New toilet criteria set for non-residential buildings

In May 2024, the previous UK government announced new requirements for single-sex toilet facilities in England in most new non-domestic buildings and those that change use, with the aim of alleviating concerns about safety, privacy, and dignity.

Toilet accommodation: Approved Document T comes into force on 1 October 2024 to support the new requirement, complemented by revisions to Sanitation, hot water safety and water efficiency: Approved Document G and Access to and use of buildings: Approved Document M.

The publication follows a 2020 call for evidence, which attracted some 17,500 replies and a subsequent consultation in 2023.

Responses to the consultation showed that 81% of respondents agreed with the intention to provide separate single-sex toilet facilities in applicable buildings, and 82% with the plan for 'universal toilets' where space allows.

A universal toilet is intended for use by all; such facilities are defined as being provided in a fully enclosed room that contains a toilet itself along with a washbasin and hand-drying facilities, for individual use by persons of whatever sex.

The requirement for separate single-sex toilets in non-residential buildings, along with individual or shared single-sex hand-washing facilities, takes effect on 1 October 2024 with the new approved document itself, subject to transitional arrangements for buildings already under construction.

Universal toilets can be provided in addition to single-sex facilities where space allows, and where there is insufficient space for single-sex toilets then fully enclosed universal toilets should be provided.

In meeting the additional requirement for single-sex toilets, building surveyors, principal designers and principal contractors should also refer to guidance on the calculation of sanitary provision.

These are considered in Approved Document G and BS 6465-4: 2010 Sanitary installations – Code of practice for the provision of public toilets.

Guidance on the number of toilets required by building type is given in paragraphs 4.12 to 4.14 of Approved Document G, which also covers the provision of handwashing facilities and the separation of toilets from kitchens and areas where food is prepared.

Other best practice guidance on the provision and design of toilets is given in BS 6465-1: 2006 + A1: 2009 Sanitary installations – Code of practice for the design of sanitary facilities and scales of provision of sanitary and associated appliances.

It also details the layout, dimensions and fittings required for two kinds of WC for ambulant people with disabilities: type A for universal and C for single-sex facilities, in sections 3 and 5 respectively. All toilets should also have clear and appropriate signage.

Guidance on the design of wheelchair-accessible unisex toilets and WC cubicles for ambulant people with disabilities is already provided in section 5 of Approved Document M volume 2, which also describes the sanitary provision that should be made for baby changing and Changing Places-standard toilets.

BS 6465-4 similarly covers children and babies in section 10.2 and people with disabilities in section 10.3 and, like Part M, considers the provision and design of wheelchair-accessible unisex toilets and WC cubicles for ambulant disabled people. Other sanitary provision for baby changing and Changing Places toilets should be provided as described in Approved Document M.

Approved Document T sets out a requirement for the provision of specific toilet accommodation to enable single-sex facilities in buildings other than dwellings. It further provides guidance on the size, layout, fittings and equipment for universal and single-sex toilets, and two ambulant options for each type.

Where space precludes the provision of single-sex toilet facilities under Approved Document T, fully enclosed universal toilets should be fitted. The space available for toilet accommodation will vary from building to building but, once reasonable provision is made for single-sex facilities, any remaining can be considered for universal toilets.

It should be noted that Approved Document T does not apply to dwellings, schools, premises used for early years provision, cells in custodial facilities or en-suite toilets in individual rooms for residential purposes at, for example, hotels and care homes.

Where toilets are provided, those carrying out the building work should take account of the needs of all potential users, whether visitors or those who live or work there. It is not appropriate other than in exceptional circumstances to assume that certain groups of people will be excluded from using the facilities.

In line with the guidance in section 5 of Approved Document M volume 2, all buildings other than dwellings should be provided with a wheelchair-accessible unisex toilet as well as single-sex toilets.

Where space reasonably precludes single-sex toilets, those requiring additional provision should take the occupancy of the building into account and the likely needs of its users.

Types A and B are primarily intended for universal use, though they may also be used for single-sex facilities if self-contained toilets are preferred to cubicles.

A universal toilet is available for everyone and is not considered a single-sex toilet. However, fully enclosed, self-contained toilets can feature as part of single-sex provision.

Part M refers to the provision of wheelchair-accessible toilets, which are already gender-neutral, and should not be confused with the universal toilet for use by all in Approved Document T.

As such, Approved Documents G, M and T do not apply where a building notice or an initial notice or application for building control approval with full plans is given to the relevant authority before that date.

To qualify, the building work to which it relates must either:

• have started and be sufficiently progressed before that day, or
• have started and be sufficiently progressed within a period of six months beginning on that day.

For the purpose of these transitional provisions, 'sufficiently progressed' signifies one of the following situations, as set out in the introduction to Approved Document T:

• where the work consists of the construction of a building and concrete pouring for the permanent placement of the trench, pad or raft foundations has started, or the permanent placement of piling has started
• where the work is to an existing building and has already started
• where the building work consists of a material change of use and has already started. 

Given the number of applicable requirements across several documents, colleagues in building control are well placed to support the understanding of the new guidance in Approved Document T and the related amendments to Approved Documents G and M.