable cost.
2.10 Accessibility information before booking BCA supports aviation-specific requirements for clear, accessible and current
information about accessibility arrangements before a passenger commits to a
booking. Information should explain what assistance and accessibility features are
available, any relevant limitations, how assistance can be requested and who is
responsible for providing it. For example, knowing whether an unfamiliar airport
provides guided assistance, how that assistance is requested and where it begins
may affect whether a person who is blind or vision impaired can confidently book a
particular itinerary or connection.
In this context, “accessible information” means information a person who is blind or
vision impaired can independently find, access, read or otherwise perceive,
understand and use, including through assistive technology.
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2.11 Accessible booking BCA supports regulation requiring mainstream airline websites and booking systems
to comply with applicable contemporary digital accessibility requirements, including
applicable WCAG Level AA requirements for web-based services.
Accessibility should apply to the complete booking transaction, including searching
for flights, fare selection, seat selection, accessibility requests, baggage, identity
verification, payment, error messages, and booking confirmation.
A separate accessible website should not substitute for an accessible mainstream
booking service. Any alternative interface should provide equivalent access to fares,
flight choices and functionality.
Technical conformance should be supported by testing with people who are blind or
vision impaired using commonly used assistive technologies, including screen
readers and screen magnification.
Where passengers are required to review, confirm or acknowledge information, they
should have an accessible means of independently understanding that information
before agreeing to it. For example, a passenger should not be required to select “I
agree” to conditions relating to a dog guide, disability aid or assistance arrangement
if the information they are being asked to acknowledge cannot be independently
accessed using a screen reader or other assistive technology.
2.12 Accessible disruption information BCA supports regulation requiring essential disruption information to be provided at
substantially the same time as other passengers and in a form accessible to the
passenger. This could be achieved through complementary channels such as
audible announcements, accessible app or SMS notifications and direct
communication where required.
For people who are blind or vision impaired, information should not be provided only
through visual displays. Where disruption changes a gate, terminal, connection or
other part of the journey, previously arranged assistance should be updated and
practical assistance provided where required so the passenger can reach the revised
location or arrangement. Accessible information alone is not sufficient if the
passenger cannot independently navigate the change.
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“My gate changed but the change appeared only on the screen. There was no
audible announcement. I realised something was happening because people around
me started moving and I followed the crowd.” — BCA member
2.13 Refusal of carriage BCA supports clear regulatory limits on refusal of carriage. Any refusal should be a
last resort based on a specific and objectively justifiable reason, after reasonable
alternatives have been considered. Passengers should receive reasons in an
accessible and useable format and have access to immediate review or escalation.
Where the airline is responsible for the refusal, it should provide an appropriate
alternative or refund.
2.14 Seating BCA supports regulation enabling passengers to access seating required because of
disability, subject to legitimate safety constraints. Seat-selection systems should be
accessible to people who are blind or vision impaired (e.g. not rely on a visual seat
map that a screen reader cannot interpret or navigate) and passengers should not
incur an additional fee solely to obtain a necessary disability-related seating
arrangement, including where a particular seat is required to safely accommodate a
dog guide.
- Airport accessibility 3.1 Retaining mobility aids BCA supports the principle that passengers should retain access to their personal
mobility aids for as long as safely possible. Where an airport process temporarily
reduces a passenger’s independent mobility, assistance should be available when
needed rather than relying solely on periodic staff checks.
3.2 Accessible check-in BCA supports an explicit aviation-specific requirement for accessible self-service
check-in and associated facilities. Accessibility requirements for self-service kiosks
and other non-web ICT should address both digital and physical accessibility and
should not rely on WCAG alone. Relevant recognised accessibility standards should
be applied where appropriate.
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Accessibility should be assessed against whether a person who is blind or vision
impaired can complete the end-to-end process, including locating the facility,
identifying and activating its accessibility functions, operating the interface,
completing the transaction, and identifying and using boarding passes, baggage tags
or other outputs.
Check-in kiosks and other self-service interfaces should provide sufficient visual
contrast, appropriately sized or adjustable text and displays that remain usable under
airport lighting conditions, including where glare affects screen visibility.
Passenger queuing and call-forward systems should provide equivalent non-visual
access to information about where to wait, when to proceed and where to go next.
Staff assistance should remain available but should not substitute for accessible
mainstream self-service systems.
3.3 Assistance points BCA supports regulation requiring all regular passenger airports to provide an
accessible and reliable means of requesting assistance. Assistance points must be
available at all airports regardless of passenger volume. Airport size may
appropriately affect how the capability is provided, but not whether passengers have
access to it.
Assistance points or equivalent mechanisms must be independently locatable and
operable without vision. The route to the assistance point and the means of
identifying and activating it are part of its accessibility.
3.4 Wayfinding BCA supports Option 1: nationally consistent accessible wayfinding requirements,
supplemented by the user testing proposed under Option 2. User testing should
inform the design and implementation of accessible wayfinding but should not
substitute for minimum accessibility requirements.
The Standards should require continuous, understandable and independently usable
accessible wayfinding across the passenger journey, including between: ground
transport and terminal entrances; check-in; security; assistance points; gates;
essential facilities; connections; baggage collection; and exits.
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Wayfinding should accommodate the different needs of people who are blind or
vision impaired through appropriate combinations of tactile, audible, visual and other
accessible information. For people with low vision, this should include appropriate
lighting, visual contrast and glare management for signage, paths of travel, changes
in level, entrances, assistance points and other important wayfinding features.
Detailed technical requirements can be established through applicable accessibility
standards and supporting guidance.
Digital navigation tools may supplement but should not be the only accessible means
of navigating an airport. Where QR codes are used to provide passenger
information, they should be designed and positioned so that people who are blind or
vision impaired can identify and use them. Core accessibility features could include
consistent and predictable placement, a tactile marker or raised border identifying
the code, sufficient size and contrast for people with low vision, and accessible
content once the code is scanned.
Accessible wayfinding requirements should also apply during temporary works and
changes to terminal layouts. Where an accessible route is altered or unavailable, an
accessible alternative route and information about the change should be provided.
3.5 Continuity of information and assistance during disruption As outlined at section 2.12, BCA supports accessible disruption information and
continuity of existing assistance arrangements. At airports, this should include guided
or orientation assistance where a change requires a passenger who is blind or vision
impaired to relocate.
3.6 Arrivals, departures and ground transport BCA supports the proposed requirements but recommends extending the focus
beyond accessible parking and loading zones to the connection between ground
transport and the terminal. Accessible wayfinding and assistance should cover taxis,
rideshare, public transport and private pick-up and drop-off points. Passengers
should have an accessible means of notifying the responsible provider that they
have arrived and, where required, obtaining assistance from a clearly designated
point outside the terminal.
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Where connecting infrastructure is outside airport control, BCA acknowledges
airports are not responsible for that infrastructure but they should reasonably
coordinate with the relevant provider to avoid an accessibility gap.
3.7 Security BCA strongly supports enforceable accessibility requirements for security screening.
Security screening can temporarily remove access to mobility aids, personal
belongings or environmental information that a person who is blind or vision impaired
uses to maintain orientation.
BCA members report significant variation in the quality of security screening,
including between individual screening staff. The accessibility of screening should
not depend on whether a passenger happens to encounter a staff member who
understands how to assist a person who is blind or vision impaired.
Accessibility procedures should therefore be nationally consistent and supported by
mandatory practical training, competency assessment and periodic refresher training
for screening staff. Training should include communication with people who are blind
or vision impaired, screening of white canes and dog guides, and providing
accessible positioning and directional instructions.
Instructions must be sufficiently specific for a passenger to act on them without
relying on sight. Directions such as “over there” or pointing towards a screening
position are not accessible. Staff should explain where the passenger needs to
move, what is about to happen and what is required of them.
Screening areas should provide:
tactile, audio or other accessible positioning guidance where required;
sufficient lighting and visual contrast to assist people with low vision to identify
queues, barriers, screening equipment and paths of travel while avoiding
unnecessary glare;
direct communication with the passenger and clear, accessible instructions;
consent before physical assistance except where immediately necessary for
safety or security; and
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appropriate information or assistance where passengers are temporarily
separated from personal belongings.
The Standards should require that a passenger’s preferred screening method be
respected wherever compatible with security requirements. A physical search or
pat‑down should not be imposed where the passenger can complete standard
screening with appropriate guidance or non‑visual cues.
Where a passenger is travelling with a dog guide, screening procedures should
enable the handler and dog to remain together throughout the screening process.
Screening staff should understand the function of the dog’s harness, leash and other
working equipment and should not require equipment to be removed unnecessarily.
Any need to handle, inspect or remove working equipment should be clearly
explained to the handler beforehand and undertaken in a way that maintains the
handler’s control of the dog and minimises disruption to the working partnership.
Screening staff should receive specific practical training in screening dog guides and
their equipment, including appropriate terminology and communication with the
handler.
Where a white cane must be screened separately, even a short period without it can
temporarily remove the person’s primary means of independent orientation and
mobility. Staff should explain what is occurring, return the cane promptly and provide
orientation or guided assistance where required.
Passengers should also have access to clear, accessible information explaining what
to expect during security screening, including procedures for white canes, dog
guides and other disability aids; circumstances in which alternative screening may be
used; what assistance can be requested; and how to seek immediate supervisory
assistance if a problem arises. Passengers should not have to know or explain
security procedures to screening staff, but accessible information about the process
can enable them to understand their rights and responsibilities and identify when
appropriate procedures are not being followed.
Priority processing can be useful but should not substitute for accessible mainstream
security screening.
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“Staff kept telling me to go ‘over there’ and then ‘not there, over there’. As a blind
passenger, I could not tell where they were pointing. I was then told I was failing to
follow instructions. An airline assistance staff member had to explain that I was trying
to comply but could not understand where the security staff wanted me to go.” —
BCA member
3.8 Accessible airport facilities BCA supports requiring people with disability to be involved early in the design of
new accessible facilities and significant changes. Essential facilities should be
incorporated into accessible routes and wayfinding.
Airport facilities should also incorporate appropriate lighting, visual contrast and glare
management to assist people with low vision to identify entrances, doors, counters,
seating, stairs, lifts, toilets, assistance points and other important facilities. New
facilities and significant refurbishments should incorporate these considerations from
the design stage and include user testing with people who are blind or vision
impaired.
Dog-guide relief facilities
BCA particularly supports appropriately located dog-guide relief facilities, with their
design informed by dog-guide handlers and relevant specialist organisations. For
major airport terminals, appropriate provision should include consideration of a relief
facility within the secure terminal area so that a handler is not unnecessarily required
to leave the terminal, navigate roads or car parks, and repeat security screening
simply to meet the dog’s needs.
Dog‑guide relief facilities must be located on an accessible route, independently
findable without sight, and designed with direct input from dog‑guide handlers. The
existence of a facility is not sufficient if a handler cannot independently locate and
reach it. Relief facilities should be incorporated into accessible wayfinding, their
location should be available through accessible pre-travel information, and staff
should know their location and be able to provide guided assistance where required.
“The dog toileting area was outside the terminal and required crossing roads and
travelling through part of a car park. I could not locate it independently and had to
find a staff member who knew where it was.” — BCA member
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Electronic and automated airport processes
BCA considers that the Standards should address the accessibility of automated
passenger-processing systems including electronic passport control. Systems that
rely on visual instructions, touchscreens or visual prompts can prevent people who
are blind from using them independently. Automated systems should provide
accessible non-visual interfaces wherever practicable. Where independent use is not
possible, timely staff assistance and an accessible alternative process should be
available without unreasonable delay.
Passenger-facing payment systems used by airlines and airports should be
independently accessible to people who are blind or vision impaired, including the
ability to identify and verify the amount being charged and complete the transaction
using accessible or non-visual methods.
3.9 Disability aids BCA supports an enforceable obligation to take reasonable measures to prevent loss
or damage to disability aids while in airline custody, including where handling is
outsourced. Loss or damage to a disability aid can have consequences beyond the
loss of ordinary baggage because the aid may be essential to the passenger’s
mobility, communication or independence.
Passengers should be able to provide handling instructions. Aids should be returned
promptly where they are needed, and tracking information should be accessible
without requiring use of a particular smartphone application.
The Aviation Disability Standards should focus on prevention, handling and
accountability. Remedies for loss or damage should be addressed through the
broader aviation consumer protection framework.
3.10 Physical transfers BCA supports enforceable requirements for consultation, consent, safety, dignity and
staff competency during physical transfers. BCA defers to people who require
physical transfers and relevant technical experts on transfer equipment, technical
specifications and methods.
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- Aircraft accessibility 4.1 Boarding and disembarkation BCA supports accessible boarding and disembarkation and reasonable passenger
choice about when to board and leave the aircraft.
Passengers who are blind or vision impaired should not be required to pre-board or
disembark last simply because of their disability or because they have requested
assistance. They may be able to board and disembark safely with other passengers,
including with guided or orientation assistance where required. Any restriction on a
passenger’s preferred boarding or disembarkation arrangements should be based on
a specific safety, equipment or assistance requirement and should go no further than
necessary to address that requirement.
Guided or orientation assistance should be available between the gate and aircraft,
including where buses or remote stands are used. Cabin orientation is addressed
further at section 5.
4.2 Cabin storage of disability aids BCA supports priority cabin storage for essential disability aids where safe and
practicable. People who are blind or vision impaired may need access to disability
aids during the flight rather than only at the beginning and end of the journey.
White canes and assistive technology required for mobility, orientation,
communication or information access should remain readily accessible to the
passenger. Disability aids should not count towards ordinary baggage allowances.
Storage arrangements should consider both safe storage and reasonable access to
the aid.
4.3 Use of disability aids onboard BCA supports an enforceable presumption that disability aids may be used during
flight wherever safe and practicable. Any restriction should be based on a specific
safety or aircraft requirement and clearly explained. Previously approved aids should
not require repeated assessment where relevant circumstances have not changed.
4.4 Return of mobility aids BCA supports an enforceable requirement for mobility aids carried in the hold to be
prioritised and returned as soon as reasonably possible. Passengers who depend on
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mobility aids may be unable to move independently through the arrival airport while
waiting for an aid to be returned.
4.5 Critical in-flight information BCA strongly supports regulation requiring people who are blind or vision impaired to
receive the same essential information at the time it is needed and in a form they can
perceive and use. Accessible safety information should be available in appropriate
formats, including Braille on request. Where Braille safety information is required or
offered, it must be reliably available in practice, including on smaller aircraft and
services. Accessible written information does not replace the need for an individual
orientation or safety briefing where requested, including relevant information about
exits, safety equipment, cabin-call controls, toilets and aircraft or seat specific
arrangements.
Essential safety information should not depend on a passenger owning a
smartphone, using Wi-Fi or relying on another passenger.
4.6 Food and drink BCA supports accessible information about available food, drink, ingredients and
allergens, together with practical cabin-crew assistance where requested. For
example, cabin crew can describe the location of items on a meal tray using a clock
face orientation where this is the passenger’s preferred method.
Where an airline has agreed to use dietary or allergy information recorded in a
passenger profile or booking, that information should reliably transfer through
relevant booking changes to catering systems and cabin crew. This can be
particularly important for people who are blind or vision impaired who may not be
able to visually identify or verify food, packaging or labels. Where a recorded
requirement cannot be accommodated, the passenger should be informed
sufficiently early to make alternative arrangements.
4.7 Aircraft toilets BCA supports the proposed two-stage regulatory approach. For people who are blind
or vision impaired, Stage 1 should require toilets to be independently identifiable and
usable non-visually. This should include an accessible means of determining whether
the toilet is occupied, and fixtures, locking mechanisms and controls that are
locatable, distinguishable and operable non-visually, including clearly identifiable
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emergency-call controls. Appropriate contrast and lighting should also support
people with usable vision.
New aircraft and refurbishments should avoid replacing tactilely identifiable controls
with interfaces that cannot be operated non-visually. Flat touch panels and visually
labelled controls can create new barriers even where the physical toilet otherwise
meets accessibility requirements.
BCA supports earlier implementation of readily achievable Stage 1 features.
4.8 In-flight entertainment BCA supports regulation requiring in-flight digital entertainment, where offered, to be
accessible. Accessibility requirements should apply both to content and to the
interface used to find, select and control it, using applicable contemporary digital and
ICT accessibility standards.
People who are blind or vision impaired should be able to independently identify
audio-described content, browse and select programs and operate essential
controls.
Where legacy systems cannot provide this access, an accessible portable device or
equivalent alternative may provide an interim solution. An alternative accessible
entertainment service should not be limited to a token or materially inferior selection
where a substantially broader service is available to other passengers.
New and substantially upgraded entertainment systems should be accessible by
design and include user testing by people who are blind or vision impaired.
4.9 Passenger controls BCA supports prospective regulation requiring passenger controls to be
independently identifiable and operable by people with disability. This is particularly
important for essential controls such as the cabin-call button. Where cabin‑call
buttons, seat‑position controls or other passenger‑operated features are provided
through touch‑screens, equivalent physical controls must also be available and
accessible by people who are blind or vision impaired.
4.10 Movable armrests BCA supports increasing the availability of movable armrests. BCA’s principal
concern is that accessible seat-selection systems clearly identify seats with movable
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armrests and other relevant accessibility features in a form that can be
independently accessed using screen readers or magnification. Where an aircraft or
seat allocation changes, the airline should identify whether a selected accessibility
feature has been affected and, where possible, provide an appropriate alternative.
- Additional issue: orientation and wayfinding within the aircraft The consultation paper does not appear to establish a coherent requirement for
orientation and independent wayfinding within the aircraft cabin.
BCA recommends that the Standards require passengers who are blind or vision
impaired to have access to sufficient information and assistance to orient themselves
and navigate essential areas of the aircraft as independently as reasonably
practicable. This should include:
individual cabin orientation on request, including the passenger’s seat
location, the direction and approximate location of the nearest usable toilet,
relevant exits, safety equipment, cabin-call controls and other essential
facilities;
guided assistance to essential facilities where requested;
tactile, Braille or otherwise non-visually identifiable information for stable
features where technically practicable, particularly toilet identification,
essential controls and seat identification;
clear, large, high-contrast seat numbers that are easy to locate and read,
together with a non-visual means of identifying seat numbers so that people
who are blind or vision impaired can identify their allocated seat as
independently as possible; and
accessibility considered from the outset when designing or purchasing new
aircraft interiors and when undertaking major cabin refurbishments.
Accessible digital cabin information and remote visual-assistance tools may provide
useful supplementary options. Access to essential cabin orientation and navigation
should not, however, depend on a passenger owning compatible technology, having
internet connectivity or using a third-party service.
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Recommendations
BCA’s recommendations are intended to support a continuous accessible passenger
journey, rather than treating individual accessible facilities or services in isolation.
- Put essential accessibility outcomes in enforceable Standards. Requirements necessary to provide consistent access should be enforceable.
Guidance should support implementation, technical detail and continuous
improvement, but should not substitute for minimum accessibility outcomes.
- Recognise that independent passengers may still require accessible information, guided or orientation assistance.
The Standards should expressly recognise guided and orientation assistance as
passenger assistance. Requiring these measures should not, by itself, be treated as
evidence that a person cannot travel independently or requires a carer, medical
clearance or physical assistance.
- Require timely accessible information, continuous wayfinding and continuity of assistance across the passenger journey.
Essential operational information should reach passengers who are blind or vision
impaired at substantially the same time as other passengers and in a form they can
perceive and use. Airports should provide continuous accessible wayfinding, and
existing assistance arrangements should adapt to disruptions and changes in the
journey.
- Require clear responsibility, active handovers and accessible escalation when accessibility arrangements fail.
The Standards should clearly allocate responsibility between airlines, airports and
other providers and require active handovers when responsibility changes.
Passengers should have access to a designated real-time accessibility contact with
authority to resolve immediate failures. The Standards should also prevent
passengers receiving disability-related assistance from being left unattended for
more than 30 minutes without their explicit agreement, and provide appropriate
review, complaint and redress pathways.
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- Prevent administrative requirements from unnecessarily restricting independent travel.
Advance notice, medical evidence, carer requirements and other administrative
processes should only be imposed where justified by the particular service or a
specific safety, medical or operational requirement. Requirements for dog guides
should be nationally consistent, align with the Disability Discrimination Act and avoid
unnecessary repetition of evidence or approvals.
- Apply an end-to-end usability test to passenger-facing technology and facilities.
Accessibility should be assessed by whether people who are blind or vision impaired
can independently locate, understand and use the service or facility in practice, not
simply whether individual components contain accessibility features or meet a
technical requirement. This principle should apply to booking, self-service check-in,
payment, seat selection, in-flight entertainment and passenger controls.
- Address orientation and wayfinding both within airports and aircraft. The Standards should require continuous, multifaceted airport wayfinding and should
also address the ability of passengers who are blind or vision impaired to orient
themselves within aircraft and locate essential facilities. Digital navigation may
supplement but should not replace non-digital accessibility and assistance.
- Require staff competency, reporting and accountability that show whether the Standards work in practice.
Accessibility requirements should be supported by role-specific practical training,
demonstrated competency and appropriate refresher training for staff whose work
affects passengers with disability.
Standardised reporting should use common definitions, performance indicators and
reporting methods, with sufficient disaggregation to identify recurring barriers
affecting people with different disabilities. Government should publish comparable
sector-wide information, and reporting should be supported by independent
monitoring and effective enforcement rather than relying primarily on individual
complaints.
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