Inclusive British Standards?

Changing Places Toilets entrance signage

The British Standard Institute’s document that deals with accessibility in buildings and the built environment (BS 8300) has been under review for some time and last month, the greatly anticipated (well by me anyway!) draft of BS 8300 for public consultation was published.

BS 8300 is a massive document with a wide ranging remit (excluding dwelling design), containing lots of essential information to enable designers, developers and service providers to take actions to enable access to our built environment for people across the full spectrum of disabilities (not just ramps and lifts – although of course they are very important!). Including this particularly welcome section about including Inclusive Design in the development process:

“An inclusive environment recognizes and accommodates differences in the way people use the built environment. It facilitates dignified, equal and intuitive use by everyone. It does not physically or socially separate, discriminate or isolate. It readily accommodates and welcomes diverse user requirements – from childhood to adulthood through to old age, across all abilities and disabilities and embracing every background, gender, sexual orientation, ethnicity and culture. It helps people to live independently and participate fully in all aspects of life.” (Clause 4, BS 8300 draft)

Changing Places Toilets entrance signageHowever (as any regular readers will know!), one of the aspects of accessibility that particularly impacts my family (and approximately 250,000 other individuals, plus their families and friends, in the UK!) is a shortage of accessible toilets with hoist and changing bench. The only description for this need currently in the BSi standards is called a Changing Places Toilet.

Therefore my primary focus so far has been on reviewing the sanitary facilities section and I’m afraid I’ve found the amendments extremely disappointing, and counter to the lovely inclusive statement above.  It still reads to me as if changing places toilets have just been added on rather than included within the standards for sanitary provision.

I’ve laid out some of my initial thoughts on the accessible toilets section in a previous post, describing why we still feel Slightly Invisible and I will publish some more of my detailed thoughts on specific clauses (including my own suggestions for improvements) soon.

I know this legislation stuff can be a bit dry (downright boring?!) and jargon filled, but it is so important!  So much of the challenge in campaigning is the drudgery of contacting individual providers, who may or may not be receptive to comments and many of whom throw back the old, ‘we’ve complied with all current legislation‘ chestnut.

In building legislation, there’s so much stuff to read, and it can be confusing even for those of us in the industry so it’s massively important that current legislation is clear, and also clearly fair (for the users and the providers).

So I thought it might help to try and explain what a BSi Standard (like BS 8300) is, and how it relates to other legislation and regulations…..

The explanation on the BSi website is:

“In essence, a standard is an agreed way of doing something” but is “designed for voluntary use”

“The point of a standard is to provide a reliable basis for people to share the same expectations about a product or service.”

The BSi standards are accepted guidelines, in some cases best practice guidelines for particular situations, products services, put together by a wide range of interested parties (in the case of buildings that is users, designers, consultants, developers, service providers etc).

They stand alongside, and support other relevant legislation, the key ones for building accessibility being the Building Regulations and the Equality Act.

Building Regulations

In England, the section that deals with accessibility is Approved Document M, Volume 2 (or Part M2 for short, Part M1 for accessibility in homes).  Scotland, Wales and NI all have their own Building Regulations documents, but all have a broadly similar approach to accessible toilet legislation as Part M (hence the pet name for the standard style of accessible toilet being the “Doc M toilet” or the fittings being called the “Doc M Pack’).

As buildings, and their contexts, vary so much (from existing buildings to newbuild, from homes to offices and sports venues, tiny to enormous, hilly sites to flat…..) the Building Regulations are set out as an “Approved” way to do things, an approved way to meet a host of other legislation affecting buildings and people and the environment etc.  You do not have to meet legislation in the way building regulations say so, if people want to, or find they can’t comply for some reason or another, there are concessions or alternative methods that may be approved on a case by case basis.  However most developments do follow the regulations if they can, as everyone knows where they are then!

There is only a small mention of Changing Places Toilets in there, which references the BS 8300 document and the Changing Places Consortium guidance.

Building regulations are only enforceable at the time of development or refurbishment, so some people argue that changing them won’t help the situation for existing buildings.

The Equality Act

The Equality Act 2010  is a more overarching legislation that covers all equality issues from race to gender, employment to access.  It does not set out specifics on how buildings should provide access, just that they shouldn’t put disabled people at a “substantial disadvantage”.

This, from the beginning of Part M of Building Regulations:

“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. 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.”

So although there is some wiggle room for developers and service providers in both the BSi Standards and the Building Regulations, they still play an extremely import role in setting out what is expected in buildings and venues and what would be considered a ‘reasonable adjustment’ under the Equality Act legislation.  It’s therefore crucial that they reflect fairness to all, and in a clear way.

So if any aspects of accessibility affect you or someone you know, please do  have a look at this draft document!

You can register with the BSi to view the draft and submit your own comments on the standards (until 13th August), as an individual or on behalf of an organisation, by entering BS 8300 into the search bar, here:  BS 8300 for public consultation

You can find a selection of posts by other bloggers about how the lack of Changing Places Toilets affects them here

Slightly Invisible

Slightly Invisible

Last week, during Carer’s Week, a twitter conversation between two of my campaigner friends made me immediately think of one of our favourite books, “Slightly Invisible” by the fabulous Lauren Child (the brand new Children’s Laureate!).

Twitter conversation between @ordinaryhopes and @topeeornottopeeIn the story, Lola and her (imaginary?) friend, Soren Lorensen, drink an invisibility potion that her brother Charlie has made with his friend. Lola, of course, doesn’t become invisible but Soren Lorensen does…. Lola is adamant that she is also invisible and says:

“You can only see me because you know what I look like. You can’t see Soren Lorensen at all”!

Just as Ordinary Hopes said in her tweet, and her post The Invisible Boy, so many people just don’t ‘know what we look like’ either!

Perhaps they can’t see us because they don’t understand us or our needs? Perhaps we’re only slightly invisible and they can see some of our more obvious needs, like wheelchair access (not that that mean’s wheelchair access is a given!), but not our less obvious needs?

Designers, developers & service providers could be forgiven for not knowing what we look like.  Nobody can ever know what other people’s needs are.  Disability is such a massive spectrum, we are all slightly invisible to each other.

That is why regulations, standards and guidance are so important!

To help make everyone visible to those decision makers and providers of facilities….

At the end of last week the BSi (British Standards Institute) published a long awaited consultation draft of the proposed changes to BS 8300.  This is the British Standard document which addresses accessibility in ALL aspects of our built environment (both outside spaces and in buildings).

I’ve been anxiously anticipating its publication (yes I am rock and roll!) and hope to publish some posts over the next few weeks on various topics covered that I have professional interest in or personal experience of.

The type of facility (or lack of) that impacts our family most, when out and about, is accessible toilets for people who can’t use the loo, those who need help to change continence pads, or those who can’t transfer to the loo without help of a hoist and/or more than one carer.  So the only section of the BS I’ve read through so far has been the ‘Sanitary Facilities’ chapter….

….and I have to say anti-climax doesn’t even cover it.

I am really disappointed to see that there’s little change in relation to those who need help to use the toilet.

I don’t believe this draft of BS 8300 will help the decision makers see us any more than they did before.

I’ve yet to do a detailed compare and contrast, but my first thoughts are that there are still clearly two classes of disabled people when it comes to toilet provision.

The intro to the sanitary accommodation chapter (chapter 18) sounds great!

“Disabled people ought to be able to find and use suitable toilet accommodation no less easily than non‑disabled people. The space requirements for suitable toilet accommodation are generally driven by the requirements of wheelchair users, although the facilities might also be used by people with other impairments..” (Clause 18.5)

“At least one unisex wheelchair accessible toilet (see should be provided at each location where toilet accommodation is provided for the use of customers, employees or visitors” (Clause 18.5.1)

So far so good!  Wheelchair accessible toilets at each location where the other toilets are! Brilliant!

If only it meant all wheelchair users.

The ‘unisex wheelchair accessible toilet’ referred to is only suitable for those who can independently transfer to the WC.  People who need hoist or carer assistance and/or who can’t use the loo at all and need somewhere to lay down to change continence pads cannot use these toilets.

In contrast to the above inclusive statement, the recommendation for where it’s appropriate to provide toilets with a changing bench and hoist (a Changing Places Toilet), is:

“Any larger building where the public have access in numbers or where visitors might be expected to spend longer periods of time is a suitable venue for a CP facility. Such facilities are particularly important in buildings that might offer the only suitable sanitary accommodation within a locality, or in buildings where public services are provided, such as those operated by local authorities. Some commercial facilities such as large retail and leisure premises might be suitable as they provide longer opening hours and are likely to have a regular cleaning regime.” (Clause 18.6)

The way I think this will be interpreted by business (and the way I think it has been so far!), is that we are a municipal ‘problem’ and businesses don’t need to bother with these ‘special’ facilities.  It’s up to the government to provide them in strategic locations, not in locations where people actually are, or want to go.  Only if you have a large building, that isn’t near another large building that already has one, do you need to bother thinking about it!

Reading this during Mencap’s Learning Disability Week, it brings it home to me that we have a long way to go to break free of the ingrained attitude in society.  The older my daughter gets, the more it feels like people with complex needs are seen as other, even within the access community.  That families like ours are expected to accept their lot, and be grateful if the council provide some facilities to enable them to get out of their homes occasionally.

Both the current and this draft of the BS for toilets with a bench and hoist are written in a very exclusive way. The only solution given being a changing places toilet, which is a combined WC and shower, and which should be locked and ‘normal disabled people’ and ‘regular families’ should be directed to the ‘normal toilets’ – I paraphrase here, but that is the jist of it.  I really believe there are various design solutions which could create more flexible, inclusive facilities that could be more easily ‘sold’ to business as an asset for more customers/visitors/staff rather than an obligation (but I’ll blog about that later).

Slightly InvisibleThis lack of provision is something that affects disabled people of all ages, but also their wider circle.  You cannot go somewhere that your friend or loved one cannot access a toilet!

I can only speak for our family.  For myself and my husband as carers, and to represent our daughter who, quite literally, doesn’t, and may never, have a voice.  However I feel that many of my campaign friends are at a similar stage of life to us, watching as our kids grow apart from society as they outgrow the baby change unit.  Seeing the opportunities to visit places and join in activities with our wider family and friends slip away.

We don’t want to allow that to happen.  We want to retain the opportunities for inclusion for our families.

We don’t want our kids, their siblings and friends to be limited by society’s views of disability.

We need to be visible to those people who make the decisions on the most fundemental of facilities (the toilet) on whether to include or exclude us.

Spectrum Sunday
Mummy Times Two