If you want a good example of how invisible disabilities are actually invisible when deciding policy, try and look for them in the government commissioned report for Document T. Document T are the regs for all public toilets and office toilets (a few exclusions such as schools) that came into force, after long consultations, last year.
The government commissioned a private company 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 detailing the statistics and need for door gaps but none of these issues were mentioned on published consultation results.
Considering they were looking at the requirements of people with long term health conditions, in the whole 171-page document there was no mention of words: seizure, faint, diabetes, cardiac, heart, epilepsy, syncope, endometriosis, asthma, menorrhagia. There was mention of ‘stroke’ in reference to a grab rail. There are two pages of lists of references to handrails. However a floor-to-door gap is vital in design for those having a stroke and those who are frail because of a previous stroke, so it can be seen they have collapsed from outside the cubicle for timely rescue. They did discuss studies for crotch heights for trans and non-binary users of urinals.
The justification (evidence and literature) for the fully enclosed toilet designs for this group comes from two American sources. These are a restroom design for a Minnesota high school and an American paper from Joel Sanders and Susan Stryker. In a recent Harvard talk (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: ‘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 on rescue times. No analysis has been done on the safety on fully enclosed cubicles. The only data was the Minnesota school questionnaire asking high school students to answer questions about the all-inclusive restroom design (shown as very open plan, with security cameras, separate sink rows). Full height ‘walls’ were rated in 3rd place for safety from the pre-supplied answer list. Only 43% of pupils, who knew both the old and new inclusive restroom types, preferred the all-inclusive model (to whatever their old restrooms were). The difference equates to the tick box questionnaire results of approximately 35 girls and 83 boys.
Therefore the recommendation for fully enclosed cubicles is from a tiny amount of 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 the most common long term health conditions, nor any analysis related to collapse.
I did not expect that this was a reason that some designs had changed to enclosed toilets when I started looking at this. It was through ploughing through all the consultation documents trying to find why my voice wasn’t heard for people with invisible disabilities and health conditions. The private company that did the report won a Stonewall Gold Award the year after this was published.
https://consult.communities.gov.uk/energy-performance-of-buildings/toilet-provision-in-buildings-other-than-dwellings/supporting_documents/Annex%20D%20research%20on%20toilets.pdf