THE BUILDING REGULATIONS 2023
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INTERSECTIONAL CHANGING ROOMS
CONTENTS EXISTING GUIDANCE 3 SUMMARY OF GUIDANCE 4 GLOSSARY OF KEY TERMS 5 INTERSECTIONAL CHANGING ROOMS 6 LIST OF FIGURES 7 GENERAL LAYOUT AND ENTRANCES 8 CIRCULATION 9 GENERAL TOILETS 10 ACCESSIBLE TOILETS AND BABY CHANGING 11 MAIN CHANGING AREA CUBICLES 12 ACCESSIBLE CHANGING CUBICLES 13 GENERAL SHOWERS 14 ACCESSIBLE SHOWERS 15 VANITY SPACES 16 CHANGING PLACES FACILITY 17 EXAMPLE INTERSECTIONAL CHANGING ROOM LAYOUT
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EXISTING GUIDANCE What is an approved document?
Recent policy debates
The Secretary of State has approved a series of documents that give practical guidance about how to met the requirements of the Building Regulations 2010 for England. Approved documents give guidance on each of the technical parts of the regulations.
Changing places facilities: In July 2020 the government announced the compulsory inclusion of Changing Places Toilets within all new public buildings.
Approved documents set out what, in ordinary circumstances, may be accepted as reasonable provision for compliance with the relevant requirements of the Building Regulations to which they refer. If you follow the guidance in an approved document, there will be a presumption of compliance with the requirements covered by the guidance. However, compliance is not guaranteed; for example, ‘normal’ guidance may not apply if the particular case is unusual in some way. Each approved document relates only to the particular requirements of the Building Regulations that the document addresses. However, building work must also comply with any other applicable requirements of the Building Regulations.
Approved Document Part M
Single-sex toilets: In July 2022 the government announced that all new public buildings should have separate male and female toilet provisions. Separate unisex toilets should also be provided, if there is space, but this must not be at the expense of female provision. Concerns have been raised about the discrimination this causes towards transgender people and those who do not identify as any gender. It means their use of public buildings is unfairly disadvantaged by the lack of provision specifically for them. Changes to the Equality Act: April 2023 saw the government propose controversial changes to definitions within the Equality Act 2010. This includes redefining sex to mean specifically a person’s sex at birth. This would make it possible for transgender people to be excluded from single-sex spaces and events.
Approved Document Part M outlines access to and use of buildings. It provides standardisations to ensure that people are able to access and use buildings and their facilities. However, as stated: Although the guidance in this Approved Document, if followed, tends to demonstrate compliance with Part M of the Building Regulations, this does not necessarily equate to compliance with the obligations and duties set out in the Equality Act 2010 [page 6].
What is Sport England design guidance? This Sports England design guidance expands upon the Building Regulations by specifically laying out instruction on how to design swimming pools that provide sporting facilities and opportunities for everyone. It provides guidance, rather than regulation, based on principles of good practice and sets out the minimum standards that should be aimed for in order to produce acceptable sports facilities.
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SUMMARY OF GUIDANCE What is a feminist approved document? A feminist approved document expands upon the existing requirements by challenging the standardisation of user needs. It acknowledges gaps within existing building regulations, where user groups are not accurately represented during the design process and are therefore not designed for appropriately. It recognises the damage to individuals when the built environment does not cater to specific needs and aims to eradicate such processes of ‘othering’ by clearly defining non-standard objectives that should be met. A feminist approved document implements feminist design principles to ensure spaces are inclusive to all. It readdresses the design process to consider the perspectives of users in line with the Equality Act 2010.
How to use this approved document This document uses the following conventions. Key terms, highlighted in orange, are defined in the glossary.
The Equality Act 2010 and the Equality Act 2010 (Disability ) Regulations 2010 The Equality Act 2010 legally protects people from discrimination in the workplace and in wider society. It replaced previous anti-discrimination laws with a singleAct in order to make the law easier to understand. It outlines the following protected characteristics, of which is against the law to discriminate against anyone because of: • age • gender reassignment • being married or in a civil partnership • being pregnant or on maternity leave • disability • race including colour, nationality, ethnic, or national origin • religion or belief • sex • sexual orientation You’re also protected from discrimination if: • you’re associated with someone who has a protected characteristic, for example a family member or friend A feminist approved document brings these protected characteristics to the forefront of the design process by considering them, as key design criteria, from the very outset. The standards outlined within this document have been considered from this perspective. It is assumed, that once followed, designs that follow this guidance will begin to rectify discrimination in the built environment.
Should ‘class’ be included? Because class is currently not a protected characteristic, it is not measured against and there is no legal protection against discrimination because of it. There are increasing arguments for this to be redressed within legislation, to ensure there is fair representation for all social classes and to prevent the damage caused by class based discrimination.
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GLOSSARY OF KEY TERMS Accessible: Relating to spaces that have been specifically designed to better accommodate people with physical disabilities. Ambulant: Relating to spaces that have been specifically designed to better accommodate people with physical disabilities that do not require the additional spaces that is provided by accessible facilities. Disability (protected characteristic): A person has a disability if they have a physical or mental impairment which has substantial and long-term adverse effects on that person’s ability to carry out normal day-to-day activities. Feminist: An advocate of women’s rights on the basis of the equality of the sexes. Gender: Social and cultural differences in bodies rather than biological ones. Genders do not necessarily correspond to sex or established ideas of male and female. Gender neutral / Non-gendered: Not relating to a specific gender or group. Genderless. Used by everyone. Gender norms: Traditional ideas about how men and women should act. This tends to align with heterosexual (or straight) norms. Gender reassignment (protected characteristic): The process of transitioning from one sex to another. Intersectional: The interconnected nature of social categories based on protected characteristics and how they apply to specific individuals or groups of people. These categories are regarded as creating overlapping and interdependent systems of discrimination or disadvantage.
subverting heterosexual norms. Othering: Viewing or treating someone (or a group of people) as different from oneself, a group of people, or society. Pregnancy and maternity (protected characteristic): Pregnancy is the condition of being pregnant or expecting a baby. Maternity refers to the period after birth, and is linked to maternity leave in the employment contract. In the non-work context, protection against maternity discrimination is for 26 weeks after giving birth, and this includes treating a woman unfavourably because she is breastfeeding. Queer: Relating to a sexual or gender identity that does not comply with established ideas of sexuality and gender, especially heterosexual norms. Race (protected characteristic): Refers to a group of people defined by their race, colour, and nationality (including citizenship) ethnic or national origins. Sensitive user group: People who, for whatever reasons, wish to use separate facilities within the changing area. Sex (protected characteristic): A man or woman. Sexual orientation (protected characteristic): Whether a person’s sexual attraction is towards their own sex, the opposite sex, or to both sexes. Wayfinding: The systems in place that allow people to navigate through and around a building e.g. floor plans, signage, colour coded areas.
Natural surveillance: The implementation of physical features, activities and people in such a way that maximises visibility. A passive process that occurs through the natural use of spaces. Non-heteronormative: Helps to define the concept of
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INTERSECTIONAL CHANGING ROOMS Intersectional design approaches
Religion or belief / Race
Intersectional design approaches considers how overlapping, or intersecting, factors (based around our protected characteristics) shape user groups and social opportunities as a foundation for more inclusive designs.
For religious or cultural reasons some people may feel uncomfortable about being visible in their swimming costumes and whilst changing. Provision of a separate changing and access route, that avoids the main changing area, should be considered.
This guidance now applies intersectionality, specific to changing rooms, to the 9 protected characteristics as defined by the Equality Act 2010 + social class. POOL
Age A range of heights (of benches and counters) to allow different age groups to access facilities. Family sized changing and shower cubicles to allow parents and children to use facilities as a group.
MAIN CHANGING AREA
Gender reassignment Non-gendered changing spaces means individuals do not have to choose which changing area they prefer to use - the changing area is shared by all. Private vanity rooms to ensure everyone has the space to comfortably ‘get ready’ to leave facilities.
Pregnancy and maternity Baby change facilities provided in all bathrooms. Inclusive policies surrounding public breastfeeding, alongside private spaces if preferred by the individual.
Disability A range of accessible toilet, changing and shower cubicles (including a changing places facility) that cater to different disabilities. Ensure that exchange, from chairs to equipment, is provided for both sides. Level access provided throughout the building, including the main entrance doors. Adequate distances between fixed furniture is maintained so that wheelchair movement is not inhibited.
Social class Free locker and hairdryer usage. Affordable hot water provision for showers.
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SENSITIVE USER CHANGING
Figure 01: Option for separate changing area to provide privacy for sensitive user groups.
Sex Recent government legislation discusses the importance of providing single-sex toilets due to safety concerns from women who feel they are losing privacy and being unfairly disadvantaged. Whilst this document aligns with gender neutral provisions, to ensure that transgender and those who do not identify as gender are not discriminated against, it also recognises the importance of providing enough toilet facilities for everyone to use. This will ensure that women, who may need to use facilities more often because of pregnancy and sanitary needs, have the appropriate amount of facilities within the non-gendered provisions. Likewise, sanitary bins and baby change facilities will be provided in all areas.
Sexual orientation Queer inclusivity is reflected in operational policies. All the other things considered, it should be a place where you feel comfortable in the spaces with other users.
LIST OF FIGURES Figure 01: Option for separate changing area to provide privacy for sensitive user groups. Figure 02: Minimum distances within changing area. Figure 03: Minimum dimensions of cubicles within main changing area. Figure 04: Accessible toilet cubicle layout. Figure 05: Baby change facility layout. Figure 06: Minimum dimensions of cubicles within main changing area. Figure 07: Accessible changing cubicle layout within main changing area. Figure 08: Accessible changing room layout. Figure 09: Accessible changing room with shower, WC, and fixed bench layout. Figure 10: Minimum dimensions of showers within main changing area. Figure 11: Typical shower area layout incorporating a changing bench. Figure 12: Accessible shower cubicle layout within main changing cubicle area. Figure 13: Typical layout of vanity benches. Figure 14: Typical layout of private vanity rooms. Figure 15: Changing places facility layout. Figure 16: Example intersectional changing room layout.
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GENERAL LAYOUT AND ENTRANCES General layout principles CUBICLES
• Simple and clear wayfinding principles used. • Buggy storage areas located on entrance to the changing area. • Vanity areas located close to the exit of the changing area and large enough to prevent congestion. • Lockers positioned on main access routes through the changing area and next to changing benches and cubicles. • Pre-swim showers located immediately before entrance to the pool hall. • Toilets located on the main route access route through the changing room, in close proximity to the pool hall. • Layout arranged to provide natural surveillance by both staff and other users. This can be achieved by eliminating hidden corners. • Pinch points should be avoided, by providing adequate space between fixed furniture, to help cope with peak capacities.
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LOCKERS
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LOCKERS
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CUBICLES
VANITY
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Entrances
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Figure 02: Minimum distances within changing area.
BUGGY STORAGE AREA
The main entrance MUST be welcoming, obvious, and have an accessible level threshold. It MUST be designed for all users and ensure that everyone enters to space via the same entrance. Accessible entrances MUST be prioritised and MUST NOT be hidden from view along the main approach to the building.
Doors External doors: • Single leaf external door - min clear opening of 1000mm. • Double external door - min clear opening, of at least one leaf, of 1000mm. • Power operated sliding doors where possible. • All outward opening doors should be recessed. Internal doors: • Clear opening of at least 850mm. • Doors to accessible toilets, showers and cubicles, baby changing facilities, vanity rooms and first aid rooms, should have a min clear opening of 900mm.
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CIRCULATION Surfaces and finishes
Wayfinding
• Durable, even, and slip resistance material choices. • Avoid surfaces that are highly polished and reflective. • Contrast in luminance between walls and ceilings and between walls and floors. • All glazed areas should have contrasting strips, or continuous designs, at heights of 1000mm and 1500mm above ground level. These should not obscure vision through the glazed panels.
• Words and symbols to be used consistently throughout sites. • Internationally recognised and pictorial symbols, with explanatory text, is preferred over text signage. • All signs should be accompanied by raised Braille and symbol versions that are located at 900mm from floor level. The depth of embossing should be at least 1.5mm. • Floor plans should be located at the main entrance to the building at a maximum height of 900mm from floor level. They should be orientated to match the building’s orientation from that point and clearly identify its location with a ‘You are here!’ signpost. • Colour coded circulation schemes should be used to identify specific areas and routes. This should be limited to 5 overall themes to avoid confusion.
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GENERAL TOILETS
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Figure 03: Minimum dimensions of cubicles within main changing area.
Cubicle A - General cubicle
General toilet provision
• Min 1000 x 1500mm • 12 non-gendered cubicles for up to 100 people.
• All toilets non-gendered. • Sinks included within toilet cubicles. • Additional sinks included external to cubicles. • No urinals. • Lever handle indicator locks included on all cubicle doors. These should be externally accessible in case of emergencies. • Sensor controlled flushing systems are preferred. • WC doors should not open directly on to a public and/or circulation area. • Dimensions of toilet lobbies should have a min 2000mm turning circle. • Lighting to be operated by sensors. • All fittings and doors should contrast in colour and luminance with the walls and floors. • Mixer taps, with lever handles, are preferred.
Cubicle B - Ambulant cubicle • Min 1200 x 1500mm • 2 non-gendered cubicles for up to 100 people.
Cubicle C - Accessible cubicle • Min 2000 x 2000mm • 2 non-gendered cubicles for up to 100 people.
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ACCESSIBLE TOILETS AND BABY CHANGING 2000mm
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Figure 04: Accessible toilet cubicle layout.
Figure 05: Baby change facility layout.
Accessible toilet facilities
Baby change facilities
• Where more than one accessible toilet is provided, these should allow for transfer from alternative sides. • Emergency assistance system to be installed.
• Baby changing facilities should not be included within accessible toilet provision. • Min door opening of 900mm. • A chair should be provided for use if required. • Nappy bins and other facilities should be recessed if possible and should not obstruct circulation space.
Key: 1. Coat hooks set at 1200 and 1800mm above floor level. 2. Mirror 1500mm high, located 600mm above floor level. 3. Vertical support rail. 4. Counterbalanced hinged support rail. 5. WC with pan height of 480mm. 6. Disposal bin. 7. Fixed horizontal support rail. 8. Hand basin, thermostatic mixer tap to be located on WC side of the basin.
9. Automatic hand dryer. 10. Shelf set at 740mm above floor level. 11. Door grab handle. 12. Baby change bench fixed on top of counter, with raised edge and wipeable soft mat. 13. Covered disposal bin, hidden under counter. 14. Chair / bench for breast feeding. 15. Hot and cold drinking water dispenser (if required).
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MAIN CHANGING AREA CUBICLES 1000mm 1100mm
2000mm
1100mm 2600mm
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Figure 06: Minimum dimensions of cubicles within main changing area.
Figure 07: Accessible changing cubicle layout within main changing area.
Cubicle A - Single person cubicle
Key: 1. Two clothes hooks set at 1400mm and 1050mm above finished floor level. 2. 600mm vertical grab rail securely fixed to side wall and set at 800mm above floor level. 3. 600mm horizontal grab rail securely fixed to back wall and set at 680mm above floor level. 4. 600mm deep cantilevered bench set at 480mm above floor level. 5. Horizontal door pull to enable door to be closed when entering.
• Min 1000 x 1100mm • Designed to be used by one person at a time. • The minimum accepted size of cubicle. • It is encouraged to prioritise the use of double cubicles (B) over single cubicles (A).
Cubicle B - Double cubicle • Min 1100 x 1500mm • Designed to be used by two people at a time. • It is encouraged to prioritise the use of double cubicles (B) over single cubicles (A).
Cubicle C - Family/Accessible cubicle • Min 2000 x 2600mm • Accessible changing cubicle within a main changing room. More specialised accessible changing cubicles required, details included on page 15.
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1 1500 x 1500mm min manoeuvring space
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ACCESSIBLE CHANGING CUBICLES 2700mm
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Figure 08: Accessible changing room layout.
Key: 1. Clothes hooks set at 1400mm and 1050mm above floor level. 2. Counterbalanced hinged support rail. 3. Vertical support rail. 4. Colostomy changing shelf for ambulant users 950mm above floor level. 5. Fixed horizontal grab rail. 6. Fixed vertical rail and adjacent alarm pull-chord with two red triangles. 7. Automatic hand dryer. 8. Low shelf with rounded corner. 9. Disposal bin. 10. Hand basin, thermostatic mixer tap to be located on WC side of the basin. 11. Door grab handle 12. Fixed horizontal grab rail used as towel rail. 13. Padded shower seat with back rest. Front edge set 600 - 700mm from back wall to allow lateral transfer. 14. Shower controls, lever operated, thermostatically controlled. 15. Shower curtain and rail.
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1500 x 1500mm min manoeuvring space
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1500 x 1500mm min manoeuvring space
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Figure 09: Accessible changing room with shower, WC and fixed bench layout.
16. Drain. 17. Mirror 1500mm high, located 600mm above floor level. 18. WC, flush level to wheelchair transfer side. 19. 600mm deep fixed seat bench with rounded corner and soft round edges.
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GENERAL SHOWERS 2000mm 1100
1250mm
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Figure 10: Minimum dimensions of showers within main changing area
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Key: 1. Shower controls. 2. 500mm deep cantilevered bench set at 480mm above floor level. 3. 1100 x 1000mm shower cubicle. 4. Clothes hooks set at 1400mm and 1050mm above floor level.
Shower B - Family cubicle
Shower A - Communal shower area
Cubicle C - Single person cubicle
• Min 1000 x 1100mm • Designed to be used by one person at a time. • The minimum accepted size of cubicle. • It is encouraged to prioritise the use of double cubicles (B) over single cubicles (A).
• Min 2000 x 2600mm • Accessible changing cubicle within a main changing room. More specialised accessible changing cubicles required, details included on INSERT PAGE NO.
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• Min 1100 x 1500mm • Designed to be used by two people at a time. • It is encouraged to prioritise the use of double cubicles (B) over single cubicles (A).
ACCESSIBLE SHOWERS 750
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375 folded Figure 11: Typical shower area layout incorporating a changing bench.
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8 1500 x 1500mm min manoeuvring space
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Figure 12: Accessible shower cubicle layout within main shower cubicle area.
General shower provisions • Shower controls should be level-operated. • Floor finishes must be slip-resistant even when wet. • Water must be contained within the wet areas. • Provision of suitable drainage systems. • Do not up-stand between wet and dry zones.
Key: 1. 500 x 500mm tip-up shower seat in corner with grab rail set on shower head wall. 2. 600mm long fixed horizontal grab rail providing additional support and can be used as a towel rail. 3. Towel hooks set at alternate heights of 1400 and 1050mm above floor level. 4. Shower controls set at 1000mm above floor level with two shower heads at 1400 and 1800mm above floor level. 5. Privacy curtain. 6. Adjustable folding bench. 7. Dry off area, with slip resistance surface. 8. Shower curtain and rail
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VANITY SPACES 2000mm
2200mm
1000mm
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1500 x 1500mm min manoeuvring space
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700mm Figure 13: Typical layout of vanity benches.
Figure 14: Typical layout of vanity rooms.
General vanity provision
Key: 1. 1000 x 500mm mirror. 2. Hairdryer for each vanity space. 3. Hand wash basin. 4. Full-length mirror. 5. Armchair.
• Hairdryers and mirrors should be provided above counters in the vanity areas. • Hairdryer controls should be set at a max of 1100mm above floor level. • Mirrors over counters should be 1000 x 500mm and positioned so that the top is 1900mm above floor level.
Private vanity provision • Intersectional changing rooms should include private vanity rooms so allow people to get themselves ready before leaving the facilities. • These can double as baby change facilities.
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CHANGING PLACES FACILITY 4000mm 1000mm 150
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Figure 15: Changing places facility layout.
Changing places facility provision • Not designed to for the use of independent wheelchair users or as baby change facilities. Use signage to indicate nearest locations of these facilities. • Changing places facility to be provided in ALL new public buildings. Key: 1. Paper towel dispenser. 2. Full-length mirror, located 600mm above floor level. 3. Sanitary disposal bin. 4. Drop down support rails. 5. Flat-topped close-coupled cistern providing a back rest and a colostomy changing surface for standing users.
6. WC. 7. Height-adjustable washbasin. 8. Waste disposal bin. 9. Hand dryer. 10. Privacy curtain. 11. Alarm pull cord. 12. Heigh-adjustable showering / changing bench, min 1800mm long. 13. Drain 14. Shower unit 15. Wide paper roll dispenser for use on the changing bench. 16. Sanitary towel dispenser. 17. Two clothes hooks at 1400 and 1500mm above floor level. 18. Horizontal door pull.
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EXAMPLE INTERSECTIONAL C GetSteamie, Glasgow | Asterisk Architecture This project reflects a contemporary perspective on a traditional bathhouse and swimming pool, colloquially referred to as Steamies in Glasgow. The refurbished factory space provides washing facilities for both bodies (baths and showers) and clothing (laundrette); swimming pool facilities; and intersectional changing areas. As a feminist factory of nonmass-production, it boasts being inclusive but not exclusive. Asterisk Architecture prioritised nonheteronormative perspectives to eradicate ‘othering’ and reverse the transience and anonymity of typical queer spaces by ensuring it is permanent, identifiable, and embedded within the local community.
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Traditionally Steamies were used by women to gather and gossip whilst going about their chores. This communal hub, centrally located between a number of residential estates (on the site of the demolished Red Road Flats) strives to reverse the gender norms associated with unpaid care work by providing safe, intersectional, and non-conforming spaces for all members of the local community to utilise.
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Figure 16: Example intersectional changing room layout.
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CHANGING ROOM LAYOUT Key: 1. Separate changing area and entrance for sensitive user groups. 2. Pre-showers. 3. Accessible pool hoist. 4. Double changing cubicles. 5. Family / accessible changing cubicles. 6. Changing places facility. 7. Non-gendered toilets including general and ambulant cubicles. 8. Accessible toilet cubicle, within main non-gendered toilet area. 9. First aid room. 10. Emergency exit for first aid room with access to car park. 11. Single shower cubicles. 12. Accessible changing room with shower. 13. Accessible changing room with shower, WC, and fixed bench. 14. Changing bench. 15. Family shower cubicles. 16. Vanity bench. 17. Private vanity rooms. 18. Accessible poolside changing rooms.
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Ground Floor plan
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First Floor plan
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