Comments on the Public Health and Wellbeing (Prescribed Accommodation) Regulations 2020.
06 October 2020
Posted by: Callum Morrison
Dear PHWR2020,
There is an opportunity while revising prescribed accommodation regulations to not just set minimum prescribed levels of standards but also encourage above and better practices to enhance the benefits of accommodation above just being a roof over vulnerable people’s heads.
Anyone who travels, even booking luxury accommodation, can easily ruin their travel experience if they acquire infections from contaminated contact surfaces, water supply, recreational water or food. They are vulnerable to unsettling their digestive or immune systems if challenged by being out of their normal accommodation environment and the microbes they are used to encountering. Visitors bring new along with them new microbes that future occupants may be vulnerable to and surrounding residents may be vulnerable to. Certainly better premises and operators don’t need as much regulation by municipalities however at least knowing where all public accommodation is located is essential to managing rapidly changing public expectations, concerns outbreaks and emergencies.
Just relying on how a premises looks on line does not necessarily translate to proper cleaning and throwing this responsibility into domestic settings does require support of Council Environmental Health Officers in many situations.
Let’s not just prescribe minimum standards but also prescribe designs that encourage better health when setting new accommodation premises up. The run down farm house for booking on line that also comes with a caravan parked nearby in a fire prone hay shed for any extra people is not acceptable !
The simultaneous decay of the environment, economy, infrastructure and social structures will put increasing load on prescribed accommodation and the prescribed accommodation will put increasing load on the neighboring properties and the surrounding environment. The condition and management of such structures can deteriorate very quickly and crime, drug issues, psychiatric illness, illegal works or poor maintenance can put future occupants quickly at risk. They are paralleled with similar issues in caravan parks.
Many are in renovations of very old building infrastructure with many pre-existing structural problems and others are very new structures with opportunities to utilize new knowledge about health and environmental benefits. Even the aesthetics and green outlooks from structures can have massive benefits to health and have revolutionized hospital design. People living closer to the environment generally have better health and those in intensive caged environments can expect poor health.
Please don’t think of environmental health and Council involvement as just the absence of disease and minimum standards. Environmental Health referrals of proposed new or redevelopments look to improve the lighting, outlook, ventilation and environmental efficiency. If we are given the time and support to do this in a proactive way from the start we can encourage long term benefits to health. We try and assess for measures to try and avoid nuisance creation such as inappropriate positioning of air conditioning units, vegetation issues etc.
In fact if we were really proactive then whole new types of human accommodation could be devised with less cost, health and environmental impact built into them rather than the artificial caves we currently live, work and play in. Zoo animals in many cases get better consideration of their accommodation design and care on some sites and the discussion documents comments are right about some people having to spend a very long periods of time in these places.
There could be far more stimulating environments for humans and communities to live in – particularly for the better physical, mental and life skill development of children. I want to try and work with some indigenous groups to invent something that would allow them to live closer to country and leap frog the shortfalls of conventional buildings plus create ecotourism and cultural education opportunities.
Some people might think that environmental health is duplicating the roles of planning, building and compliance approval however it is our routine visits and assessments to look at food and swimming pools or other health issues that show up a problems for other parts of Council they would otherwise be unaware of. Internally in Council, EHO’s work in with Business Development, event management and tourism departments. This is actioned or then also referred internally or externally to responsible authorities such as energysafe, worksafe, fire and water authorities.
With all authorities shrinking their core business then when something goes wrong like quarantine or aged care it becomes everybody’s responsibility and a community embarrassment. It is important this legislation upholds standards and does not effectively send our communities backwards in time. Once authorities and the supporters of this legislation start to slide backwards, then it can be very hard work to recover decent standards. A poorly maintained unit or property can drag down a whole neighborhood and potentially now really serious long term contamination of buildings can occur if occupants use ICE. Where there is illegal manufacturing this can cause explosions in some cases demolishing buildings and showering others with debris.
Council Environmental Health Officer involvement is needed to ensure basic standards are upheld. Many places are poorly maintained by underpaid staff, cleaners, security and trades people with serious implications for the occupants and neighbours. Please confirm in the legislation that caravan parks that also have fixed rooms, houses or other associated accommodation available other than UMD’s are required to have prescribed accommodation registration as well.
We are now entering a time where genomic testing can connect cases of infection forensically and antibiotic resistance is also on the rise. Climates are changing and pest vector types are changing as well. Setting minimum space requirements is important but cleaning schedules and elimination or minimization of sources of likely infection are probably also just as important.
The regulations need to clarify whether B&B operations are regarded as prescribed accommodation when those in areas where there is no town water or town sewerage are frequently found to have inadequate water supplies or onsite wastewater management. The “Exclusive Occupation of the Occupier” works fine until multiple additional families or a party starts up.
As with packaged food only premises, there should the requirement that any public accommodation providers at least “notify” Council of their presence so they can be informed by the Council of their limitations and triggers for when registration would be required.
I will leave you with a case study that I hope this revised legislation would prevent happening.
A restaurant on the ground floor of a building had a dwelling in disrepair above. This was occasionally checked as part of the food premises inspection because of food or equipment storage and possible pest issues. The stairs did not comply with building safety or fire safety requirements. I conducted an inspection of the restaurant and asked if any accommodation was happening upstairs and this was denied. A week later there was a fire and one double bed and two single beds were vacated in a hurry and significant damaged to the building occurred. Another B&B operator reported an enquiry the next day from someone wanting accommodation because the place they had booked in town had burned down.
The number of beds is important but there are many other factors that can be dangerous that Council EHO’s can put on the record and reasonably ask to be fixed. Termite ridden decking, household wiring that looked like a child had done it with live bare copper and sticky tape or serious rodent infestations.
Generally about 1 in 10 premises have some really significant safety issue and for most we can usually value add to a business if a Council EHO visits. We also uphold standards in the industry so substandard competition is less likely to set up. One negative incident can easily undermine the reputation of the industry and the region.
You will probably hear from others with responsibilities for the alpine resorts. Maybe there should be consideration for whether differing standards might apply for those in hardship compared to those who are using this accommodation out of choice and for pleasure with minimal time spent in the actual accommodation rooms.
Regards
Callum Morrison
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