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Feminism: Sex and gender discussions

ICA in London: loos

31 replies

LittleBitofBread · 19/10/2025 15:55

I was at this venue this weekend and they have, in one room, four standard cubicles plus an accessible cubicle, with sinks and hand dryers outside the cubicles. Obviously both men and women were using them. Am I right in thinking this isn’t lawful?

OP posts:
Keeptoiletssafe · 20/10/2025 10:53

Are these them @LittleBitofBread ? Are the shared sinks to the right, obscured by the wall?
A quick google of their website showed me this picture. Their website is very inclusive in terms of helping people to navigate and understand what to expect when visiting.

edit: photo didn’t attach so adding link https://www.ica.art/visual-story-guide#what

Lovelyview · 20/10/2025 12:23

MyAmpleSheep · 19/10/2025 17:51

Can I ask: do unisex loos have to open onto a public area? What’s the reasoning?

I would ask anyone claiming that they do to say which regulation requires this.

You are correct that the specifications for providing single sex toilets in
The Workplace (Health, Safety and Welfare) Regulations 1992 only apply to employees. However, failing to provide women customers with female only toilets or properly enclosed unisex toilets could be discrimination or harassment. This hasn't been tested in law yet. OP, write to the ICA and explain how uncomfortable you felt sharing a toilet space with men. Ask them to provide single sex toilets or properly enclosed toilets for their customers. It is really uncomfortable sharing a hand washing area with men and you are not being unreasonable to raise this.

MyAmpleSheep · 20/10/2025 12:25

LittleBitofBread · 20/10/2025 09:08

Good question. I probably won't/wouldn't try to say it was harassment, for the reason you give. I may well write and point out that it discriminates against women who cannot use such an intimate mixed-sex facility for religious/cultural reasons though, and point out that we have a problem in the UK with attendance at galleries and museums by people belonging to minorities, which this cannot help. As well as it infringing the rights of both men and women to privacy and dignity.
I can already envisage what kind of reply I'm going to get, though.

I think what you propose to write is good.

Keeptoiletssafe · 20/10/2025 13:45

‘Under the Health and Safety at Work, etc Act 1974 (HSWA) the person who is in occupation or has control of the premises owes a duty of care to all their visitors. Employers must ensure, as far as is reasonably practicable, that in the course of their activities, persons who are not their employees are not put at risk.
Furthermore, the Management of Health and Safety at Work Regulations 1999 require an employer to “make a suitable and sufficient assessment of the risks to the health and safety of persons not in his employment arising out of their undertaking”. So the duty to carry out risk assessments extends to visitors as well as employees. A risk assessment should look at the potential risks for a visitor entering your premises and decide what precautions should be put in place, such as communicating on site safety information.’ This is from a lawyers website. The HSE info on 1974 regs is here.

I can see a lot of problems in terms of risk assessments for the toilets on their website which I have managed to attach a picture now. The coloured lighting I am presuming is a design choice rather than a way of preventing drug use (which has been deemed unsafe anyway). There are health and safety risks with coloured lighting and the British Toilet Association does not recommend it. I would not consider coloured lights to mean the cubicle is ‘well-lit’ like it should be in legislation.

It looks like the toilet cubicles can be opened easily with a coin turn which is good but I am not sure how they change to open outwards, to allow the retrieval of someone collapsed against the door. A good demonstration of good design can be seen .

There is a danger of someone being in there for a long time as the floor-door gap is minimal. This discriminates against people with medical conditions such as epilepsy, diabetes, heart conditions.

It does say there are female and male toilets in other sections of the building so it could be argued that people with known conditions or those that prefer single sex toilets would have a choice. However, this isn’t great for anyone having a medical emergency like a cardiac arrest (11% happen on loos) or a woman or child getting pushed into the loo. You need good sightlines for many women to feel comfortable. Also having shared sinks isn’t very dignified if you have blood on your hands in front of men.

Unisex toilets (which was traditionally the disabled one) were placed opening on to a main foyer for safety reasons - so you could monitor who was going into the private design. I have got lots of examples where women and children have been abused in toilets in very public spaces for example train carriages, stations, schools, clubs. What seems to be the common factor is the privacy and sound resistance. These don’t look the worst but it depends where they are positioned.

As well as preventing assaults, the door gaps serve as a very quick way of evacuating a building in the event of a fire. When you ‘check the loos’ in a fire drill, it takes much longer when you are checking each individual cubicle rather than checking for feet. There is a duty to risk assess for fire safety. There were some nasty accidents which lead to the introduction to the 1974 Act. There are regs on which doors need to be considered fire doors.

The final bit is ventilation. There should be a specific number of ‘turnovers of air’ so pathogens and smells don’t build up. These should probably need mechanical ventilation to be compliant. I can’t tell from the photo.

There are best suited to healthy men.

ICA in London: loos
UtopiaPlanitia · 20/10/2025 15:59

@Keeptoiletssafe Thanks again for the information you provide across multiple threads, I always find your subject knowledge informative and helpful.

LittleBitofBread · 20/10/2025 16:25

Keeptoiletssafe · 20/10/2025 13:45

‘Under the Health and Safety at Work, etc Act 1974 (HSWA) the person who is in occupation or has control of the premises owes a duty of care to all their visitors. Employers must ensure, as far as is reasonably practicable, that in the course of their activities, persons who are not their employees are not put at risk.
Furthermore, the Management of Health and Safety at Work Regulations 1999 require an employer to “make a suitable and sufficient assessment of the risks to the health and safety of persons not in his employment arising out of their undertaking”. So the duty to carry out risk assessments extends to visitors as well as employees. A risk assessment should look at the potential risks for a visitor entering your premises and decide what precautions should be put in place, such as communicating on site safety information.’ This is from a lawyers website. The HSE info on 1974 regs is here.

I can see a lot of problems in terms of risk assessments for the toilets on their website which I have managed to attach a picture now. The coloured lighting I am presuming is a design choice rather than a way of preventing drug use (which has been deemed unsafe anyway). There are health and safety risks with coloured lighting and the British Toilet Association does not recommend it. I would not consider coloured lights to mean the cubicle is ‘well-lit’ like it should be in legislation.

It looks like the toilet cubicles can be opened easily with a coin turn which is good but I am not sure how they change to open outwards, to allow the retrieval of someone collapsed against the door. A good demonstration of good design can be seen .

There is a danger of someone being in there for a long time as the floor-door gap is minimal. This discriminates against people with medical conditions such as epilepsy, diabetes, heart conditions.

It does say there are female and male toilets in other sections of the building so it could be argued that people with known conditions or those that prefer single sex toilets would have a choice. However, this isn’t great for anyone having a medical emergency like a cardiac arrest (11% happen on loos) or a woman or child getting pushed into the loo. You need good sightlines for many women to feel comfortable. Also having shared sinks isn’t very dignified if you have blood on your hands in front of men.

Unisex toilets (which was traditionally the disabled one) were placed opening on to a main foyer for safety reasons - so you could monitor who was going into the private design. I have got lots of examples where women and children have been abused in toilets in very public spaces for example train carriages, stations, schools, clubs. What seems to be the common factor is the privacy and sound resistance. These don’t look the worst but it depends where they are positioned.

As well as preventing assaults, the door gaps serve as a very quick way of evacuating a building in the event of a fire. When you ‘check the loos’ in a fire drill, it takes much longer when you are checking each individual cubicle rather than checking for feet. There is a duty to risk assess for fire safety. There were some nasty accidents which lead to the introduction to the 1974 Act. There are regs on which doors need to be considered fire doors.

The final bit is ventilation. There should be a specific number of ‘turnovers of air’ so pathogens and smells don’t build up. These should probably need mechanical ventilation to be compliant. I can’t tell from the photo.

There are best suited to healthy men.

Yes, that's them. They're on the ground floor just after you go in, on the left. You enter by the main lobby.
I didn't realise there were more elsewhere (I have been to the ICA quite a few times, but this was my first time for ages, and I can't remember any other loos).
In theory you could use the others, but on this occasion I was there for a film, which was screening just a short walk further on from these loos. Obviously being a film I had to be there for the start time (as in, I wasn't going to an exhibition where you can just wander in whenever), so going to find another set of loos would have been time-consuming and might have meant I missed out on the start.
I don't know if they have mechanical ventilation. I don't remember thinking they stank though.

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