Detailed toilet and venue reviews from places I visit are on Euan’s Guide.
British standards are helping businesses thrive. Some of them define access for disabled people outside and inside public buildings.
What is a British Standard?
Standards define best practice in many different areas. They’re put together by groups of experts and come in a number of different kinds, from a set of definitions to a series of strict rules.
… Standards are not the same thing as government regulations, but they’re often used in legislation to provide the technical detail.
Standard BS 8300 defines access requirements from ‘set down points’ in car parks to the distance to the toilet or width of lifts. There is a section about toilet access, dimensions, fixtures, fittings etc which is best practice.
A new draft for BS 8300 is available to read and comment on. There are two parts – the toilet section is on 8300-2.
Link to draft BS 8300-1 and BS 8300-2 (enter 8300 in the search).
What is a RADAR Key?
The RADAR key opens toilets fitted with the RADAR National Key Scheme (NKS) locks. Toilets fitted with these are for the use of disabled people and are found all over the country (e.g. pubs, restaurants, leisure venues, tourist places, shopping centres, stations, airports etc).
Why is it called a RADAR Key?
The NKS scheme used to be administered by an organisation called RADAR (The Royal Association for Disability Rights). This has now merged with two other organisation to become Disability Rights UK. The name RADAR Key has stuck since then and is was going to be relaunched but this no longer appears to be the case.
What types are there?
There are two types – one with a small head and one with a very large head for people with grip or dexterity difficulties. Both are silver with the word RADAR Key embossed on them and will fit into an NKS lock which looks like this:
They are long handled to bypass vandal protection blocks built into doors.
Who can have one?
Any individual with an impairment / medical condition who needs access to these larger toilets or hygiene facilities or needs facilities to assist mobility or navigation (such as hand rails, lower basin, contrasting colours, different toilet height or seat arrangement, changing table, hoist for example).
One downside is that you do not need proof of need to purchase one so parents and non disabled people can abuse the scheme.
Where do I buy a genuine key from?
You can buy genuine keys from http://www.disabilityrightsuk.org. At the time of writing (updated August 2016) they cost £4.50 (RADAR, when audited showed no profit in the keys – they actually made a loss at this price).
The Blue Badge Company are also promoting a genuine key with a blue handle for £6.00
I have seen them for sale elsewhere – do they work?
There are hundreds of places claiming to sell ‘genuine’ keys including many prominent charities and mobility shops. One of the reasons for relaunching a new key is to avoid people being ripped of by fakes that may be so rough cut and out of shape that they don’t easily open toilets, if at all.
Tom Gordan from their sales team told me:
How do I find a toilet?
A booklet for regional locations is available on their website costing £3.50. However, it will cost you £70 to purchase all regions.
The majority of toilets use the scheme so it’s probably best to just follow signs to toilets/accessible toilets as anyone would do.
A new RADAR Key App will be available around September 2016 listing toilet locations.
Why are accessible toilets often locked with these in the UK?
Many places choose to install NKS locks on their toilets to keep them clean and reduce the chance of them being abused by people who don’t need to use them, vandalised or used for drugs, sexual activity or a wide range of other things.
So for the last 6 months or so there has been much discussion on gender neutrality and which toilet you use.
Followed by ‘if anyone can use a toilet, what sign do we put on the door’. Oh my goodness – do you put a man and a woman, both, half and half, something totally different …. or maybe just a picture of a toilet would be pretty sensible?
Whilst the world goes crazy trying to figure this out …. accessible toilets have been caught in the cross fire.
Our ‘unisex’ toilets don’t have any gender specific symbol
You see, we never had any gender identity to begin with. Someone thought ‘we’ might be best represented by a genderless person, usually with no neck, sitting rigid (probably because they sat on a broom handle or something) in an odd shaped wheelchair.
If we had gender then wouldn’t we have had this toilet sign?
We don’t think – is this representing a man, woman etc to decide whether to go in or not …. we just see the symbol, on a single occupancy room, and know that beyond the door is a toilet which is hopefully surrounded by adaptations and space to use it.
This symbol isn’t even toilet specific – it might not be a toilet behind the door it could be an ‘accessible’ anything because this is just a universal symbol for access in relation to disabled people.
Not only genderless but not representative
One of the issues is that this symbol doesn’t even represent three quarters of the people who can use an accessible toilet – anyone with a medical condition who needs the adaptions or quick toilet access.
It doesn’t represent people who have an impairment but don’t use a wheelchair. It’s also a major barrier for people who think the symbol represents disability and they don’t identify with being disabled (e.g. older people, people with IBS and mental health problems often do not define themselves as disabled and feel the toilet is for ‘others’). How do you get over that?
Do we need a totally new, universal accessible toilet symbol – and how on earth could we pick something meaningful to everyone. This has been the problem and reason why most countries stick to keeping the symbol of a wheelchair user.
Why this symbol does not make it the designated gender neutral toilet.
Because of the rise in people speaking out about needing a toilet that is gender neutral, some businesses are saying ‘ we already have a toilet just for you [points to the accessible toilet].
This is not a toilet for ‘anybody’ to use … if people don’t have an impairment then they shouldn’t be taking up a toilet with adaptations.
People looking for a gender neutral toilet don’t want to be taking up facilities that are for disabled people. It’s awkward and discriminatory, all round. People just need a toilet. One with adaptations and one without. It’s simple.
Disabled people might need quick access to the toilet because of their medical condition (and may need to go more frequently and stay longer). Every ‘other’ person (be it a parent needing baby changing or a transgender person etc) is taking away the accessibility feature of ‘availability’ every time they use it.
I sincerely hope that we don’t start seeing this sort of thing become the norm. A sign to represent a gender neutral toilet – attached to what used to be an accessible toilet only for disabled people. I am hearing that this is starting to happen though and it’s worrying.
This will cause so much distress to disabled people who need quick toilet access but may now have to wait because the toilet has been opened up to anybody – all because of a sign.
Today we launch our new campaign #BiggerIsBetter [Bigger Is Better].
We hear over and over again how much people struggle with the size of wheelchair accessible toilets.
Unfortunately, the size suggested by building regulation guidance is far too small for the types of wheelchairs and scooters that people use today.
We need to raise awareness and explain why meeting building regulations does not mean they are meeting their legal duties to provide usable toilets under the Equality Act [Disability Discrimination]. Very few businesses are aware of this.
Wheelchair users can often not get into these toilet spaces, turn around or transfer safely. They become unusable. An unusable toilet might as well not be built.
Every toilet that gets built to this size could mean decades of being unable to use that toilet. If nothing happens now – the future will remain bleak.
If the standards are not going to change, then the only way forward is to reach out to as many businesses and new developments as possible and encourage them to see that bigger is better.
We need to encourage larger spaces and where possible Space to Change or Changing Places. Without larger spaces, wheelchair and scooter users will continue to struggle to live as equal citizens in the UK.
Please join the campaign and help spread the word. Share our posters, pictures and your experiences.
Disabled people of all ages, and those who support them, are putting their health at risk because of lack of usable toilets within NHS hospitals and clinics.
Inaccessible toilets at UK hospitals and clinics are also having an impact on the health and recovery of people who may not identify themselves as a disabled person. People with dementia, bowel/bladder disorders, those receiving treatments for cancer or heart/lung disease, rehabilitation therapies or mental health illness for example.
Our 43 page report with a summary of key findings (below), brings together the experiences of patients and families.
Contributors all have a long term health condition or illness which makes it difficult or impossible to use the toilets currently provided.
Download the report from the link below.
We a very grateful to everyone who participated, providing much needed insight of the urgent need for equality of toilet provision, within the NHS, to support physical and mental wellbeing.
Key findings 2015-2016
- Due to stigma, embarrassment and sometimes cultural or gender reasons, patients and visitors rarely complain about difficulties accessing/using the toilet or sharing their experiences.
Rights and Equality
- Provision of toilets are the most overlooked Human Right contained in the European Convention on Human Rights and the UK Human Rights Act.
- Access to sanitation is a Human Right being ignored within the NHS.
- Equality Act duties are not being met because a worse standard of toilet provision is provided for disabled people with no reasonable adjustment.
- Patients who do not meet the Equality Act definition of ‘disabled’ are also affected by lack of facilities due to short term illness, injury etc.
- NHS buildings are failing to meet building regulations or strive for British Standards.
- Standard wheelchair (Approved Document M ) accessible toilets are not meeting the health and sanitation needs of a wide range of people, particularly those with:
- Muscle weakness / neurological impairments
- Spinal injury
- Stroke related difficulties
- Limb loss
- Shortened limbs
- Arthritis / joint immobility
- Urinary Incontinence including urgency needs
- Bowel Incontinence
- Learning Difficulties
- Brain injury and balance disorders.
- Some toilets have been found to be unsafe e.g. by not using non-slip flooring, no emergency cords / unreachable cords or not having the right type and placement of support rails.
- Hospitals are failing to ensure dignity, safety and well being of patients, staff and carers by offering unsuitable alternatives to standard toilets.
- There are 155 acute NHS trusts plus 56 mental health trusts as of October 2015. Many having multiple buildings across several locations. Out of all these buildings, only 42 provide a basic Changing Places toilet with hoist, extra space and bench access.
- NHS staff, for the safety of themselves and patients, can not assist by lifting people from wheelchair to toilet or from a seated to standing position. Where Changing Places are not provided or other suitable equipment such as adjustable height toilets, patients must take a family member to do manual lifting/assisting. This has caused long term back pain for many carers and is painful and dangerous for those being lifted.
- NHS staff are not familiar with the needs of patients regarding sanitation which results in poor signposting to toilets / inability to locate a toilet and unsuitable ‘alternatives’ being offered.
- Not all toilets are shown on hospital maps/signs – and the facilities in each are variable, resulting in difficulty locating a suitable toilet.
- Very few NHS websites detail information about where toilets are located and the facilities in each – making planning for an appointment difficult.
- Toilet signs are often difficult to understant, see or follow.
General Health and Wellbeing
- Women are worst affected due to the need to be seated on the toilet, menstrual hygiene needs, increased risk of urinary infections and being more likely to have bladder problems such as urgency.
- Patients say they would rather miss appointments because of fear of not having toilet access.
- Families are prevented from visiting their spouses/children or friends in hospital because they can’t access a suitable toilet.
- Patients are choosing to stay at home rather than go to A&E where long waits and no usable toilets are normal.
- Patients are having surgery to remove the need to sit on a toilet (ostomy or suprapubic catheters) because of access reasons not because of a medical need.
- A healthy adult empties their bladder every 2-3 hours, yet many disabled patients are avoiding food and liquids for several hours because they know they can not use toilets at hospitals and clinics.
- Avoidance / withholding urination and defecation has caused kidney, bowel and bladder damage.
- Patients are taking extra medication to prevent urination or defecation when outside their homes for several hours impacting work, leisure and attending health appointments/treatments.
Difficulties specific to wheelchair and Scooter users
- Wheelchair and Scooter users can not get close enough to the toilet for safe transfer. (People with a wide gait, obesity, users of frames/walkers or crutches are also affected by this space restriction).
- 82% of powered wheelchairs will not fit into the transfer space at the side of a toilet that meets current building regulations.
- Out of 613 models of scooter and powered wheelchairs – only 140 can turn around in the turning circle recommended in the current building regulations.
- Severely disabled patients are spending several hours in soiled pads whilst they attend hospital appointments because of no hoist or changing bench facilities.
The NHS, by its very nature, will serve a higher percentage of people who need very specific facilities to use the toilet. Therefore, adapted toilets need to be of a higher quality to maximise independent toilet use and maintain a high standard of dignity, safety and hygiene compared to other ‘away from home’ facilities.
Due the nature of a persons’s impairment, illness, injury or medical condition, they may:
- need the toilet more urgently
- spend longer on the toilet (and getting on and off the toilet). 30 – 40 minutes is an average time.
- go more frequently
- require furniture/equipment to aid removal of clothes e.g. bench/chair
- need toilet provision beyond what is required within building regulations e.g. extra space, access to bidet facilities/washrooms, access to a hoist and changing bench, access to a height adjustable toilet or other equipment.
To substitute a dedicated room (that non-disabled people are provided with) which has a flushing toilet, sink, waste bins, toilet paper, privacy (locked door/single person use) and space for any of the following (which are common practice alternatives) is not appropriate and probably unlawful.
- offering no support or equipment – no usable toilet.
- offer of a commode, spare bed / cubicle (often with a wait) alternative for people who could use a toilet room if one was provided.
- suggesting patients pre-arrange hoist and nursing support (where space exists to safely use these as a hoist can not be used in a standard wheelchair accessible toilet space). Few people know exactly when they will need the toilet to plan days in advance.
Many alternatives cause pain, embarrassment, and mental distress. Solutions exist because people are able to use the toilet in their own homes – so why not in hospitals and clinics?
Whilst not a legal guide, information is provided here, and in our guides, to help you assess if your toilet provision is meeting the required standards and your Equality Act duties. Only a court can decide if you have failed to prevent or caused disability discrimination. Similarly, toilets which do not comply with health and safety will be subject to further actions and investigation from relevant safety bodies.
• Guide to Accessible Toilet Standards and Equality Act Requirements
The Equality Act 2010
In the UK, the Equality Act protects the rights of all disabled people, as individuals – which includes sanitary facilities that are provided.
Facilities being offered must provide equal access to toilets for disabled customers / visitors and employees, to the same standard as non-disabled people. This means meeting their Equality Act 2010 obligations. Public bodies such as councils, schools and hospitals have additional duties under human rights law and the Equality Act.
The Equality Act does not recognise ‘minimum standards’. An individual disabled person or carer could argue that there has been no ‘reasonable adjustments’, as required by law, as it relates to them. Also, what is ‘reasonable’ changes over time and adjustment is an ongoing obligation.
A business should pay close attention to how ‘reasonable’ is judged in courts and described in the Equality Act. Many businesses underestimate the extent of their duty to make adjustments and do what is reasonable in all of the circumstances. Citing ‘too expensive’ or ‘disruptive’ without evidence of a thorough assessment and providing strong reasoning would be unwise.
Businesses must take positive steps to remove barriers to disabled people and make reasonable adjustments. They must think ahead and plan to remove barriers – not wait until a person has had difficulties or feels they have been discriminated against.
Listen to the experiences of disabled people and if a problem has occurred take reasonable action to prevent discrimination from re-occurring in a timely manner – the ongoing obligations of the Act.
If someone doesn’t cooperate with their duty to make adjustments, the Equality Act says it’s unlawful discrimination.
The duty to make reasonable adjustment, imposed by the Equality Act 2010, means that provisions beyond that in Approved Document M [AD M] of the building regulations are likely to be required to anticipate the needs of a range of disabled people so they have equal toilet access.
You may have to upgrade your toilets now rather then wait for a ‘refit’ or new toilet block to be built.
Reasonable adjustments may include:
- Gaining a thorough understanding of the needs of a range of different people and understanding particular needs e.g. asking “what do we need to do specifically for people with profound and multiple learning difficulties” as opposed to ‘what facilities do disabled people need’ or ‘what is the minimum standard we have to meet’.
- Auditing toilet facilities thoroughly – not just against minimum standards.
- Consulting with disabled staff, customers or other organisations to ensure facilities meet a wide range of people with different hygiene needs.
- Making physical adjustments / building new toilets.
- Providing Changing Places toilets or hiring a mobile unit
- Publishing access statements about toilet facilities.
- Making people aware of the type of facilities you have (e.g. widths of doors, heights of toilets, layout of grab rails, type of lighting etc).
What do the building regulations say?
Although the guidance in this Approved Document, if followed, tends to demonstrate compliance with Part M of the Building Regulations, this does not necessarily equate to compliance with the obligations and duties set out in the EA [Equality Act].
This is because service providers and employers are required by the EA to make reasonable adjustment to any physical feature which might put a disabled person at a substantial disadvantage compared to a non-disabled person.
In some instances this will include designing features or making reasonable adjustments to features which are outside the scope of Approved Document M. It remains for the persons undertaking building works to consider if further provision, beyond that described in Approved Document M, is appropriate.
How do I upgrade my existing toilets?
To provide good facilities the following types of venues (but not inclusively) should be looking at 1 or more Changing Place toilets alongside provision of toilets that meet the latest building regulations (October 2015) – these have diagrams of exactly how to fit out a toilet, what size it should be etc for maximum accessibility.
- major transport terminals or interchanges such as airports, large railway and bus stations
- motorway service stations
- sport and leisure facilities, including entertainment arenas, stadiums, large hotels, large theatres and multiplex cinemas
- cultural centres such as museums, concert halls and art galleries
- shopping centres, large retail developments and Shopmobility centres
- key public buildings within town centres such as town halls, civic centres and principal public libraries
- educational establishments, including universities
- health facilities such as hospitals, health clinics etc.
- portable facility at outdoor events
There is also a British Standard for accessibility BS8300:2009.
Guides on our link/resources page will also help you.
Full details about Changing Places and are available from:
Smaller venues should look at recent building regulations below and also look at whether other facilities could be offered e.g. a hoist or a changing bench for disabled children if they can not provide a Changing Place.
If toilet facilities are not meeting the needs of individual disabled people, organisations must change things to make sure there is suitable toilet provision. Not having useable toilet facilities would be a major barrier to using / visiting , or working for an organisation.
Having no usable toilet facilities is also highly likely to prevent substantial income generation from disabled people and their families because they would be unable to visit, or visit for the same length of time as non-disabled people might.