Last reviewed 10 July 2020
Mike Sopp advises on the steps organisations can take to encourage social distancing and prevent the spread of the virus in bathrooms during the Covid-19 pandemic.
The UK coronavirus alert level now sits at level 3, meaning the virus is considered to be “in general circulation” and that there could be a “gradual relaxation of restrictions” including the return to work for many employees and the opening of businesses to customers.
As part of the “new normal”, UK organisations must operate under Covid-19 secure guidelines that are aimed at preventing or reducing the risk of transmission of the virus.
One particular challenging area for many organisations is making toilet facilities Covid-19 secure, be they for employees, customers or members of the public.
The transmission of Covid-19 is thought to occur mainly through respiratory droplets generated by coughing and sneezing, and through contact with contaminated surfaces.
As such, the Covid-19 secure guidance being issued by the UK Government and devolved administrations focuses on risk prevention and mitigation through social distancing, physical barriers and hygiene control measures.
As well as access and egress, traffic routes and working areas/workstations, employers or those in charge of the premises must consider the ongoing use of welfare facilities and, in particular, toilet facilities.
Depending on the type of organisation, there is a requirement to provide:
employee toilet facilities in line with the Workplace (Health, Safety and Welfare) Regulations 1992
customer toilets in line with the Local Government (Miscellaneous Provisions) Act 1976, Regulation (EC) 852/2004 or venue licence requirements.
In addition, some organisations provide more general public toilets, such as those found in transport hubs, civic centres, parks, etc. Many businesses now also participate in “community toilet schemes” whereby they are paid by local authorities to allow access to toilets by the general public in cafes and bars, for example.
In respect of employee toilet facilities, UK Government guidance states that the objective is to “help everyone keep good hygiene through the working day”.
For customer toilets, the objective is to “ensure that toilets are kept open and to ensure/promote good hygiene, social distancing, and cleanliness in toilet facilities”.
Why there are differing objectives is not known but it may be advisable to take a consistent approach to all toilet facilities and have the same objective for both (that is social distancing, hygiene and cleanliness).
So, how can we make our facilities Covid-19 secure?
Risk assessing the “journey”
Risk assessment is at the heart of an organisation's response to ensuring the most appropriate Covid-19 risk control measures are adopted. Unfortunately, there is limited guidance on what to include in such an assessment when it comes to toilet facilities.
One method is to undertake the risk assessment by looking at the toilet users' “journey” when utilising the facilities. This will entail breaking down the journey into stages and identifying at each stage the potential hazards in terms of social distancing “pinch points” and “touch points” where the virus could be on a surface.
For example, the journey and hazards could be as follows.
Access to and egress from the toilet facilities, with pinch points where people enter or leave the facilities and touch points on door handles.
Access to and egress from cubicles, with pinch points inside the facilities and touch points on door handles and door locks.
Use of facilities, with touch points on toilet seats, flush mechanisms and toilet roll holders.
Handwashing, with pinch points around the sinks/dryers and touch points on soap dispensers and air hand dryers or towel roll.
Another factor to consider will be the levels of ventilation available in the toilet facilities, as the more ventilation available the better.
Simply closing facilities is rarely an option. Organisations must remember that they have duties under the legislation noted above to provide facilities. There are also certain best practice toilet ratios that will need to be met as detailed in BS 6465 Sanitary Installations.
As well as the ratios, when considering any changes, thought must also be given to the requirements of the Equality Act 2010 in terms of provision of disabled toilet facilities as detailed in BS 8300 Design of an Accessible and Inclusive Built Environment.
Finally, some toilet facilities may also have baby changing areas, which should also be included in the risk assessment process, using the same journey principles.
The reduction of social distancing requirements from 2 metres to 1 metre plus may ease some of the difficulties, but it does not mean an organisation does not have to consider other measures. The Government guidance highlights that this only applies where 2 metres is not viable, and the 1 metre distancing must only be used “with risk mitigation”.
It should be borne in mind that organisations must do what is reasonable and as such a combination of measures may be needed to meet the above criteria. In general terms, the measures necessary will based around the following.
Signage: using signs and posters to build awareness of good handwashing technique, the need to increase handwashing frequency and to avoid touching the face, etc.
Sanitisers: consider making hand sanitiser available on entry to toilets where safe and practical to do so.
Queuing: consider the use of social distancing marking in areas where queues normally form, and the adoption of a limited entry approach, with one in, one out.
Distancing: limit the number of people within facilities with multiple stalls/urinals, eg with signage on the door instructing users to wait outside if they find that the facilities are occupied.
Physical barriers: consider physical barriers where urinals and handwashing facilities do not enable social distancing, along with floor markings and signage (cubicles normally provide barriers).
Handwashing: ensure suitable handwashing facilities, including running water and liquid soap, and that suitable options for drying (either paper towels or hand driers) are available — preferably sensor operated.
Taps: consider adjusting the time that push/sensor taps are on to encourage 20 seconds of handwashing.
Equipment: reusable items should be removed and replaced with disposable versions (eg fabric towels, baby-changing mats). Ensure that there are adequate hands-free waste disposal units (ie foot-operated bins).
Egress: reduce the number of touch points after handwashing. This could include fixing doors open where possible (which will also assist in ventilation).
Communication: consider providing a contact number for users to raise concerns or report problems.
Emergency: have in place procedures for immediate cleaning in instances of vomiting and diarrhoea, along with reported Covid–19 illness.
Current guidance advises that enhanced cleaning is likely to be required as Covid-19 can survive on surfaces for up to 72 hours. Measures to consider include:
putting in place enhanced cleaning regimes commensurate with toilet usage
paying particular attention to frequently touched areas including toilet flush, toilet seat, toilet locks and handles, taps, paper towel and soap dispensers and door handles on access/entry
providing cleaning materials for surfaces (eg cleaning wipes for baby change areas)
increasing the frequency of waste collection where paper towels are used
clearly displaying enhanced cleaning rotas and ensuring they are adhered to (ie include a record that the checks have been carried out for users to see)
ensuring staff are trained in enhanced cleaning regimes and are provided with any necessary PPE.
Technology and innovation
As Plato noted, “necessity is the mother of invention”. A need or a problem encourages efforts to meet the need or solve the problem.
Certainly great strides have been made over the years in respect of toilet hygiene. It is now commonplace to see sensor activated elements in toilets such as flush mechanisms, soap dispensing and water taps.
That said, the current Covid-19 crisis has again generated innovation. A simple search of the internet will flag up numerous examples of businesses developing, in particular, hands-free door opening devices, either distributed to individuals or attached to doors.
Toilet hygiene has always been a major concern in terms of the spread of disease.
Many organisations may not have the resources available to convert toilet facilities to modern standards of hygiene but it can be argued that, as the new normal is likely to be here for some considerable time, organisations should be considering upgrades in terms of hardware for toilets.
All organisations should be risk assessing their toilet facilities — whether they are for employees, customers or the public — to ensure they are, so far as reasonably practicable, Covid-19 secure.
By breaking down the toilet “journey”, businesses will be able to identify where social distancing pinch points and touch points will occur.
Measures to be taken will be a combination of physical control, changes to equipment or materials, changes to hygiene arrangements and cleaning regimes.