And since we are talking about toilets…..
I want to keep everyone safe. But look at the history of where this has now got us. Single sex toilet designs for people that are more dangerous than before.
Document T details the toilet design legislation that will come in to force in October. There is a glaring problem that means the toilet designs are dangerous for everyone but in particular, disabled people, medically vulnerable, women and girls.
There are 4 toilet designs:
• A Ambulant universal - full height door and full height floor to ceiling partitions
• B Universal - full height door and full height floor to ceiling partitions
• C Single sex ambulant - profile diagram shows full height door and no door gaps
• D Single sex - no profile diagram, no mention of door or partition heights, AND can be designed as Type A or B ie fully enclosed for single sex use
None of the designs specify a door gap at the bottom of the door or at the top.
Why do gaps matter?
Because toilet door gaps save lives.
If you collapse, being able to survive or if you suffer long-term damage, will be down to whether someone notices and rescues you.
If you’re out and about or at work and feel nauseous/ill you are likely to head to the toilet.
There are around 100,000 hospital admissions due to heart attacks in this country, equating to one every five minutes.
There are also around 100,000 strokes in this country, equating to one every five minutes. There are known medical reasons for a disproportionally high frequency of cardiac arrests and strokes while an individual is in the toilet.
Around 1% of people in this country have epilepsy and around 80 people are diagnosed with epilepsy each day. To put it into perspective there are around 9 children with epilepsy in an average secondary school.
There are many other conditions that lead to collapse where you need to be noticed and accessed quickly eg. diabetes.
I have experience of saving a young woman’s life as I noticed her blue hand poking out of a door gap on a nightclub toilet floor. We got over the top of the door (there was a large gap between the door top and ceiling), pulled her body out the way and opened the inward opening door. She had choked on her own vomit and was silent but we cleared her mouth and she started breathing properly again. A recent government report noted 80% of the incidents of drink spiking happen in public places, usually in bars and clubs, mainly to women, average age 26.
Prevention of sexual assaults
In any space that becomes private, more offences are likely to take place. In Parliament it was discussed that there was at least 1 rape inside a school premises each day (over 600 in a 3 year period). The data, collected by the BBC, mentions an example occurring in a private cupboard. This was in 2015, before many schools decided to change their toilet designs to fully enclosed and mixed sex. There is no available data on these new toilet designs but, teachers and pupils are reporting many problems with drug dealing, dirt and sex. The toilet door gaps are vital for safeguarding to help prevent activities that stop pupils, especially girls, going to the toilet. There are known problems of girls avoiding toilets and getting urinary infections or missing school. The legislation does not affect schools but they are at the ‘coalface’ in new design.
A quick internet search brings up the disproportionate number of sexual assaults and rapes that happen to able bodied and disabled women and girls in disabled toilets in this country which are obviously mixed sex and fully enclosed toilets, often in very public places.
More problems with toilets with enclosed full height doors are:
- Ventilation is decreased so there’s a higher risk of disease spread.
- Evacuation times are greatly increased as a responder can’t tell quickly if stalls are occupied.
- Hygiene is compromised as a mop can’t go underneath the doors nor floor be washed down. It is awkward to enter the cubicle with a mop and detritus ends up on the partition corners.
- Doors are more likely to get stuck/warped and the cubicle out of action.
- People are more likely to engage in illegal activities (drugs) or self harm if they are in a private space.
- The length of time in a cubicle is increased, especially if the wash basin is in there so queues are longer.
- Occupants can’t see if anyone is lying in wait outside their cubicle if they are feeling vulnerable.
Why have toilet cubicle door gaps disappeared from the new public toilet designs?
There are many articles and videos on why we have gaps under and over toilet doors - so it is worrying these have been ignored. The initial government consultation that was publicised several years ago led to Stonewall coordinating a response and very effectively dominating the results. There is nothing wrong with this lobbying but the policy goals that were created from the initial consultation concentrated on mixed sex ‘universal’ toilets and privacy because of toilets being mixed sex.
ARUP was appointed by the Department for Levelling Up, Housing and Communities to carry out research into the toilet requirements of the population of England in the built environment, in particular disabled people and people with long-term health conditions. The government also did a second consultation. I wrote a lengthy response to the second consultation, detailing the statistics and need for door gaps but none of these issues were mentioned on published consultation results.
In the ARUP document, the justification (evidence and literature) for fully enclosed toilets comes from two American sources on p.129 of the report. I have spent time analysing these sources as so much seems to depend on them. One references the other which has the reason for the fully enclosed idea discussed in their paper referenced by ARUP: ‘A better solution, supported by many transactivists, and increasingly found in trendy nightclubs and restaurants, is to eliminate gender-segregated facilities entirely and treat the public restroom as one single open space with fully enclosed stalls.’
No safety concerns of fully enclosed cubicles were acknowledged in these two ARUP ‘evidences’.
So the Arup recommendation for fully enclosed cubicles is from a tiny amount of very poor evidence and literature focused on a different group. Their ‘evidence’ bears no resemblance to any of the designs of UK toilets in Document T. Their ‘evidence’ does not take into account any long term health conditions nor disabilities’ analysis.
In the whole Arup document there was no mention of the words: seizure, faint, diabetes, cardiac, heart, epilepsy, syncope, endometriosis, menorrhagia, collapse. There was one mention of ‘stroke’ in reference to a grab rail. However I would argue that a floor-to-door gap is vital in design for those having a stroke and those who are frail because of a previous stroke.
What other equality impacts have been done?
I can not find any other evidence or research as to why the designs are fully enclosed in the published documents. Obviously this does not mean everything has been published. However, the Equality Impact Assessment for the Provision of Toilets (updated 15th May 2024) does not mention door gaps. It goes through all protected characteristics and does not identify any negative impacts of full enclosure.
Conclusion
Specifying toilet door gaps will enable offices, shops and entertainment venues to be suitable for workers and children with health conditions where there is a chance of collapse without warning and then Document T will comply with Equality Act 2010, The Health and Safety at Work Act (1974), Children Act 1989.
In terms of negative impacts for the protected characteristics in the Equality Act (2010), the absence of door to floor gaps in design affects age, sex (discussed above), disability (discussed above), and pregnancy and maternity. It affects everyone in terms of disease prevention, a medical emergency and fire evacuation.
I tried contacting Lee Rowley MP and his Department of Levelling Up, Housing and Communities department, Kemi Badenoch, the Health and Safety Executive (they say it’s for Department of Levelling Up, Housing and Communities department) and the Building Safety Regulator (who say it's for the Health and Safety Executive). And the shadow equivalents. No response.
The designs in Document T do specify that every door should be able to be opened from the outside and an inward opening door catch released so it can be pulled outwards (although I am not sure how public-savy the design will be for rescue). At the very least there should be a door gap of sufficient height between the floor and the bottom of the door to safeguard the occupant in single sex toilet designs C and D. As the designs are in Document T, there is no specification other than full height doors.
The government needs to enable people with long-term health conditions to live safe lives and help them be independent and in work. It needs women and children to be safe and prevent assaults through good design.
So has the government dismissed the rights of certain disabled groups (people with epilepsy etc) to a safe working and leisure environment?
Have they completed an emergency evacuation assessment and a fire risk assessment for a row of fully enclosed toilets compared to a ‘traditional’ row of toilets with door gaps?
Have they risk assessed the impact of disease spread from less cleanable and less well ventilated fully enclosed toilets?
Do they recognise the danger of fully enclosed toilets for the chances of surviving a long term injury or death from collapse such as from a heart attack, stroke, epilepsy, brain injury, diabetes and fragility?
And do they recognise the dangers, particularly to women and children, that a private space in a public area brings?
The single sex designs C and D need to specify floor-to-door safety gaps. If models A or B are used in single sex toilets, they need their design altered to include floor-to-door safety gaps. I would prefer mixed sex toilets to have door gaps too but if single sex are the default, then that’s a start.
Mind the gap! It could save your life.