National
Assembly for Wales / Cynulliad Cenedlaethol
Cymru
Health
and Social Care Committee/
Y Pwyllgor Iechyd a Gofal Cymdeithasol
Public Health (Wales) Bill/ Bil Iechyd y Cyhoedd (Cymru)
Evidence from The British Toilet Association – PHB 53 / Tystiolaeth gan Cymdeithas Toiledau Prydain – PHB 53
The
British Toilet Association Ltd
Enterprise House, 2-4 Balloo Avenue
Bangor, Co. Down, Northern Ireland, BT19 7QT
Tel: XXXXXXXXXXX Mob:
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The British Toilet Association
Limited
Is
a Not-for-Profit Members Organisation working to promote the
highest standards of hygiene and provision in all “away from
home” toilet facilities across the UK. The Association, as a
whole, has a wealth of knowledge on toilet related issues and
practices and every day handles a constant stream
of enquiries from everyone who has a real desire to help
improve the current provision as well as reduce the number of
toilet closures. We support consumers and suppliers alike on the
future development and installation of more hygienically clean
publicly accessible toilets across the country. Our survey
team carries out a number of consultations each year, which
can include a wide variety of detailed reporting
on: toilet facilities and their fixtures, hygiene, cleaning,
design and innovation, specification and maintenance, current &
future provision along with change of purpose, use and
operation. As an independent body we are frequently invited to give
an opinion, statement or judgement regarding legal issues and
regulation revolving around publicly accessible toilets. Having
access to a wealth of knowledge through our growing membership can
allow us to be proactive in many instances. We are currently
developing a Toilet Map project that will greatly enhance the
public’s quest for finding a decent clean – open
– facility as the map will contain/identify all recorded
sites and then give a detailed profile of what each
contains.
Written Evidence on the general principles of the Public Health
(Wales) Bill.
Part 6 – Provision of Toilets
Question 1: What are your views on the proposal that each local
authority in Wales will be under a duty to prepare and publish a
local toilets strategy for its area?
The BTA fully supports - Option 3 of the proposal – to place
every council in Wales under a duty to prepare a local strategy for
the provision of public toilets.
However, very careful consideration must be given to the foundation of these strategies to make sure that authorities continue to control and administer the correct levels of provision. It would not be acceptable for councils to devise a strategy that pushes the total responsibility onto other providers – whether community or private – and thereby relinquishes all responsibility for the strategy. A combination of council and community toilets working in tandem/partnership is probably the most effective overall solution across the country – but especially in the less populated towns and villages. Individual strategies should not allow councils to completely opt-out of providing toilets.
Since
the Public facilities Grant was withdrawn in 2014 and the monies
transferred to the Revenue Support Grant in a move to increase
flexibility of funding to local authorities, it is our
understanding that only a very small proportion of this money was
in fact used for the provision of toilets. We believe that the
impetus has been lost and the department would need to revisit this
funding structure and make sure that monies originally intended to
improve public provision are ring-fenced for that purpose.
When any of us are travelling and away from home for an extended
time, we will on one or more occasions require the use of a decent,
clean toilet. There are also an increasing number of specialist
user groups, whose lives are adversely affected by the poor state
public toilets across the country. These include people with
mental or physical disabilities and their carers; older persons and
many focus groups; families with babies or young children,
schoolchildren and residents and visitors of all ages who are
coping with a range of medical conditions. This is a basic human
function and we need to have a greater level of adequate provision
for everyone and anyone who has a sudden urge to find relief when
they are away from their normal residence. It’s a problem
faced by thousands of people every day, truck/lorry and van
drivers, car drivers and that includes taxi & private hire,
coach drivers and passengers, emergency services and transient
workers.
The failure to get to or use a toilet, when the need arises to, can
very often lead to both embarrassing medical and social
problems.
Question 2: Do you believe that preparing a local toilet strategy
will ultimately lead to improved provision of public
toilets?
Public toilets – owned or operated by local authorities
– have historically fallen into a shared responsibility over
a number of departments. This has made overall management and
ultimate responsibility difficult to assign, and in many cases has
led to neglect and the lowering of acceptable standards in many
facilities across the country. The preparation of a toilet
provision strategy can only have extremely beneficial outcomes in
focussing attention onto this vital provision for so many
independent users. With improved management and a clearer
understanding of the needs of residents and visitors, must come
higher standards of health and hygiene.
Question 3: Do you believe the provision in the Bill to ensure
appropriate engagement with communities is sufficient to guarantee
the views if local people are taken into account in the development
of local toilet strategies?
The BTA believes it is absolutely vital to involve not only local
communities and community groups but consideration should also be
given to engagement with local support groups, shop owners and
representatives from organisations who completely understand the
needs and daily requirements for people living with medical and
social conditions that require them to visit the toilet on a much
more frequent basis. A wealth of knowledge can be gained through
interaction with local community representatives.
Question 4: Do you have any views on whether the Welsh
Ministers’ ability to issue guidance on the development of
strategies would lead to a more consistent approach across local
authorities?
The provision and placement of public toilet facilities has a
significant impact on the health and vitality of the local
community and the surrounding area. Anyone suffering with any type
of medical or social problem relating to toilet usage can find
themselves isolated or unable to move around an area when no
provision is easily accessible. The range of health problems is
often underestimated and we need to have a clearer understanding of
the problems being faced by a growing number of individuals who
need to plan their journeys and daily routines around the need to
frequently visit a toilet facility. The BTA is delighted that the
Health Minister has understood and had the foresight to question
the current lack of any strategy to answer the needs of those with
disabilities, older persons, families with young children, pregnant
women, and all persons who are transient through their work. It is
our firm belief that public toilet provision specifically addresses
the following issues:
Health
& Well-being, Equality, Social inclusion, Privacy & Public
Decency
Question 5: What are your views on considering toilet facilities
within settings in receipt of public funding when developing
local strategies?
It has been our long-term belief that local authorities should be
in receipt of direct funding from central government to provide
these types of facilities. It has always been extremely difficult
for councils to maintain a range of facilities and to attain
acceptably high standards of hygiene and provision when government
refuses to recognise its responsibilities to public health. The BTA
has continuously worked with local authorities and the relevant
departments in trying to maintain an acceptable standard of
provision as expected by the general public and a considerable
number of specialist user groups. The responsibility for these
facilities has always been perceived to belong to the local
authority. Considerable efforts have been made in recent years to
involve shops, stores, and other local providers to enter into
controlled community toilet schemes. This has had a significant
effect on the amount of provision available, however, unless
closely controlled there can still be a considerable number of
variants and negative factors that can affect the overall
provision. Opening times, bank holidays, closures, management and
staff attitudes as well as high volume visitor numbers can lead to
businesses withdrawing their support after only a short period.
Careful consideration and management must be applied.
Question 6: Do you believe including changing facilities for babies
and for disabled people within the term ‘toilets’ is
sufficient to ensure that the needs of all groups are taken into
account in the development of local toilet
strategies?
In recent years we have seen a considerable positive shift in the
provision of toilets, where we now have child changing beds in both
male and female and in a growing number of cases, a completely
separate unisex baby-changing room. The growth of these types of
units is to be applauded as we invite more families to visit and
enjoy our towns and city centres, as well as our parks and beaches.
In our work with Mencap, we have been heavily involved in the
promotion and installation of Changing Places toilets that are
designed for users with profound and multiple difficulties. We
believe all toilets should be equally accessible for all persons
whether able-bodied or struggling with a temporary or permanent
disability; and this must include carers and parents who need to
attend to a range of special needs. Normally a block of toilets
will contain both male and female facilities along with a separate
accessible unit. Many of these disabled units are poorly maintained
and this has a detrimental effect on the health and well-being of
many visitors.
Question 7: Do you believe the proposals leading to toilet
provision in the Bill will contribute to improving public health in
Wales?
The BTA believes this is a huge step forward in striving to improve
the health and well-being of both residents and visitors to Wales.
Without decent, clean public toilets, many citizens affected with
bowel and urinary problems will find it almost impossible to move
around and enjoy the normal freedoms the rest of us take for
granted. A lack of decent, clean public facilities can be
correlated directly to isolation, infection, dizziness,
disorientation and a general distress at feeling unwell. We know
from studies that more and more people are experiencing reluctance
to leave their own homes, or in some cases temporarily altering
their medication to allow them to stay away from home for longer
than usual. Drivers and road users may become disorientated and
unwell from the effects of not being able to relieve themselves for
extended periods. This could in extreme cases result in a loss of
control of a vehicle, or extremely poor judgement at major
junctions. It is our belief that operating a vehicle and not being
able to find a toilet when necessary could be a major factor in the
number of accidents that occur on our roads each year.
Public toilets are a major health issue, which has gone
unrecognised for many years. In extreme cases the inability to
relieve oneself can lead to
raised blood pressure, stroke or even heart attack. When one
considers the cumulative effect of all the points and
considerations above, it becomes blatantly apparent that Wales has
through this proposed bill taken a massive step in recognising the
importance and trying to address the health and equality
inadequacies that its people have faced since austerity first began
to bite.
Finance Statement
What price can you put on public health? It was recognised in the 11th Century as part of the Magna Carta that the health and well-being of the populace, far outweighs that of the government and the crown. If your people are sick it has a massive effect on all aspects of life. Costs go through the roof for healthcare, welfare and social services. Whilst sick people are not fit to work, shop or go on holiday, the economic imbalance is very easily understood.
The figures as detailed in Part 2 of the Explanatory Memorandum seem perfectly fair and correct. Negated over a five year period, it appears to cost in and around £5000 per council, per year, to implement and administer the strategy around public toilets. The BTA like many other organisations is working with local authorities to reduce overall running costs, whilst maintaining the highest possible level of provision and hygiene. The installation of charging gates and doors, the introduction of franchising and commercial partnerships, along with the inception of the community toilet scheme are all current methods employed to reduce the pressure on capital and revenue budgets.
The BTA is the leading authority on the provision of public, private and commercial toilets, and is ready and willing to work with local authorities and government to formulate ideas and plans covering the implementation of any future strategy.
Assuring you of our best attention at all times.
I remain yours faithfully,
Raymond Martin
Managing Director
British Toilet Association