How to design toilets in non-residential buildings

As the new Building Regulation T1 of Schedule 1 comes into effect in England from 1 October 2024, I thought it might be helpful to attempt to interpret, consolidate and simplify the requirements for toilets in more common non-residential buildings.

It is important to note that the new requirement T1 will not apply in relation to building work where a building notice, an initial notice or an application for building control approval with full plans has been submitted to the authority prior to the new regulation coming into force on 1 October 2024 and either the building work;

a. has started and is sufficiently progressed before the 1 October 2024

or

b. is started and is sufficiently progressed within the period of six months beginning on 1 October 2024.

In simple terms, Requirement T1 does not apply to;

a. schools

b. buildings used for early years provision

c. cellular accommodation in prisons

d. en-suite toilets provided in individual rooms in hotels and care homes.

Whether you agree with the new legislation or not, the intention of Part T1 is to preserve separate single-sex toilet accommodation. In addition to separate single-sex toilet accommodation, there is still scope to provide ‘universal’ fully enclosed and self-contained toilets, which anyone can use.

The following hierarchy references the design guidance in the Building Regulations new Approved Document T: Toilet accommodation (ADT) 2024 edition, Approved Document M Volume 2 – Buildings other than dwellings (ADM) 2015 with 2024 amendments and various British Standards.

The new Approved Document T (ADT) describes four types of toilets;

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).

Hierarchy of toilet provision for non-residential buildings

1. In very small premises, such as small café’s, provide a minimum of one wider unisex wheelchair accessible toilet with corner WC and additional standing height wash basin.

Refer to British Standard BS 8300-2: 2018 Figure 41

If baby changing facilities are needed in small premises such as a small café or self-contained units within buildings where it is not possible to provide more than one toilet, it is acceptable to combine the baby change within a unisex wheelchair accessible toilet.

Refer to British Standard BS 8300-2: 2018 Figure 44

However, for any larger premises with more than one toilet and where baby change facilities are required,

Refer to British Standard BS 6465-2

For any premises larger than a small café (as an example), the hierarchy is as follows;

2. Provide separate single-sex male and female toilets plus at least one unisex wheelchair-accessible toilet with corner WC at each location in a building where separate-sex female and male toilets are provided.

Refer to ADT Section 6: Type D for single-sex toilet cubicles

Refer to ADM Section 5: Diagram 18 Unisex wheelchair-accessible toilet with corner WC as a minimum level of provision

Alternatively, and as a best practice option, consider a slightly wider facility to provide a 1500mm x 1500mm turning space not compromised by fixtures and fittings

Refer to British Standard BS 8300-2: 2018 Figure 40

Note: If preferred, self-contained universal toilets can be used instead of cubicles for single-sex accommodation or if there is insufficient space to provide a series of cubicles in single-sex accommodation. However, each self-contained toilet must be designated with suitable signage as either male or female.

Refer to ADT Section 4: Type B – fully enclosed self-contained universal toilet.

3. I recommend that in addition to (2) above, one or more self-contained universal toilets are provided at each location where separate-sex female and male toilets are provided. I believe it is important to provide personal choice for everyone irrespective of sex, differences in sex development (DSD) or gender identity under the Equality Act 2010.

Refer to ADT Section 3: Type A – fully enclosed self-contained ambulant universal toilet

or

Refer to ADT Section 4: Type B – fully enclosed self-contained universal toilet

4. In separate single-sex toilet accommodation with toilet cubicles provide at least one ambulant accessible toilet.

Refer to ADT Section 5: Type C – ambulant single-sex toilet cubicle (not self-contained)

Note this replaces ADM Section 5 Diagram 21 WC cubicle for ambulant disabled people

5. Where separate single-sex toilet accommodation is provided as fully enclosed self-contained ‘universal’ style Type B toilets and designated with male or female signage, I recommend that you consider providing at least one Type A fully enclosed self-contained ambulant universal toilet, if space is available. This scenario has yet to be clarified in the approved documents.

Refer to ADT Section 3: Type A – fully enclosed self-contained ambulant universal toilet

6. In separate single-sex toilet accommodation where there are four or more cubicles, provide an enlarged cubicle 1200mm wide for people who need extra space. This is in addition to the provision of one or more Type C ambulant accessible toilets. The specification of enlarged cubicles should be based on that of the Type C ambulant toilet incorporating grab rails etc. It could also be based on the Type A toilet where Type B toilets have been specified in lieu of cubicles.

7. Provide at least one Changing Places facility in larger buildings as described in ADM Section 5 provision 5.7e. Changing Places facilities should be in addition to unisex wheelchair accessible toilets, ambulant toilets, separate single-sex toilets, universal toilets and baby change facilities.

Refer to Changing Places: The Practical Guide and British Standard BS 8300-2: 2018 Figure 48 Example of fittings and accessories in a Changing Places toilet.

How many toilets do I need to provide?

Most scenarios can be calculated by following the design guidance in British Standard 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. Please note that this British Standard is currently under review (as of 23.07.24).

Important

As you can appreciate, designing toilets can be complicated. I need to include a caveat here as there may be other ways to comply with the Building Regulations which are not described in the approved documents. While the advice provided is given in good faith as of 23.07.2024., I recommend that you seek the advice of an access or inclusive design professional who will be able to advise on your project’s unique circumstances.

Please get in contact if you need support with this.