Changing places policy

Publication date: 21 May 2024

Changing Places toilets are necessary to meet the needs of many children and adults
with disabilities, their families, carers/assistants and people with similar needs. The
draft policy for consultation reflects our commitment to equality for all service
users.

Associated Documents

Safeguarding children and vulnerable adults policy

1. Introduction

This policy sets out our commitment to providing Changing Places Toilets (CPT) in council facilities open to the public across our area.
It should be read and considered in conjunction with all other relevant council policies and guidance e.g. Safeguarding children and vulnerable adults policy. Through the ethos of the Community Plan and the Statutory approval and Consultation roles the council will also seek to promote and influence the provision of Changing Places Toilets amongst developers, its partners, and local businesses in relevant buildings open to the public across our area.
In the absence of Changing Places facilities, people with disabilities and/or carers face significant restrictive and potentially undignified visit ability when accessing council
services.
This policy seeks to ensure commitment, where practicable, to equality for all council
service users.

2. Background

Standard accessible toilets meet the needs of some people with disabilities – but not all. According to research commissioned by other interested organisations it has been indicated that over 230,000 individuals in the UK need personal assistance to use the toilet or change, including for example people with profound and multiple learning disabilities, spinal injuries and individuals living with stroke.
Without appropriate facilities, carers are forced to change continence pads etc. on public toilet floors or wait until they go home.
A standard accessible WC is designed for independent use by an individual. Grab rails are located to the side and rear of the pan, aiding self-transfer between wheelchair and the WC. In some cases, a wheelchair user may be assisted, but there is usually insufficient room for two assistants. Standard accessible WCs are designed to facilitate access by a standard wheelchair, but are unlikely to accommodate a powered wheelchair, or those fitted with additional head or leg supports.
It is important therefore, where practicable, that individuals with profound, complex and multiple disabilities and impairments are able to safely, comfortably and hygienically spend time away from their home. Changing Places Toilets support this by providing sanitary facilities, with extra space and equipment that can be used by people who require the assistance of one or two carers/companions. As they are designed for assisted use they should supplement, not replace, standard unisex accessible toilets.
Following the publication of the results of a Consultation on Introduction of Provisions for Changing Places Toilets within building regulations, undertaken by the Scottish Government, responses indicated overwhelmingly that introduction of provision of CPTs through building regulations is seen as beneficial, both in increasing the number of facilities and in raising awareness of the need to consider such facilities in similar existing buildings.

3. Our approach

The provision of a CPT standard facility shall be considered routinely for all proposals for new council buildings, significant refurbishments and other council owned or controlled facilities such as parks, outdoor spaces and events as follows:

New construction

We will adopt the approach as provided in The Building Regulations (Northern Ireland) 2012 – Amendments Booklet – AMD 8, Amendments to Technical Booklet R – June 2022 when assessing the need for Changing Places Toilets within our own property ownership open to the public.

Conversion or extension

Where a Changing Places Toilet is not already present within a building, one should be provided if it is reasonable and practicable to do so: where a building in the relevant categories is created by conversion or where such a building is extended such that its gross floor area increases by 25% or more and its floor area exceeds. 5,000m².

Parks, outdoor spaces and events

Where practicable and reasonable we will provide permanent or mobile portable CPTs at our larger owned or controlled facilities such as parks, other outdoor spaces and at our events. Where necessary an event should be equality screened to ensure that the need for such mobile facilities is properly assessed. Have a clear rationale for the decision.
Where we are not the asset owner we will endeavour to adopt an influencing role through our regulatory framework to encourage facility owners or developers to provide a Changing Places toilet within the guidance triggers suggested.

Layout and facilities

Provision of a CPT will be in addition to the provision of standard and accessible sanitary accommodation and will be located to provide easy access for users.
A CPT will provide adequate space to allow a user to be assisted by carers. It will be a minimum of 3 m wide by 4 m long, with a minimum ceiling height of 2.4 m and a door with a minimum clear opening width of 1 m.
Floor surfaces should have a non-slip finish. The room should include the following
sanitary facilities and fixtures:

a peninsular WC;
a height adjustable wash hand basin;
a ceiling-mounted tracking hoist;
a height adjustable adult sized changing bench (minimum length 1.8 m);
a retractable privacy screen;
grab rails to assist in use of facilities;
a call assistance system; and
within a building that includes other changing facilities for users, such as swimming pools/leisure centres, the provision of a wall-mounted shower and floor drainage

Coat hooks, mirrors, toilet paper dispensers and other fixtures that may further assist in the use of accessible sanitary accommodation are outside the remit of the building standards.
There may be some buildings or facilities which are relatively small in size, but which have substantial visitor numbers and therefore might justify provision of a Changing Places toilet. In these cases, visitor numbers might be a better metric for consideration as a trigger. This is discretionary and will be considered on a case by case basis.
Where the space required for a full Changing Places toilet is not available or the cost is prohibitive due to potentially extensive building works to create the additional space, a smaller-sized one could be provided where achievable. It is proposed in these circumstances that an alternate of a minimum 3m by 3m (9m2) Changing Places toilet with a door with a minimum clear opening width of 1m and a minimum ceiling height of 2.4m be provided.

Promotion of changing places toilets within our area

We will ensure that any Changing Places provided within our area are promoted through our website and also registered with the Changing Places Consortium. This is so as to ensure that the public estate and the private facilities accessible to the public, are being considered in a holistic manner and that public expenditure meets its value for money obligation.

4. Review

This policy will be reviewed regularly and updated to reflect changing needs and/or relevant legislation