Toilets, change rooms and eating areas: the Facilities Regulations checklist

Short answer: toilets, washbasins, drinking water, seating and, except for office workers, a safe place for belongings, plus showers, changing rooms and a separate eating area where the work calls for them. The Facilities Regulations, 2004 set these duties but print no toilet-per-employee ratio. For that, they refer you to SABS 0400, the code of practice for applying the National Building Regulations.

The regulations were published under the Occupational Health and Safety Act, 1993 as Government Notice R. 924 in Government Gazette 26636 on 3 August 2004. They remain in force.

Toilets and washbasins (regulation 2)

• How many: sanitary facilities must be provided "in accordance with Parts F, P and Q" of SABS 0400.

• Small workplaces: where fewer than 11 people are employed on one premises, the employer may arrange in writing for them to use closets and washbasins on adjoining premises (sharing a common boundary line). These must be freely and readily accessible, and comply with the regulations and SABS 0400 for the total number of users and their condition.

• Supplies: free toilet paper and toilet soap (or a similar cleansing agent), a seat on every pan designed to have one, and at washbasins a towel for each employee's sole use, disposable paper towels, hot air blowers or clean portions of continuous cloth towels.

• The room: a conspicuous gender sign outside the entrance, screen walls, partitions or doors for privacy, and ventilation in line with Part O of the National Building Regulations.

• Water source: water for showers or washbasins that does not come from a local authority supply must comply with SABS 241.

Showers, changing rooms and lockers (regulations 2(4), 3 and 4)

• Showers: required in the circumstances set out in Table 4 of Part P of SABS 0400, with smooth, impermeable walls, a slip-free floor sloped to drain, and obscure glass in any windows. Regulation 2(4) also requires running hot and cold, or premixed hot and cold, water for washbasins and showers. "Hot water" means water at more than 35 degrees Celsius.

• Changing rooms: required for employees for whom showers are prescribed, or who need to undress. They must be separate for males and females, in accordance with Part C of SABS 0400, and those employees must change only there.

• Changing room layout: no direct opening into a room with exposure to a hazardous chemical substance or hazardous biological agent, or where untanned hides or skins, or unwashed wool or mohair, are treated, processed or stored. Each needs seating for the most people using it at one time, obscure glass in any windows, a screened entrance, a gender sign, ventilation, no unrelated storage, and somewhere to dry clothes if employees may get wet at work.

• Lockers: every employee except office workers must have a personal facility for safekeeping clothes and personal items, and must use it.

Eating areas, drinking water and seats (regulations 4(3) to 9)

• When a separate dining room or eating place is needed: where employees are exposed to a hazardous chemical substance or hazardous biological agent; come into physical contact with a known poisonous substance that may cause illness if taken orally; are exposed to dirt, dust, soot or similar filth; or handle or process untanned hides or skins, or unwashed wool or mohair. It must be on the premises and sized in accordance with Part C of SABS 0400.

• Dining room layout: tables and chairs for the most people using it at one time, no direct opening into the rooms listed for changing rooms, no unrelated storage, and ventilation.

• No eating in exposed work areas: in those workplaces, smoking, eating and drinking must be prohibited, with conspicuous signs (regulation 6).

• Changing room as eating area: allowed if an obscure partition reaching the ceiling or roof separates showers from eating places and there is no direct communication with the toilets, but this does not meet the dining-room duty above.

• Drinking water (regulation 7): an adequate supply of water that complies with SABS 241, and clear, conspicuous marking on taps and pipes not fit for human consumption.

• Seats (regulation 8): where reasonably practicable, an ergonomically sound seat for work that can be done effectively while sitting, and seating so that people who normally work standing can sit when the chance arises. Seats need backrests where the nature of the work allows.

• Condition (regulation 9): keep every room and facility clean, hygienic, safe, whole and leak-free, and in a good state of repair.

A quick self-check

• Count the employees using each ablution block and check the toilets, urinals and washbasins against SABS 0400. If fewer than 11 people are employed on your premises and use a neighbour's facilities, put the arrangement in writing.

• Walk through each ablution block: toilet paper, seats, soap, towels or dryers, gender signs, privacy, ventilation and leaks.

• Where employees work with chemicals, biological agents, poisonous substances, dust or dirt, confirm there is a separate eating area and "no smoking, eating or drinking" signs in work areas.

• Mark every tap that does not supply drinking water.

• Check that seated work has proper seats, and that people who stand all day have somewhere to sit.

How Qualitas can help

Our facilities assessment checks ablutions, showers, changing rooms, eating areas, drinking water and seating against the regulations, and ranks what needs fixing, in a report written for management, SHEQ teams and auditors.

Facilities are one part of preparing for a Department of Employment and Labour inspection, and an occupational health risk assessment shows who is exposed to the agents that trigger the dining-room duty.

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article summarises the Facilities Regulations, 2004 (Government Notice R. 924, Government Gazette 26636, 3 August 2004) for general guidance. It is not legal advice; refer to the regulations and SABS 0400 for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.