The British Association of Teachers of the Deaf
Promoting Excellence in Deaf Education

BATOD response to Revision of Building Bulletin 93

  1. BATOD (British Association of Teachers of the Deaf) is the sole professional association for Teachers of the Deaf in the UK. The Association organises CPD courses and national and regional meetings to provide relevant up-to-date information and to disseminate good practice. Strong links are maintained between BATOD and Government and voluntary agencies, especially the RNID and NDCS, to contribute to policy development in this field and to represent the interests of deaf children, their families and their teachers. It has five standing committees, one of which, the Audiology Committee, has worked on this document.

  2. By ‘deaf’, we mean anyone with a permanent significant hearing impairment. This could be a mild, moderate, severe or profound hearing loss.

  3. The nomenclature of ‘deaf and hearing-impaired’ is unnecessary and we would prefer ‘deaf’.

  4. 'Children with special hearing requirements'; this descriptor widens the 'affected' group to include children with Auditory Processing Difficulties (APD) and Auditory Neuropathy/Dysychrony (and possibly a host of others). At the present time there is no UK accepted diagnosis of APD except to say it is not a hearing loss. We would not want the term 'children with special hearing requirements' included in the revision. Unless this group is more specifically defined, we feel it lacks clarity and is open to interpretation.

  5. Deaf children are at a disadvantage in the learning environment. The provision of hearing aids does not fully restore hearing for speech and deaf children will continue to find it difficult to hear in all environments. Deaf children find listening for extended periods of time fatiguing especially where the acoustic environment is poor. Acoustic factors, which make it difficult for the deaf child, are long reverberation times and high levels of background noise. Both these factors have the effect of reducing the signal to noise ratio to a point where all children might find listening difficult and the deaf child more so.

  6. We should point out the inaccuracy of the NDCS statistics on achievement. The stats only include deaf children who have a Statement or are at ‘Action Plus’ on the school’s SEN register. In some LAs a significant number of deaf pupils do not have a Statement nor are they classified as ‘Action Plus’. A significant number of the most able deaf pupils have been left out of the statistics. The NDCS statistics currently underestimate the performance of deaf pupils in schools.

  7. BB93 was a welcome document in that it laid down acoustic standards (amongst others) which would make the learning environment acoustically more favourable than it had been in the past. Whilst there is no empirical evidence, to our knowledge, which details educational achievement in relation to the acoustic environment, it is clear to most teachers that a poor acoustic environment is difficult to teach in and may give rise to slower progress for many children. This effect is likely to be more pronounced where the child has a hearing loss.

  8. We appreciate that all classrooms have their own qualities, which vary according to the use to which they are put. We agree that some classrooms should have different acoustic standards from others. The current recommendations are endorsed by BATOD and we continue to take this stance. The recommendation relating to deaf children is more stringent than that applied to general classrooms. This is appropriate given that intensive language work will take place in a specific environment, which would benefit from the best acoustic conditions.

  9. We feel it would be helpful for acoustic recommendations to be specified for areas of schools designated ‘shared areas’. These specifications should be in-line with the use to which the area is to be used. Shared areas in schools are often a useful resource for sessions where children are withdrawn either singularly, or in small groups, for specific teaching. We would welcome clarification on acoustic recommendations for these areas.

  10. It would be helpful for the document to include greater clarity of the way the recommendations should be applied. For example, some organisations believe the acoustic limits recommended for specific areas where deaf children are taught should be applied to all general classrooms. The rationale for this is that deaf pupils are now more and more to be found in integrated settings. Deaf children have always been represented in integrated settings although numbers are greater now than in the past. We feel it would be impractical and punitive to recommend that all classrooms reach the standards set for deaf pupils. We are in agreement with the current recommendations for general classrooms whether a deaf child is educated in it or not.

  11. It would be helpful if some greater emphasis were placed on the assistive technology available for deaf pupils to overcome the detrimental effects of poor acoustics. This is not to highlight poor acoustics per se but to illustrate the benefits of FM technology in overcoming the detrimental effects of background noise and poor signal to noise ratio. No matter how ‘good’ the acoustic environment is, deaf pupils will always be at a disadvantage compared to their hearing peers. This is simply a consequence of being deaf. We would like to see greater emphasis given to assistive technology, teaching style and specialist advice.

  12. We have encountered assertions from some organisations that appear to give undue emphasis to acoustics. It would be helpful for the document to guide the reader in understanding the relative benefits of the whole education package. At present, the document lacks clarity in these areas.

  13. There have been, to our knowledge, some accusations that although a new build has been designed to meet BB93, in reality it does not. It would be helpful for the document to explain how the recommendations are met and how they are policed. The limitations of predicting outcomes from the design phase are poorly understood. There may well be a discrepancy between fulfilling the recommendations at the design stage and what is measured (in a completely different way) in the resultant room. We have reports of practitioners from some organisations measuring the acoustic qualities of a classroom during the school day and with the room fully furnished. It may be helpful to guide the reader in understanding what is a valid measurement.

    We would like to see an addition to the document, which describes the way in which acoustics are planned into a building; for example: Acoustic recommendations are included at the design stage. The architect and designers (including advice from acousticians) design the size and shape of the room to satisfy a number of requirements; one of which is the number of pupils the room will accommodate. Different wall, floor and ceiling construction materials have different absorption characteristics and these are specified so that the room meets the recommendations. From this data the architect is able to predict the acoustic qualities of the room.

    Given that design calculations routinely take place in building design, it seems unlikely they would differ significantly from the final build. This can be tested of course; when the room is built, and before any furniture is added, a measurement could be made to confirm the predictions. [We would assume this is the responsibility of a building inspector or acoustician]. There could be a difference in acoustic qualities if the designer has specified one material and the contractor has used another. This might result in a difference between the intended room acoustics and the actual room acoustics when built. To uncover this difference there would need to be some form of check as described above. If builders used the specified materials there would be no need for a confirmation measurement at the end of the build. Any measurement which includes furniture and fittings does not equate to the original specifications made at the design stage. That is to say, if the room when designed and built meets the specifications - it has met the recommendations. Any further measurement, which includes anything additional in the room, is not valid when establishing compliance with the recommendations.

  14. We feel that BB93 is a helpful document and will ensure schools are built to the best standards. The policing of the recommendations should be explained in the document to allay any fears that the recommendations are being flouted. This is undoubtedly something that building standards personnel take very seriously and it would be helpful for the document to illustrate confidence in this process.

Teachers of the Deaf give advice on all aspects of education for deaf pupils including curriculum access and acoustics. Personal FM systems are used widely throughout the country and we would support their mention in BB93 (Revised) outlining their many advantages in overcoming the disadvantages of background noise and poor acoustics.

We apologise that our submission has not been made prior to the final date of 23rd January 2009. Although we were included in the original draft of BB93, we have been omitted from the list of contacts for this revision consultation. It is unfortunate that the British Association of Educational Audiologists has also not had the opportunity to contribute to this consultation.

BATOD Audiology Committee

Collated by David Couch

February 2009