Is this what a sane but pro-Trans response to the EHRC Guidance looks like?

[RareGoalsVerge]

I thought this was worth sharing as a potentially welcome, rational response to the EHRC guidelines. It's not perfectly in line with what we as feminists want, but it is way better than the toddler-tantrum responses I have seen elsewhere:
https://transfiguredmission.uk/wp-content/uploads/2026/06/faqs-for-churches-following-ehrc.pdf

It is clearly written from the point of view of wanting to be as inclusive as possible, within the scope of the law as it stands.
You cannot expect or require trans people to use the ‘wrong’ toilet, therefore you will need sufficient mixed sex / all gender toilets. You must be careful not to simply repurpose the disabled toilet as this could amount to unlawful disability discrimination.

If you have single rooms / cubicles with a lockable floor-to-ceiling door the simplest way to cater fairly to everyone is to make them all unisex – or most of them if you have lots. If you currently only have two – one labelled M and one F - you must do this.

This seems rational to me. The document goes on to highlight that for the most part, everything that reasonably can be unisex/open to all should be - and describes that things which should be legitimately single sex might include

• whether women are likely to be in a state of undress
• whether there will be limited ability for women to leave or to choose an alternative service
• whether the service is provided a result of, or connected with, male violence against women
• whether the physical differences between men and women are relevant to the experience of the service and put women at a particular disadvantage

Most single-sex church groups would not be ‘necessary’ under this analysis. You cannot require trans people to attend the group that corresponds to their ‘birth sex’

There's plenty not to like - I wish they didn't refer to things that are legitimately single sex as being for cis women - obviously cis is inappropriate for large numbers of women who have just been getting on with their lives for a many decades just existing as best they can under a patriarchy without the luxury or priviledge of the leisure to work out if they have a gender identity, and also many things in the above bullet-pointed list would be very much appropriate for people who are female but identify with a masculine or non-binary identity, so a better document would highlight benefits to female people of all gender identities rather than using cis. In the toilets section the authors clearly know, by implication, that gender neutral toilets are only legitimate if they are fully enclosed with floor-to-ceiling walls and doors, but fail to explicitly mention this or to draw attention to the well-known health and wellbeing detriments that arise when people are taken ill in such facilities. And the fact that they signpost to the Good Law Project at the end is disappointing.

But despite all this I thing its a welcome example of how reasonable organisations of good intention might do their best to find a reasonable way forward within the law, rather than just trying to ignore the law and carry on prioritising male people's wishes over female people's needs.

My work here is done 😅

This document in the original post not been written by anyone who has knowledge of toilet regulations. There are certain phrases that I would question who the author was as I have heard them before. I would add a disabled toilet has been called an accessible toilet for years because it is for the needs of users with many different conditions, not just wheelchair users.

Yes you can’t make the accessible into a non accessible toilet. That would be very uncharitable and building control would not be happy. However, people who can not use the male or female toilets as they are not suitable for any reason, can use the accessible.

It’s not great if disabled people have to wait longer. It’s also not great that disabled people don’t have the option of single sex toilets. It’s not great that unisex toilets cause safeguarding problems for all different reasons and may exclude people. ‘you must provide toilets for everyone’ is not true unfortunately as that means changing places toilets would be widespread.

Toilets should based on absolute need not want. Is there a working toilet? Is there a toilet that all can physically use? Is it safe to use and clean? Those are the basics.
Churches usually try very hard to have an accessible toilet for the needs of their congregation. I know it was the only toilet design in my local church as it only had one toilet.

So, to the OP, like others, I don’t think this is a good document and isn’t useable.

I was interested in the legal link but it displayed a 404 page to LewisSilkin.

Anecdotal, rather than proper evidence, but I get the impression some men think that any man who debases himself by wanting to be a woman, do think these men aren’t proper men any more.

Similar to homophobia, I guess, but there are undoubtedly men who feel uncomfortable with these men in their spaces.

It really is them who should get over it, because those cross dressing men don’t present a genuine risk to other men, the way they do to women.

No, it is not.

Moral behaviour, inclusivity, cooperation and compassion are the basis of a civilised society.

The law simply attempts - and very often gets it wrong - to codify these principles into a set of guidelines we largely agree to live by.

I think some single cubicles are a way forward. Lots of places have this. My workplaces slammed a gender neutral sticker on all of these months ago but we still need single sex spaces.

I went to a venue yesterday with a staircase down to an area sign posted as “5 single cubicles.” First door wide open middle aged man back to us taking a piss. Ushered kids past into the empty cubicles and I said loudly “mate it’s unisex you need to shut the door.”

as I said to my daughters men just cannot behave and in this instance can turn a unisex space into somewhere my daughters should not have to be in.

I don't like the idea of more unisex toilets either, but the EHRC guidance does say that trans people shouldn't be left without an alternative. And as someone with a disability, I would add that it shouldn't be at the expense of disabled people.

I collapsed in a toilet once and was helped by a woman who saw me on the floor.

Since the vast majority of the people who use the meeting rooms are women, we've had situation where women are waiting for one toilet while the other went unused.

Aside from the fact that men do tend to be more messy I've never understood why women do this (or why single cubicles are ever sexed, for that matter). If the "mens" is a single lockable room then I use it if there are no men waiting for it.

Of course that will now be trespass (a civil offence not a criminal one), but I'll still be doing it.

Emergency cords and buttons are far, far safer than just expecting someone to come by and see you in a gap under the door.

Provided you can reach them from your position on the floor and provided you haven't lost consciousness before being able to activate the alarm.

'Moral' behaviour, though, is not a definitive item or list in the way suggested.

'Morality' is s set values, principles, rules or considerations which people use to guide their behaviour and choices, not something that is super-imposed rigidly onto every situation. Our assessment of any given situation will vary in how we decide to approach it and where we decide the boundaries lay

'Inclusion' is really only a recently inserted moral good. There is nothing inherently good about 'inclusion' as a value, and certainly not when it is used to include men in categories that have been set aside to provide for the dignity and safety of female people. In fact. 'including' some men is to many wholly immoral in that it over-rides the boundaries ( boundaries are, in certain respects, the very foundation of morality) that have been established to do just that.

It is not 'kind' to evaluate the needs of one group as as being of higher value than those of the group who that category/facility/service was originally set up to cater for.

Contrast

Your starting point in the provision of services should be that they should be provided to everyone. So all gender / mixed sex services should be the default.

If you wish to provide a separate or single sex service (which would exclude anyone not of that sex i.e. most trans and non-binary people, as well as people of the opposite sex) you have to be able to justify why that is necessary, show there isn’t a less intrusive option available, and balance the impact on trans people.

with

It is also lawful generally to provide a service only to people who share a particular protected characteristic, e.g. a group for gay people, or a group for trans people.
It is likely also to be lawful to provide a service only for people of more than one particular protected characteristic – e.g. LGBT people

So you can provide services like breakfast clubs for any of the protected characterisitics except for the sex-class of women. If you want to provide them for the sex-class of women you need to jump through lots of hoops and be labelled as one of those 'virulent anti-trans campaigners' to boot.

This is the same age-old misogyny from those Churches and is further exemplified by the Quakers link, where I can almost feel the contempt for women dripping off each word. I'm sorry OP, but I dont see anything in that document other than an attempt to push the limits of the law as far as possible in favour of the boundary-crossing men.

That really isn't anecdotal, its an opinion, which is fine to have.
But you are just buying into a line that clearly isn't happening

Because if there was an issue with trans women being attacked in men's toilets it would be all over the news and internet. As that is what the trans lobby have used, to push their agenda.

There are even two trans women that take pictures in men's toilets to show how safe it is.

For the talk of men must make trans women welcom in their toilets, the actual truth is that men just don't spend long enough in there to care.

@AimsAndObjectives This is the same age-old misogyny from those Churches and is further exemplified by the Quakers link, where I can almost feel the contempt for women dripping off each word. I'm sorry OP, but I dont see anything in that document other than an attempt to push the limits of the law as far as possible in favour of the boundary-crossing men.

I was particularly saddened by the Quakers' position statement. It has moved on a lot. In 2019, the Norwich Meeting hosted a WPUK meeting, which caused a furore, and they published this thoughtful account of it and of what they did to try to understand both sides better. It's been deleted from their website (odd, that), but some smart person archived it. It's long, but IMO worth a read, and the seeds of the current position can be seen very clearly: https://archive.is/2SeXW (I'm also amused that that link's address includes the word Sex!).

Extract: We understood that transphobia is a real, constant and appalling threat to transgender people; but we also realised that there are genuine causes for concern among some natal women about the proposed change to the GRA. Quakers have a tradition of attempting to build bridges between parties in conflict and, as this conflict had arisen on our premises, as a result of a decision we had made, we considered the possibility of bringing together individuals on either ‘side’ to hear one another’s stories, and hopefully gain empathy for one another’s positions. It quickly became clear, however, that those people who consider any discussion of the nature of female identity or of possible threats to women by natal men who say they are female, and make their objections in hostile or threatening ways, would not agree to meet with individuals with different perspectives.

Emergency cords and buttons are far, far safer than just expecting someone to come by and see you in a gap under the door.

In a high-traffic environment, door gaps are just as good as a cord for prompt detection of an ill person. Door gaps don't have the problem of prankers or small children activating them. Door gaps can't be left tied up just below the ceiling by the installer and never unknotted, making them useless, whereas I've lost count of the number of pullcords I've seen like that (and personally climbed up and unknotted or else complained to the staff about). Door gaps can't snap off, be cut off by building occupants sick of false alarms, or be looped up out of the way of the floor mop by cleaners§. Door gaps work during power cuts. And lastly but most importantly, door gaps work when the toilet user is unconscious.

§ IME, cleaners are the biggest risk to an organisation's buildings safety. If you find a fire door with "fire door keep shut" literally written on it chocked open anywhere, a cleaner will have done it.

There is nothing in the law or EHRC guidance that stops trans-identifying people from using the correct toilet of their sex. No organisation is going to stop a trans-identifying female from using the ladies' loos, even if a rape counselling service says "lass, you've got a full beard, we can't let you into group therapy sessions".

@SqueakyDinosaur Thanks for this link. It does show that at least one section of the Quaker movement tried to listen to both sides, but it seems that the movement as a whole, whether it listened to both sides or not, came down on the side of the men.

As a bit of an aside, when I used to work in public buildings with an accessible toilet, I used to get Red Cord Awareness cards (which hang on the cord) from Euan's Guide to make public and staff aware to not tie up the cords. If I see cords tied up when I'm out and about, I let the premises know about the cards.

That’s against building regulations.

I always unravel the cord but must get some of these cards.

Hopefully a positive is that people will have new found respect for the accessible toilet and start treating them better.

Cleaners are at risk themselves in toilets. I can understand why some women don’t want to clean them out of hours.

Is it? This is in Scotland. I’d be interested to know more about this as I might complain.

There were sinks, floor to ceiling doors. But obviously if you leave the door wide open it’s neither here nor there.

Not to mention using them for purposes other than peeing or pooing. Especially if there are women in adjacent cubicles.

The inevitable consequence of this incoherent, car-crash guidance is that providers will, as much as possible, switch to mixed-sex provision. That's what you get when you wish on a monkey's paw. Gender critical people will be spending a lot more of their time pissing in rooms with actual men rather than one in a hundred times pissing in a room with a trans woman.

The most efficient provision is STALLS and STALLS + URINALS.

The one which large companies go for is unisex lockable cubicles with a loo and a urinal.

Quick poll fellow UK posters! (as this is UK legislation)

Do you ever use the word 'stalls' to refer to toilet cubicles?

@Waitwhat23 Never