New homes - enhancing accessibility, adaptability and usability: consultation analysis

12. HfVN Part 1 Section 14: Bathrooms and WC compartments

This chapter presents an overview of responses to Question 26 to Question 31. Quantitative responses are shown in the following chart and tables.

Below, we discuss the responses to each question in this section.

Question 26. In cases where a wet floor shower facility is not provided in the dwelling, how do you feel about the proposal to update clause 14.2.6 of the current guide to require:

• that an electrical connection and a capped drainage connection should be installed in the main bathroom to allow for its future installation
• that the floor build up in the proposed area for a future wet floor shower should be able to accommodate a tray former and associated plumbing with minimal disruption at a later date
• that if the floor is of solid concrete construction, a dropped section should be built in to meet the requirement of the second bullet point above
• that adjacent walls should be of robust construction to be capable of supporting a shower screen to enclose the shower area or grab rails if required?

Just over half (53%) of those who answered Question 26 agreed with all the proposed updates to clause 14.2.6 (which related to all dwellings except for those specifically designed for wheelchair users). Just over a third (35%) agreed with some but not all, 8% disagreed with all and 4% neither agreed nor disagreed. Individuals were more likely to agree with all the proposals than organisations (77% compared with 48%). With 88% of those answering agreeing with all or some of the proposals, this was the joint second highest level of agreement recorded across the 34 questions which asked respondents if they agreed with all, some, or none of the proposals.

Potential advantages

Open responses to this question were provided by over half of all respondents. The most common argument in favour of the updates was that they will help to streamline future wet room adaptations, minimising the cost and disruption of such works. A few highlighted the increasing demand for such adaptations.

The inclusion of a reference to ensuring robust construction of walls adjacent to a future wet floor shower, highlighting the importance of the walls being able to support grab rails to promote safe, independent or assisted washing, was also welcomed.

Potential disadvantages

The main concerns about the proposed updates to clause 14.2.6 were the perceived potential additional cost of the measures, and the impact on size and layout. These issues were raised by individuals and organisations. For example, some raised issues around concrete floors that could increase costs. Another noted that JJI joists may be used, but these could be difficult or costly to design in advance.

“This change will result in considerable additional cost as most homes currently built have a solid ground floor and would therefore require a dropped section of concrete slab to be formed… Accommodating possible future adaptation for wet rooms, shower screens and grab rails will add significant cost.” - Organisation

Some raised concerns about specific aspects of the proposals; for example, three organisations raised concerns that capping a plumbing supply for a shower to be installed at a later date can lead to stagnant water collecting inside the pipe thus increasing the risk of legionella, but approved of the other proposals. Two organisations raised concerns about hazards of having an electrical point in a bathroom where wet areas could occur.

Two respondents raised access issues related to shower screens, with one suggesting that a mobile screen or weighted curtain would be preferable. A few emphasised the need for shower tray formers to be of adequate size to prevent flooding or damage.

A few felt that the measures are unnecessary for general needs housing.

“In considering the size of any shower trays, the standard size of 1.2 x 1.7 does not always meet the needs of individuals and can cause excess flooding and lead to the bathroom/wet room having to be completely redone to include sufficient capacity for water by including a larger shower tray.” – Organisation

Calls for more information and clarification

Two respondents requested the inclusion of guidance on the appropriate or minimum dimensions that will accommodate a tray former. Other singular requests for more information included a breakdown of the costs associated with the work to understand the increase and any knock-on effect to the build and clarification on what is considered 'minimal disruption', as this could be subjective.

There was some confusion among respondents about where the proposals would apply. Considering the proposals in clause 14.8.2 about providing sanitary accommodation on the principal living level that could be adapted to accommodate a shower or form a larger space for wheelchair users at a later date, respondents would like clarity about whether the requirement in clause 14.2.6 would apply to the main bathroom (which might be on a different level) or the future sanitary facilities on the principal living level.

Other themes

Six organisations from a mix of sectors submitted near-identical comments under Question 26, each noting that they agreed with points 1 and 4 for all property types, but felt that points 2 and 3 should only apply to bungalows and ground floor flats. Three of these respondents added that a low-level tray with grab rails can be fitted in 2 storey housing to cater for the ambulant and elderly along with a stair lift.

A few respondents felt that wet rooms should be provided in new builds as standard. Two organisations who agreed with the proposals advised that care should be taken with the construction used in timber kit homes to avoid water penetration and that it is important to ensure that any conversion does not introduce a step and remains level.

Some respondents noted that the proposed updates have already been incorporated into their practice.

Question 27. How do you feel about the proposal to update clause 14.8.2 of the current guide to require:

• that accessible sanitary accommodation located on the principal living level, where the accessible bath or shower is located on another level, should be capable of being adapted to accommodate a future shower or form a larger space for wheelchair users at a later date
• that this space allowance should contain an electrical connection and a capped drainage connection
• that the floor build up in the proposed area for a future wet floor shower should be able to accommodate a tray former and associated plumbing with minimal disruption at a later date
• that if the floor is of solid concrete construction, then a dropped section should be built in to meet the requirement of the third bullet point above
• that adjacent walls should be of robust construction to be capable of supporting a shower screen to enclose the shower area or grab rails if required.

Among those who answered Question 27, 45% agreed with all the proposed updates to clause 14.8.2 (which related to all dwellings except for those specifically designed for wheelchair users). A similar percentage (43%) agreed with some but not all, and 10% disagreed with all the proposals. A much higher proportion of individuals agreed with all the proposals than organisations (85% compared with 38%). With 88% of those answering agreeing with all or some of the proposals, this was the joint second highest level of agreement recorded across the 34 questions which asked respondents if they agreed with all, some, or none of the proposals.

Cost implications

Just over half of all respondents commented on Question 27. The most prevalent theme was disagreement with the indicative additional costs for the proposed updates. Several questioned the assertion in the consultation paper that there would be no additional costs, with some pointing out where they believed costs would be incurred. For example, a few argued there would be considerable additional cost associated with requiring a dropped section of concrete slab (in cases where the floor is of solid concrete construction) or requiring “reinforced” walls.

Potential advantages

Several respondents supported the proposals on the basis that they will ensure ease of adaptability to a wet floor shower in the future. A few added that this will help to reduce cost, effort and disruption to residents in the future.

Potential disadvantages

Some respondents raised concerns about the possible loss of storage space in cases where such space (for example, a cupboard) is converted to accommodate a shower or form a larger space for wheelchair users. A few warned that the proposed updates will have significant design, space, and layout implications for homes, particularly in smaller residences. One organisation highlighted technical/construction challenges associated with forming a recessed area in a concrete floor. Concerns raised under the previous question about the potential safety hazards of an electrical connection or a capped drainage connection were reiterated under Question 27.

“Implementing the requirements stipulated under clause 14.8.2 will have a direct impact upon a dwelling floorplan design. This would significantly impact the way in which dwellings can be designed along with overall space requirements. Once again, this proposal would have a larger impact upon smaller dwellings likely increasing the size of a typical home for first time buyers.” - Organisation

Other themes

There were calls for more detail on wet floor area and shower tray size requirements. A few others recommended minimum dimensions that could be used; for example, one organisation suggested that the dimensions allowed for the shower area should be at least 900mm x 1200mm to allow for varying needs.

As with the previous question, six organisations from a mix of sectors submitted similar comments under Question 27. In these responses, agreement with points 1, 2 and 5 were noted.

A few respondents suggested that this clause could be aligned to the requirements of the English Building Regulations, which also allow for one and two-bedroom dwellings to revert to Part M4 requirements, reducing the impact on smaller dwellings.

Question 28. How do you feel about the proposal to update clause 14.9.1 of the current guide:

• to require that the layout and dimensions of the bathroom allow for a wet floor shower area with floor gulley, a wash-hand basin and WC and their associated activity spaces
• if no bath is provided, to require that space, plumbing and drainage allowances should be made to facilitate the future installation of a bath
• to require that activity spaces should not overlap the space allocated for a future bath
• to require that the bathroom must have a sealed impermeable floor and all fittings must be of a design to suit wheelchair use
• to include within the updated guide reference to the fact that it is beneficial if bathrooms in dwellings within a development contain different layouts to allow for different hand preference?

Among those who answered Question 28 (which related to dwellings specifically designed for wheelchair users), just under half (49%) agreed with all the proposed updates to clause 14.9.1, approximately a third (34%) agreed with some but not all, and 9% disagreed with all the proposals. There were higher levels of agreement with all the proposals among individuals than organisations (77% compared with 44%).

Potential advantages

Just under half of all respondents commented in response to Question 28. Several respondents welcomed the proposals, with a few describing the measures as beneficial for meeting the future needs of residents. One organisation added that the measures are of particular importance in ground floor properties.

“Bathrooms come out as a key area in both the Descha and ISPA Projects. The element of future-proofed through design around drainage and electrics saves money in the future.” – Individual

Cost implications

The most common theme in open responses to this question was again disagreement with the indicative additional costs for the proposed updates. Several respondents did not agree with the assessment in the consultation paper that there would be no cost implications associated with the proposal, arguing that the updates require additional space, which will increase the size of the dwelling and subsequent construction costs.

Potential disadvantages

The most common concern about the proposals raised was the impact of the updates on dwelling size. Several felt that allowing space for a bath to be installed in the future would increase the size of the dwelling, which could lead to higher construction costs and purchase prices or affect the supply of new homes. Some respondents did not see value in allowing space for a bath, citing a lack of demand for such provisions and suggesting this should be considered on a case-by-case basis.

“While desirable in terms of increasing accessibility, the proposal will incur additional cost (although no cost estimate is provided). This proposal will add to the footprint of a dwelling and this in turn will mean that sites might deliver less units which may result in increased land costs and/or lower delivery.” – Organisation

“OT advice is that wheelchair users almost never require a bath unless exceptional circumstances which would be a bespoke property for individual needs.” - Organisation

[The quote above includes ‘OT’ which means ‘Occupational Therapist’]

Comments about hand preference

Some commented specifically on the clause which proposed that the updated guide makes reference to the fact that it is beneficial if bathrooms in dwellings within a development specifically designed for wheelchair users contain different layouts to allow for different hand preference. While a few agreed this would be beneficial, it was noted that there may be challenges at the sale or letting stage as the available provision may not align with a new resident’s requirements. A few organisations suggested that alternative handing could be catered for in mirrored semis rather than both hands within the same property.

Other themes

A few organisations discussed the opportunity to align the requirements with those outlined in English Building Regulation Part M4(3), noting that alignment would offer consistency and coherence in standards for wheelchair-accessible dwellings. Some felt it was unclear whether the requirement to accommodate a bath in future is in addition to the shower or instead of. A few respondents also requested guidance on the recommended dimensions for bathroom size.

Question 29. How do you feel about the proposal to update clause 14.9.2 of the current guide:

• to require that the space in the bathroom should allow for someone in a wheelchair to turn through 180^o, that is a circular area of 1800mm diameter, without being impeded by the door
• to include within the updated guide reference to the fact that, except in very large bathrooms, this is helped by the door opening outwards, or by the use of sliding or pocket doors as an alternative to hinged doors – but only in cases where the use of sliding or pocket doors would be appropriate for the needs of the household
• to require that the plan of the dwelling should ensure that if the door opens outwards this does not cause a hazard
• to require that there is space for a helper alongside a wheelchair in the bathroom
• to require that the allowance for a turning circle should not overlap the wet floor shower area or the area identified for the installation of a bath (where no bath is provided)?

Of those who answered Question 29 (which related to dwellings specifically designed for wheelchair users), just over half (51%) agreed with all the proposals to update clause 14.9.2. Just over a quarter (27%) agreed with some but not all, and 13% disagreed with all the proposals. Levels of agreement and disagreement were similar across organisations and individuals.

Potential advantages

Open responses to Question 29 were provided by just under half of all respondents. Several expressed support for the proposals, with some commenting that the updates will enhance accessibility and reduce the need for future adaptations. The proposal to increase the turning circle space to 1800mm was highlighted as particularly important by some, with a few describing existing standards as inadequate and one noting that the increase will allow wheelchair users to move around with ease and increase the flexibility for transferability around toilets. Another added that larger floor space in bathrooms will allow for easier use of shower equipment and more space for carers.

Potential disadvantages

The most common theme in response to Question 29 was concern over the perceived impact of the requirements on dwelling size, space and costs. While supportive of measures to increase accessibility for wheelchair users, several respondents noted that the requirements will increase bathroom size, with concerns raised about the potential subsequent impact on overall dwelling size, construction costs, the supply of homes, sale prices and maintenance costs for residents.

Some disagreed with the proposed increase in wheelchair turning circle size, arguing that current requirements are sufficient, and the increased size is unnecessary for most wheelchair users. Others added that the requirement to prevent the turning circle from overlapping with the wet floor shower is unnecessary.

“Providing for an 1800mm turning circle outwith door swings and sanitaryware fittings would make overall size of the bathroom very large. There is no reason why the wheelchair area cannot overlap the wet floor shower area as the gradient on floor formers are very shallow and easily achievable for a wheelchair. It is not feasible to provide a bathroom to this size in all circumstances and dwelling design can be adaptable or purposely designed should a wheelchair user require this.” – Organisation

Some objected to the inclusion of a reference to offering sliding or pocket doors as an alternative to hinged doors, raising concerns about technical challenges in installing, maintaining and repairing sliding or pocket doors.

“Do not support the provision of sliding or pocket doors as an alternative to hinged doors. They require frequent maintenance and servicing and in ‘high traffic’ areas such as a bathroom will be prone to faults. Entry doors off common areas may also be subject to fire protection measures which would preclude this type of design.” – Organisation

Other themes

A few respondents suggested that consideration should be given to aligning clause 14.9.2 with English Building Regulation Part M4(3). One respondent called for clarification that the specification is for the main bathroom only, and suggested there is a need to clarify requirements in en-suite bathrooms.

Question 30. How do you feel about the proposal to update clause 14.11.6 of the current guide to require that all WCs in dwellings should have a suitably protected fused spur adjacent to each WC to allow for any future installation of a WC with washing and drying facilities?

Of those who answered Question 30, 70% supported the proposed update to clause 14.11.6. It was opposed by 9%, and the remaining 21% neither agreed nor disagreed. Levels of agreement and disagreement were similar across organisations and individuals.

Potential advantages

A third of all respondents commented in Question 30. Most comments were supportive, describing the proposed changes as ‘logical’, ‘cheap’ and ‘easy to do’. Some felt that the update will offer an element of future-proofing by reducing the cost and disruption of future adaptation. A few organisations involved in the design and construction of homes confirmed they already meet this requirement.

Potential disadvantages

Some respondents questioned whether the proposed updates are necessary for all general needs homes, citing low demand for the installation of a WC with washing and drying facilities. A small number raised concerns about the potential safety risks attached to locating an electrical socket in a wet space, and one noted that further information about the protection zoning would be required to understand the impact on wet rooms and showering areas. A few felt that the indicative costs have been underestimated in the consultation paper and additional costs will be incurred by the proposed update. One flagged that local water authorities may require additional permissions for the adaptations outlined in the updated clause.

Question 31. How do you feel about the proposals for the rest of the clauses within Section 14 of Part 1 of the current guide?

Among those who answered Question 31, 39% agreed with all the remaining proposals for Section 14 of Part 1 of the current guide (as set out in Annex N of the consultation paper), 42% supported some but not all, and 7% disagreed with all the proposals. Individuals were more likely to agree with all the proposals than organisations (54% compared with 37%).

Open comments were provided by just under half of all respondents in response to this question. Some expressed broad approval of the proposals, while others commented on specific aspects they either agreed or disagreed with. There was, however, little consensus among the comments.

Specific proposals that respondents agreed or disagreed with

Clause 14.5.1, particularly the suggested (not ‘as standard’) minimum 400mm space at the head of the bath, was questioned by some, with a few describing it as ‘unjustified and unnecessary’. Concerns were raised that this requirement could potentially lead to an increase in overall bathroom and dwelling size. A few called for clearer rationale to be set out for the decision to retain this clause.

A few raised concerns that clause 14.6.2 which states that all showers should have heads that are adjustable in height and have a flexible hose that is demountable and can be hand-held, would exclude commonly used rainfall fixed shower heads and suggested this should be revised.

In the context of dwellings specifically designed for wheelchair users, a few raised concerns about the reference to shower areas preferably being sunk and covered with a grating (clause 14.14.1), highlighting barriers both in terms of use and cleaning/maintenance.

Other themes

One organisation advised against using the phrase 'on medical grounds' in clause 14.1.2 and suggested using the phrase ‘for disability and/or ill-health reasons' instead. A few commented on the need for consideration of ‘Jack and Jill’ or en-suite bathroom designs in relation to clause 14.2.7, which currently stipulates that a bathroom door must open outwards to allow access if a person should collapse against it in cases where dwellings are specifically designed for older or ambulant disabled people. One noted that such designs provide a second entry/exit in case of collapse behind one door and may be a better solution than an outward opening door which causes some degree of obstruction or hazard in an adjacent hall.

Some made comments about dimensions sizes, either requesting that additional minimum size requirements are specified in the guide or suggesting alternatives to those proposed. For example, one organisation suggested that a minimum shower tray size should be specified in clause 14.6.1, and another felt that a minimum size of 1000mm x 1000mm as specified in clause 14.14.1 is not large enough for a shower area within bathrooms in dwellings specifically designed for wheelchair users.

A few advised that the guide should include specifications which ensure that baths are slip resistant and bathing aids can be used.