The Case for Changing Places Toilets, Part 2

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Friday, June 12th, 2015
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Public toilets are a necessity for everyone, but are suitable toilets available for everyone’s use?

Part 1 of this 2 part series discussed the need for an additional type of toilet facility within large public facilities, transport hubs, airports, shopping centres, sports stadiums and the like.

These facilities, known as ‘Changing Places’, cater for a different user group that the current building codes and access standards ignore. ‘Changing Places’ will greatly benefit the 200,000 Australians with a severe or profound disability and will allow them greater access to the types of facilities with hoists and change tables they need.

When we drill down into the technical aspects of building legislative requirements it has been suggested that we, as a Nation, are letting these people down. This is where things gets a little technical when we identify key aspects of the Building Code of Australia (BCA), forming part of the National Construction Code 2015 and the Disability (Access to Premises-Buildings) Standards 2010 (Premises Standards).

The first important consideration is the overall goal of the BCA, which is “to enable the achievement of nationally consistent, minimum necessary standards of relevant safety (including structural safety and safety from fire), health, amenity and sustainability objectives efficiently”.

Secondly, within each Part of the BCA, the structure comprises:

  • Objectives and ‘Functional Statements’, being guidance material only;
  • The ‘Performance Requirements’, for which all Building Solutions must comply: either by meeting prescriptive ‘Deemed-to-Satisfy’ provisions; or by developing a flexible and innovative ‘Alternative Solution’ that meets the Performance Requirements; or a combination of both.

When we review Part F2 ‘Sanitary and Other Facilities’ of the BCA we find:

  • The objectives include safeguard of occupants from illness caused by infection and from loss of amenity arising from the absence of adequate personal hygiene facilities.
  • Functional Statement FF2.1 says that a building is to be provided with suitable sanitary facilities and space and facilities for personal hygiene.
  • Performance Requirement FP2.1 states that suitable sanitary facilities for personal hygiene must be provided to the degree necessary appropriate to the use of the building, the number and gender of the occupants and the disability or other particular needs of the occupants.

As stated above, neither the BCA or Premises Standards has specific requirements for Changing Places toilets – but it does have obligations to consider these unique needs of occupants in the Objectives, Functional Statements and Performance Requirements, which have not been addressed within the prescriptive ‘deemed-to-satisfy’ provisions of either the BCA or Premises Standards.

In terms of Changing Places we must remember that we now mandate for inclusive buildings under the BCA and Premises Standards and we need to ensure these minimum Performance Requirements have been met. This then raises a few questions:

  1. Could it be time for the Australian Building Codes Board (ABCB) to acknowledge this short-fall of the BCA and to take a proactive approach?
  2. Could an ABCB non-regulatory handbook be used to guide industry?
  3. Would it be reasonable for the ABCB and Building Surveyors to consider the use of Changing Places facilities within the Performance Requirements of the BCA and allow some flexibility in how toilets are provided in large public buildings, transport hubs, sporting centres and the like?
  4. Could there be a place for a 4th type of toilet in Australia’s building regulatory system?
  5. Should Changing Places be a recommended facility within the Premises Standards?

Only time will tell, but at the moment up to 200,000 Australian families will benefit greatly if we take an approach similar to the United Kingdom.

For those wishing to learn more the ‘Changing Places Transforming Lives Information Kit’ can be downloaded here.

Additionally, interested individuals and organisations will be interested to know that the ABCB is currently seeking comments on the draft changes to the 2016 edition of the National Construction Code until Monday 3 August 2015.

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