Changing Places: the new norm


What’s happened and when?

Following a public consultation which RSUA contributed to on the provision of accessible Changing Places toilets in new and existing buildings, the Minister of Finance has announced new statutory guidance in Technical Booklet R (Access to and use of buildings) of the Building Regulations which comes into effect on 30 June 2022.

What’s in it that’s relevant to me?

The new guidance provides for ‘Changing Places’ toilets to be provided in certain types of new buildings or in existing buildings where there is a material change of use.  Building types that must include a Changing Places toilet:

(a) assembly, entertainment and recreation buildings with a capacity of 350 people or more or a collection of smaller buildings associated with a site used for assembly, entertainment and recreation, such as theme parks, zoos and venues for sport and exhibitions, with a capacity of 2000 people or more

(b) shopping centres/malls, or retail parks with a gross floor area of 30,000 m² or more;

(c) retail premises with a gross floor area of 2500 m² or more;

(d) leisure and sports buildings with a gross floor area of 5000 m² or more;

(e) hospitals and primary care centres; and

(f) cemetery and crematorium buildings.

In addition to the changes made today, the Department of Finance is planning to carry out further research in the new Assembly term as to how to extend the provision of Changing Places toilets to include specified buildings where building work is to be carried out to extend or alter an existing building.

What does RSUA make of it? Is there great news for the built environment?

In RSUA’s response to the consultation, the organisation supported the Changing Places provision in new buildings and existing buildings, where these are undertaking major refurbishment work which would be defined by either a financial scale or square footage of the refurbishment as a proportion of the total building.

Where both criteria are met, the RSUA consultation response suggested that the building owners/operators must submit an ‘Operating Plan’ that would outline what provision they would put in place for someone with profound and multiple learning disabilities (PMLD), severe physical impairment or disability who needs WC provision at their property.

RSUA outlined that this could mean owner/operators may have to provide new CPT provision, demonstrate that staff on the premises are trained to adequately address the needs of people with PMLD, severe physical impairment or disability utilising the existing provisions within the building, or that they have to help provide access to a CPT facility in an existing building within proximity.

RSUA will respond to any further calls for evidence to support the provision of Changing Places toilets in existing buildings when the Department announces its plans in the new Assembly term.