Government consults on mandatory Changing Places

The government is undergoing a public consultation (part 1) providing the finer details of including Changing Places toilets in the Building Regulations (Document M, Sanitation).

Visit: Changing Places (England) Consultation

You can have your say on issues such as:

  • Types of buildings
  • Trigger values eg cinemas would be based on x number of seats, others triggered by footfall or space.
  • Size and equipment provided
  • Costs to businesses
  • Equality impact assessment of provision.

Full details are contained in the pdf document provided on the consultation page. You can participate by email or online.

Using a toilet as a first aid room

First aid room toiletYou were having a nice day out until you took a tumble and you’re now bleeding profusely from your knees and elbows …. off to the first aid room you go.

Would you accept treatment if the first aid room was a toilet / restroom and the ‘seating/rest’ area was a bed near the toilet that had previously been used to change a filled nappy?

Would you be thinking ‘surely this isn’t the right environment to treat an open wound?’

When a first aid room becomes a toilet room

I think most of us would be quite shocked to know that first aid rooms at some public venues / tourist locations are being offered up as ‘toilets’ to disabled people? Did you know that disabled people are having soiled pads changed on first aid beds? Some disabled people may be using camping toilets or commodes in the same space.

Should this be allowed? Let’s look at the issues.

[Article by Louise Watch. Louise has formerly worked for 7 years managing mobile and static first aid posts at public event and venues. Louise also uses a wheelchair and hoist].

Why is it happening?

There are large numbers of visitors to public events who can not use standard ‘accessible toilets’. On a number of occasions first aiders and ambulance staff have had to help people who have not been able to get up from the toilet or who have fallen – usually because the space has been too small to use safely.

Some people need carer support, space, a hoist to transfer from wheelchair to toilet or a bed to lay on to remove clothing, use a catheter, have a continence pad changed. However, venues across the world have been declining to put in suitable toilet facilities known as Changing Places, and instead are telling visitors with these requirements, to use the first aid room.

Safety and practical concerns

  • The obvious first problem is that this assumes that older and disabled people are incontinent – and use adult nappies. So they can just lay down on the bed and change, right?

Wrong. Most are not, they just need a toilet in a room with enough safe manoeuvring space or a hoist available … and first aid rooms do not have a toilet in them. They also do not have hoists or the space to use them.

I have been in hundreds of first aid rooms whilst looking after sick and injured visitors and never once seen a toilet inside. Usually there is a cupboard with medical supplies and a bed, chair, sink and maybe a privacy curtain. So how the offer of a first aid room is going to help continent disabled and older people is a mystery.

  • Are they thinking about supplying a commode or camping toilet?

Maybe – but it’s not something a first aid room would have as standard and commodes vary a lot and come with their own hazards eg stability, wheels that need breaks on, variable heights and seat types. People can easily fall if it’s not suited to their balance or abilities. Proper accessible toilets have specific features for a reason eg

  1. gently curved toilet seats or specific shapes that support hip stability and protect pressure sores.
  2. a toilet that is anchored to the ground and won’t tip over
  3. a seat specially designed to withstand ‘rough’ transfers,
  4. support rails at a particular height either side
  5. if a person stays in their hoist sling then this is a total body support in itself.

Commodes can be dangerous if they don’t match the needs of the person and can cause serious accidents.

Commodes also need to be cleaned/emptied between different people and human waste and menstrual blood has to be disposed of correctly. First aid rooms are not equipped for this which means someone will have to walk the filled pan to a nearby toilet to flush away. Will that be staff or visitors?

It is also questionable whether hygiene standards for spills and splashes could be dealt with in a first aid room environment. Infection control becomes a big issue that would probably need a full risk assessment.

  • What about people who just need a bed?

People who need a bed to have a soiled pad changed could possibly use a first aid room but there would have to be a full risk assessment to look at the following areas:

  1. If a hoist is needed, is there sufficient space for a portable or gantry hoist? In my experience, there is rarely enough room.
  2. Infection control is needed if urine, faeces and other fluids are likely to have touched the bed. It might be possible to risk assess alongside the usually assessments for cleaning up body fluids such as blood, vomit and saliva wipe down methods for infection control. This should be in place in a first aid room as standard. Carers/assistants are likely to already be familiar with this when using Changing Places toilets and home facilities.
  3. There is, however, a greater risk if a proper cleaning procedure has not been followed by staff or carers – eg if the next casualty to use the bed has open wounds. Equally, an immune compromised disabled person may be at risk if a casualty has used the bench and has an infection and has vomited over the bed as is often the case. I have seen some pretty poor hygiene and infection control practices in first aid locations.
  4. Access to a sink for water to clean and wipe the person should be available from the first aid room sink – again infection control protocol could be used and general wipe down procedures that toilet cleaning staff might also utilise.
  5. There would need to be access to human waste and sanitary bins not provided by first aid rooms.

Duel use at the same time

The other challenge to turning your first aid room into a toilet is that it can take 40-60 minutes to hoist a disabled adult onto the treatment table, change and clean them, then get them back comfortably in their wheelchair. Then add on another 15 minutes for cleaning and disinfecting. What if there is a casualty who needs treatment during this time. Both can’t use it at the same time unless you have a first aid room laid out like a hospital with cubicles and more than one treatment area/bed.

Should first aid rooms be offered as toilets?

In light of the above – no, unless the first aid room is very large and more like an A&E department with staff training to match regarding infection control and clinical waste disposal.

Even if I was offered a commode, hoist and private cubicle I would find it insulting and undignified to have to visit a first aid room, where patients might be, to use the ‘toilet’. This would not be equality in terms of bathroom provision. It is certainly not an appropriate solution for the hygiene needs of older and disabled visitors/guests.

Helpful or not – petitions

There are over 80 petitions on Change.org calling for signatures to back calls to governments and businesses for accessible toilets. Most are by individuals calling particularly for Changing Places toilets.

Are petitions helpful?

Psychologically petitions and demonstrations by disabled people and carers are useful – providing the 'I feel I am doing something rather than nothing'. People who sign genuinely want to say 'this needs to change'. However, the reality is that petitions rarely achieve results.

No amount of signatures is going to change the law or monitor adherence to building regulations. In the UK, the government have heard, via parliamentary debates, how we need accessible toilets. They end with empty promises.

As we speak the draft of revised access standards has been drawn up – setting British standards for what could be used in buildings which last over 50 years. They don't include any change to toilet provision. They are based on the dimensions of wheelchairs, for example, from 20 years ago. Petitions won't impact these.

Dilution of support

Petitions aim for x number of signatures …. people might sign one or two but 80? If campaigns were centralised into one petition there could be thousands of supporters rather than a few hundred.

Change in strategy

The movement to ensure toilets for all is disjointed. Often it's based on promoting the needs of children rather than the needs of disabled people of all ages. People with obesity, dementia and autism are often totally ignored. Many campaigns are based on the need for hoists and changing benches – yet we still have toilets being built that are supposed to follow strict building regulations, but don't for 'independent' disabled people. There are failings at every level. Equality laws do nothing to persuade businesses that disabled people need accessible toilets.

What can we do to actually make a difference?

  • Share a petition rather than recreate one for yourself
  • Look out for opportunities to comment on building regulation guidance, local access consultations, health consultations etc.
  • At every opportunity provide feedback about toilet access. Use social media, review websites, council feedback forms, patient feedback cards at hospitals etc.
  • Use formal complaints procedures.
  • Write to your MP
  • Provide witness statements for parliamentary debates

Sounds like a lot of effort? That's why it's easier to sign a petition and have our social guilt relieved – we've done all we can, right? Now everything will be ok?

No it won't – but deep down you know that.

Poo at the zoo.

This week is Love your Zoo Week run by BIAZA. The British and Irish Association of Zoos and Aquariums (BIAZA) is the professional body representing the best zoos and aquariums in the UK and Ireland.

Baby elephant
Chester Zoo
 
1.3 million people visit member organisations every year. Only a small percentage are disabled people and their friends/families because few venues provide toilet facilities with 

  1. a hoist and changing bench, 
  2. space for modern wheelchairs or 
  3. one that is fully equipped for able wheelchair users and those with other impairments e.g. Bowel/bladder disorders, autism, mental ill health, epilepsy, obesity, shortened height.

 BIAZA members contribute over £650 million to the national economy.

If the venue doesn’t provide a hoist or height adjustable toilet, this means a lot of people can’t visit. People with poor balance, weak legs or arms may not be able to stand up from an accessible seat. 

People with muscle and nerve disorders, balance or co ordination difficulties or frailty from old age may need this equipment.  They may not necessarily use a wheelchair.  

There are no height adjustable toilets in any zoo, aquariums or wildlife parks in the UK.

If standing up from the loo (or standing by the loo) is impossible, such individuals have to be lifted up / carried in the arms of relatives or find a toilet with a hoist and changing bench. Wheelchair users with weak arms/legs also need hoist facilities.

Hoist, toilet and changing bench
Chester Zoo

There are a number of zoos etc who provide such essential equipment and the space to use it. 

These are:

  • Marwell Zoo (first in UK to equip toilets for all visitors)
  • Bristol Zoo Gardens
  • Blair Drummond Safari Park
  • Tilgate Park
  • Chester Zoo
  • Chessington World of Adventures Resort
  • Tropical Wings Zoo (opening soon)
  • Folly Farm Adventure Park and Zoo
  • Cotswold Wildlife Park
  • Colchester Zoo
  • Yorkshire Wildlife Park (hoist and toilet)
  • Wingham Wildlife Park
  • Pili Palas Nature World
  • Camperdown Wildlife Centre (opening soon)
  • Edinburgh Zoo (hires in a bed and hoist for 1 week per year)
  • Whipsnade

(List excludes bird and wildlife reserves and parks/forests).

Possible future venues:

  • Living Coasts
  • Paignton Zoo
  • Newquay Zoo
  • Twycross Zoo
  • London (only hoist and bench currently – no toilet)

Specifically stating no hoist facilities:

  • Woburn Safari Park

However, there are over 100 venues who do not offer usable toilet facilities – not even for people who don’t use a hoist.

Why do they exclude disabled people?