Hi I know some posters will have seen this long post before but a couple have asked me for the links.
Because the last government were looking at all the concerns people had about all new designs of public toilets (like the ones people mention here), they had been looking at standardising designs for the past few years. Unfortunately the designs they came up with need refining to be safe. They are going to be in any new non domestic building, or any toilet refurbishment in places like shops, offices, cinemas, stadiums etc.
Document T details the toilet designs that will come in to force in October 2024 in the UK. The toilet designs are dangerous for everyone but in particular, disabled people, medically vulnerable, women and girls.
Universal is for everyone and includes a sink and hand dryer . Ambulant is for frail people or people needing extra place.
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, no partition 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. It is estimated there are 400,000 people in the U.K. with undiagnosed cardiac problems.
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.
A recent government report noted 80% of the thousands of 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. This legislation does not affect schools but they have been at the ‘coalface’ of new experimental toilet designs so it a good demonstration of what goes wrong.
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 such as busy train stations and shopping centres.
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.
- Occupants can’t see if anyone is lying in wait outside their cubicle if they are feeling vulnerable.
- because they are enclosed the regulation states they have to be easily opened from the outside, so people can let themselves in when not wanted too.
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 analysed these sources as so much seems to depend on them. These are a restroom design for a Minnesota high school and an American paper from Joel Sanders and Susan Stryker. The later two authors are referenced in the Minnesota project. In a recent Harvard talk (from Stud to Stalled YouTube April 2024), Sanders said that transgender access to public restrooms rekindled his interest in queer space so he set up the ‘Stalled’ company with Prof Susan Stryker, but he admitted he did not have enough data on whether his designs worked as so few had been built. The reason for the fully enclosed idea is 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’. No analysis has been done on the safety on fully enclosed cubicles. The only ‘evidence’ was the Minnesota school questionnaire students to answer tick box questions, about the all-inclusive restroom design (very open plan, with security cameras, separate sink rows). Only 43%, who knew both restroom types, preferred the all-inclusive model to whatever their old restrooms were (the difference approx 35 females, 83 males).
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.
Considering it was looking at the requirements of people with long term health conditions, in the whole 171 pages of the 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. There are two pages of lists of references to handrails. However I would argue that a floor-to-door gap is vital in design so it can be seen they have collapsed.
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. 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.
The Health and Safety Executive have responded to my emails by saying that ‘the the gaps at the bottom of a door and cubicle partition were removed for universal toilets (Types A and B) to give people the option of privacy and dignity…’
I think the option of greater health and safety will be denied if only A and B are used.
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 satisfy the requirements in 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.
The new 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.
These designs have dismissed the rights of certain disabled groups (people with epilepsy etc) to a safe working and leisure environment.
There appears to be no 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.
There is no risk assessment on the impact of disease spread from less cleanable and less well ventilated fully enclosed toilets.
They do not 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 they do not recognise the dangers, particularly to women and children, that a private space in a public area brings.
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.
It would also be life-saving to have floor-to-door safety gaps in all medical settings that are single sex in design.
Safety should always come first. Door gaps are like a car seat belt - you might never need them but when you do they are lifesaving.