DDB 122 Royal National Institute for the
Blind
Royal National Institute of the
Blind (RNIB)
Memorandum to the Joint Committee on
the Draft Disability Discrimination Bill
Additional clause for the draft
Disability Discrimination Bill (February 2004):
Councillors and members of the Greater London Authority
1. Comments on section 5B
1.1 RNIB has concerns around the provisions
in clause 15B (4). We are concerned that the provision in 15B(4),
allowing for the introduction of regulations that state when less
favourable treatment which relates to a person's disability can
or cannot be justified, may lead to the justification of less
favourable treatment in cases where this would not be desirable
or appropriate because the threshold used ('material and substantial'
(Section 3A (3)) is a low one. We would urge the Joint Committee
to gain assurances that the regulations will not be used to lower
this threshold any further.
2. Comments on section 15C
2.1 We are concerned that the reasonable
adjustment provisions within 15C do not contain provisions requiring
auxiliary aids and services to be provided where they would enable
or facilitate the official business of councillors. This duty
is vital in securing the access needs of disabled councillors
in cases such as;
- A blind or partially sighted councillor
who needs written information in an accessible format such as
tape or large print.
- A councillor who is hard of hearing
and requires a BSL interpreter or a palantypist.
2.2 Without such vital provision we
are concerned that the new clause will fail to assist disabled
councillors who have additional communication needs.
2.3 We would therefore like to see
the wording of 15C amended so that it makes adequate provision
for auxiliary aids and services that enable and facilitate the
access of disabled councillors when performing official business.
Contact
Dan Scorer
Parliamentary Officer
020 7391 2382
dan.scorer@rnib.org.uk
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