Rank: New forum user 
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I am a health and safety consultant and usually work in the construction sector. I'm currently engaged with a new retailer who sells stationary. They are going to open quite a few stores in the UK but do not seem to want to provide their staff welfare facilities in their retail units. These units are fairly small, typically only having up to five staff at any one time. The units will all be in established shopping centers. I am providing guidance to them on the welfare requirements of the Workplace regulations. They want to know what is the legal minimum requirement for toilets, rest facilities and places to eat and drink. As the units are all in shopping centres they want the staff to use the center facilities and provide the bare minimum in their own back of house area. There appears to be no guidance out there on what would be acceptable and in which circumstances it would be acceptable to provide nothing in the unit for the staff. Any pointers would be appreciated.
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Rank: Super forum user 
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If you are taking over existing units I'd see what's already in there and find out what the neighbouring units are doing. You have to provide an area seperate from the place of work to allow them to take breaks and eat meals (unless of course they're not going to be given shifts exceeding 4hrs an I doubt that would be the case for the branch managers). It might be possible that the shared toilet provision is acceptable but I'd check what the neighbours are doing.
Not providing anything at all is going to prove mighty expensive when you get caught out and have to retrofit every store to bring it in-line.
You also have provide a source of drinking water.
You cannot insist they take their breaks in local cafes unless the company is going to pay for they're food drinks which I'm guessing they won't.
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Rank: Super forum user 
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I refer you to para 195 of the Workplace Regs ACOP: The use of public facilities is only acceptable as a last resort, where no other arrangement is possible.
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Rank: Super forum user 
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Outcome likely to be fait accompli depending on what is (and what is not) provided within each unit.
On the face of it, it seems perfectly acceptable to use the central facilities, particularly where the centre is so designed, and the centre management acknowledge and formalise this via terms of let.
The sticking point is likely to be provision of somewhere to rest and eat without charge or obligation to buy food or drink. Cafe Units are themselves often a separately let facility and the operator is unlikely to welcome non-paying "customers"!
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Rank: Super forum user 
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To add to the points already made, it is likely that in some situations, that if the welfare facilities aren't already in place, then there is every chance that it would be to all intents and purposes, impossible to retrofit them.
I think you need to take a 'measured' and practical approach when giving your advice.
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Rank: Super forum user
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Talk to the local EHO's but do not expect much
Kiosks: Kiosk workers are an example e.g. 1 person working in a tiny space where whatever arrangements can be made is usually the acceptable norm - The enforcers may say, if the say anything at all, if public toilets are local, warm and clean and cafés are around then that is acceptable
U will find that there are different standards everywhere in the UK in every industry; - take farming compared to an office where the nearest toilet to a tractor worker could be miles away! And construction appears to be, in my personal view, picked on as against other areas especially those paying into the council by way of business rates and similar and land owners have a lot of weight!
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Rank: Super forum user
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As advised a measured approach considering the local facilities on offer in the shopping centre. There is nothing wrong with using public facilities in the centre, its quite the norn for many retailers in similar situations as this.
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Rank: Super forum user
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Effectiveness in practice of what is vaguely called a 'measured approach' depends on what is being measured.
To the extent that time to go to facilities and back, employee turnover, discipline and grievances and successful court claims for unlawful dismissal are accurately included in the 'measures', the style of management proposed is likely to be very costly.
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