Hi Vaila, 

I understand the impact that lack of appropriate facilities has and agree that things must change, its more of question of what to. 

I have been in touch with Clos-o-mat, not specifically about their Space to Change involvement, but about the accuracy of some of their 'white papers' more generally. I have stopped reading them the past year or so. Don't get me wrong, they supply some great kit which often ends up in my projects. 

In my experience larger developments / projects are happy to install full CP's when it is well explained and reasoned out. I have four completed/completing in the past 12 months with another 3 on current projects. So, I am an advocate for CP's subject to the specifics. 

I must admit, I wrote that email when more than a little frustrated. I had just looked at a planning application for a shall we say a 'small ish' leisure facility. They had provided a full CP but no traditional corners layout WC. I then found another application by the same operator where they had done the same and I am guessing there are more. Just a few days before a Building Control officer had recommended a CP on a small project I am working on. He had suggested we upgrade the only public facing corner layout WC (there's CP in the Library next door in this instance just to make matters worse). He didn't realise this would disadvantage more people then it would help. 

In my understanding providing a peninsular instead of a corner layout means that people who can use a corner layout safely and independently would be deprived of the traditional facility in favour of a CP.  Its some time ago, probably 2006-2009 but I recall an authority putting in peninsular WC's and someone had a fatal accident trying to use it independently (I might have even seen it via this forum). There are what I believe to be good arguments for the benefits of corner layout over peninsular which I won't go into now. That said, a peninsular in addition to corner layouts are a great idea. 

The issue of locking down a CP is in my view site specific. I have built them with no lock (other than the usual occupied/vacant bolt). One that opens later this year will be under lock and key as it's in a highly public environment which is subject to abuse (there are turnstiles to the male and female, but not the accessible WC's). A lot of people choose to lock them down for a multitude of reasons the most common being; 1) occupiers liability (if a child gets in an injures themselves messing with the hoist for example), 2) vandalism/cost of equipment (the main equipment for my last few has topped £13K - if it gets broken its won't be replaced overnight). 

My concern with the 'middle ground' as you describe it is organisations will choose that over a full CP. At the moment I am already asking for 2 x corner layouts, accessible baby change, plus ambulant and enlarged ambulant and then, wherever it’s a decent size project, or the only facility in the area a CP. The problem with the 'middle ground' in my view is its not large enough to operate a hoist and have an adult suspended with two more carers plus a wheelchair in the room (at 7.5m/sq). There is a diagram in BS8300 which shows a mobile hoist requiring 2.3m turning circle (Guessing slightly less would be find for ceiling track?). The issue with hoist and corner layout WC's is that corner layout won't allow a carer either side, so if we provide benches with corner layouts and then don’t get a full CP, some people will have to use the bed when they could have been hoisted onto the WC had it been peninsular.

My view on your specific questions that you asked in the AA LinkedIn page and below:

1) I don't know why - one for DCLG. I signed the petition to put CP's in the buildings regs as a requirement circa 2013. The consultation response at the time suggested they were overwhelmed by the response (I think about 600+ wanted CP's out of about 700 comments). Cost presumably as the building regulations under the government are seen as a bad thing - as disagreeable as that is. 

The second question you posed is one I think is very interesting. '"Why does protection from discrimination not apply to those with more complex needs?" I believe it does in the form of the Equality Act. The problem being its enforcement mechanism making it rather toothless. That said, in the right circumstances I think there could be a claim for failing to provide a CP. 

2) the 12m/sq is about right for convenient use. However, I do think that slightly less is sufficient - about 9.5m/sq last time I designed one to go in an existing blg with limited space. Fig 46 isn't hoisted. I always found fig 48 to be more appropriate. I imagine the bath as the changing bed and that gives 10.5m/sq. Hence, if smaller I would opt for flip up bed. 

3) again, in the right circumstances (where there isn't space for separates etc) I am not oppose to including baby change within a CP. In some circumstances though this would mean it would be in pretty constant use for baby change purposes. The same argument has bubbled along regarding including baby change in corner layouts for years so better not go there now.

I would fully support a clear requirement for CP's within the Building Regs, perhaps based on occupancy or floor area or something similar. That would go a long way. I would also support a two tier CP requirement, eg 12m/sq for new build, 9.5m/sq for existing build which I also think would give people more confidence when making the sorts of compromise that are made when refurbishing. I joined one project a little later than usual, RIBA E had just started. When asked why no CP the response was they could only get 10.5m/sq so thought best not to, which is a real problem (in my view symptomatic of a much wider lack of understanding).  

As for where the BS CP came from. Not entirely sure but I believe it was developed in by the CP Consortium and the various parties represented on the committee for BS8300 (Access Association, NRAC, RIBA, RICS, DCLG, LABC, Limbless Association, CAE and possibly the Ceiling Track Hoist Users club). Obviously then it went through the standards BSI process of going out to public comment before publishing. 

Regards

Martin

-----Original Message-----
From: Accessibuilt list [mailto:[log in to unmask]] On Behalf Of Vaila Morrison RIBA
Sent: 29 January 2017 18:13
To: [log in to unmask]
Subject: Re: Changing Places/Space to Change

Dear All

I was directed to this conversation by a couple of different people as I have a large personal and professional interest in this provision. 

I’m so sorry if this message sounds grumpy or adversarial as that’s not how I want to be at all – I want to see innovation! I think there are lots of options for positive inclusive design solutions, however I’m really sad to see quite a negative thread of comments, even here in the access world.  I know there are issues with the ClosOMat Space to Change solution, but I wonder, has anyone tried to work with them? I know nobody has been in touch with their partner in the campaign, Firefly, because I know Claire Smyth well and she is very enthusiastic to work to develop a way to increase facilities.  

This lack of provision isn’t an issue that affects individuals, for example, this affects my whole family of 4 – how can we go on an outing to somewhere that my daughter has no access to a toilet? 

I think much of this is due to an ingrained attitude in society.  It feels like people with complex needs are still seen as an ‘extra provision’.  That people like my daughter are destined to live in care homes and be happy with outings to day centres.  This is one reason I think that it’s parents who are leading this campaign – we want inclusion for our families.  We don’t want our kids to be limited by societies views of disability.  As our kids grow out of the baby change provision, we are seeing them growing apart from the ability to be included in society, included in activities with our wider family and friends. 

The BS for changing places itself is written in a very exclusive way – in that changing places should be locked and ‘normal disabled people’ and parents with children should be directed to the ‘normal toilets’ – I paraphrase here, but that is the jist of it.  

The Changing Places standard has everything thrown in, including a shower (surely a location specific need – would you expect a shower in any other toilet provision at the cinema for example?)! There are various diagrams for standard accessible toilets and showers and a combined WC and shower in part M – yet as soon as a bench and hoist is mentioned it’s lumped together with a peninsular toilet and a shower. Why no middle ground?  Why turn it into an exclusive, expensive ‘extra’ that no business wants to install.

I asked this series of questions in the Access Association Linked In group and have had no response in there....

“I do not think it is acceptable that there are only 2 toilets (that I know of, other than at her school) that my daughter can use in our whole city (despite the hard work of our access officer and local disability groups). There are none that I know of in my local authority at all.
I am actively campaigning and trying to raise awareness of changing places among fellow architects, and my local area, but I'm struggling with several things:
1. That omission of provision for people who need assistance in the loo still seems to be an acceptable compromise - do we know why? Why does protection from discrimination not apply to those with more complex needs? 2. The size of the changing places standards - 12sqm - is this really a reasonable adjustment? And is this, therefore, the reason why compromise is being accepted in away from home loo provision? Does anyone know where the 12sqm standard has come from? What are the minimum parameters (I cannot find any detail about this in the BS, in the way that there is about the unisex accessible WC). I can't find any similar sized sanitary provision in BS8300 guidelines - e.g. Fig 46 an assisted bathroom with peninsular toilet is 7.75sqm - why the jump to 12sqm when away from home?
3. Finally, why the exclusive nature of what should be a facility to create inclusion? Why can older child and adult changing facilities not be combined with accessible baby changing, for example, to create a 'family changing' facility? - surely more inclusive - and (I'd argue) that if a facility is beneficial to more user groups then it would be more 'valuable' to a venue and therefore it's more likely more would be installed by multiple organisations?
I'd be really interested to hear your thoughts and if you could signpost me to where I can find out the background on the standards and what research has been done.”

Again I apologise if this is perceived as a bit of a rant, and maybe I am too close to this issue, but when toilets with changing bench and hoist don’t even get a paragraph of their own in part M (and in that paragraph are listed after luggage!), it does feel there is an element of put up and shut up about it. 

Regards
Vaila
www.theinclusivehome.co.uk

(PS we parents may well use unsafe lifting methods, but that is because we have no choice, and we know only too well that our kids will grow into adults and will be further denied access to society if things do not change).

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