SWECO BUILDING STANDARDS GUIDANCE NOTE

Part T Building Regulations Summary – Toilet Accommodation

Introduction

The introduction of Part T – Toilet Accommodation to the Building Regulations has formalised the Government’s intention to use regulation to encourage the installation of single-sex toilets over gender neutral facilities. Following research, the Government felt they needed to address “particular concerns from women, elderly and the disabled who felt unfairly disadvantaged as publicly accessible toilets are increasingly being converted into gender neutral facilities where users share cubicle and hand-washing facilities. This leads to increasing waiting in shared queues, decreased choice and less privacy and dignity”.

Part T applies to applications that are made after 1 October 2024 or made prior to this but fail to be sufficiently progressed by 1 April 2025. The toilet provision has a major impact on the design of cores, and Part T tends to result in a greater space allocation. Clients should be made aware of the need to take this into account on projects that will not benefit from the transitional requirements.

Guidance on the meaning of sufficiently progressed and buildings which Part T does not apply to is outlined towards the end of this guidance.

Part T has been added to Parts A, B1, B3, B4, B5 and M as a section that defines building work under the building regulations,  in relation to “material alterations”. This means any change of toilet design and/or designation covered by Part T, in an existing building, would need statutory approval. The consideration of compliance would be subject to the “no more unsatisfactory” consideration in terms of reasonableness.

Part T also applies to material changes of use where the building is:

  • A hotel or boarding house where it previously was not;
  • A public building where it previously was not;
  • Not an exempt building where it previously was; or
  • A shop where it previously was not.

Guidance

In consideration of the appropriate approach to sanitary provision the following Building Regulation guidance should be referred to:

  • Part G (numbers of toilets provided)
  • Part T (Single Sex, Universal Toilets split and design)
  • Part M (Accessible facilities – Wheelchair Accessible, Changing Places, Enlarged and Ambulant)

The Building Safety Act 2022 places criminal accountability on the duty holders to ensure that the design and construction complies with the regulations.

Any application that Part T applies to should be provided with documented justification to the approach that is taken to comply with Part T.  This “justification” could be extracts from the “Principal Designer’s Building Regulations Relevant Requirements Tracker”.  Ideally the document would be signed off by both the design team and the client, indicating the client understands and agrees with the approach proposed.

The client’s requirements may determine the need for universal provision in addition to the single sex facilities.

Critically the regulation states that Universal Toilet Provision is considered as additional to the single sex toilet provision. Consequently, Sweco’s view is that the single sex toilet provision should, on its own, meet the numbers of toilets to be provided to satisfy Part G. If toilets designated to a sex are designed to the universal standard these may count towards the numbers of toilets required by Part G.

Part G gives a number of guides to assist in calculating provision for specific uses, where a specific guide does not exist BS 6465-1-2009 should be used. The guides are:

  • The Workplace (Health, Safety and Welfare) Regulations 1992 Approved Code of Practice (ACOP)
  • Sport England’s guidance on ‘Accessible facilities’
  • School Premises (England) Regulations 2012 (for maintained (local authority) schools)
  • Education (Independent School Standards) Regulations 2014 (for Academies and independent schools)
  • Education (Independent School Standards) Regulations 2014 (for Academies and independent schools)
  • NHS England’s Health Building Note 00-02: Sanitary spaces

It should be recognised that although ACOP is given as acceptable guidance, for Workplace provision, this guidance does not reflect current thinking particularly with respect to female provision. The provision in ACOP is based on BS 6465 Part 1 1994, which has been withdrawn following updates in 2006 and 2009. The updates tend to result in a greater provision and in particular recognised the under provision for females that resulted from the guidance given in the 1994 version. If a client uses the ACOP they should be made aware that, although acceptable as a minimum standard for the building regulations, they may not be meeting market expectations. In many cases the client will be aware of this and want to be BCO compliant. If this is the case the number of toilets will be calculated using BS 6465 Part 1 2009 and adjusted to meet the “60-60” rule. This will lead to more toilets being provided than the minimum for building regulation purposes, calculated using ACOP, and provides an opportunity for gender neutral provision alongside single sex toilets.

A corridor serving several universal toilets designated to different sexes, may be compliant in building uses where a “shared access lobby” is not seen as a threat to the safety, privacy and dignity of users.  If a shared lobby is considered satisfactory it must be well lit, and the width will need to accommodate any outward opening doors.

Interpreting a variation that proposes universal facilities in lieu of sex designated toilets, on the basis of “not sufficient space”, will need to be done on a case-by-case basis.  One situation where it is likely to be acceptable is where the premise is so small that it could be served by one universal toilet (5 people population) or two universal toilets (25 people population) as opposed to a Unisex Disabled Toilet, a female toilet and a male toilet.

 

Part T includes typical layouts for the following cubicles:

  • Type A – Fully enclosed self-contained ambulant universal toilet
  • Type B – Fully enclosed self-contained universal toilet
  • Type C – Ambulant single-sex toilet cubicle (not self-contained)
  • Type D – Single-sex toilet cubicle (not self-contained)

The guidance in Approved Document M, BS8300 Part 2 and BS6465 Part 2 2017 all differ in ways to that in Approved Document T. If the design team propose to use any of the alternative guidance documents, they should record why this is appropriate. The Part T diagrams reflect the most up to date thinking  in terms of accommodating more substantial grab rails (ambulant), sanitary disposal bins and “assistance” shelf.

The layouts in Approved Document T are not prescriptive. Alternative layouts should maintain the level of facility and activity space given. Any alternative layout should illustrate these as well as showing that the “column of clearance” is provided. (See table and diagram in our PDF download below).

Sufficiently progressed is defined as:

a) Where the building work consists of the construction of a building, when the pouring of concrete for the permanent placement of the trench, pad or raft foundations has started, or the permanent placement of piling has started; or

b) Where the building work consists of work to an existing building, when that work has started; or

c) Where the building work consists of a material change of use of a building, when work to effect that change of use has stated.

The following toilets are excluded from Part T:

a) Those in Dwellings,

b) En-suite facilities in individual rooms for residential purposes and care homes,

c) Premises used for early years provision,

d) Schools, and

e) Cellular accommodation in custodial facilities.

As referenced earlier, it is acknowledged that there is more appropriate guidance for educational, sports and healthcare buildings which may be followed.

The contents of this Guidance Note are confidential to Sweco and the intended recipient and are subject to copyright in favour of Sweco.  The content of this Guidance Note must not be reproduced by any person (including the intended recipient) without the prior written consent of Sweco.

The Guidance Note does not constitute professional advice and Sweco hereby offers no reliance and accepts no liability (in contract, tort (including negligence) or otherwise) for parties acting on the content of this Guidance Note without taking specific professional advice from Sweco. The Guidance Note is provided as generic guidance only and any opinion, views or advice expressed in this Guidance Note are made without any representations or provide any assurances or warranties as to the content.  If you require specific advice with respect to your own project or circumstances, please contact Neil Badley.