Author’s Comments

Public Health (Wales) Act 2017 Section 8: Local Toilets Strategies

On 31 May 2018 it was officially announced that under the Welsh Government’s Public Health (Wales) Act, all local authorities in Wales are expected to improve the availability of toilet facilities in their communities. The local authorities now have one year to assess the needs of the local community, including changing facilities for babies and Changing Places facilities for disabled people, and to put a strategy in place to ensure members of the public will have greater access to these facilities.

It is expected that the strategy will go beyond the provision of traditional stand-alone public toilets and will look at new and creative solutions, including bringing toilets in public buildings into wider use and working with private businesses to make their facilities available to the public.

The Health Secretary, Vaughan Gething said:

“While we would all benefit from greater public access to toilet facilities, there are certain groups for whom a lack of public toilets can cause distress, eventually discouraging them from visiting parts of the community.

“I understand the pressures on local authority services, but as well as isolating members of the community, poor provision can impact on tourism, the economy and use of public amenities. Through long-term planning and creative thinking we can improve people’s experiences when they are out and about in their communities.”

: Mr Gething added:

“I expect local authorities to talk to the public and representative groups about the challenges they face in accessing local toilets, listen to their concerns and get them involved in improving access in their community.” (end of quote)

The Welsh Government is to be congratulated on taking this issue so seriously and it is to be hoped that other countries follow their example.

Statutory guidance on how local authorities in Wales prepare, consult on and publish their local toilets strategies will be issued in the coming weeks. Please check “Author’s Comments” for up-to-date news.

Susan Cunninghqam - 1st June 2018
The Public Health (Wales) Act 2017 is a very, very important piece of legislation for Local Authorities in Wales, as Section 8 of the Act places a duty on every Local Authority in Wales to create a public toilet strategy for the provision of toilets in villages, towns, cities, sites of cultural, sporting and historical interest, along highways and active travel routes, etc.

Once again, I congratulate all those people concerned in this section of the Act which relates to “away from home” toilets. Their hard work has continued and resulted in a very well-thought- out consultation document:

Public Health (Wales) Act 2017 Section 8: Local Toilets Strategies – Consultation Document on Statutory Guidance for Local Authorities

The consultation document asks for comments on draft statutory guidance which sets out how Local Authorities in Wales should meet the requirements of Section 8 of the Public Health (Wales) Act 2017. Under this legislation, Local Authorities in Wales are required to prepare, consult on and publish a local toilets strategy for their authority area according to criteria set within the Act. The draft statutory guidance is intended to assist Local Authorities in successfully implementing their duties under Part 8 of the Act and identifying the matters they should take into consideration when preparing, reviewing and consulting upon a local toilets strategy.

A technical guidance document on the mapping of toilet locations is included within the documents as it is referred to in the draft statutory guidance document. It is included for information and does not form part of the consultation.

I recommend that everyone with an interest in the provision of public toilets, access the consultation document and supporting papers at the following link:

and I ask all my readers to pass this link onto others who may have an interest in the consultation exercise.

With regard to the provision of public toilets, the Welsh Government has taken the lead with the Public Health (Wales) Act. Perhaps this will lead to appropriate new legislation in England and other countries.

Susan Cunningham - 3rd February 2018
As you will see from the information given in previous “Author’s Comments”, many different organisations are working to gain improvements in the provision of lavatories / toilets for use by members of the public.

It is increasingly important that “providers” are aware of current British Standards and new legislation, e.g. the Public Health (Wales) Act. Also, that “users” are able to form links with suitable organisations and make their requirements known.

Statistics demonstrate that this website continues to attract many visitors, who read the Author’s Comments, download the free Public In-Conveniences Guide, etc.

In order to make it easier for visitors to make helpful comments, we now provide a direct link to a dedicated address

All visitors’ comments will be read, although I cannot guarantee a quick reply, due to the volume of correspondence. Comments of particular interest may be featured in the Readers’ Comments section of this website.

Susan Cunningham - 25th September 2017
Congratulations to all those concerned with the Public Health (Wales) Bill which received Royal Assent on 3rd July 2017. Now to be referred to as the Public Health (Wales) Act 2017; in part, this very important piece of legislation places a duty on every local authority in Wales to create a public toilet strategy for the provision of toilets in villages, towns, cities, sites of cultural, sporting and historical interest, along highways and active travel routes, etc.

For further details please read Part 8 – Provision of Toilets – Local toilets strategies on the following link:,%20as%20passed.pdf

For the National Assembly of Wales, Public Health Minister, Rebecca Evans has stated that this wide-ranging legislation will have a significant, lasting positive impact on health in Wales. It will make a real difference to people of all generations, including older people who will benefit from better planning of public toilet provision. She added that she would like “to thank all of the partners who worked with us to develop this Act, and look forward to continuing to work with them as it is implemented.”

Indeed, I feel sure that improvements in the planning and provision of public toilets throughout Wales will improve the quality of life of people of all age groups; tourists as well as residents. Wales is leading the way with this legislation and I hope it is only a matter of time before England, Scotland and Northern Ireland follow the lead given by the National Assembly of Wales

I am assured that the British Toilet Association will continue to be actively involved in the future standard of toilet provision throughout Wales and I thank the Association for the important part it played in the consultations leading to the Public Health (Wales) Act 2017.

Susan Cunningham - 14th July 2017
This seems an appropriate time to provide the latest information on several toilet-related initiatives, ending with some very good news!

The Parliamentary Women and Equalities Committee inquiry into Disability and the Built Environment.

The Committee published their report on Tuesday 25th April. I was pleased to see the importance attached to the provision of “away from home” toilets in enabling people with disabilities to lead a fulfilling lifestyle.

However, I am concerned that whilst great emphasis seems to be placed on provision for people with severe levels of disability, I could find no mention of the many thousands of people who live with “invisible” disabilities. The lack of basic public toilets can have a very detrimental effect on them and their more simple needs should also be met.

The published Report is now awaiting a Government Response and due to the general election on 8 June 2017 the Committee has now closed this inquiry. Government responses to committee reports may be published in the next Parliament.

The Law Commission consultation for their Thirteenth Programme of Law Reform.

On 17th March I received a letter from the Law Commission, thanking me for responding to their Thirteenth Programme consultation and for proposing that the Law Commission consider undertaking a law reform project on the question of whether there should be a legal requirement regarding the provision of public toilets.

Regrettably, following their internal decision procedure, it was decided not to include my project in their Thirteenth Programme of Law Reform because the issue I identified is a matter of policy to be determined by Government, rather than a subject for a review conducted by the independent, non-political Law Commission.

However, I was interested in the following section of their letter (quote):

“You may be interested to know, however, that we are considering a wider project on public health legislation. Commissioners will be deciding on the final list of projects in May, after which, as required by the Law Commissions Act 1965, we shall refer the programme to the Lord Chancellor for approval. All being well, we hope to publish the Thirteenth Programme of Law Reform in July 2017.”

It will be interesting to follow the progress of the project on Public health legislation, if it does become a viable project, Might Wales’ example be followed? (see final item)

British Standard 6465-2 “Sanitary Installations. Space recommendations. Code of Practice”

On a more positive note, I am pleased to report that the revision of British Standard 6465-2 “Sanitary Installations. Space recommendations. Code of Practice” is making good progress and I have reason to suppose that certain of the recommendations will be very positive in terms of cubicle sizes, baby changing options, etc. It is hoped that the revised Standard will be published at the end of June, or earlier.

Public Health (Wales) Bill

As previously mentioned (Author’s Comments, 10th August 2016) the Public Health (Wales) Bill has been reintroduced in an amended form. The Bill includes a requirement for local authorities to prepare a local strategy to plan how they will meet the needs of their communities for accessing toilet facilities for public use.
Here is a link to the Bill as amended at Stage 3 of the proceedings.

Part 8 concerns the provision of toilets, starting on page 113.,%20as%20amended%20at%20Stage%203.pdf

Stage 4: On 16 May this Bill came before the Welsh Assembly for the final stage. Plaid Cymru, the Welsh Conservatives and UKIP all said they would support the revised proposals prior to the vote.

Public health minister Rebecca Evans said if passed the bill “will create the conditions which enable people to live healthy lives and will protect them from preventable harm”.

I am very pleased and proud that this Bill was passed, having been unanimously backed by AMs. Wales is taking the issue of the provision of “away from home” toilets seriously, and leading the way!

Susan Cunningham - 16th May 2017
There is currently a lot of activity which may have a positive effect on the provision of public toilets in the future.

As previously mentioned (Author’s Comments, 10th August 2016) the Public Health (Wales) Bill has been reintroduced in an amended form. The Bill includes a requirement for local authorities to prepare a local strategy to plan how they will meet the needs of their communities for accessing toilet facilities for public use.
The Bill is currently at Stage I and has several stages to pass through before it is adopted. The British Toilet Association is committed to fully support the progress of this important Bill and I am very pleased to inform you that Raymond Martin, Managing Director of the BTA, has been invited to Cardiff to meet with Rebecca Evans AM, the Minister for Social Services and Public Health, Departmental heads and representatives. It is my intention to keep readers informed of the progress of this Bill.

The revised draft of BS 6465-2 “Sanitary Installations. Space recommendations. Code of Practice” has been loaded on to the BSI drafts website and I have commented on the contents of the draft in some detail. Comments close on 3rd December and it is to be hoped the final version of this Standard will reflect the current and future requirements of the population of Britain.

Westminster is also busy. The Parliamentary Women and Equalities Committee launched an inquiry into disability and the built environment. The deadline for submissions was 12th October 2016. My submission was accepted and published, with many other submissions from interested parties.
My written evidence can be read at:

There is a thriving network of “toileteers” who are working hard to improve the provision of “away from home” toilets. It came to our attention that the Government carries out regular consultations on the need to change the law and thus gives members of the public the opportunity to influence future legislation. The Law Commission recently had a consultation for their Thirteenth Programme of Law Reform. Despite a few “I.T.” difficulties, I made a proposal on-line and now quote part of the Law Commission’s most recent response:

“We are carefully assessing the details of your proposals on public conveniences. The Law Commission is very grateful to you for the work that has been undertaken to produce your proposal. We will contact you regarding the outcome of your proposal in due course”
I am encouraged to hope that the importance of good toilet provision is now receiving the serious attention which so important an issue merits.

Please revisit this website to receive up-dates on the progress of all the items mentioned in this edition of Author’s Comments.

Susan Cunningham - 15th November 2016
However good the toilet facilities, without correct signage, problems will occur.

In “Public In-Conveniences: A Practical Guide” we have addressed the importance of Signposting, addressing specific areas of concern. To the information given in the text, I would like to mention two further points for consideration.

1. Hidden disabilities. Many people have “hidden” disabilities, for example, Inflammatory Bowel Disease, Crohn’s Disease, Ulcerative Colitis, bladder problems, etc. These people may need to use a toilet very urgently, or need the extra space and facilities found in a fully accessible toilet. Unfortunately, there have been instances of people with more obvious disabilities assuming that “their” toilets are being usurped.

With commendable attention to their customers’ requirements, Asda are going to place new signs on the “disabled” toilets in more than 400 of their stores. These signs simply state “Not every disability is visible – Accessible toilet”.

This simple and relatively inexpensive measure will raise awareness of hidden disabilities and help more people to enjoy active and stress-free lifestyles.

2. Dementia-friendly environments. It has been brought to my attention that people with dementia have certain environmental requirements which, if met, will reduce anxiety and confusion. The following link includes a valid point:
“Remember to check corridors, for example leading to the toilet; people can go in following the signs but not remember which door they came in by. A simple “way out” sign on that internal door will help.”

After careful consideration, I would like to add to that advice. For larger toilet blocks, more “way out” signs may be necessary; for example, placed near the hand washing and hand drying facilities. In some layouts, signs on the walls may be difficult to place. Perhaps providers should consider using “footprint” markers on the floor, to direct people to the exit. These signs are used successfully by certain large stores to direct customers round the sales areas, so they would not be unfamiliar to people with dementia.

Susan Cunningham - 10th August 2016
The First Minister of Wales, Rt. Hon. Carwyn Jones AM, is the leader of the Welsh Government. I am pleased to note that when he announced the first year of the legislative programme for the National Assembly (2016-2017), he included the information that the Public Health (Wales) Bill is to be reintroduced, as it was amended at Stage 3 in the last Assembly.

The Bill deals with several important issues relating to public health and Part 6 of the Bill contains an impressive section on the provision of toilets and local toilets strategies. Although before the summer recess there was cross-party consensus on a great number of proposals, agreement was not reached on proposals relating to restrictions on the use of e-cigarettes. Mr Jones stated that the reintroduced Bill will not contain restrictions on the use of e-cigarettes in enclosed public spaces; this should assist cross-party consensus on this popular Bill.

In my opinion, assuming the text relating to public toilets is included in full in the final version, this Bill will represent a welcome acknowledgement of the importance of public toilets in the lives of residents of Wales and all visitors to Wales.

It is my intention to keep readers informed of the progress of the Public Health (Wales) Bill on this website. For readers who would like more information, the text of the amended version (Stage 3) is to be found on page 70 of the following link.

Part 6 Provision of Toilets – local toilet strategies

Susan Cunningham - 10th August 2016
Addendum: Please note: is The Children’s Bowel & Bladder Charity, which originally was referred to as “Education & Resources for Improving Childhood Continence”
Susan Cunningham - 4th February 2016
Readers will find that the text of Public In-Conveniences (3rd edition) briefly mentions the four sections of BS 6465 which relate to Sanitary Installations, e.g. the recommended minimum size of a standard cubicle (see Public In-Conveniences, page 15) refers to BS 6465-4 (2010) Code of practice for the provision of public toilets.

Since this edition was published, I have done further research related to the height and weight of the average man and woman in Britain, from 1840 – 2015. Also, Public Health England estimates that by 2034, 70% of adults are expected to be overweight or obese.

Taking all my findings into consideration, I recommend that the absolute minimum dimension of a standard cubicle (with inward-opening door) should be 950mm wide by 1700mm in length (a total length of 1900mm to include space for the flushing mechanism).
The provision of larger cubicles as “standard” should not be allowed to result in any reduction in the number of cubicles provided.
BS 6465 parts 1-4 will be revised at intervals and I feel sure that in future their recommendations will better reflect the changing nature of the population.

It is my intention to update the 3rd edition when any important new Standards, legislation, etc. are made public. I hope this free guide helps you to ensure the provision of public toilets which really are fit for the 21st century.

Susan Cunningham - 3rd February 2016

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