Memorandum by The British Standards Institution
As the UK's National Standards Body, BSI British
Standards welcomes the opportunity to submit a Memorandum on the
subject of the Provision of Public Toilets.
This Memorandum outlines the proposed addition
to the British Standard BS6465 Sanitary Installations series—Part
4: Code of Practice for the provision of public toilets. It also
references a Draft for Public Comment (DPC) for BS 8300: Design
of buildings and their approaches to meet the needs of disabled
people. Code of practice.
(Copies of the BS 8300 DPC are attached by way
of supplementary information, please note that this material is
subject to BSI copyright and may not be published on the UK Parliament
website with this Memorandum. BSI is happy for the DPC to be circulated
to the members of the Select Committee for Committee purposes
only).
BSI would like to state that this submission
is the only approved evidence to be considered as from BSI British
Standards.
BSI BACKGROUND
1. BSI British Standards is the UK's National
Standards Body, incorporated by Royal Charter and responsible
independently for preparing British Standards and related publications.
BSI has 107 years of experience in serving the interest of a wide
range of stakeholders including government, business and consumers
ensuring standards are useful, relevant and authoritative.
2. BSI presents the UK view on standards
in Europe (to CEN and CENELEC) and internationally (to ISO and
IEC). BSI has a globally recognized reputation for independence,
integrity and innovation.
3. A Standard is a document defining best
practice, established by consensus and approved by a recognized
body (such as BSI). Each standard is kept current through a process
of maintenance and reviewed whereby it is updated, revised or
withdrawn as necessary.
4. Standards are developed when there is
a defined market need through consultation with stakeholders and
a rigorous development process. National committee members represent
their communities in order to develop standards and related documents
by consensus. They include representatives from government, business,
consumers, testing laboratories, suppliers, academic institutions,
social interests, manufactures, regulators and trade unions.
UPDATE ON
BRITISH STANDARDS
WORK RELEVANT
TO THIS
INQUIRY
Existing BS6465 Sanitary installations series
— BS6465—Part 1 provides standards
as to the numbers of sanitary appliances required, primarily in
relation to workplace and other private premises situations, with
a very short new section on public toilet provision.
— BS6465—Part 2 provides details
as to the design and layout of toilets with emphasis upon domestic
and institutional situations with a small section on wider toilet
provision.
— BS6465—Part 3 gives recommendations
on the selection, installation and maintenance of the most commonly
used sanitary and associated appliances to be provided in new
and refurbished buildings. It also covers portable toilets used
as supplementary sanitary facilities, for workplaces and events.
Proposed BS 6465—Part 4
5. The proposal for this standard was submitted
to BSI on behalf of the British Toilet Association (BTA) and included
the following arguments in support. BSI accepted the proposal
as a prima facie business case for a new standard, but the arguments
will be tested in the usual way for the development of standards,
as described in 4. above. The standard will have regard to the
Select Committee's Inquiry and the Regulatory situation at the
time of publication.
6. The BTA envisaged the proposed standard
as covering key public toilet considerations such as the location,
distribution, catchment hierarchy, or levels of provision in the
first section, followed by a second section on the user-related
requirements in respect of the design of the whole toilet block,
access, gender equality, security, crime and design, and the third
section would provide guidance on management and maintenance issues
specific to the public toilet situation.
7. The standard is intended to provide a
comprehensive standard for providers of public toilets, which
takes into account physical (spatial/geographical) distribution
issues, user requirements and design considerations (including
the Gender Equality Duty [GED] of the 1975 Sex Discrimination
Act) and practical, economic and management issues.
8. The standard is aimed at those responsible
for the planning, commissioning, managing, designing and providing
of public toilets. This will include all the professionals who
currently need to consult BS 6465, plus;
— local authority planners;
— policy makers who are responsible
for determining toilet location, design and management;
— highways and possibly urban design
departments;
— most architectural, building services
engineering practice;
— all private-sector toilet providers;
— all local authority officers concerned
with toilet decision-making, building control, planning, contracting,
design, in cleansing, planning; and
— environmental health departments.
9. The BTA contended that over 40% of public
toilets have been closed in the last 10 years, and yet there is
a very high level of public demand from user groups, and considerable
political debate, on improving toilet provision, and a renewed
interest from local authorities, private providers and central
government in new ways of solving the public toilet problem. Public
toilet provision also ties in with the current range of DCLG,
DEFRA and DBERR policy objectives and concerns in respect of environmental
sustainability, economic viability, social equality and inclusion.
10. The BTA pointed out that there is particular
relevance to preparations for the 2012 Olympic Games, sport &
leisure facilities, and tourism with public toilets a factor in
encouraging people to holiday in the UK and thus reduce air travel
and the associated environmental impacts. The increasing use and
specification of standalone automatic public conveniences (APCs)
and self-contained pods for incorporation into other buildings
is also creating a need for a standard that addresses these less
traditional approaches to public toilet provision.
11. Research, urban policy and public demand,
are reported by the BTA to have shown that public toilet provision
is essential in creating accessible and sustainable cities, and
meeting the needs of commuters, tourists, visitors, and residents.
But, official guidance on provision is limited, fragmented, and
not readily available. In spite of the need for toilets, local
provision is in decline. Creating a standard specifically on the
provision of public toilets would provide clear guidance to both
public and private sector providers and remove ambiguity and confusion
as to what is required and how the benefits resulting. Socially,
the new standard would benefit all sectors of society.
12. Economically, the BSI business case
argued that adequate toilet provision encourages people to visit
a location, stay longer and spend more money. Environmentally,
it went on to argue that public toilets are a missing link in
creating sustainable cities as people are more likely to leave
their cars at home and travel on public transport, on foot, or
cycle if they know that public toilets are readily available within
walking distance.
13. The BSI drafting group currently includes
representatives of the following organisations and this composition
is in the process of being widened:
British Plastics Federation
Chartered Institute of Architectural Technologists
Chartered Institution of Building Services Engineers
Department for Communities and Local Government
Institute of Plumbing and Heating Engineering
Royal Institute of British Architects
14. Expected publication February 2010
BS 8300: Design of buildings and their approaches
to meet the needs of disabled people. Code of practice
15. BS 8300 concentrates on the provision
of, and facilities within, toilets for disabled people within
buildings used by the general public. This has been the case since
the first edition in 2001. The 2005 amendment made no change to
the scope of BS 8300.
16. However, the proposed 2008 edition,
which is currently out as a Draft for Public Comment (DPC), includes
additional recommendations for a special type of toilet accommodation
called "Changing Places" (see 12.6 in the DPC draft)
for people with profound and multiple disabilities who may need
a changing bench, a hoist system or shower facilities. The recommendations
on the general provision of toilets for disabled people can be
found at 12.5.1 in the DPC.
17. The other proposed change is to the
provision of accessible bedrooms with en-suite bathroom facilities,
eg in hotels and motels (see 12.3.1 of the DPC).
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