How the new approved T-document addresses the controversial issue of same-sex toilets | Opinion

The Government has recently published a new requirement in Schedule 1 of the Building Regulations 2010, entitled Requirement T1, which relates to the provision of toilets in non-domestic buildings. Other excluded types include schools, nurseries, nursing homes or student residence bathrooms.

It is apt, if coincidental, that requirement T applies to toilets – T is the next available letter in the Regulations sequence. The regulations were introduced to ensure the safety and privacy of people using toilets in newly built workplaces and public buildings.

In addition to the revised regulations, a new Approved Document T and related amendments to Approved Documents G (Sanitation, Hot Water Safety and Water Use Efficiency) and M Volume 2 (Access to and Use of Buildings) have been published.

The new requirement and guidance will enter into force on 1 October 2024 and does not apply to buildings for which an application for full construction design, preliminary notice or notice of construction was submitted to the building control authority before that date and for which work commenced on on 1 October 2024 and have either made sufficient progress or will become so within six months from 1 October.

The Part T requirements were introduced after a long period of research, analysis and consultation by DLUHC. The first call for proposals in 2020 received over 17,000 responses from industry and wider society. I understand that this number of responses regarding building regulations is unprecedented and, given the number and importance of the issue at hand, the Government needed to prioritize work on policy development. Following a call for evidence, the Government announced in July 2022 that it planned to amend building regulations to include requirements for separate men’s and women’s toilets, the provision of unisex toilets where possible, and that the latter facilities must provide privacy for users.

Particular attention should be paid to the privacy and safety of people using universal toilets

One of the aims of the policy changes is to ensure that in new developments, people of both sexes do not use toilets or sinks in the same room at the same time. This puts an end to the scenario of shared washbasins in unisex spaces, as is currently the case in some bars, hotels and clubs, for example.

The new requirement applies to single-sex toilets with shared same-sex handwashing facilities or sinks in toilet cubicles. This requirement is above all. In addition to single-sex toilets, universal toilets for both sexes may be provided – these will be single rooms or cabins with integrated washbasins. If space constraints do not allow the provision of single-sex toilets, only universal toilets may be provided.

Careful consideration must be given to the privacy and security of those using universal toilets, which also includes navigation instructions and toilet identification signage. You should also consider the requirements of workplace regulations, building regulations, Part M and Part G, as well as any sector guidance on the provision of toilets.

The approved document T contains guidelines for the dimensioning and design of ambulatory and universal toilet cabins. It also includes wayfinding and signage tips. There is no definition of “space constraints” and it is expected that it must be interpreted on a building-by-building basis. It can be expected that this alternative approach will not apply to large buildings, but only to buildings such as small commercial premises and small light industrial facilities where space is more limited.

Parts Q, R, S and now T have been introduced into building regulations in recent years in response to social and technological changes, as well as safety and security concerns. You may be wondering what Part U will address and when it will be published. With only six letters of the alphabet left, the government will soon have to consider what the title of the seventh new building regulation will be, if one is in fact needed.