It is a basic consumer right to have access to products and services. Discrimination exists if older people and people with disabilities cannot use many of today’s mainstream consumer products and services. ANEC believes that standards are a suitable tool to overcome this discrimination if Design for All (DfA) principles are applied. Design for All means designing mainstream products and services so as many people as possible can use them - whatever their age and ability.
The ANEC Accessibility Working Group unites experts from both the consumer movement and the disability/elderly organisations. Its work is based on the ANEC Policy Statement on Design for All.
For several years now, ANEC has lobbied for the use of standards in order to enhance the safety and usability of products and services for older people and people with disabilities. If standards for mainstream products and services do not meet the requirements of all consumers, it means that many products and services cannot be used by a large part of the population, despite the current demographic trends in Europe.
As a result of lobbying by ANEC, several working groups focusing on accessibility of product and services standards have been set up such as CENELEC TC 61 WG 4 ‘Safety of household appliances by vulnerable people’, CEN/BT/WG 213 ‘Strategic Advisory Group on Accessibility (SAGA)’ and ISO/IEC JTAG for the revision of ISO/IEC Guide 71.
ISO/IEC Guide 71
ANEC contributed to the revision of ISO/IEC Guide 71,’ since the ISO/IEC Joint Technical Advisory Group for the revision of Guide 71 was set up in 2011 with a view to increasing its implementation. The revised Guide 71 now called ‘Guide for addressing accessibility in Standards' was published in December 2014 by the International Organisation for Standardisation (ISO), International Electrotechnical Commission (IEC) and the International Telecommunication Union (ITU). The publication of the revised Guide 71 is accompanied by a policy statement from IEC, ISO & ITU on standardisation and accessibility. Both documents are available on the ISO website.
The document outlines the developments in thinking (around design, and accessibility itself) since the publishing of the previous version in 2001. It goes on to discuss the various approaches to accessibility in more detail, acknowledging that there is no single definition in current use worldwide.
In 2015, on the occasion of the International Day of Persons with Disabilities celebrated on 3 December, ANEC made public our recently published guidance on the use of ISO/IEC Guide 71:2014 and CEN/CENELEC Guide 6:2014 “Guide for addressing accessibility in standards”.
Vulnerable consumers’ needs in EU policies
ANEC is also working to build a momentum within the European Institutions to put the needs of vulnerable consumers (children, people with disabilities and older people) at the center of EU policies. Based on the position paper we issued in December 2011 we influenced the European Parliament Report on Vulnerable Consumers adopted in May 2012 and the European Commission Communication “Consumer Agenda”.
On 7 February 2013, the European Consumer Consultative Group (ECCG) approved an ECCG Opinion on consumers and vulnerability, drafted by ANEC and BEUC based on ANEC’s position paper on Vulnerable Consumers of December 2011. The aim of the Opinion is to provide a better understanding and increased consideration for all consumers’ needs so as to develop an inclusive and targeted policy approach by the European Commission, and in particular in their response to the European Parliament Resolution a strategy for strengthening the rights of vulnerable consumers of May 2012.
The call made by ANEC for standards to be developed to meet the needs of vulnerable consumers has also been taken into account in the European Commission proposal for a Consumer Product Safety Regulation and Market Surveillance Regulation from February 2013. Products safety and risk assessment should be performed taking into account the characteristics of vulnerable consumers (children, elderly people and people with disabilities). The draft Regulations were adopted by the European Parliament in April 2014 but the adoption of the Council of Ministers is still pending.
In February 2014, the Parliament and Council adopted several product safety directives under revision (“recast”) such as the Low Voltage Directive and the Lifts Directive to align them to the New Legislative Framework (NLF). ANEC lobbied for the concept of foreseeable use to be included in the legislation in order to have the needs of all consumers taken into account. We are of the opinion that consumers can be effectively protected only if their (foreseeable) behaviour is duly taken into account by manufacturers when designing products. MEPs and Member States took on board our call to consider real consumer behaviour when setting safety requirements. We also welcomed the need for standards supporting the Low Voltage Directive to respect the UN Convention on the Rights of Persons with Disabilities.
In April 2014, the revised R&TTE Directive, now called Radio Equipment Directive (RED) was published in the Official Journal of the European Union, after the European Parliament and the Council of Ministers agreement. The concept of “foreseeable use” has to be taken into account for conformity assessment, as proposed by ANEC, to protect vulnerable consumers.
In February 2014, the final draft of a new Directive on Public Procurement was adopted by the co-legislators. The new rules that we supported will require all public authorities to include accessibility requirements in their tenders when possible. These new provisions, which will be applicable in the coming years, should set the legal basis for safety and accessibility standards to meet the needs of all consumers.
The 3rd European Standardisation Summit, held on 11 June 2014 in Istanbul, was dedicated to the theme of how standardisation can support the silver economy. To mark the event, ANEC published the Position paper ‘Wiser standards for an ageing world’. Since ANEC’s foundation, accessibility, and the safety of people with disabilities and older people have been key among its priorities. Regrettably, standards tend to focus on mainstream consumers and do not always address the needs of older people. At the same time, ANEC believes standards can be suitable in making products and services safe and accessible to all consumers, whatever their age and ability. It is now high time for the needs of older and disabled people to be reflected in standards systematically.
On the eve of the 2014 European elections, ANEC published a position paper on the accessibility of voting, accompanied by a press release. We believe that modern solutions, using standards, should be used to help all voters exercise their democratic choice.
ANEC contribution and comments on the EC proposal for a European Accessibility Act
The European Commission published on 2 December 2015 the long-awaited proposal for a directive on accessibility requirements for certain products and services (referred to as the European Accessibility Act). For many years ANEC has been pressing for regulatory action to increase access to every day products and services for consumers of all ages and abilities. Hence, ANEC welcomed in its press release, the European Commission’s proposal to facilitate the accessibility of products and services through standards.
In February 2016, ANEC submitted preliminary comments on the proposed directive, in response to a consultation launched by the Commission.
ANEC welcomed the new ISO standard on access to the built environment ISO 21542 ‘Accessibility and usability of the built environment’, published in February 2012. Since work initiated in 2005, ANEC contributed in the elaboration of ISO 21542, which purpose is to define how the built environment should be designed, constructed and managed in order for people to have independent means of both access and egress, irrespective of their ages or abilities. ANEC was able to establish certainty that the standard does not replace National standards that require higher levels of accessibility.
ISO 21542 can benefit those countries, particularly developing countries, where there is no, or relatively little, provision of accessibility standards. Moreover, ANEC believes ISO 21542 could form the reference document for a European Technical Specification that would also reflect established standards in European countries. We have made such a proposal in the framework of the adoption of the final report on phase one of Mandate M/420 on access to the built environment and public procurement. The Final Report of phase 1 of Mandate M/420 was approved by the European Commission in April 2012. Phase 2 is still pending.
ANEC further welcomed the new ISO standard ISO 23599 ‘Assistive products for blind & vision impaired persons — Tactile walking surface indicators’ (TWSIs), which was published in March 2012. The standardisation of TWSIs is needed to help ensure one indicator indicates the same obstacle or impediment around the world.
ANEC has worked very hard as well to ensure the standard is not seen as a replacement for National regulations, notably where these may be more demanding. It will have particular value in countries without guidance or regulation on TWSIs.
Due to the enormous impact of the Information Society on consumers’ everyday lives, it is vital for Electronic Communications to be accessible by all. The ANEC Accessibility WG’s aim is that regulations and standards ensure adequate levels of safety and accessibility for all. This horizontal issue is common to both the Accessibility and Digital Society WGs.
It is also a priority for the ANEC Accessibility Working Group to mainstream Design for All principles within and outside ANEC. The plan is to provide input on standardisation activities that are related to accessibility issues addressed by the other ANEC Working Groups. As an example, collaboration with the ANEC Domestic Appliances (DOMAP) WG on the exclusion clause issues has proven to be effective (see section below).
As far as the collaboration with disability organisations is concerned, in June 2008 ANEC signed a Memorandum of Understanding (MoU) with the European Disability Forum (EDF) for three years. Building on the long-standing collaboration between the ANEC Accessibility WG and EDF, the EDF Executive Committee and the ANEC Steering Committee agreed to join forces in order to achieve a high level of safety and accessibility for consumers of all ages and abilities. Against the background of the high level accessibility has reach on the policy and standardisation agendas, ANEC is extremely proud of the results achieved and looks forward to future collaboration with EDF and its partners. The ANEC/EDF collaboration will now be focused on the “Access denied” campaign (web accessibility legislation underpinned by standards), but enlarged to the European Blind Union (EBU) and AGE Platform Europe (see below).
- (ISO/IEC Policy Statement): ’Addressing the needs of older persons and people with disabilities’.
- ISO/IEC Guide 71: This document gives general guidance to standards writers on the different human abilities, which they need to consider when writing standards.
- CEN/CENELEC Guide 6: Guidance document to standards writers on how to take into account the different human abilities when drafting standards. European version of ISO/IEC Guide 71.
- EC Mandate 273, ’Design for All and assistive technology in information society standardisation’.
- EC Mandate 283, Guidance document in the field of safety and usability of products by people with special needs.
- EC Mandate 376, ’European accessibility requirements for public procurement of products and services in the ICT domain’. The standard EN 301 549 and technical reports are available on the ETSI website.
- EC Mandate 420, ’European accessibility requirements for public procurement in the built environment'.
- EC Mandate 473 Standardization Mandate to include Design for All in relevant standardization activities
Furthermore, a close link between research projects and standardisation should be ensured in order to gather scientific evidence to support the application of Design for All principles from the very beginning of product design.
ANEC is represented in:
- CEN TC 122/ ISO TC 159 ‘Ergonomics’
- CEN/BT/WG 213 ‘Strategic Advisory Group on Accessibility (SAGA)’
- CEN TC 293/ISO TC 173 ‘Assistive products for people with disabilities’
- ISO TC 173 WG 10 ‘Assistive products for cognitive disabilities’
- CEN TC 10 ‘Lifts’ ‘Lifts, escalators and moving walks’
- CEN TC 10 WG 1 “Lifts and service lifts”
- CEN TC 10 WG 7 “Accessibility to lifts for persons including persons with disability”
- CEN TC 10 WG 8 "Stairlifts and vertical lifting platforms for persons with impaired mobility"
- CEN/CENELEC/ETSI JWG 'eAccessibility under M/376'
- CEN/CENELEC JWG 5 "Design for All"
- CENELEC TC 61 WG 4 'Safety of household appliances for vulnerable people'
- CENELEC TC 62 WG 1 ‘Medical beds for children’
- ISO TC 59 SC 16 'Access to the built environment'
- ETSI TC 'Human Factors'
- ETSI Special Task Force 488 ‘Recommendations to allow people with cognitive disabilities to exploit the potential of mobile technologies'
On 26 October 2016, ANEC welcomed in a press release the adoption by the European Parliament of a Directive on the accessibility of Public Sector Bodies’ websites and apps, which aims to ensure access to on-line public services to all consumers, regardless of their age or ability. The Parliament, in agreement with the Council, made significant improvements to the original Commission proposal issued in 2012, in terms of the websites covered and enforcement provisions, as well as the inclusion of access from a handheld mobile device and mobile apps. These improvements are largely in line with ANEC’s position .
The adoption of the directive brings to a close several years of intensive work by ANEC and its partners in the disability movement, in campaigning for mandatory web-accessibility legislation . “80 million people with disabilities, 150 million people aged over 50, are among the many consumers who will benefit from this legislation”, remarked ANEC Secretary-General, Stephen Russell.
Currently, less than one third of public websites are accessible, while over 60 % of the European population accesses the Internet every day. Many citizens, especially persons with disabilities and older people, are excluded from taking full advantage of the Internet since the websites are not properly designed for them. The European Parliament has understood that it is certainly feasible to change this situation by following the worldwide acknowledged accessibility guidelines which are already incorporated in a European Standard: EN 301 549 from Mandate M/376. With Mandate M/376, the European Commission had requested the development of a series of European standards on accessibility requirements for the public procurement of ICT products and services. ANEC participated in the development of these standards, and will further contribute to their update to include apps.
Websites need to be designed to be accessible, and in compliance with accessibility standards, if people with disabilities and older people are to be able to access on-line services. ANEC calls on Member States, who now have 21 months to transpose the text of the Directive into their national legislation, to ensure timely implementation of the directive so that Europe can deliver for its citizens.
Consumers expect electrical household appliances to be safe, for themselves, their children and the older members of their families. Regulators want a high level of health and safety protection for all consumers, as expressed in European Directives. However, in the case of electrical household appliances, these principles are undermined by the EN 60335 series of standards used to support legislation, which feature an ‘exclusion’ or ‘limitation’ clause to the effect that the standard “... does not, in general, take into account the use of appliances by young children or infirm persons without supervision.”
Why is it discriminatory?
For many years, ANEC has been concerned about the limited scope of these standards. The standards exclude the use of electrical household appliances by a substantial group of consumers- children and “infirm persons”. This is discriminatory. We have fought for the deletion of this exclusion clause, against strong opposition from industry
What is ANEC doing?
Since 2005, ANEC has proposed changes to the standards for toasters, microwave ovens, hobs and ovens, hairdryers, water heaters, lawnmowers and trimmers, and grills and similar portable cooking appliances. The aim is to make those appliances safer for all.
Knowing how to use a grill or electric kettle is a prerequisite for safe use. We therefore suggest instructions for use be made more legible as no one, especially people with diminished vision due to age, “remembers to read the small print!” The risk of burns from a hot oven door can be avoided if surface temperatures are lowered to a safer level for older people, taking into account their often slower reaction times.
The ANEC proposals are based on a Research and Testing project to review Parts 2 of EN 60335 series of standards. It was on ANEC’s request that a special working group on this issue (CENELEC TC 61 WG 4) was set up in 2006. As a result of lobbying by ANEC, the European Commission has issued a standardisation mandate to support the group’s work. This work in CENELEC is expected to come to conclusion at the end of 2015. About 60 standards have been revised to make them take into account the safety needs of vulnerable consumers.
The first six revised Parts 2 of EN 60335 were adopted by CENELEC in April 2010, covering vacuum cleaners; electric irons; cooking ranges, hobs and ovens; washing machines; appliances for skin or hair care and those for oral hygiene. This was a huge achievement for ANEC and for the consumer movement. Since then, CENELEC continued the revision of several Parts 2 to the EN 60335 series, based on ANEC’s proposal covering a particular appliance and embracing vulnerable consumers’ needs. ANEC and Consumers International continue their joint efforts to remove the exclusion clause by proposing improvements to different Parts 2 of EN 60335 and IEC 60335, as well as on lower surface temperature limits in IEC 60335 series so that consumers from around the world can benefit from the requirements for greater protection and improved accessibility we have won in Europe.
What can you do to help?
ANEC believes that electrical products should be safe for all consumers and calls for the revision of relevant standards.
ANEC urges organisations established for consumers and for people with disabilities to lobby their national standards bodies in order to support consumer views in CENELEC TC 61 WG 4. A complete list of the CENELEC national members is available at www.cenelec.eu