Memorandum by The British Toilet Association
APPENDICES[1]
COMMUNITIES AND LOCAL GOVERNMENT COMMITTEE
PROVISION OF PUBLIC TOILETS INQUIRY
1. BTA BACKGROUND
1.1 The British Toilet Association was established
in 1999, primarily in response to increasing requests to help
save public toilets in particular areas from closure and also
to give best practice advice on how to raise standards of existing
public toilets to Local Authority providers.
1.2 The BTA promotes the annual Loo of the
Year Awards scheme, introduced in 1987, and run independently
since 1993. Some 20,000 public toilet facilities have been inspected
since the start of the scheme and many Authorities use the scheme
as an annual independent benchmarking audit of their facilities.
Recommendations for improvements are offered to all entrants and
competition for the Loo of the Year Awards "Premier League"
of Local Authority providers intensifies each year. (www.loo.co.uk
or Refer Appendix A).
1.3 The BTA is a campaigning body—not
a Trade Association—with one major objective, namely, to
promote higher standards of "away from home" toilet
provision in all types of location and on behalf of all users.
1.4 The BTA currently has 160 members of
whom 61 are Local Authorities. Refer Appendix B.
1.5 The BTA is a Founder Member of The World
Toilet Organisation and hosted the 2005 World Toilet Summit in
Belfast—the first ever such Summit held in the West. The
300+ delegates who attended the Summit from thirty three different
countries endorsed The Belfast Protocol. Refer Appendix C.
1.6 A total of 75 UK Local Authorities entered
the 2007 Loo of the Year Awards, out of 468 down to District Council
level. Refer Appendix D.
1.7 The BTA, together with the Loo of the
Year Awards, promotes a Toilet Charter covering the basic requirements
for a public toilet. Refer Appendix E.
1.8 Many Local Authorities continue to attach
a high priority to their public toilet service and there are a
significant number of existing public conveniences currently being
refurbished as well as new facilities being constructed. There
are many fine examples of best practice in operation in spite
of the discretionary nature of the service.
1.9 The key issue is that too many Authorities
have basically given up on public toilet provision and, without
a clearer lead from Government, requiring an adequate level of
provision—either directly or indirectly, further closures
of existing LA public toilet facilities are inevitable.
1.10 The recently published Access to Public
Toilets Guide, prepared by the CLG department, is very much welcomed
as an acknowledgement that the issue of public toilet provision
is a relevant one in a modern civilised society such as that pertaining
in the UK.
1.11 The BTA fears however that, without
a stronger Government lead on the issue, increasing numbers of
Local Authorities will assume that society's toileting needs can
be wholly satisfied by other commercial premise providers.
1.12 The BTA believes that Local Authorities
should be required to provide a front line flagship convenience,
or Visitor Welcome Centre (Refer Appendix F) in every City, Town
and key visitor area within their geographical control, as a starting
point.
1.13 Local Authorities should, as a minimum,
be required to prepare a toilet provision strategy for their area,
to ensure adequate levels of toilet provision during the hours
of primary need. This strategy could cover a range of options,
including negotiated arrangements with other, existing commercial
providers, as well as the opening up of other public building
toilets for general public use—eg libraries, town halls
etc.
1.14 This would allow some flexibility for
both the providers and the users and ensure that, while Local
Authorities may no longer need to be assumed to be the principal
public toilet service providers, they should be required to be
seen as the local public toilet service delivery body, accepting
that satisfying people's toileting needs is a front line municipal
public service.
1.15 It should be emphasised that Local
Authorities can and many already do, contract out their public
toilet facilities to one of a number of specialist public toilet
contractors, who provide a turnkey operation—often with
financial benefits to the Authority involved.
2. THE NEED
FOR PUBLIC
TOILETS
2.1 Every member of every community and
particularly visitors to each community, require to satisfy their
toileting needs a number of times every day of their lives. These
needs are required to be satisfied "away from home"
for all of us when we go about our daily business.
2.2 While the work place is required by
law to provide adequate sanitary facilities for employees, there
are no legal requirements to provide toilets for customers or
visitors—except where food and drink is to be consumed on
the premises and even then, different rules seem to apply with
different Local Authority areas.
2.3 Shopping centres are generally providing
a good standard of toilet service for their visitors because they
appreciate that, in order to maximise customer lengths of stay,
toileting, as well as eating and drinking needs have to be satisfied.
2.4 Hotels, restaurants, pubs and cafes
also provide customer toilets for similar reasons. Eating, drinking
and toileting are key considerations for any hospitality establishment.
2.5 Britain led the way in public toilet
provision in Victorian times, when concerns for public hygiene
standards and street fouling were unacceptably high.
2.6 The BTA suggests that the full circle
has been achieved and we should be as concerned today, at the
start of the 21st Century, as people were 160 + years ago, about
the levels of hygiene in public places and the problems associated
with public urination and defecation.
2.7 Some of the attitudes and behaviour
associated with toileting are not commensurate with a so-called
civilised society such as that assumed to be pertaining in Britain
today. This is more a behavioural issue as opposed to a cultural
one.
2.8 Other important factors which impact
significantly on today's society are the increasing numbers of
children with single parents, the ageing population and large
numbers of people with a variety of special needs and not necessarily
in a wheelchair.
2.9 A significant percentage of the 1500
entries received in the 2007 Loo of the Year Awards did not have
a fully DDA compliant accessible toilet facility.
2.10 There are very few toilets in publicly
accessible places dedicated for children's use with appropriate
child-sized sanitary equipment.
2.11 While there has been a significant
increase in the numbers of (pull down) wall-mounted babychanging
units—often in locked disabled toilets, to provide for unisex
use, there are very few dedicated babychange facilities which
cater for parent use as well. In other words, the parent or carer
can change baby's nappy but then has to access the ordinary ladies
or gents to satisfy their own toileting needs. What then happens
to baby? We need dedicated family friendly facilities to satisfy
the toileting needs of family groups.
2.12 We see an increasing number of low
level urinals for boys—often alongside adult urinals but
with no privacy screening—but there are seldom low level
washbasins to facilitate proper hand washing for children. This
does not encourage proper hand hygiene in our younger members
of society.
2.13 If we are to encourage inclusivity
within our society we have to provide adequate toilet facilities
for members of society with serious mental or physical impairment
and whose carers need a height adjustable changing bed and a hoist
to assist their toileting needs. We identified only forty of these
Changing Places toilets throughout the UK in the 2007 Loo of the
Year Awards.
2.14 The BTA does not support the RADAR
key scheme used for the majority of disabled toilets, and, increasingly,
in other types of toilet where the provider feels obliged to keep
their facilities locked.
We feel it is something of an insult, not to
say discriminatory, for a significant section of the population
to have to possess or ask for a key in order to fulfil a basic
human function.
Conversely, while disabled toilets might be
accessible by a RADAR key out of hours, the other eighty five
percent of the population are denied access to ordinary male or
female facilities, once they are locked at dusk or at weekends.
We require toilets for all sections of the population
when the need arises.
2.15 The ageing population in Britain requires
not only proper facilities with enhanced fixtures and fittings
(eg grab rails in cubicles) but also much better access to clean
and safe public toilets.
2.16 Most members of society will have a
special toileting need during their lifetime and toilet provision
generally deserves, if not demands, a much higher level of priority,
not just in the minds of the provider's but also in the minds
of regulators and enforcers.
2.17 The bottom line is that toilets are
seen as cost liabilities and not as revenue generators in a profit
driven world—hence the need for Government intervention
/ enforcement. There is nothing discretionary about needing to
go to the toilet when away from home.
2.18 While the BTA supports the development
of Community Toilet schemes, as one provision option, it is important
to recognise that most participants in any such scheme only provide
toilets designed and maintained specifically for their own particular
customers.
3. WHY PROVISION
HAS DECLINED?
3.1 The BTA believes that the majority of
closures of public toilets in the last twenty years has been due
to the discretionary nature of the service, coupled with the pressure
on Local Authority finances.
3.2 Increasing levels of anti-social behaviour
and particularly wanton vandalism have also exacerbated the problems
surrounding public toilets.
3.3 The BTA also believes that the decline,
over many years, in the use of toilet attendants, has been an
important factor in accelerating the demise of the municipal public
toilet. When we consider the significant sums of ratepayers money
expended on public toilets over the years it is hard to justify
the abandonment of these important public buildings to all and
sundry. We wouldn't leave our homes open for anyone to enter and
abuse. Why do we allow it to happen with public toilets—ie
public money?
3.4 There are, however, encouraging signs
that toilet attendants are coming back. We all feel much safer
in a park or public garden or a public toilet, if we know there
is someone "in authority" looking after it and its customers.
3.5 Much of the decline in society's confidence
in public toilet provision is due to the fact that we are not
sure what is going on inside the unattended public toilet facility.
We therefore tend to avoid using public toilets and they become
"hot spots" for other activities.
3.6 There have been many reported illegal
substance overdose deaths in public toilets in recent years. Local
Authorities feel that, to protect ordinary members of the public,
as well as cleaning staff, they need to install sharps disposal
boxes inside public toilets because so much drug taking occurs
in the (normally unattended) public toilet. This further alarms
the ordinary public toilet user who, quite naturally, prefers
not to share space with people who use public toilets as a base
for their drug habit.
3.7 Far better, in a modern, civilised society,
to establish dedicated drug consumption rooms, properly managed
and controlled. It is time to stop pretending on these matters
and agree a better way forward. Toileting needs, as well as the
needs of drug abusers, have to be managed more effectively by
all parties.
3.8 Similarly, the use of public toilets
for sex is a matter of great concern. Sexual activity in a public
toilet is still a criminal offence and there needs to be a much
higher, pro-active enforcement of the law, if public confidence
in public toilets is to be restored. Here again, a managed building
environment helps act as a deterrent for all anti-social activities
but the person or people managing the facility require proper
training on these issues and also adequate and regular support
from the crime prevention and enforcement authorities. Public
toilets are at the cutting edge of society and that is why the
Loo of the Year Awards recognise the valuable roles played by
toilet attendants, as well as mobile cleaning staff, in managing
many of society's anti-social issues. They are certainly not just
toilet cleaners.
3.9 Public toilets cost significant sums
of money to maintain. £25k—£40k per annum for
an attended facility. This is often seen as a potential cost saving
from a discretionary public service budget but the BTA argues
that these costs have to be seen in a much wider context, to include
the impact on local quality of life—particularly the health
and life style of residents as well as the visitor economy and
the reputation of the area both at home and abroad.
4. WHO PAYS?
4.1 Public toilets may still be free to
use in many areas but certainly do not come cheap to staff, equip
and maintain.
4.2 Nothing of quality is free in a modern
world and someone has to pay for consistently high quality public
toilet provision.
4.3 Costs have to be covered either by:
— Government—the central taxpayer;
or
— Local Councils—the local Council
taxpayer; or
— The User—through entry charges;
or
— A combination of one or more of the
above.
4.4 There is a strong (historical) case
for arguing that Local Authorities should provide free public
toilets since they are a front line public service, affecting
a much wider sphere of influence within the local community.
4.5 Most people surveyed or questioned by
the BTA over many years indicate a willingness to pay something
towards their use of public toilets—provided that the experience
is a clean and—as important—a safe one.
4.6 Charging for toilets is becoming increasingly
"acceptable" to the majority of toilet users, although
the use of coin operated turnstiles outside toilets on stations
is not a pretty site, with visitors, often with luggage, having
to find correct coins, get through the turnstiles and then go
down stairs to access the toilets. They are not visitor or user
friendly!
4.7 It would be far better for Government
to insist that adequate free toilet provision has to be part of
any agreement with train operating companies on all trains and
stations and included in the cost of the ticket.
4.8 This also overcomes the problem associated
with certain sections of society who would always refuse to pay
to go to the toilet and simply urinate somewhere close by and
hope they don't get spotted on CCTV.
4.9 The simpler we can provide for this
essential, everyday need the better.
4.10 The Government could also, at a stroke,
relieve the pressure on inadequate public toilets by requiring
all commercial premises (above a certain size) to provide not
just toilets for employees but also toilets for customers / visitors.
4.11 The BTA believes that, if adequate
toilet provision is to be secured, a partnership financial approach
would be preferable, with Government contributing through business
rate relief and Local Authorities also being obliged to draw up
and agree a local area toilet provision strategy which could include
partnerships with other existing commercial premises.
4.12 The Local Authority should be the (local)
body tasked with ensuring an adequate toilet service delivery.
4.13 It would also be preferable, in the
BTA's view, for there to be a consistent policy throughout the
UK, or at least England, regarding the charging of users. Many
of the best LA public toilet providers currently do not charge
for their public toilets. They consider the provision of public
toilets a high priority public service.
4.14 If the Government was bold enough to
request a visible £10 public toilet tax on every Council
Tax bill, perhaps along with a £10 litter tax and a £10
graffiti tax, we believe this would help focus public attention
on these three important areas of daily life in our communities
and result in higher standards all round. We need a positive lead
from Government. Local Authorities should not be allowed to abdicate
their responsibilities so easily in respect of public toilet provision.
5. OPENING HOURS
5.1 Toilets need to be available for all
types of user—young and old, abled and not so abled—when
they are needed.
5.2 Lack of availability or uncertainty
about finding a toilet, impacts significantly on people's lifestyle—particularly
the more vulnerable members of society.
5.3 Public toilets are normally shut at
dusk and often at weekends and are therefore not able to provide
a public service—except where users (and abusers) possess
a RADAR key to access the disabled facility—where one is
provided.
5.4 Pubs and other commercial premises with
easy public access, do provide toilets while they are open, which
extends hours of availability to potential users.
5.5 Many commercial premises currently display
signs saying "Toilets for Customer use only"
indicating the management do not wish members of the public to
assume they can enter their premises simply to use the toilet.
5.6 This emphasises the need to ensure that
every local area Community Toilet Scheme is properly drawn up
and formally implemented between the Local Authority and commercial
providers. Monitoring the scheme also requires a dedicated Council
employee to manage to best effect and keep the scheme up to date,
if not continuously expanding, as local businesses come and go
or change hands.
5.7 This is a Council "on-cost"
and the BTA concern is that, if CT schemes become more widely
established, they might not be properly managed, following the
initial set up and high profile media launch in any particular
area.
5.8 One solution is to ensure that all CTS
non-Local Authority toilets are independently audited at least
once a year to ensure the consistency of the quality of service
provided. The BTA / LOYA scheme is able to support this initiative.
5.9 The other key issue is one of convenient
access. Many public toilets remaining are in prime public locations
with relatively good access and, often, adjacent convenient parking.
5.10 While the BTA supports the concept
of the Community Toilet Scheme, the concern is that Councils will
seize on these as an excuse to close further public toilets and
so "save" more money from a discretionary public service
budget.
5.11 CTS toilets are not so easily accessible—often
at the back of cafes or pubs, are normally much smaller in the
scale and variety of provision and should not be seen as a total
substitute for the traditional Local Authority public convenience.
6. SECURITY
6.1 As previously indicated, public toilets
have been left to look after themselves for too long—hence
the general public concerns or "fear" associated with
using an unattended facility.
6.2 We know that many Authorities use attendants
in some or all of their public toilets and attendants are increasingly
being used in other high profile locations, such as shopping centres,
night clubs etc.
6.3 In today's modern, 24 hour society,
the BTA believes that all major centres of population should have
at least one 24 hour Flagship Public Convenience, or Visitor Welcome
Centre (Refer Appendix F).
6.4 With the (inevitable) introduction of
charging for public toilets, the BTA believes that the days of
the unattended and "free to all" public toilets are
numbered.
6.5 The need to pay to enter a locked facility
does provide some deterrence to the anti-social elements of society,
although determined vandals find ways of wrecking anything that
is not properly managed.
6.6 Residents' pass cards could provide
free use for local residents but also allow charging for visitors.
6.7 Many people, particularly the elderly,
are frightened of using one of the automatic types of public toilet,
fearing they may get locked in, or spray washed or exposed by
an automatic door opening.
6.8 The more modern APC's are much more
user friendly with audio messaging and other reassuring features
but some people prefer not to be seen entering a toilet cubicle
in a public place—which is effectively what APC's are.
6.9 The BTA believes there should be a mix
of toilet provision in any area, as follows:
— One or more Visitor Welcome Centres
with a range of facilities including adult changing, child toilets
and age friendly toilets.
— Other (preferably staffed) Council
provided public toilets in areas of busiest pedestrian traffic.
— Automatic public toilets in more
rural or isolated areas—where CTS facilities are not practicable.
— Non-Council provided toilets located
in commercial premises and formally promoted as part of a local
Community Toilet Scheme, possibly with Council grant support towards
cleaning and maintenance costs.
6.10 All public access toilets—both
Council provided as well as those located in commercial partner
premises, should be regularly monitored by Council or Public enforcement
staff, to minimise anti-social behaviour and to be seen to be
supporting provider management in their endeavours to maintain
an acceptable public service.
7. THE GENDER
BALANCE
7.1 Britain's public toilets were established
in an age when men walked, cycled or caught a bus to work and
women stayed at home to raise the family.
7.2 This resulted in many more male facilities
being provided than female.
7.3 While the balance in favour of women's
facilities is slowly changing, there are still too few female
cubicles compared to men's urinals and male cubicles.
7.4 Women take on average, twice as long
to visit the toilet as men and the BTA recommends a ratio of provision
of 2 female to 1 male facilities.
Most people compare cubicle numbers only but
the male urinals have to be added to male cubicles to ascertain
the total male provision.
Hence, where a toilet has three male urinals
and two male cubicles—ie a total of five male facilities,
the female toilet should have ten cubicles to achieve the 2:1
ratio.
7.5 The British Standard BS6465, is currently
being updated to include the gender equality provision issues.
The BTA is involved in this update.
7.6 An alternative solution to the imbalance
of provision, particularly in busy establishments or at outside
events, is to provide unisex facilities.
7.7 Although this is the norm at home, many
people prefer not to use a unisex lavatory in a public place both
on safety as well as hygiene grounds.
8. PROVISION
BEYOND THE
LOCAL AUTHORITY
8.1 We all tend to nip into a convenient
pub or hotel or shopping centre to use the toilet—mainly
because there is not a public convenience available nearby or,
if there is, it is not fit for our purpose.
8.2 It is obvious therefore that we need
to encourage all commercial premises with customer toilets to
make them available to the general non-customer public.
8.3 One can understand the reluctance of
many business providers to be used as a substitute for a failed
or non-existent public toilet service. They work hard to attract
money paying customers into their premises in order to succeed
with their particular business.
8.4 If the Community Toilet Scheme is to
become properly established across Britain, there needs to be
a Government led policy which allows for everyone—providers
and potential users to understand clearly the rules of engagement.
8.5 If private business providers are being
asked to allow the public in to use their customer toilets, they
would expect some financial encouragement to participate—either
a contribution to their toilet consumable and cleaning costs and/or
also some acknowledgment that they are providing a front line
public service through some business rate relief.
8.6 A promotional benefit to their business
could be the placing of directional finger signs, naming their
business in the adjacent area (such as those being developed by
Richmond Borough Council in London). However, the more successful
the local CTS, the more prolific the finger signs become, which
could impact on the local street scene environment.
8.7 The use of "SAT LAV" and other
web based location maps could become the appropriate way to source
a convenience toilet facility near to your current GPS position,
assuming you are carrying a mobile phone.
9. TOURISM
9.1 First impressions of any location or
area are normally made in the toilet (assuming one is found) by
arriving visitors. These are the lasting impressions visitors
tend to take home with them.
9.2 Tourism authorities receive more complaints
about the state or lack of public toilet facilities than anything
else.
9.3 The BTA was established in 1999 mainly
as a result of residents, Councillors and visitors complaining
about the poor public toilet service in Britain and their plea
for the BTA to help save public toilets from closure.
9.4 Many friends and colleagues return from
visits to foreign countries, praising the quality of public toilets
visited.
9.5 Britain's public toilets, once the envy
of the civilised world, are now often the subject of ridicule
or criticism, due to poor standards of management and/or provision.
9.6 Beijng have spent in excess of £25
million installing 3500 five star tourism toilets in time for
the Beijing Olympics.
9.7 Westminster City Council's 28 attended
public toilets north of the Thames are used by over 15 million
people a year. That's more people than attend all of London's
Theatres in a year!
9.8 The South Bank, between Lambeth Bridge
and the Tate Modern, has in excess of 14 million visitors each
year. There are no public toilets provided by Lambeth Council!
9.9 Birmingham, Britain's second City, has
only a few automatic public conveniences throughout the city centre.
9.10 Liverpool, European City of Culture
for 2008, has only two Council provided automatic public toilets.
9.11 Coach companies do not stop in tourist
centres where the public toilets have been closed.
9.12 The Hotel that won the first Loo of
the Year overall UK Award in 1987, doubled its turnover the following
year.
9.13 Tim Martin, Chairman of pub chain J.
D Wetherspoon, acknowledged that winning the 2001 Loo of the Year
Awards Trophy contributed to a significant increase in turnover
the following year.
9.14 The quality of public toilet provision
in any area is a significant contributor to the overall impressions
gained by visitors.
9.15 The theming of some high class restaurant
and pub toilets is a sure way of encouraging customers to return
and, through their social networks, tempting new customers to
visit.
9.16 The new public toilets at Frinton-on-Sea
in Essex, costing ratepayers in excess of £500,000, have
already received considerable publicity—nationwide. The
publicity—good and bad—has helped put Frinton-on-Sea
on the map and should ensure a significant increase in the numbers
of visitors to the area. They'll know there is a decent public
toilet nearby.
9.17 A number of old Victorian public toilets
are tourist attractions in their own right. The Victorian toilets
on Bute at Rothesay Pier were featured some years ago on the Jill
Dando Holiday programme and have been visited by Prince Charles.
Tourists travel out of their way to visit some of these British
gems.
9.18 East Lothian—east of Edinburgh—have
provided the best portfolio of public toilets throughout Britain
for nearly twenty years.
9.19 Edinburgh and Cardiff's public toilets,
both capital cities, are considered by the BTA to be a national
disgrace.
9.20 It is time for the UK Government to
grasp the whole issue of public toilet provision and set out a
clear agenda for change. It is the BTA's considered opinion that
Britain's reputation at home and particularly abroad, is under
some significant threat as a result of our poor public toilet
service.
9.21 This reputation is only partly mitigated
by the many providers who already acknowledge the shop window
nature of their (public) toilets through winning Loo of the Year
Awards each year.
9.22 The BTA believes that all "away
from home" toilets, particularly toilets available for use
by the public and visitors to Britain, should be subjected to
an annual, independent quality audit and given a star grading,
along the lines already operated by the annual Loo of the Year
Awards scheme.
British Toilet Association
April 2008
1 Not printed. Back
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