Functional Trial Accessiblity Assessments in Transport Part 2.

Discussing Disability Standards for Accessible Public Transport 2022 (DSAPT) – Part 15 Toilets

The Disability Standards for Accessible Public Transport 2022 (DSAPT) is currently undergoing a reform process.

In our May newsletter we published an overview of these changes and discussed the first area of compliance – DSAPT Part 3 Manoeuvring areas in more detail. In this edition of our newsletter, we will be discussing DSAPT Part 15 Toilets.

DSAPT Part 15 Toilets

15.4 Conveyances – requirements for accessible toilets (ferries and accessible rail cars)

  1. An accessible toilet must:
    1. comply with the requirements set out in this section; and
    2. allow passengers in wheelchairs or mobility aids to enter, position their aids and exit.

In this article we will discuss DSAPT Part 15.4 and the demonstration outcomes within the Queensland Rail IMU (Interurban Multiple Unit) 160 DSAPT upgrade project.

DSAPT Part 15 Toilets

In proving DSAPT compliance, the solution we used included a process of consultation and collaboration with people with lived experience of disability. This relates to the NGR Forde Commission of Inquiry recommendations 17- 20 requiring consultation with the disability sector.

Recommendation 19

Consultation with the disability sector about the design of public transport infrastructure (undertaken before, during or after procurement) be structured around the obligations of the disability legislation and functional requirements.

As part of the Queensland Rail existing rolling stock DSAPT upgrade project the Queensland Rail City fleethas had an extensive upgrade to the toilet modules on the IMU 160 trains including consideration of circulation and manoeuvrability of mobility devices within the toilet.

Architecture & Access was engaged by Queensland Rail to conduct a functional trial of the toilet mock-up in March 2022. A full-size mock-up of the on-board toilet was constructed and assessed by the trial participants.

Objectives of the toilet module mock-up engagement session

  • To test out the proposed layout for the modified toilet module and provide feedback to inform the final design of the layout for the upgrade of the IMU existing fleet
  • To determine if the proposed toilet module design compliant as defined by ‘enter, position their aids and exit’ as per DSAPT Part 15.4 (1) (b).


  • A Pre-trial survey was used to ascertain general health status, physical exertion level and comparative participant experiences with other accessible public amenities (either on or off the train). Pre and post-trial, questions relating to participant experiences of comfort, perceived safety and ease of use were also assessed. Ratings were provided pre and post-trial to assess if the experience had improved or not improved with the proposed change to the toilet module.
  • Participant’s mobility device was photographed and measured to compare against the 800mm x1300mm DSAPT footprint requirements.
  • Participants were asked to manoeuvre through the toilet mock-up and provide feedback on its usability and their thoughts on the experience, assessing 8 distinct functional areas (See Plan 1)
  • Eight participants with varying disabilities, ages and devices, four powered wheelchair users; three manual wheelchair users and one scooter user participated in the trial

The conclusion of the trial indicated that participants use and manoeuvrability within the facility had improved and therefore confirmed compliance with the DSAPT Part 15.4 (1) (b). This information has provided confidence for Queensland Rail to progress to the next stage of upgrades to the toilet modules on the IMU. This will ensure a compliant and functional vehicle that provides a safe and equitable journey for all users.

Architecture & Access


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