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Since the release of Approved Document T in the Building Regulations on toilet accommodation in October 2024, there has been growing confusion around whether visual contrast applies to all types of commercial toilet seats or just to ambulant and accessible ones.

In this article, we will break down what the washroom regulations actually say about commercial toilet seat requirements and explore where the confusion stems from, particularly due to inconsistent guidance.

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Types of WCs referred to in Document T

Toilet Pan Seat: Doc T

Approved Document T in the Building Regulations provides broad guidance on toilet design in the common design provisions, stating that commercial toilet seats should provide a visual contrast with the sanitaryware they are seen against.

Based on this statement, many assume this requirement applies to all the WCs referred to in Document T, including:

  • Type A: Fully enclosed, self-contained ambulant universal toilet
  • Type B: Fully enclosed, self-contained universal toilet (commonly referred to as a superloo)
  • Type C: Ambulant single-sex toilet cubicle (not self-contained)
  • Type D: Single-sex toilet cubicle (not self-contained)

However, when reviewing the specific washroom equipment for each Type, we find that visual contrast is only explicitly mentioned in Type A and Type C for ambulant toilets.

This is where the confusion arises, and why so many questions have been raised about the applicability of these commercial toilet seat requirements.

Accessible Washroom at Victoria Embankment

Wheelchair Accessible Toilet Seat: Doc M

Approved Document T does not cover commercial toilet seat requirements in wheelchair accessible washrooms, which is why you need to refer to Approved Document M for accessible washroom regulations.

However, Document Part M does not provide specific guidance on visual contrast for a Doc M toilet seat but frequently refers to BS 8300-2:2018 for more detailed accessibility guidance.

Upon reviewing BS 8300, we find that it specifies that a WC seat should visually contrast with the WC pan and cistern. BS 8300 also advises against using a WC seat cover, as it can obstruct side wheelchair transfers when raised, and recommends avoiding gap front toilet seats for better accessibility.

ambulant-superloo-2

Interpretation of Visual Contrast Guidance

The inconsistency of commercial toilet seat requirements in Document T introduces ambiguity. It is unclear whether the general statement on visual contrast is intended to apply to all toilet Types, or whether it is only critical in ambulant toilet layouts where it is specifically reiterated in the washroom equipment section.

Given the structure of Document T, it is reasonable to interpret that the common design provisions are intended to apply across all toilet Types, unless otherwise indicated.

But the issue remains: the provision appears open to interpretation. Many are still questioning whether it implies that all commercial toilet seats in single-sex cubicles and universal toilets—many of which are typically white—must now feature a visual contrast, or whether the requirement applies solely to ambulant toilet layouts.

Superloo at Arding & Hobbs

Steps Architects Can Take Now

Given the inconsistency in the information provided across various documents, architects are encouraged to confirm specific commercial toilet seat requirements with their building control body to ensure compliance with the Building Regulations.

At Dolphin Solutions, we are actively seeking the clarification everyone needs around the legal requirements for commercial toilet seat visual contrast and colours, and we will update this article as soon as we have definitive guidance on what is expected for commercial toilet seats and their design.

To find out more about commercial washroom design, washroom products, including commercial toilet seats, WC pans, and the latest on washroom regulations, reach out to a Dolphin washroom consultant who will guide you through tailored washroom solutions and help ensure your project meets both aesthetic and compliance standards.

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