AS/NZS 3695.3:2016 – What is it and what does it mean for you?

I was alerted to an article published in various media sources that gave many mobility device users cause for concern and as promised, I have investigated.

I discovered there’s much ado about nothing.

The article (click here to read article) wrongly stated that changes were being made that would prohibit the use of certain devices on road related areas, public transport and other public space if they didn’t comply to the changes. It’s not surprising though that this misconception has occurred. They never write these documents in simple language and this one in particular has a significant number of past references to other documents so unless it’s read in context with those documents it’s jibberish.

So let me lay it out for you.

Australian Standards 3695 was already currently two parts. Parts one and two covered the design and testing requirements for mobility devices such as wheelchairs, powerchairs, power assist add ons and mobility scooters, to ensure they adhere to the safety standards required for sale in Australia. This third part is an additional part of the existing safety standard for a compliance labelling system called the Blue Label system.

What is the Blue Label System?

This will outline the requirements for devices that meet the compliance to safety standards for safe use of devices on public transport systems. There are already regulations and guidelines for safe use of mobility devices on public transport in each state of Australia. These requirements cover things such as width, length, weight and maneuverability of a device so that you can access public transport safely. The Blue Label System will make it easier to identify which devices are compliant to these safety standards.

See, what is happening now is that we are being sold devices that don’t comply to these existing regulations but many people are unaware until they try to use them and discover they don’t fit. It poses a serious risk of safety, particularly on the matter of weight, when the ramps that have be designed for loading us onto trains and such have a maximum load limit, and our devices exceed that limit.

So while the Blue Label System may make it easier for operators of public transport to identify that our device is not safety compliant and refuse us entry, this isn’t something new and it’s not a breach of the DDA because it is for our own safety. It is our responsibility to ensure that if we are going to need to use our devices on public transport that we acquire one that meets the safety requirements as this is what is also required to meet our needs.

The reference in the Standards draft document to road related areas is also an existing regulation under the Australian Road Rules that will be identified on a Blue Label or if a device is not Blue Label compliant, on a yellow label. It’s speed and slope stability. We are restricted to 10kph in public areas including footpaths and roads. Under the compliance requirements for the Blue Label your device will need to be either restricted to a maximum speed of 10kph OR, have an override switch that can restrict to 10kph and have a speedometer for use on road related areas. It also outlines the safety requirements for stability on slopes to a maximum of 7.1 degree pitch (although I do wonder about this one considering there are so many footpaths and access ramps that do not meet the safety standards for us to use them).

What does this mean for you?

Better safety. Better knowledge when purchasing a device.

Little Eleanor

Little Eleanor

Big Eleanor

Big Eleanor

I have two mobility scooters, known as Big Eleanor and Little Eleanor. I have two because they both serve very different purposes. Little Eleanor was my introduction to motorised mobility devices when I lost my capacity to drive independently. She’s small with a maximum speed of 8kph and easy to use in small spaces, such as buses and trains. I use her when I’m travelling long distances by public transport with short distances between destinations because her distance capacity is only small between battery charges. Big Eleanor is in excess of the size requirements for public transport. We tried. It doesn’t work. While I can get her onto the train she takes up the entry way and the wheel base width is in excess of the loading ramp width. She’s all terrain though and I can take her on all kinds of surfaces like the park with the kids, some beach surfaces and she handles the really crappy footpaths that are in dire need of repair but there never seems to be any budget for. She also travels long distances on one battery charge. She can’t go into supermarkets and she has a maximum speed over 10kph but also has an override switch to restrict her to less than 10kph. They both serve two different purposes but Big Eleanor will not be Blue Label compliant for public transport. She will get a yellow label outlining what her specs are.

I want to stress that there is nothing in the standards that prohibit you using a device that is not Blue Label compliant device in public areas provided it meets the regulations of the Australian Road Rules on the yellow label.

What concerns still need to be raised?

Well besides the fact that no matter how many organisations and websites related to disabilities in Australia that I am subscribed to I didn’t come across this document until AFTER public consultation had closed, I still have some concerns.

There is nothing yet to outline what if any, deadline there is for existing devices to gain a Blue Label OR how this will happen.
Who will re responsible for the expense if any of obtaining a Blue Label to continue using compliant devices on public transport.
Will there be any compensation for people who have unknowingly been sold devices that do not comply to the standards and cannot be used in any public area (lord knows there shouldn’t be any like this in Australia that are not for specialised use ie: beach chairs).

Unfortunately it’s not a simple task buying a wheelchair these days. It’s become as perplexing and expensive as buying a car. I hope this compliance system will make it somewhat easier for people to know what they’re getting into when they buy a new device.

To view the draft document of the addition to the standards click here


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