Why are we consulting?
Through consultation we are seeking to determine a proportionate and equitable requirement, set through building standards, for the provision of such facilities as part of new development. Such provision would be over and above the current provision of standard and accessible sanitary facilities in buildings.
Development of Changing Places Toilets
The Building Standards Division of the Scottish Government became involved with the work of PAMIS and the Changing Places Consortium in 2008-9 through support for the introduction of guidance on Changing Places Toilets into BS 8300: 2009 (‘Design of buildings and their approaches to meet the needs of disabled people. Code of practice’), the UK reference document for delivery of inclusive environments. This publication was the result of several years of work by organisations such as PAMIS to promote awareness of the need for, and benefit of, such facilities and to assist organisations and building owners in the provision of such facilities on a voluntary basis.
The presence of Changing Places Toilets in a wide range of buildings where members of the public have easy access has, for the past decade, been recommended good practice in the provision of inclusive buildings.
The Changing Places consortium publish a comprehensive resource for organisations who wish to consider the provision of a Changing Places Toilet in a new or existing building. They also maintain a directory of active facilities on their website at: http://www.changing-places.org/. At the time of publication there are 187 Changing Places Toilets across Scotland.
Research commissioned by MENCAP in 2016 to update the original 2009 work indicates that there are in the region of 20,000 people in Scotland who directly benefit from the use of Changing Places toilet facilities. The research notes that most users would be persons with developmental disabilities, neurological degenerative conditions and disabilities resulting from aging, illness or injury. There is also a continued increase in age-related conditions within our population. People with such conditions and disabilities are more likely to experience difficulties in mobility and self-transfer and have high continence needs.
Recognising the benefits that these facilities can offer within our communities, Scottish Ministers are seeking to support provision of CPTs. One means of doing this is to require their provision as part of new development. Building regulations offer an established mechanism for such action.
Building upon current provisions
The good practice advice within BS 8300 is generally implemented within building regulations in Scotland and across the UK for the provision of accessible sanitary accommodation. This is designed around an understanding of a need for additional space and assistive fixtures to enable people to use sanitary facilities safely and without assistance where practicable.
However, this ‘standard’ provision of accessible sanitary accommodation does not adequately address situations where a person will be more reliant upon assistance and one or more carers will be present. Similarly, it does not consider the need for mechanical assistance in the transfer of a person to and from sanitary facilities such as WCs. The Changing Places specification was developed to provide these facilities and offer sanitary accommodation that will meet the needs of people with more complex care needs.
The ‘Changing Places’ specification has proved to be successful where implemented and is delivering significant benefits to users in Scotland and to their families and carers. The presence of a Changing Places Toilet in a building or location enables people with complex care needs to take part in everyday activities such as travel, shopping, family days out or attending a sporting event.
The facility is significantly larger than current sanitary accommodation and is intended to supplement, not replace, such accommodation. This is important to recognise as a single use of a CPT will generally result in a longer period of occupation that a normal accessible toilet.
Current good practice guidance – BS 8300
The good practice guidance within BS 8300 includes recommendations on the types of building within which a CPT should be considered. This list recognises the benefits of provision in buildings that are open to the public, have a managed environment and will generally have consistent opening hours when the facility can be accessed. The list includes examples of public and commercial premises, buildings associated with the transport network and larger ‘destination’ buildings.
Extract from BS 8300-2: 2018 (good practice, text is copyright BSI, 2019)
CP toilets should be provided in buildings and complexes such as:
a) major transport termini or interchanges, e.g. large railway stations and airports;
b) motorway services;
c) sport and leisure facilities, including large hotels;
d) cultural centres, e.g. museums, concert halls and art galleries, and faith centres;
e) stadia and large auditoria;
f) large commercial retail premises and shopping centres;
g) key buildings within town centres, e.g. town halls, civic centres and main public libraries;
h) educational establishments;
i) health facilities, such as hospitals, health centres and community practices;
j) other visitor attractions, such as theme parks, monitored beaches and parks.
Proposals for the introduction of CPTs into building regulations
In developing proposals for introduction of CPTs under building regulations we have considered where, based upon current good practice guidance, a requirement can reasonably be set where development occurs.
In doing so, there was recognition that inclusion of such an addition in larger developments would offer a proportionate initial approach. Discussions by the BSD Working Group, which considered these proposals in 2018, also offered a positive response to a proportionate approach to delivery of these facilities as part of new development. Initial proposals for the introduction of a requirement for Changing Places toilets as part of several types of new development of non-domestic buildings is set out in the next section.
We recognise that the proposed action to increase the number of facilities in new development across Scotland is only part of broader activity that may be needed on an ongoing basis to extend the current network of Changing Places Toilets in Scotland.