LNER have been pushing their “Wellness Train” for some weeks now.
— London North Eastern Railway (@LNER) April 21, 2022
(one wonders if she / the customers will be keeping their clothes on…)
There are serious concerns about the accessibility of this event. I therefore tweeted Freedom of Information requests for the relevant Equality Impact Assessments.
Please supply the Equality impact assessment for this event.
NB: this tweet meets the legal definition of a Freedom of Information Request, but I'm hoping you can supply it under Business As Usual anyway…
— Doug Paulley (@Doug_Paulley) April 1, 2022
Is there any movement on responding with the Equality Impact Assessment, please?
A subsequent Freedom of Information Request (NOT resetting the timescales of the original):
All original drafts of the Equality Impact Assessment, and all emails and comments on them.
— Doug Paulley (@Doug_Paulley) April 4, 2022
They have now sent me their LNER Wellness Train Equality Impact Assessment FOI response. (As my request was public, I thought I would make the response public too).
I think it is… interesting in what it reveals. Some key comments (emphasis added):
- “Can we maybe invite (redacted) or discuss with him guidance on the compliances for wheelchairs
access as I believe we would be in breach“
- “we should not use coach A for walk on or regular online sales as customers with wheelchairs will not be able to get off at Lincoln (the train hangs off platform after coach H)”
- “I know you’re in the process of doing an EqIA for this wellness train. I’m a bit concerned that it’s already planned and advertised and that this process is supposed to be signed off before that happens“
- “we are currently in a position where we are launching the event before an EqIA has been done. This means we have failed to consider our obligations under the public sector section of the Equality Act. If we do receive any challenge, this immediately undermines any ability to defend and is a breach of the law in itself.“
- “how are we making reservations available for non-event passengers who need a wheelchair space on that train? If we don’t do this, we are in breach of our license. 10% of all seats on the unit must be unreserved priority seats, even in event carriages. How are you ensuring this is the case?”
- “how are we reassuring ourself that the trainers/instructors are competent to train someone who is blind, deaf, on the autism spectrum, etc.? How are we engaging with these suppliers too, are they deemed ‘contractors’? We have obligations to deliver training to anyone representing LNER who directly interacts with customers under our license”
- “how are we selling these EventBright tickets? If I go into a travel centre can I get them? If I call the contact centre can they offer these? If this is online only then it is a potential Equality Act breach. We have spent a lot of time and money on the accessibility of our platform. How are we reassured about this for EventBrite?”
- “there is a celebrity in attendance for one of the carriages. If a wheelchair user picks that event and is in a different carriage, will they get to meet the celebrity? How is this planned?”
- at some point some other person reckoned that the event is “Fully Inclusive – NO RISK“. A view evidently not shared by the Accessibility and Inclusion Manager (who as revealed in this, is excellent, as expected)
It’s pretty clear that this whole thing was put on without thinking of the accessibility implications, then they have had to attempt to retrospectively bolt-on adjustments and justification – which never really works. Accessibility should be designed in from the start in everything anybody does, and in particular anything a publicly owned body such as LNER does.
However I understand that the lessons from this debacle have been learned, or certainly are being learned, as is made pretty clear in the release:
- “Once we have completed our event we will look for feedback from the cm who attended the event, with this information we shall look to implement any changes (where possible) for any future events. In addition to this there will be a full debrief of the event with the Accessibility & Inclusion Manager, Senior Customer Relations Manager and Events Manager to look at lessons learned.
- “Moving forward for future appropriate events these will be discussed within the accessibility forum.“
So I’m not going. (aren’t I a good boy!)
I remain sceptical as to how many people will pay £50 to turn up in Kings Cross at 08:06 to travel to Lincoln whilst doing adult doodling etc. on a normal service train. I suspect this may well prove a flop – but we’ll see.
I’ll certainly be very surprised to see anything like this happen again. It damn well shouldn’t; treating accessibility as an afterthought is never acceptable.