Episode 170 - Approved Document T

This week we will be talking about Approved Document T. This episode content meets PC3 - Legal Framework & Processes of the Part 3 Criteria.

Resources from today's episode:

Websites:

Law: 

• https://assets.publishing.service.gov.uk/media/67167c02d100972c0f4c9b38/ADT_2024.pdf

Information:

• https://www.planningportal.co.uk/applications/building-control-applications/building-control/approved-documents/part-t-toilet-accommodation/approved-document-t

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Transcript

Episode 170:

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I am your host Maria Skoutari and this week we will be talking about Approved Document T. Todays episode meets PC3 of the Part 3 Criteria.

The latest approved document to be released by the Building Regulations is Approved Document T relating to Toilet Accommodation and took effect on the 1st of October 2024.

It includes information relating to the design and layout of universal toilets, ambulant toilets and toilet cubicles and is applicable to new buildings other than dwellings and certain buildings undergoing a material change of use.

Part T excludes toilet facilities in:

• Dwellings,
• En-suite facilities in individual rooms for residential purposes and care homes
• Premises used for early years provision
• Schools, and
• Cellular accommodation in custodial facilities. 

What is the purpose of Approved Document T and why was it released:

The introduction of Part T officially formalises the Government’s intention to use regulation to encourage the installation of single-sex toilets over gender neutral facilities. Essentially, this came out from research the Government carried out where which identified particular concerns from women, elderly and the disabled who felt unfairly disadvantaged as publicly accessible toilets are increasingly being converted into gender neutral facilities where users share cubicle and hand-washing facilities. This leads to increasing waiting in shared queues, decreased choice and less privacy and dignity. As such the Government felt they needed to address these concerns via the introduction of Part T to ensure the privacy and safety of those using toilets in newly created workplaces and publicly accessible buildings. This puts an end to the scenario of communal wash hand basins within a space accessed by both sexes as is currently found in, for example, some bars, hotels and clubs.

As mentioned, Part T applies to applications made after 1st October 2024, projects with building control applications submitted before 1st October 2024, and which are sufficiently progressed by 1 April 2025, are exempt from the new requirements. 

As part of its release, Part T has been added to Parts A, B, G and M as a section that defines building work under the building regulations, in relation to “material alternations”. This means any change of toilet design and/or designation covered by Part T, in an existing building ands new buildings, would need statutory approval.

Now in relation to sanitary provisions, applicants would now need to refer to:

• Part G for the number of toilets to be provided, 
• Part M relating to accessible facilities,
• The Workplace (Health, Safety and Welfare) Regulations 1992,
• And now Part T also for single-sex, universal toilets split and design

So let’s look at the document itself and the requirements it sets out:

The document is organised around 7 key sections:

1. The Introduction - listing the key contents of the document.
2. Followed by the requirements, application, guidance and performance sections relating to in which instances and how the Approved Document guidelines should be used.
3. Then under Section 2 - it lists the Common Design Provisions to be followed for all types of toilet accommodation.
4. And lastly under Sections 3-6 which look at the 4 different toilet accommodation types.
5. Followed by a number of Appendices.

Looking at each section now in more detail, starting with the Requirements set out within the Approved Document:

This is outlined as Requirement T1: Toilet Accommodation and it essentially lists that reasonable provisions must be made for specific types of toilet accommodation in buildings other than dwellings. Requirement T1 is met by ensuring:

1. Separate single-sex toilet facilities are provided. Universal toilets can be provided in addition to single-sex provision and where space allows. All toilet accommodation should have clear and appropriate signage.
2. Where space precludes single-sex toilet facilities from being provided, fully enclosed universal toilets should be provided.

Available space for toilet accommodation will vary from building to building; once reasonable provision is made for single-sex toilet facilities, any remaining space for toilet accommodation can be considered for universal toilet provision. 

Single-sex toilets are defined within the Approved Document as toilet facilities intended for the exclusive use of persons of the same sex and provide washbasins and hand-drying facilities in either the toilet room cubicle, or a separate which are intended for use only by persons of that sex. 

Universal toilets are defined within the Approved Document as provided in fully enclosed rooms which contain a water closet, washbasin and hand drying facilities, and are intended for individual use by persons of either sex. 

The Document then proceeds to Section 1 relating to Application, Guidance and performance. 

As the title alludes to, this section outlines in which circumstances Approved Document T is applicable, makes reference to the toilet accommodation types outlined in Sections 3-6 and also refers to Approved Documents M and G which should be referred to in addition to Part T when designing toilet accommodation. 

Now moving on to Section 2, which outlines the Common Design Provisions:

It essentially outlines the provisions to be followed for all types of toilet accommodation. The provisions outlined in this section are in addition to the type specific provisions set out in Sections 3 to 6.

This section set out the required equipment and minimum requirements to be considered and provided within each toilet cubicle or room containing a WC. It also sets out the minimum sizes and layouts for universal toilets, ambulant toilets, and toilet cubicles specified to ensure accessibility and usability.

Wayfinding and signage requirements are also specified to aid all users in locating toilet facilities on each floor of a building, including those with disabilities. Different symbols should be used depending on the type of toilet facility.

This section also outlines the performance standards for controls, fixtures, fittings, ventilation, and hygiene.

Now let’s move on to the next sections which outline the different types of toilet accommodation, starting with Type A under Section 3:

Type A is for a fully enclosed self-contained ambulant universal toilet. Under Section 3, it lists out: 

• The minimum overall dimensions, 
• Door Arrangement relating to the minimum clear opening width, to have a self-closer if fitted with a fire door, bar position requirements,
• Equipment to be provided, including washbasin, bin, assistance shelving, hooks and visual contrast requirements, 
• And recommended layouts to be followed when designing ambulant universal toilets.   

Similary under Sections 4, 5 & 6, they list out the recommended provisions when designing: 

• a Type B toilet facility for fully enclosed self-contained universal toilets 
• a Type C toilet facility for ambulant single-sex toilet cubicle (not self-contained)
• a Type D toilet facility for single-sex toilet cubicle (not self-contained)

,respectively. 

Types A and B are primarily intended for universal use, though they may also be used for single-sex facilities if self-contained toilets are preferred to cubicles. Key note to mention is that a universal toilet is available for everyone and is not considered a single-sex toilet. However, fully enclosed, self-contained toilets can feature as part of single-sex provision. Part M refers to the provision of wheelchair-accessible toilets, which are already gender-neutral, and should not be confused with the universal toilet for use by all in Approved Document T.

The additional guidance provided in Approved Document M, BS8300 Part 2 and BS6465 Part 2 2017 all differ in ways to that in Approved Document T. If the design team propose to use any of the alternative guidance documents, they should record why this is appropriate. The Part T diagrams reflect the most up to date thinking in terms of accommodating more substantial grab rails (ambulant), sanitary disposal bins and “assistance” shelf.

The layouts in Approved Document T are simply there for guidance. Alternative layouts adopted should maintain the level of facility and activity space given. Any alternative layout should illustrate these as well as showing that the “column of clearance” is provided.

To sum up what I discussed today:

• Approved Document T officially came into effect on 1st October 2024, applying to new buildings (excluding dwellings) and certain buildings undergoing material change of use. It does not apply to dwellings, en-suites in care homes or residences, early years provision, schools, or custodial accommodation.
• Part T aims to prioritise single-sex toilet facilities in response to public concerns—particularly from women, elderly, and disabled users—about the growing use of shared, gender-neutral toilets that compromise privacy, dignity, and safety.
• The Toilet Facility Types are defined as: Single-sex toilets: Exclusively for one sex with dedicated handwashing facilities and Universal toilets: Fully enclosed, self-contained rooms usable by any gender. The provision of universal toilets must be in addition to, not instead of, single-sex facilities—unless space constraints apply.
• The four different toilet types outlined within the approved document includes: Type A is for a fully enclosed self-contained ambulant universal toilet, Type B toilet facility for fully enclosed self-contained universal toilets, Type C toilet facility for ambulant single-sex toilet cubicle (not self-contained) and Type D toilet facility for single-sex toilet cubicle (not self-contained)
• Part T now forms part of the Building Regulations along with Parts A, B, G, and M. Any alterations to toilet design in existing buildings now require statutory approval.