EPISODE: 036 - APPROVED DOCUMENT T - TOILET ACCOMMODATION
- Piotr Bytnar BEng (Hons) MSc CEng MIStructE
- Nov 21, 2024
- 17 min read
Updated: Jun 27
BYTNAR - TALKS
EPISODE: 036 - APPROVED DOCUMENT T - TOILET ACCOMMODATION
This episode is for people who want to know more about Approved Document Part T
You should like this episode if you ask yourself questions like:
What are the building regulations for unisex and single-sex toilets in the UK?
What are the minimum dimensions for ambulant toilet cubicles under UK regulations?
What are the requirements for universal toilet design in non-dwelling buildings?
How do UK toilet regulations define accessible and inclusive restroom design?
What are the accessibility standards for toilets in public buildings?
When are unisex toilets allowed instead of single-sex toilets in the UK?
What are the privacy and safety requirements for toilet cubicles under UK building standards?
What are the general design provisions for toilets in workplaces and schools?
What features are required in ambulant and wheelchair-accessible toilets?
This is Bytnar Talks: The Engineer Takes on Construction, Episode 36
Hi, I'm Piotr Bytnar. Each day, I help my clients plan and design building projects through Bytnar Limited, a consulting Chartered Structural Engineers practice. My biggest passion, and the cornerstone on which I've built my business, is finding clever solutions for construction projects.
I am a Chartered Structural Engineer and a budding software developer, so you can rest assured that I will strive to talk about the best practices and the use of new technologies in the industry. If you're embarking on a construction project, or are involved in planning, designing, and building the world around us, you'll find this podcast useful.
Approved Document T: Toilet Accommodation
Hi guys, and welcome to Bytnar Talks, your favorite podcast on all matters of architecture, engineering, and construction. It is Thursday, the 21st of November 2024, and I'm here back with you with the 36th episode and information on Approved Document T: Toilet Accommodation.
What an end to last week! Bytnar had the pleasure of taking part in the fundraising gala dinner for the local charitable grant-making trust that works to alleviate physical impairment, poor mental health, and homelessness in Kent. What a name, innit? They help our families, your neighbors, or relatives make ends meet when life strikes unexpectedly with hardship of all sorts — from accidents and sicknesses to the inability to cope with economic or mental situations.
What is particularly important is that they help locally, making a big impact in people's lives. If you can help, go to dwa.org.uk to find out more about them and to chip into local help for local people.
Last week, we started an outreach campaign as well to gather your views on construction in England. We are waiting for your engagement, so don't hesitate and just keep on sending those emails and direct messages. When we gather your opinions and experiences, we will be able to combine them for the benefit of all. So please, do not hesitate to email us — together, we will be able to deliver better results.
Okay, that is it from me. Let's go back to the delivery of this episode, starting with the recap of the last one first.
In the last episode, I talked about Approved Document S: Infrastructure for Charging Electric Vehicles.
Section 0 of that document told us that these guidelines apply to new residential and non-residential buildings, those undergoing significant use changes, and major renovations. Mixed-use buildings are included if relevant work is performed. We were also reminded of related regulations, including Regulation B, K, M, and P.
Section 1 covered new residential buildings. For residential buildings with parking requirements, S1 and Regulation 44D are satisfied following the recommendations of the document obviously. Charging points must match in number the parking spaces or dwellings served. If no on-site parking exists, charging points are unnecessary. For spaces without charging points, provisions for future installations are required if costs stay under £3,600 per connection. Building control must verify connection costs with at least two quotes, one from a Distribution Network Operator.
Section 2 deals with change of use and major residential renovations. When it comes to material change of use, Requirements S2 and S3, together with Regulation 44E and 44F, apply. When adding or removing dwellings, charging points must match the number of new dwellings — unless electrical upgrades are needed. Exemptions may apply to historic or traditional buildings.
Major renovation, on the other hand — for renovations with 10 or more parking spaces — requires charging points proportional to the number of spaces or dwellings, kept at 7% of renovation costs. Covered spaces need future-ready cable routes, even if charging points aren't installed.
Section 3 talks about new non-residential buildings. Here we're talking about non-residential buildings with 10 or more parking spaces — at least one charging point is required in such cases, plus cable routes for every five additional spaces. Cable routes should ideally be external but must be provided in covered parking areas if applicable.
Section 4 deals with major non-residential renovations. Here, if after renovation a non-residential building has 10 or more parking spaces, it needs at least one charging point and cable routes for every five spaces. Again here, if installation cost goes over 7% of the total renovation cost, we don’t need to do it.
Don't forget: external charging points are not always needed, but cable routes are mandatory in all cases.
Section 5 deals with mixed-use buildings. If we don't know how many parking spaces to provide, just follow the residential (dwelling) side of things. This section combines the residential and non-residential rules. For renovations, the strictly residential standards usually apply. Charging points and cable routes should be installed externally where possible, with internal installations only if needed.
EV charging standards are covered in Section 6, which should comply with fire and electrical safety codes like BS EN 61851 for systems and BS 7671 for installations. Charging points must offer at least 7 kilowatts of output, have a universal socket, and meet safety codes. Cable routes should enable future installations — be marked, accessible, durable, and safe. Accessibility and spacing must support convenient future upgrades — so enough space all around the point where the cables come out. That will be different for a charging point that stands on the floor versus one that hangs on a wall.
In this episode, I will move to Approved Document T: Toilet Accommodation. So, without further ado, let's dive straight into it.
In this episode, I'll talk about the strategic guidance contained within Approved Document T: Toilet Accommodation.
Anyone who has ever struggled using public toilets in non-residential buildings should be a little bit happier with the new standards coming in — whether in new buildings being built or old ones undergoing major renovations. The document covers Requirement T1, which is a new requirement altogether, freshly added to the suite on the 1st of October of this year. It is contained within seven sections — Sections 0 to 6 — and is a sort of addition to Requirement M, "Access to and Use of Buildings." It covers the introduction, application guidance, and performance, as well as common design provisions for toilets — and it divides them into types A to D.
So, let's get into the nitty-gritty of this document.
All right, guys — starting with the text of the legislation:
Part T: Toilet AccommodationRequirement T1
Paragraph 1 — Toilet accommodation in buildings other than dwellings:(a) Must consist of:(i) Reasonable provision for male and female single-sex toilets; or(ii) Where space precludes provision of single-sex toilets, universal toilets; and(b) May consist of universal toilets in addition to single-sex toilets.
Paragraph 2 — In this requirement:
Single-sex toilets means toilet facilities which:
(a) Are intended for the exclusive use of persons of the same sex; and
(b) Provide wash basins and drying facilities in:
(i) Either the toilet room or cubicle; or
(ii) A separate area intended for use only by persons of that sex.
Universal toilet means toilet facilities which:
(a) Are provided in a fully enclosed room that contains a water closet, wash basin, and hand drying facilities; and
(b) Are intended for individual use by persons of either sex.
Requirement T1 does not apply to:
(a) Toilet and washing facilities in individual rooms for residential purposes;(b) Residential rooms in care homes, as defined in Section 3 of the Care Standards Act 2000;(c) Schools, as defined in Section 4 of the Education Act 1996;(d) Premises, or part of any premises, used wholly or mainly for early years provision within the meaning of Section 20 of the Childcare Act 2006, by early years providers to whom Section 40 of that Act (duty to implement Early Years Foundation Stage) applies;(e) Cellular accommodation in custodial facilities.
So, what is the Secretary of State happy with?
In Section 0, we are told that although building regulations do not impose maintenance requirements on us, they do assume the building will be properly maintained. The design should be inclusive of all genders, ages, and abilities — whether visiting, living, or working in a building.
This document deals with unisex or single-sex ambulant toilets, but for wheelchair-accessible unisex toilets, baby changing facilities, or Changing Places toilets, we are referred to Requirement M, Volume 2.
We are reminded that the ways to satisfy this requirement — as contained in this document — are minimum standards, and anything over and beyond is acceptable.
This requirement applies to buildings other than dwellings, which are either newly built, extended, or undergoing work that materially alters them or provides or extends controlled services and fittings. As ever, the existing building cannot be less compliant than it was before — and any work carried out after 1st October 2024 must bring the building up to this new minimum. They must not obstruct emergency exits. If the doors open inwards, they should still be fitted with an emergency release mechanism and be easily openable.
All new elements must comply with current regulations, even in existing buildings being renovated. This document gives guidance on the design and layout of universal toilets, ambulant toilets, and toilet cubicles.
In gist, we shall follow the priority of providing single-sex toilets first, with either separate or shared handwashing facilities. Unisex toilets may be provided if space allows. On the other hand, if there is not enough space to facilitate single-sex toilets, we may consider providing fully enclosed unisex toilets instead. All should be clearly signed, though.
Section 1 deals with application guidance and performance.
We already know the application: it applies to buildings other than dwellings. Additionally, schools, early years provision premises, cellular accommodation in custodial facilities, en-suite rooms in hotels, care homes, or similar residential settings are not included.
This requirement also extends the provision of facilities under Regulation 20 of the Workplace (Health, Safety and Welfare) Regulations 1992, and it directs us to HSE publication L24. This document describes the size, layout, fittings, and equipment of universal toilets and single-sex toilets, and acts as an extension to some considerations already made under Requirement M — particularly the ambulant versions of these toilets.
We are reminded that other provisions will also be required — such as those for changing children or supporting disabled people.
For calculating the number of required toilets, we are referred to:
BS 6465 (Sanitary Installations) — specifically Part 1 and Part 4
Workplace Regulations
Sport England Guidance
School Premises Regulations
Educational Regulations
NHS England’s Health Building Note 00 Part 2
When it comes to performance, this document concentrates on four types of toilets that are considered suitable for satisfying this requirement:
Type A: Fully enclosed, self-contained ambulant universal toilet
Type B: Fully enclosed, self-contained universal toilet
Type C: Ambulant, single-sex toilet cubicle (not self-contained)
Type D: Single-sex toilet cubicle (not self-contained)
If there are no clashes with Part M requirements, we can choose what to do — either A, B, C, or D — so long as we stay in the same category (either universal or single-sex). The performance criteria apply accordingly.
As per Requirement M, we must provide a wheelchair-accessible unisex toilet. Therefore, other toilets should be single-sex, in numbers judged by the occupancy of the building.
Where required, ambulant toilets should be either Type A or Type C.
Single-sex cubicle stalls should ideally open outwards into properly sized spaces used within single-sex environments. Universal toilets should open into well-lit corridors or circulation spaces.
Regarding the spaces and dimensions of the toilet accommodation, we are again referred to BS 6465, this time Part 2.
Accessible and inclusive toilet layouts are generally provided within Approved Document M or BS 8300-2.
In any case, the layout — for entering, exiting, and using a toilet or cubicle — should cater for the safety, privacy, and dignity of users. The minimum space size for each type of toilet is given in the next sections, and an itemised list is provided in Appendix D. So, when you go about planning the space, these are good places to start — especially if you want to go above and beyond and provide more items within the space. This will necessitate larger spaces overall.
Section 2 deals with design provisions that apply to all types of toilet accommodation — in other words, general provisions for toilets, regardless of type.
We’re told to look into BS 6465 for general standards — that’s the base reference. But this document also mentions some specific aspects, such as:
Urinals should be divided with privacy screens.
At least one urinal should be provided for children if separate urinals are provided to extend capacity where needed.
Toilet cubicles or rooms should have:
A toilet paper dispenser
Enough space for a disposal bin
Two hooks:
One at 1685 mm above floor level
One at just over 1000 mm
The door to a cubicle, toilet room, or universal toilet should:
Not obstruct emergency exits when opened
Ideally open outwards, but if it opens inward, it must have:
An emergency external opening mechanism
Be suitable for operation by a closed fist
Require less than 30 Newtons of force to open to 30°, and 22.5 Newtons to open to 60°
Adequately resist sound transmission
If the doors open inwards they should not encroach on a circulation space in front of the water closet pan, also known as the column of clearance or activity space. The column of clearance is considered to be a 465 mm diameter circle.
An outward-opening door, on the other hand, should have a closing bar installed. Functionality is the key throughout, but more about the door features can be found in BS 8300-2.
Doors opening onto corridors should be recessed and have 1200 mm of space in front of them when opened.
Direct sightlines from the corridor to the water closet and wash basin should be avoided, while also reducing the necessity for lobbies, as these can make access more difficult.
Clear wayfinding should be provided — such as signage throughout the building and at each toilet facility, on every floor.
You guessed it — the universal toilet sign (showing a pair of male and female figures) is covered by an international standard. It should comply with PIPF 003 from BS ISO 70001.
Controls, fixtures, fittings, and alarms should follow relevant standards — for example, wash basins as detailed in paragraph 5.4 of Approved Document M, Volume 2.
A flush mechanism should cater to people with dexterity or strength impairments.
Fire alarms should emit both visual and audible signals.
Lighting controls that require precise hand movements should be installed 750 mm to 1200 mm above the floor, ideally as simple push buttons, and should not be placed higher than 1200 mm.
As is the case in Document M - heat emitters must either be screened or operate at temperatures below 43°C.
We are again reminded that this document considers space within the toilet unit — so, if features such as piping concealment or vanity units violate minimum required space, the overall space must be increased accordingly.
We must also think about visual contrast between toilet features and the surfaces they are mounted on, and ensure clear transitions — such as at floor-to-wall junctions — are suitable for diverse user needs.
For this, we are referred to PAS 6463: Neurodiversity and the Built Environment.
We are also reminded that baby changing facilities should be provided in addition, and must not be contained within any of the four toilet types covered in this document. They also should not be located in a wheelchair-accessible unisex toilet, unless it is the only sanitary facility in the building.
So, let us move on to the types of toilets, which are covered in the next four sections.
Section 3 covers Type A: Fully Enclosed, Self-Contained Ambulant Universal Toilet.
As they say — a picture tells a thousand words — so I won’t describe every detail of the typical toilet layout. Please refer to the diagrams in the document for the full visual guide.
I’ll mention only the main points relevant for general understanding.
For universal toilets, we must also refer back to Volume 2 of Document M.
The minimum overall dimensions are:
985 mm width
2125 mm length
The door’s clear opening width must be at least 750 mm, and it must not impact the activity or column of clearance space.
One way to achieve this is by using outward-opening doors. These should have a horizontal closing bar, with:
At least 60 mm hand clearance
A length of at least 500 mm
Positioned at 900 mm above floor level
With a diameter between 19 mm and 35 mm
The column of clearance is a 465 mm diameter circle, and the activity space in front of the water closet pan is 600 mm by 800 mm.
Typical features also include:
Horizontal grab rails on both side walls of the toilet
Vertical rails to assist with standing up
Wash basin and hand drying facilities within the cubicle
Full-height doors and partitions (floor to ceiling)
Provision for a disposal bin, at least 540 mm by 210 mm
A small corner shelf above the bin, 250 mm by 150 mm, located 780 to 800 mm above floor
Hooks on the wall beside the basin — one at high level and one at low level
Section 4 covers Type B: Fully Enclosed, Self-Contained Universal Toilets
Again, I strongly recommend referring to the diagram in the document — it shows the complete picture.
It is worth noting that provisions for universal toilets (Type B) can also be used in self-contained toilets that are part of single-sex toilet facilities.
Minimum overall dimensions:
1050 mm width
1685 mm length
Door’s clear opening width:
Must be at least 650 mm, and it must not impact the column of clearance or activity space
Column of clearance is again a 465 mm diameter circle
Activity space in front of the water closet pan: 600 mm by 800 mm
Mirror and hand-drying facilities should be provided within the cubicle, along with a full-height door and partitions (i.e., floor-to-ceiling construction). There should also be space provisions for a disposal bin, at least 540 mm x 210 mm, and a small corner shelf above the disposal bin, 250 mm x 150 mm, positioned at 780–800 mm above the floor. Hooks should be installed on the wall beside the basin at both high and low levels.
Section Five moves us to Type C toilets, which are ambulant single-sex toilet cubicles, not self-contained.
The minimum overall dimensions here are 920 mm by 1465 mm.
The door’s clear opening width should be 750 mm or more, and must not impact the activity or column of clearance space.
One way to achieve this is by providing outward-opening doors, which should have a horizontal closing bar with:
At least 60 mm hand clearance
A minimum length of 500 mm
Positioned at approximately 900 mm above floor level
Handle diameter between 19 mm and 35 mm
The column of clearance is a 465 mm diameter circle
The activity space in front of the water closet pan is 600 mm x 800 mm,
But there should be a minimum of 765 mm clear space in front of the pan.
Typical features:
Horizontal grab rails on both side walls
Wash basin and hand-drying facilities shared in a communal space
Full-height doors and partitions
Disposal bin space (540 mm x 210 mm)
Small shelf (250 mm x 150 mm) at 780–800 mm above floor
Hooks on one wall at both high and low levels
We see a pattern: most features are consistent, but the space within and dimensions vary depending on user capability.
Section Six deals with the last type, which is Type D: Single-Sex Toilet Cubicle, Not Self-Contained.
Aside from general considerations (which I’ll mention in a moment), urinals can also be installed in male toilets, following BS 6465 Parts 1, 2, and 3.
Minimum dimensions are 910 mm by 1740 mm.
Door clear opening width should be 650 mm or more.
The column of clearance remains at 465 mm diameter, and the activity space in front of the water closet pan is 600 mm x 800 mm.
Typical features:
Wash basin and hand-drying facilities in communal areas
Full-height doors and partitions
Disposal bin space (540 mm x 210 mm)
Small shelf (250 mm x 150 mm) at 780–800 mm above floor level
Two hooks on one wall — high and low
More information is provided in Appendix D, including minimum sizes and requirements for:
Wash basins
Hand-drying facilities
Toilet pan and system
Disposal bin space
Grab rails (horizontal and vertical)
Closing bar
Small shelf
Toilet paper dispenser
Mirror height
Hooks at different levels
So that’s it, folks — Approved Document T: Toilet Accommodation.
I hope all the toilet spotters out there are satisfied with the new regulations and what they can think about when roaming around public spaces.
Let’s sum it up section by section:
Section 0 — Introduction and Scope:Building Regulations assume buildings are properly maintained and inclusively designed for all genders, ages, and abilities. This document outlines minimum standards for unisex and single-sex ambulant toilets, while requirements for wheelchair-accessible toilets and baby-changing facilities are addressed in Approved Document M, Volume 2.Regulations apply to newly built or altered buildings, and new elements must meet current standards without reducing compliance of existing parts.Guidance prioritizes single-sex toilets with separate or shared handwashing. If space constraints prevent this, fully enclosed unisex toilets may be provided. All toilets should have clear signage to ensure accessibility and privacy.
Section 1 — Application Guidance and Performance:Applies to non-dwelling buildings, excluding schools, custodial accommodations, and some workspaces. The document extends guidance under the Workplace Regulations 1992, referencing BS 6465 for toilet provision calculations and other guidance for specific environments like NHS facilities.Performance focuses on 4 toilet types:
Type A: Fully enclosed ambulant universal toilets
Type B: Fully enclosed universal toilets
Type C: Ambulant single-sex cubicles
Type D: Standard single-sex cubicles
Designs must comply with Document M for accessible toilets, and ensure sufficient single-sex provision based on occupancy. Layouts prioritize safety, privacy, and dignity, with space standards detailed in later sections.
Section 2 — Common Design Provisions:General provisions for all toilets emphasize privacy, safety, and accessibility.Features include:
Privacy screens for urinals
Hooks at two heights: 1050 mm and 1685 mm
Space for disposal bins
Outward-opening doors with emergency mechanisms and minimum force requirements
Clear wayfinding signage
Visual contrast for neurodiverse users (per PAS 6463)
Lighting and thermal controls
Baby changing facilities must be separate and not included in accessible toilets unless it is the only facility available
Section 3 — Type A: Fully Enclosed Ambulant Universal Toilet
985 mm x 2125 mm minimum
750 mm clear door opening, preferably outward
Horizontal grab rails, disposal bin, shelf, hooks, and activity space (600 x 800 mm) with 465 mm clearance column
Section 4 — Type B: Fully Enclosed Universal Toilets
1050 mm x 1685 mm minimum
650 mm door opening
Same fixture requirements as Type A
Can also serve within single-sex toilet rooms
Section 5 — Type C: Ambulant Single-Sex Toilet Cubicle (Not Self-Contained)
920 mm x 1465 mm minimum
750 mm door with horizontal closing bar
Grab rails, communal washbasins, and minimum 765 mm clear space in front of WC
Standard fixture set: bin, shelf, hooks, etc.
Section 6 — Type D: Standard Single-Sex Toilet Cubicle (Not Self-Contained)
910 mm x 1740 mm minimum
650 mm door
Similar activity space and features as Type C
May include urinals in male toilets, per BS 6465
Appendix D — Contains tabulated minimum dimensions and requirements for all fittings, including:
Wash basins
Grab rails
Mirrors
Shelves
Hooks
Dispensers
Bins
In the next episode, I will move on to Approved Document S: Materials and Workmanship.
I hope you enjoyed this episode and that your understanding of Approved Document T: Toilet Accommodation is a bit clearer now.
If you have any questions, reach out to me on LinkedIn or send me an email — I’m more than happy to help you out.
At Bytnar, we deal with planning, designing, and managing construction projects. We’re always glad to facilitate a free initial consultation to steer you in the right direction.
Visit www.bytnar.co.uk and get in touch — whether your question is “Can you help me with my project?” or “What should I do?”, we’ll give you honest, no-obligation advice.
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Thank you again for listening.Voice your opinions — I’m waiting to hear from you on LinkedIn!See you next week.
Bytnar Designs the World Around You.Toodloo!
Piotr Bytnar BEng (Hons) MSc CEng MIStructE
Chartered Structural Engineer who deals with the Architecture of buildings. His Master's Studies led him to an in-depth understanding of risk and contract arrangements in construction as well as specialist knowledge in soil mechanics.
He and his team help homeowners and property developers to design and deliver construction projects reducing waste in time and the cost. He believes that the construction project is an iterative process that can be well managed and it is best managed if all the aspects of the project definition and management are dealt with in-house or coordinated by one organisation. His team works to all stages of RIBA and ISTRUCTE stages of work and enables contractors to deliver projects on-site providing risk evaluations, methodologies for execution of works and temporary works designs.
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