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The Safety Line: Accessibility – More than a compliance exercise

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Why Diversity Impact Assessments should shape rail projects from the start

Moving DIAs beyond compliance to create safer, more accessible and better-performing railway projects.

On rail projects, accessibility problems are considerably easier to address while they are still lines on a drawing. Yet Diversity Impact Assessments can sometimes be treated as documentation to complete rather than a tool to influence design. Used properly, a DIA can help project teams identify who may be affected by a proposal, challenge assumptions and embed inclusive thinking before decisions become difficult or expensive to change. It aims to provide a built environment without barriers that is safe to use by all people.

The real test of a DIA is not whether the document exists, but whether it changes a decision, a layout, a route, a phasing plan or an operational response.

A DIA is a design tool, not a tick-box exercise

A DIA is an integral part of Network Rail’s design development and approval process. A DIA has recently been renamed an Equality Impact Assessment (EQIA), however, the process and principles remain the same. A DIA/EQIA is completed and submitted on an online digital platform. We complete a DIA in close liaison with the designers and submit the report on the digital system.

At its core, a DIA is a structured assessment of how a project may affect different people, with particular attention to people who share protected characteristics under the Equality Act 2010. That assessment needs to consider both the construction phase – including temporary works, disruption and altered access – and the in-use phase, when passengers and staff are interacting with the completed asset or service.

That distinction matters because an apparently accessible finished design can still create significant barriers while work is taking place. A temporary diversion may add distance or steep gradients. A relocated ticket vending machine may create an obstruction or force users into a congested area. A construction phase that removes seating or changes wayfinding can affect some passengers far more than others. The DIA creates a disciplined way of finding those impacts early and deciding what to do about them.

The intended outputs are straightforward: identify the impact, agree the mitigation or design change, and create a clear action plan. The value comes from doing that while there is still time to influence the project.

Why DIAs matter beyond legal compliance

There are clear legal and policy drivers, including the Equality Act 2010, the Public Sector Equality Duty and accessibility commitments made by Network Rail and train operating companies. But treating the DIA only as a compliance requirement misses the wider business and operational case.

Inclusive decisions generally create a better customer experience. They can reduce complaints, avoid expensive retrofit and make an asset more resilient to demographic change. They also support safer operations by reducing risk for vulnerable users and giving staff clearer arrangements for managing incidents, disruption and changes to normal passenger routes.

This is particularly important because accessibility is rarely confined to one piece of infrastructure. A passenger’s experience is a chain of interactions: arriving at the car park, reaching the entrance, understanding the signage, buying or validating a ticket, moving through the station, accessing facilities and boarding the train. A weakness at any point can make the overall journey inaccessible, even when individual elements technically meet a standard.

DIAs apply to far more than major station schemes

The need for a DIA should be considered across almost any rail-related project that changes how people access, navigate or use the railway. Examples include:

  • new or upgraded stations and platforms
  • footbridges, lifts, access routes and car parks
  • depots, sidings, control rooms and staff facilities
  • signalling, telecommunications and lineside assets where routes or access are affected
  • digital and ticketing systems such as apps, ticket vending machines, validators, customer information systems and websites
  • operational, timetable or policy changes that alter how people travel.

The common thread is not project value or physical scale. It is whether the change could affect people differently. A relatively small intervention can create a disproportionate impact if it alters an accessible route, removes a facility or introduces a new barrier.

The earlier the assessment starts, the more useful it becomes

The strongest DIAs begin at early option or feasibility stage, when the project team can ask two simple questions: who could be affected, and where are the biggest risks? At outline design, the assessment can then influence route choices, key design principles and access strategies. At detailed design, it should be updated against actual layouts, gradients and equipment locations.

The same assessment should follow the project into pre-construction, where attention shifts to temporary works, phasing and access arrangements, and then into completion and handover, where the team checks that the built solution reflects the agreed mitigations and records any residual risks.

This lifecycle approach prevents a common failure: producing a DIA late in design when the important decisions have already been made. At that point the document can describe a problem, but the project’s ability to solve it may be constrained by cost, programme, consents or completed design work.

A practical lifecycle for DIA activity

Early option/feasibility – Identify who could be affected and the highest-risk issues.

Outline design – Influence route choices, access strategies and key design principles.

Detailed design – Test detailed layouts, gradients and equipment locations.

Pre-construction – Assess temporary works, phasing, diversions and access arrangements.

Construction – Review construction arrangements in progress, to ensure there is good quality information provided to all station users on the operational and layout changes of the station and that the temporary set up does not impact the safety of any station users.

Completion/handover – Check the built solution and update residual risks and actions.

Five steps that keep a DIA focused on outcomes

  1. Define the scope and aims: Be clear about what is changing and who could be affected.
  2. Gather evidence: Use baseline data, usage patterns, local demographics, existing issues and complaints rather than relying on assumptions.
  3. Analyse the impacts: Consider construction and in-use impacts by protected characteristic and by user type.
  4. Identify mitigations and design changes: Turn findings into design tweaks, operational measures, communications, phasing changes or other practical responses.
  5. Record, assign and review: Create an action plan with owners and dates, and update it as the design evolves.

What a DIA can reveal at station level

Many of the most important issues are not dramatic technical failures; they are everyday barriers that can make a journey more difficult, confusing or unsafe. Step-free routes may technically exist but be indirect, cluttered or poorly signposted. Accessible parking bays may be too far from an entrance or linked by an unsuitable gradient or surface. Gaps and steps between the train and platform can create boarding difficulties. Wayfinding can fail through language, contrast or inconsistency.

The same principle applies to the location of ticket vending machines and validators, the availability and suitability of toilets and waiting areas, lighting and acoustics for visually impaired and hard-of-hearing users, and emergency egress routes that involve long distances, steep gradients or insufficient resting points.

These examples show why compliance with individual standards is not enough on its own. The assessment needs to look at the real journey through the asset and ask how the arrangement works for different people in practice.

Good practice is visible in the project, not just in the report

A useful DIA is started early, written in plain English and connected directly to the scheme. It should explain the issue, the consequence and the agreed response without burying the conclusion in generic text or jargon. Standards are important, but they should support the assessment rather than replace it.

Ownership is equally important. The client or sponsor may commission the assessment, but the design team owns the design responses, the Principal Contractor manages construction-phase impacts and access, and accessibility specialists may lead or support the assessment itself. Network Rail teams covering sponsorship, operations, safety, accessibility and the Built Environment Accessibility Panel may need to contribute, alongside passengers and user groups on larger or more complex schemes.

The best result is a live conversation between these parties, with the DIA updated at key stages and shared with the project team. When an issue is identified, there should be an action owner. When the design changes, the assessment should be revisited. And when mitigation is agreed, the change should be visible in the drawings, layout, phasing or operating plan.

The warning signs of a weak DIA

  • Treated as a formality or tick-box exercise
  • Completed too late to influence the design
  • Generic, with no real link to the scheme
  • Actions have no clear owners
  • Design and construction teams are not involved
  • Not updated when the project changes

From compliance to better decision-making

The strongest case for a DIA is therefore not that a project has to produce one. It is that inclusive thinking improves the quality of project decisions. It forces the team to look beyond the average user, test how a proposal performs under disruption as well as normal operation, and resolve barriers while there is still time to do so efficiently.

For rail projects, where assets remain in use for decades, and construction frequently takes place in live operational environments, that early thinking has lasting value. Better accessibility, fewer avoidable complaints, safer operations and reduced retrofit are all outcomes that support passengers and project sponsors alike.

A DIA should not sit at the edge of the design process. It should be part of the process by which the project proves that the railway it is creating – temporarily and permanently – works for the people who need to use it.

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Martyna Szypowicz

Director - Compliance

Martyna Szypowicz