Memorandum from the Federation of Small
Businesses (DDB 109)
1. Introduction
The FSB represents the interests of self-employed
and owners of small businesses. Although founded as recently as
1974 it now has over 185,000 members across all industries, trades
and services. FSB members together employ 1.25 million people.
1.1 There are 8.7 million disabled people
in the UK and the FSB does inform its members that no business
can afford to ignore customers with an annual spending power of
£45 billion.
1.2 The FSB was represented on the Disability
Rights Task Force along with the CBI, BCC and IOD.
1.3 The FSB provides a free 24-hour legal
advice line to its members covering disability legislation.
1.4 The FSB in-house magazine carries a
feature on the DDA in each edition.
2. Transport
Extending the DDA to cover discrimination in
relation to the use in the means of transport will have implications
for taxis, private hire vehicles and private rental and car hire
firms. The quicker the timetable on regulations (to lift the part
III exception from transport operators) is tabled, the better
it will be for such operators who are in the main small businesses.
The move may be very beneficial in clamping down on unsafe operators
in this sector.
3. Discrimination by Public Authorities
We have no comment on this aspect.
4. Private Clubs
Whilst we have no objection to extending the
DDA to private clubs perhaps a staged approach would be better.
We would urge that initially clubs with 50 or more members should
be covered. In the meantime clubs with between 25 and 50 members
should be informed that the Act will apply to them in say a years
time giving the smallest of the private clubs with little resources
time to prepare.
5. Letting of Premises
We agree with the written evidence given by
the National housing Federation on this aspect namely, a very
clear definition of reasonableness in needed here and special
statutory provisions so that funds are available to smaller land
lords to enable effective implementation of this element of the
bill.
6. Duties of Public Authorities
We have no comment on this aspect.
7. Definition of Disability
A final, settled and comprehensive definition
of disability will be helpful to the business sector.
8. Councillors
We have no comment on this aspect.
9. Other aspects
As a volunteer organisation itself the FSB has
no objection in extending the protection of the law to volunteers,
provided a pool of funding on the lines of the Access to Work
scheme were put in place by the DWP.
9.1 There is some pressure to make part III
DDA cases enforceable through employment tribunals. This should
only be done by copying the proposals, which will streamline equal
value employment tribunal cases.
10. Compliance Cost for Business
The DWP estimates that landlords may face costs
of around £650,000 as a result of extending to them the duty
of reasonable adjustment. Many of these landlords will be small
businesses. Given the costs to service providers in the taxi and
private hire sector there may be an argument for such training
to be part funded by government.
March 2004
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