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Educational Buildings White Paper

Considerations and specification of accessible toilet facilities in educational buildings

Building Bulletin103
Building Bulletin104
Statutory Instrument No 2
BS8300: 2018
Equality Act 2010
Priority School Building Programme Facilities Output Specification

The number of disabled children has increased by 62% in the past 25 years. 

  • One child in 20 under the age of 16 is disabled.
  • Some 60% of statemented children are now in mainstream schooling.
  • Over 20,000 students have a disability – almost 10% of the student population.
  • According to research by the Bog Standard campaign for better school toilets, 57% of schools surveyed did not have any disabled toilets.
  • A study has found 1,600 pupils over 5 are still wearing nappies at school.

Even pupils who are toilet trained can still have accidents. School staff need appropriate environments and equipment to deal with this hygienically, and ensure the children go back to class clean.

This document covers the legal requirements, Government guidelines and ‘good practice’ procedures for toilet specification for disabled students from primary to further education in mainstream and special schools.

By law (under the Equality Act 2010, which replaces the Disability Discrimination Act) service providers are required to make reasonable changes – including to the built environment – where a disabled customer or potential customer would otherwise be at a substantial disadvantage; previously, such changes were only required if it would have been impossible or unreasonably difficult for the person to access or use the service.

The Equality Act 2010 requires that service providers must think ahead and take steps to address barriers that impede disabled people. You should not wait until a disabled person experiences difficulties using a service.1
1 Government Equalities Office Equality Act 2010 Disabilities Quick Start Guide

Further, Statutory Instrument No 2 specifies the number of toilets that pupils MUST have, and lays down a minimum of 1 toilet for every 20 pupils overthe age of 5, and the number of toilet facilities must be adequate having regard to age, gender, and any special requirements.

The Priority Schools Building Programme Facilities Output Specification requires pupils should feel “that their needs are respected and met…in areas such as toilets…”.

The Bog Standard campaign for better toilet facilities in schools has found that where schools provide quality toilets, pupils respect that commitment.

Detailed specification guidance for disabled toilet facilities is covered under the Department for Education’s Building Bulletins 104 and 103, the Early Years Foundation Stage Framework, and BS8300:2018.

Building Bulletin 104 Area guidelines for SEND and alternative provision

BB104 replaces BB102, and applies to new build and refurbishment/conversion projects of educational setting. It addresses ambulant special,non-ambulant special, alternative provision (AP), specially resourced provision (SRP) and designated unit (DU) school accommodation.

The total area of toilet and personal care facilities must include the following toilet provision:

  • For special schools, SRP and Units where pupils are less independent,and for pupils aged two to four in any setting, approximately one fitting for every 10 (full-time equivalent) pupil places in total (where hygiene rooms are provided all but one of these can be counted towards this number);
  • For any setting where pupils are independent and aged five years and above, one fitting for every 20 pupils in total;
  • For all settings, at least one accessible toilet for disabled pupils per floor;
  • Where there is a hydrotherapy pool, one accessible toilet adjacent to the pool;
  • For all settings, separate toilets for staff comprising at least one toilet with wash hand basin plus one for every 25 full-time equivalent members of staff (not including catering staff) rounded up, see the Workplace Health,Safety and Welfare Regulations 1992, Approved Code of Practice and Guidance, L24;
  • For all settings, at least one accessible toilet for staff or visitors (which may also count towards the number of staff toilets above).

Hygiene rooms should be provided as follows:

  • For non-ambulant special schools or Units, one hygiene room for every 12 non-ambulant pupil places with fixed hoist, a changing bed, a wash hand basin, an accessible WC and accessible shower (if the changing bed doesn’t incorporate one) and space for assistants to change a pupil; for ambulant special schools and AP, one hygiene room per setting with fixed or mobile hoist, a changing bed, a wash hand basin and an accessible WC (alternatively the WC can be adjacent and separately accessed).
  • There should be enough fittings in any setting to ensure they are easily accessible, particularly where pupils need assistance with their personal care or are learning to be more independent. In a suite for severely autistic pupils there may need to be more toilets to ensure there is one immediately adjacent to a classroom. Accessible toilets for pupils may need to be provided within each key stage area (ideally alongside standard toilets). All accessible toilets must meet the travel distances and access requirements of ADM.

Facilities should also be of the right size – fewer well-placed rooms of the right size work better than an over-provision of undersized rooms. Facilities must also suit the age of the pupils:

  • Primary: a changing bed against the wall with wash hand basin:7m2;
  • A changing bed against the wall with wash hand basin and accessible WC:9m2;
  • For AP, ambulant special schools or if there are other larger hygiene rooms: a changing bed against the wall, an accessible WC and accessible shower: 12m2;
  • A peninsular changing bed (so that staff can support a pupil on each side)and an accessible WC - 15m2;l A peninsular changing bed, an accessible WC and an accessible shower - 20m2;
  • All hygiene rooms should have either a sluice or some other facility for dealing with waste (to suit the school’s arrangements) and storage for pads, spare clothing etc.

Space to Change Typical Layout

Typical small (6m2) toilet and shower for mainstream school where additional support may be needed, and for use by visiting children and adults.

Hygiene Rooms Typical Layout

Typical 12m2 toilet/hygiene room for inclusive primary or secondary school.


Building Bulletin 103 replaces the previous Building Bulletins 88 and 89 re area guidelines for mainstream primary and secondary schools. It requires that the total area of toilet and personal care facilities must include:

  • Toilets for pupils: approximately one for every 20 pupils in total, but there must be one for every ten full-time equivalent pupils aged two to four,including reception and nursery places.
  • Separate toilets for staff: at least one toilet with wash hand basin plus one for every 25 full-time equivalent members of staff (not including catering staff);
  • Accessible toilets for disabled pupils, staff or visitors (which may also count towards the number of staff toilets above);
  • In schools with pupils in Year 7 and above, facilities should also include a specialist hygiene room with fixed or mobile hoist and space for assistants to change a pupil. In a primary school this should contain a changing bed and accessible WC unless this is included in an adjacent accessible toilet (9m2). In a secondary school this should contain an accessible shower, sluice toilet and a changing trolley (12m2).

Some of the spaces listed above may be designed to allow facilitie sappropriate to:

  • Use outside the school day;
  • Particular religious requirements, including orientation and ablutions.


The Standard sets down good practice for accessible building design in premises to which the public have access, and specifically lists educational establishments within its scope. It advises that disabled people should be able to find and use suitable toilet accommodation no less easily that nondisabled people. 

Where space is limited, the provision of a single accessible unisex peninsular WC for assisted use caters for all needs, and should be sited as close as possible to the entrance and/or waiting area of a building. It should be no less than 2200mm x 2400mm. The time taken to reach a toilet is an essential element to be taken into account in its siting.

The Standard further recommends that any larger building where the public have access in numbers or where visitors might be expected to spend longer periods of time, and specifically itemises educational establishments among key locations, should have a Changing Places facility.

A Changing Places toilet involves the creation of a larger, better equipped accessible toilet compared to Document M versions, which only address the needs of someone who can toilet unaided. A Changing Places facility should be provided in addition to other wheelchair-accessible (Document M type)toilets. Each Changing Places toilet aims to meet the needs of people who need a carer to assist, and provides as a minimum:

  • The right equipment ie a height-adjustable adult-sized changing bench, height-adjustable wash basin, shower and shower seat, and track or mobile hoist system
  • Enough space, to enable manoeuvring for the disabled person and up to two carers, for a centrally located (peninsular) toilet with room either side for carers, and a screen or curtain to allow some privacy
  • A safe and clean environment, ie wide tear off paper to cover the bench, a large waste bin and a non-slip floor.
  • The room should be 3m x 4m, with a ceiling height of 2.4m
  • It is noted that a wash & dry toilet in place of a conventional WC can give users greater dignity & independence.

Changing Places Typical Layout

The Closomat Solution

Closomat is the UK’s largest and longest-established specialist supplier of disabled toileting equipment.

It is unique in offering, in-house, full design advice, supply, installation,commissioning and maintenance.

Manufacturer of the biggest-selling automatic wash and dry (automatic shower) toilet, Closomat also supplies the full ambit of accessible toileting,washroom, hygiene and changing room equipment, including shower equipment, hoists, height adjustable fixtures and fittings. It is already expert inthe provision of disabled toilets, hygiene rooms and Changing Places toilets in schools, colleges, universities and the latter’s halls of residence, eg:

  • Strathclyde University
  • Wakefield College
  • South Birmingham College
  • Coleg Menail Bournside School
  • Elmwood College
  • Harlaw Academy
  • Cramlington Village Primary School
  • Lonsdale School
  • Teeside University
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Closomat Limited, Building 1, Brooklands Place, Brooklands Road, Sale Cheshire, M33 3SD