Access Audits: The 3 Journeys Your Building Has to Support
Commission an access audit and you will get a thorough report on arriving and entering. Parking bays, dropped kerbs, door opening forces, threshold heights, lift controls, corridor widths, accessible WCs. All of it useful, all of it necessary.
Then read your fire strategy and notice that it assumes everyone can use the stairs.
Those two documents describe the same building and almost never describe the same person. An access audit follows someone in. A fire risk assessment gets a notional occupant out. The disabled employee who uses both journeys every day exists in the gap between them, and that gap is where most organisations are exposed.
A building has to support three journeys, not two. Here is what each one covers and why the third is the one that fails.
The duty behind all three
Worth establishing precisely, because the statutory wording settles the argument.
Section 20 of the Equality Act 2010 sets out the duty to make reasonable adjustments in three requirements. The second applies where a physical feature puts a disabled person at a substantial disadvantage, and requires reasonable steps to avoid that disadvantage. Section 20(9) explains that avoiding the disadvantage includes removing the feature, altering it, or providing a reasonable means of avoiding it.
Then section 20(10) defines what counts as a physical feature. It includes a feature arising from the design of a building or the way it was built, fixtures and fittings, any other physical element or quality, and, in terms, "a feature of an approach to, exit from, or access to a building."
Exit. The statute names it alongside approach and access, in the same breath, as a physical feature capable of placing a disabled person at a substantial disadvantage. An audit that covers approach and access but not exit has examined two thirds of the duty.
The duty reaches both staff and visitors through different routes. For employees it runs through the employment provisions in Schedule 8; for people using a service it runs through section 29 and Schedule 2, which is why a university, a law firm with client meeting rooms and an insurer with a walk-in office all carry it twice over. Note also section 20(7): you generally cannot ask the disabled person to contribute to the cost.
Journey one: getting to the building and in
The part access audits do well, and the part a fit-out team can usually evidence.
It starts further out than people expect. Routes from public transport and from parking, the gradient and surface of external routes, the location and number of designated bays, drop-off provision, lighting and the legibility of the approach. Then arrival: level or ramped access, threshold detail, door opening force and ironmongery, vision panels at the right heights, and whether the entry system can be operated by someone who cannot reach a standard panel or cannot hear an intercom.
Approved Document M is the reference point for new work and material alterations in England, and the British Standard on the design of accessible buildings sits behind most professional audits. Both are design guidance rather than the duty itself, which is a distinction worth holding: compliance with the guidance is evidence of reasonableness, not a defence in its own right, and an older building that cannot meet current guidance still owes the section 20 duty.
Journey two: using the building
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Broader than most organisations assume, and the journey where the audit findings are cheapest to act on.
Horizontal circulation, meaning corridor widths, passing places, and whether a hot-desking layout has quietly narrowed a route. Vertical circulation: lifts, their controls, their speech and tactile indication, platform lifts and whether their keys are actually available. Doors throughout, where self-closers fitted for fire reasons regularly exceed the opening force an accessible route needs, which is the most common direct conflict between the two disciplines. Sanitary provision, including whether the accessible WC is being used as a store. Wayfinding, signage, lighting levels and acoustics, which matter more for sight and hearing impairment than any single physical feature.
Then the working environment itself: height-adjustable desks, meeting rooms with hearing enhancement, and whether a visitor with a hearing impairment can participate in a meeting at all. For employees this is where the reasonable adjustment conversation and the display screen assessment meet, and where the answer is usually individual rather than architectural.
Journey three: getting out
The journey that fails, and it fails for a structural reason rather than through carelessness.
Access audits are commissioned by estates or by diversity and inclusion. Fire risk assessments are commissioned by compliance. The first assumes the building will be evacuated competently, the second assumes the occupants can walk. Nobody owns the overlap, so the lift that provides step-free access during the day is the lift nobody may use in a fire, and the accessible entrance on the far side of the building is not an escape route at all.
Article 9 of the Regulatory Reform (Fire Safety) Order 2005 requires a fire risk assessment that considers the people who may be present, and article 14 requires emergency routes and exits to be adequate for the people using them. That is not satisfied by a generic strategy.
Five things belong in this journey and rarely appear in either document.
A plan for each person who needs one, agreed with them rather than written about them, which our note on personal emergency evacuation plans covers in detail. Refuge points that are identified, unobstructed and equipped with a means of communication that someone answers. A documented position on evacuation lifts: whether the building has one, whether it may be used, and who authorises that. Alerting arrangements that work for someone who cannot hear a sounder, which usually means visual beacons or a vibrating pager rather than a louder bell. And trained assistance, with enough people on each floor and a plan that survives a Friday afternoon when half of them are elsewhere.
For residential premises the position has also moved: the Fire Safety (England) Regulations 2022 added specific duties for multi-occupied residential buildings, which matters for any university or operator with accommodation alongside its teaching or office estate.
The three journeys side by side
| Journey | Typically assessed by | Covers | Where it breaks |
|---|---|---|---|
| Getting to it and in | Access consultant, fit-out team | Approach, parking, external routes, entrance, entry systems | Older buildings judged against current guidance alone, with no section 20 reasoning recorded |
| Using it | Access consultant, facilities | Circulation, lifts, doors, WCs, wayfinding, acoustics, workstations | Door closing forces fitted for fire exceed accessible opening force |
| Getting out | Nobody, or assumed | PEEPs, refuges, evacuation lifts, alerting, trained assistance | Access route and escape route are different routes, and only one was audited |
The right-hand column of the third row is the finding worth acting on this quarter. It is also cheap to close, because it is largely a planning and training exercise rather than a capital one.
Who should carry out the audit
Access auditing is a recognised specialism, and the professional reference points in the UK are the National Register of Access Consultants and the Centre for Accessible Environments. If you are buying one, two questions separate a useful engagement from a report.
Ask whether the audit will address egress, explicitly, and whether the auditor will read your fire risk assessment as part of the work. And ask for findings prioritised with the section 20 reasoning attached, rather than a list of departures from design guidance, because a long schedule of technical non-compliances in a listed or older building is not the same thing as a schedule of reasonable adjustments.
One terminology note for anyone searching: an accessibility audit sometimes means a digital audit of a website against the web content guidelines, which is a different discipline entirely. If you need the building assessed, say access audit of the premises.
Why a group standard travels badly
Multinationals usually write one accessible fit-out specification and apply it everywhere, and it is the wrong unit to standardise.
The United States works to a different legal architecture altogether, with enforceable design standards under its civil rights legislation rather than guidance supporting a reasonableness test, and dimensions that do not match the British figures. Germany works to its own design standards for barrier-free building, and the European Accessibility Act operates largely on products and services rather than on existing premises. The result is that a specification built around UK guidance will under-build in some jurisdictions and over-build in others, and in neither case will it answer the local legal question.
What does travel is the method: three journeys, assessed per building, with the local design standard and the local egress rule attached to each line. Holding that per site, with the adjustment, its owner, its cost and its review date, is where health and safety consultants and software are worth more in combination than either alone, because an adjustment agreed with an individual in 2024 needs revisiting when they change floor, change role or the layout changes around them. Periodic health and safety audits should then test the third journey specifically, by picking a named individual and asking how they would leave.
Where Arinite fits
Arinite has spent 15+ years working across the line where premises, fire and people meet, which is precisely where this question sits. We support 1,500+ businesses in 50+ countries and protect 100,000+ employees, with 95%+ client retention. Our health and safety consultants work extensively with education, office and legal clients, and the egress gap is one of the most consistent findings we report. Where the premises are in scope it sits alongside your existing fire safety arrangements rather than separately from them.
For multi-country estates, our global health and safety consultants apply the local design standard and the local escape requirement rather than exporting the UK specification, and our international health and safety consultants can tell you which sites your group standard does not answer.
Pick one person in your building who would need assistance to leave, then see whether both your access audit and your fire risk assessment mention them. Then book a free gap analysis and we will tell you in one call which of the three journeys is unassessed.
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Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
