Tell it as it is – for world toilet day.

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19th November is World Toilet Day , a global opportunity to explain how lack of toilets impacts many aspects of life.

Join our Tell It As It Is event to share your story about the lack of usable and accessible toilets in the UK.

Starting on the 18th of November, we will be putting up a Facebook post on our page – inviting you to tell it as it is.

How does the lack of usable / accessible toilets impact your life?

Whether it’s just a sentence or a short story or photo – please do drop by and share your story by replying to that post on the 18th or 19th.

You can also join our Twitter hashtag #tellItAsItIs and also use the main tag #WorldToiletDay

*All replies will be moderated and those advertising a product or not meeting our adult and child protection policy will not be displayed.

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Standards for people with sight loss

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For buildings completed since October 2015, the following features will satisfy the requirements for sanitation provision.

These features are essential so that people who are blind or have a visual impairment, can access the toilet.

General considerations

  • Contrasting colour of door handles, door and door frames – always good to know where the door is and how to open it! 
  • An auditory alarm to warn of a fire (i.e not just a visual indicator)
  • An emergency chord alarm that is distinguishable from the fire alarm
  • An emergency chord that is identifiable and visible
  • Surface finishes of fittings and support/grab bars must have a particular level of contrast with the wall and floor (and the wall and floor should also contrast).

I have been into many toilets where there is a white floor, white walls, white toilet, white sink, white emergency chord  ….. a field of white glare to many people with visual impairments. I also find it a bit disorientating and I have good vision.

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Lack of contrast colours in a hospital accessible toilet and written only information

The statement on what is meant by ‘visual contrast’ has been deleted in the latest Building Regulation Doc M. Further work is being done to evidence what level of contrast or finish might improve visibility.

Light reflected of surfaces can be measured – called LRV (Light Reflection Value) when a surface is illuminated. Nearer to 0 would represent black and nearer 100 represent white on this scale.

The difference in visible light reflected provides differences in these values.  A LRV difference of 30 was generally a good figure to use and to avoid high gloss finishes. This would enable more people to tell the difference between surfaces when their vision is impaired – which may cause a reduction in the hue (nature of the colour) or chroma (intensity of the colour). 

Equality Act considerations

For any toilet room / toilet block, the following are also ways to meet the Equality Act 2010 to complement the above.

  • Clearly defined toilet roll dispenser (or toilet roll)
  • Assistance to navigate to the toilet room
  • A Braille description is good practice for any visual signs (toilet door symbol, warning signs, how to operate equipment etc). 
  • Appropriate space inside or outside the toilet room for assistance animals.

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People with sight loss need to be able to find a toilet and use it to have equal access to sanitation. This might mean altering signage or providing someone who can audio describe where the features are in the toilet. 

I’ve been to toilets where the  toilet roll is randomly placed on the floor, a shelf or ‘pick a wall, any wall’. This would probably be unlawful as it creates barriers for people.

The last thing you want to be doing is feeling around a public toilet or having to get so close to see something that you can almost touch it with your nose. Pretty disgusting.

Poor lighting, flickering lighting – it all makes a difference.

It is also useful to consider that some people with sight loss may also have other impairments such as learning difficulties, hearing loss, brain injury, or a person be on medication which impairs vision – so they should be equally able to use an accessible toilet. 

Attention to lighting can help people with autism as well – so insist on new accessible toilets meeting the full British Standard as a minimum to feel confident you have tried to be as inclusive as possible.

 

 

 

 

New report: Toilet access within the NHS

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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.

NHS Accessible Toilet Report 2016

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

Stigma

  • 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:
    • Obesity
    • Muscle weakness / neurological impairments
    • Spinal injury
    • Stroke related difficulties 
    • Limb loss
    • Shortened limbs
    • Arthritis  / joint immobility
    • Dementia
    • Diabetes
    • Urinary Incontinence including urgency needs
    • Bowel Incontinence  
    • Learning Difficulties
    • Brain injury and balance disorders.

Safety concerns 

  • 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.

Poor signposting

  • 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?

The future of public accessible toilets

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Further improvements are needed if we really want to make ‘away from home’ toilets truly usable for all disabled people. 

The best we have in the UK are those in new buildings which have followed guidance (Approved Document M) on meeting building regulations for access/features etc.

Most places provide single room, wheelchair accessible toilets to the UK wide specified design. A small percentage also provide Changing Places toilets (which take usability a step further by providing a high/low adjustable changing bench, hoist, toilet, sink and larger space). Changing Places are encouraged but not required in buildings. 

However, I feel we need to aim higher – because even these toilets aren’t always usable by a large number of people. It’s not just a case of whether someone can urinate or deficate – it’s about comfort for different body shapes, it’s about safety, dignity and hygiene. All these support people’s physical and mental health.

What might the future look like?

Changes in the law and building regulations.

  • Improved British Standards which would feed into
  • improved design within building regulations, for new buildings (e.g. more space)

Most importantly:

  • New laws on sanitation and equality for public toilets (both around access for disabled people and access for many other users).
  • Laws that make buildings older than 2004 upgrade their toilet facilities to the current specifications to meet duties under the Equality Act (2010) around disability.

*Currently buildings only have to provide disabled access to the level that was specified in the building regulation at the time of the build. Therefore, older buildings will not have the same level of access required today or may have no access at all.

Clear signage

There are so many different symbols, signs and words – which can be confusing for people looking for a toilet. A clear system of symbols would be helpful.

Usage

Promote the proper use of accessible toilets – many people need the facilities but don’t go in because of the words ‘disabled toilet’ or a picture of a person with specific, visual, impairment (e.g. wheelchair symbol/person with a stick). We need more public awareness that toilet like these are for anyone who needs the more specialised facilities inside.

Clearly stating that baby changing should be in an accessible parent/child location would make them more easily available to those with urgency needs.

Use of technology / equipment provision to open up accessibility to more people

Significantly high numbers of people need more than just a standard toilet, shelf and sink to meet their hygiene/toilet needs.

  1. Automatic washing and drying toilets

There are hundreds of thousands of people that are unable to clean themselves easily, or where it causes them great pain or puts them at risk of falls.

  • People with upper body limb loss
  • People with muscle weakness or paralysis
  • People with back problems who can not bend or twist.
  • People with severe arthritis 
  • People with obesity
  • People with dexterity/grip difficulties
  • People with balance and coordination difficulties.
  • People with bladder/bowel disorders/ incontinence
  • People with shortened arms
  • Disabled women particularly during menstruation.

2. Toilets which can be adjusted in height

These are essential for wheelchair users where modern chairs come in a range of heights (and people generally need to be at the same height to manually transfer from chair to toilet etc). Also, people with muscle weakness, neurological impairments or those who have difficulty moving their joints may not be able to stand up from the toilet unless it can be raised up to a height which suits them.

Variable height toilets also suit many lower limb amputees and people with short legs. Adjustability is key to prevent falls and enable people to sit/stand safely and more easily.

3. Sinks which can be adjusted in height

These facilities are only ‘desirable’ and not necessary within current guidance.

Safety

Toilets do not always have none-slip floors or alarm cords. Shouldn’t these be standard in every accessible/adapted toilet?

Space

Did you know that 82% of powered wheelchairs for sale will not fit into the transfer space inside an ‘accessible’ toilet and their is not enough room for assistance (or ambulance staff to get in to help if you fall)?

Increased number of toilets

Large venues like a shopping centre or stadium may have several visitors who need highly adapted toilets – providing one Changing Places is not enough.

What about the cost?

When someone pays for a new building – an office block, hospital, cinema/shopping mall, airport, train station … there is never a question of ‘do we need to put any toilets in the building – because we might not be able to afford it’. It is a ‘given’ that for public health, toilets must be provided. So if a place is going to provide toilets – they need to be usable by everyone (or they are as good as no provision). 

Of course, accessible toilets may have additional costs to ensure the space, technology, maintenance, security etc of the above. Those with an adult changing bench and shower need even more space.

Well, how much do you value disabled people as part of your community or workforce? How much do you want their custom (and their friends/carers/family etc)? How do you put a price on doing the right thing and enabling people to leave their homes and participate in life? What about complying with the Equality Act regarding Disability Discrimination?

Let’s be blunt – how much money are you making in your business – because most of the technology and space adaptations could be done for around £10,000 – £15,000 for the full works and is very affordable.

In my own home I have space, a ceiling hoist and a height adjustable toilet that also washes and dries – for around £5000. 

 

 

 

 

 

 

Equality of toilet provision – The Equality Act 2010

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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

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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.

Being Reasonable

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.

Making adjustments

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.

[http://www.planningportal.gov.uk/uploads/br/approved-documents-amends-list_2013.pdf]

How do I upgrade my existing toilets?

cp_doorTo 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:

http://www.pamis.org.uk/cms/files/publications/Changing%20Places%20a%20Practical%20Guide.pdf

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.

http://www.planningportal.gov.uk/buildingregulations/approveddocuments/partm/adm/
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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.

Sanitation and the purple pound

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If disabled visitors can pee and poo, the purple pound will come to you.

It’s that simple.


Sanitation is possibly the most overlooked provision that can bring profits down and decrease the number of visitors you will attract.

When asked what is the biggest factor that would prevent or deter you from visiting an attraction – disabled people generally say it’s the toilet facilities that influence their decision the most.

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A toilet that fails disabled people

Let’s face it – would you visit somewhere for the day that had no toilets?

We need to remember that an ‘accessible toilet’ that is not usable (or doesn’t have the full compliment of access features for people with different needs) can be regarded as absent.

Your toilet is as good as absent if:

  • it is poorly signposted. If you can’t find it when you need to – it might as well not be there.
  • locked (aside NKS keys)
  • has the wrong fixtures and fittings
  • poorly maintained (dangerous, wrong flooring, poor illumination, wet etc)
  • cluttered or being used as storage space
  • Does not have the full range of access features needed by visitors – would you know what makes a toilet usable for all?

I have been to 14 places of interest in the past year (Museums, gardens, historical buildings, wildlife parks/zoos, heritage railways) for days out.  Being passionate about sanitation, I looked in every ‘accessible toilet’ on all but one site  – not a single one met the full access requirements as detailed in the current building regulations for a new toilet.

In other words, they all had elements which would have made them unusable for people with particular needs.

Only 2 had a hoist for people who can not raise themselves out of a wheelchair onto a toilet, and only 1 had an adult changing bench for those who need a pad change.

I have what is required by law.

This may be true in respect of building regulations – but the Equality Act 2010 requires equality of sanitation provision for disabled people. (See our free guides for information)

To fail to bring your facilities up to the most recent standards gives a strong message that disabled people and their friends and families are not welcome. You are not interested in supporting social inclusion and are not interested in taking your share of the purple pound.

What is the Purple Pound?

The purple pound is money that disabled people and those that come with them (e.g. family, friends etc) have to spend on tourism.

  • In 2013, 20% of all Tourism Day Visits in England included someone with a health condition/impairment. That’s a spend of £9.4 billion.
  • Over 500,000 people each year visit England from abroad, who also have a health condition or impairment – worth £341 million.

In total – disabled people and companions are spending £12.4 billion pounds a year within tourism.

Why would you not want some of this money?

The quality and standard of your toilet provision says a lot about you. Get it wrong and it’s going to cost you money and your reputation.

Written for World Tourism Day 2015:  http://wtd.unwto.org

Share your experience tool kit – challenge discrimination

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Our new guides and ‘Experience form’ make up our new tool kit to challenge discrimination.

The tool kit is available for disabled people and their assistants / carers, to enable them to approach a company who has failed to provide accessible toilets that meets their needs.

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It can be the start of a conversation to challenge discrimination and provide business with an opportunity to explain their approach to equality in the area of toilet access / sanitation / hygiene provision.

 


 

Step 1:

If you have had a bad experience, either download our form (or copy and paste the text into an e-mail).

The form (and a link to a text version to copy and paste) is available from: Links and resources page

Step 2: 

To fill out a pdf. form, use the ‘text’ and ‘highlight’ functions on your pdf viewer, save it and attach it to your e-mail.

  • Even easier is to create a new e-mail, and copy and past the text straight into it  from here.

 

Completing the form:

Once you have completed your basic details, go through the list of statements in the following 10 topics:

  1. Finding and entering the toilet area
  2. Entering / securing the toilet room
  3. Inside the toilet (space/colours/lighting/equipment)
  4. About the toilet / bench / hoist
  5. Sink
  6. Accessories (e.g. mirror/dryer etc)
  7. Horizontal support rails
  8. Vertical Support rails
  9. Emergency cord
  10. Other

simply deleting the ones that don’t apply – or highlighting the ones that do.

don’t forget to attach any pictures of the toilet you had difficulties using – this is important evidence.

Step 3 – Understanding the company response

The person may respond with a general statement like ‘… we do our best to make our venue accessible and will look into it’. In which case,

  • reply with a reminder to ask if they can let you know what they found out
  • ask about what they intend on doing and
  • when you might hear back from them.

Another type of reply might be something like ‘we have already complied with Document M and provide accessible toilets’. In this instance, you may want to read and supply the company with one or more of our guides, pointing out that meeting Document M guidelines does not mean they have met their duties as required by law within the Equality Act 2010 – and that the toilets did not meet your needs.

If you are unsure what these mean, our guides will also help you understand these standards and equality law.

Our guides to support you and the company include:

You can view the contents of these by clicking on the above links. They can all be downloaded from our links and resources page.

Step 4

If you are not happy with their reply you could consider continuing your discussion with them or you could consider sharing the communications with an advisor or legal expert to explore the option of taking legal action and the costs which might be involved.

Other options might be to contact your MP and explain the difficulties you have or consider a social media or local media campaign.

Remember, you have the right not to be discriminated against and treated differently when it comes to public toilet provision or as an employee who needs accessible toilets.