Building regulations, particularly for pupils with special needs

This factsheet has chosen a few of the relevant regulations and guidance from the Building Regulations and is by no means comprehensive. It is intended to provide some basic information and pointers for further investigation.

The current Building Regulations that apply in England and Wales are ‘The Building Regulations 2000’ and they cover most building projects. This means that they cover most new build and most modifications or adaptations to buildings. They are based on the 1984 Building Act and are to support the health and safety of people in and around all types of buildings. They also provide for energy conservation and for access and facilities for disabled people. These regulations cover all non-dwellings whether they are owned by the local council, a private landlord or the school itself.

They set out the requirements for all building projects. These requirements are shown in schedule 1 and are grouped under thirteen parts. The parts deal with different aspects of building design as follows:

A Structure
B Fire Safety
C Site preparation and resistance to moisture
D Toxic substances
E Resistance to the passage of sound
F Ventilation
G Hygiene
H Drainage and waste disposal
J Combustion appliances and fuel storage systems
K Protection from falling, collision and impact
L Conservation of fuel and power
M Access and facilities for disabled people
N Glazing – safety in relation to impact, opening and cleaning

All parts relate to school toilets, but Parts F, G, H and M are particularly relevant.

Part F looks at the different kinds of ventilation that can be used but specifies that in a non-domestic building all sanitary accommodation and/or washing facilities must have 3 air changes per hour. This is amended in the 2000 Building Regulations to say that 6 air changes per hour in sanitary accommodation are desirable. It refers to the following publication: Building Bulletin 87, Guidelines for Environmental Design in Schools, published by The Stationery Office for the Department for Education and Employment ISBN 0-11-271013-1.

Part G looks at hygiene. The number, type and siting of appliances is listed in the relevant documents for the type of building and in the Food Hygiene (general) regulations 1970. Statutory Instrument 1999 No. 2 is the Education (School Premises) Regulations 1999, ISBN 0 11 080331 0 from The Stationery Office and states in regulation 3, that the basic number of sanitary fittings should be:

a) 10% of the number of pupils at the school where the pupils are under 5 years of age, or it is a special school;

b) 5% of the number of pupils at the school where the pupils are over 5 years of age. However, this is the basic number and any relevant special requirements of the pupils need to be taken into account.

This section also states that for children over 11 years, where there is a room with fewer than 3 sanitary fittings, there should be a washbasin for every fitting: otherwise, there only needs to be two thirds the number of washbasins to sanitary fittings. It also states that separate washroom facilities for boys and girls needs to be provided for children over the age of 8, except for toilets provided for anyone who is disabled.

The Education (School Premises) Regulations 1999, ISBN 0 11 080331 0 defines special requirements as:

“For the purposes of these Regulations a pupil has ‘special requirements’ if he has any needs arising from physical, medical, sensory, learning, emotional or behavioural difficulties which require provision in terms of any of the facilities referred to in regulation 3 or regulation 9 which is additional to or different from that generally required by children of his age in schools other than special schools.”

Regulation 3 covers washrooms in non-dwelling buildings of a school and regulation 9 covers washrooms in boarding schools.

Part M covers access and facilities for all disabled people and this specifies extra arrangements relating to toilets which will benefit many children. All new build toilets or toilets which are being extended or undergoing a material alterations and are in non-dwellings need to be built or adapted to Part M Building Regulations.

There is now extensive guidance on the interpretation of these regulations from the Office of the Deputy Prime Minister called “Approved Document M – Access to and Use of Buildings (2004 Edition), available from The Stationery Office or online from www.odpm.gov.uk/stellent.groups/odpm_buildregs/documents/page/odpm_breg.

This document gives the following useful guidelines in section 5:

5.1. “In multi-storey buildings, the consistent location of toilets on each floor can help people with learning difficulties to locate these facilities easily.”

5.3 “…Taps and WC cubicle doors should be operable by people with limited strength or manual dexterity and doors to cubicles should be capable of being opened if a person has collapsed against them while inside the cubicle. Preferably, all doors to WC cubicles and wheelchair-accessible unisex toilets open out or, if they open in, the door swing should not encroach into the wheelchair turning space or minimum activity space. Where possible, light switches with large push pads should be used in preference to pull cords. (see 4.28)

5.4 “…any bath or washbasin tap is either controlled automatically, or is capable of being operated using a closed fist, e.g. by lever action;

…WC compartment doors, and doors to wheelchair-accessible unisex toilets, changing rooms or shower rooms are fitted with light action privacy bolts so that they can be operated by people with limited dexterity and, if required to self-close, can be opened using a force no greater than 20N

…WC compartment doors, and doors to wheelchair-accessible unisex toilets, changing rooms or shower rooms have an emergency release mechanism so that they are capable of being opened outwards, from the outside, in case of emergency.”

5.5 “Toilet accommodation needs to be suitable, not only for disabled people, but for all people who use the building. For disabled people, suitable toilet accommodation may take the form of a specially designed cubicle in separate-sex toilet washrooms, or a self-contained unisex toilet. For wheelchair users in particular, a self-contained unisex toilet is always the preferred option since, if necessary, a partner or carer of a different sex can enter to give assistance. Wheelchair-accessible unisex toilets should always be provided in addition to any wheelchair-accessible accommodation in separate-sex toilet washrooms.”

5.9 “A unisex toilet is approached separately from other sanitary accommodation. …It is more likely to be available when required. This is particularly important as some disabled people need to use a toilet more frequently than other users. The time needed to reach a wheelchair-accessible toilet should therefore be kept to a minimum when considering the location of unisex toilet accommodation. In addition, a unisex toilet enables one or two assistants of either sex to assist a disabled person.

5.10 “Wheelchair-accessible unisex toilets will satisfy Part M if…one is located as close as possible to the entrance and/or waiting area of the building …any wheelchair user does not have to travel more than 40m on the same floor…the emergency assistance call signal outside the toilet compartment is located so that it can be easily seen and heard by those able to give assistance.

5.11 “Separate-sex toilet washrooms above a certain size should also include an enlarged WC cubicle for use by people who need extra space. …Consideration should be given to installing a fold-down table e.g. for baby-changing. Standard WC compartments should also have a minimum manoeuvring space clear of any door swing.

Although Part M guidance is related to toilets for disabled people and not specifically for children, all schools must comply with Part M regulations and these requirements therefore support the provision of adequate school toilets. A child does not need to have a permanent disability to find the extra facilities helpful. For example, an alarm may re-assure a child who is afraid of being bullied and the regulations state that the emergency assistance call signal is located so that it can be easily seen and heard by those able to give assistance – not just outside the washroom door. Also, an accessible toilet has to be not more than 40m from a disabled person using the building, and, although 40m is a long distance, it is at least a standard which is enforceable which may help children with urgency or frequency for whatever reason.

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