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Gilby  
#1 Posted : 24 January 2023 17:31:21(UTC)
Rank: New forum user
Gilby

Hi, I have a question about emergency lighting in toilet cubicles. Our emergency light consulants have suggested that all of the toilet cubicles in our building require their own emergency light because they have floor to ceiling walls and doors. We currently have only 1 emergency light in the hand washing area outside of the cubicles. I've queried this with a fire safety advisor and in his opinion each cubicle is not required to have emergency lighting if the area of the cubicle is less than 8m squared, which they are. In reply to this, our consultants have commented that the 8m2 rule does not apply because the cubicles are considered to be rooms within a room. Clearly, there exists a difference of opinion on this question, so just wondering if any of the forum users have any opinions / experience on this? Thanks.

achrn  
#2 Posted : 25 January 2023 09:25:51(UTC)
Rank: Super forum user
achrn

I assume that you've already seen https://www.gov.uk/gover...ssment-offices-and-shops because you've referenced the 8m2 (which is found on page 100).  I assume the documents for other workplaces say similar but haven't read them all.

I observe that it very clearly says "An emergency escape lighting system should normally cover the following ...  windowless rooms and toilet accommodation exceeding 8m2;"  So even if the cubicles ARE considered to be individual rooms, they are windowless rooms not exceeding 8m2 and covered by that statement.

None of the cubicles in my building (which also have floor-to-ceiling walls and full height full closing doors) have emergency lighting.

thanks 1 user thanked achrn for this useful post.
Evans38004 on 25/01/2023(UTC)
Messey  
#3 Posted : 25 January 2023 11:40:44(UTC)
Rank: Super forum user
Messey

The key to all this is professionals being blinded by guidance and losing sight of the UK legislation. It doesnt matter which part of the UK you apply the law, the FRA is the hub of what you need to do. The aim of the legislation changes that began in 2006 was to get rid of the prescriptive requirements contained in scores of previous laws and bylaws and  instead apply ‘risk assessment’ methodologies - i.e common sense.

But from the beginning, safety professionals have applied the Guidance and BS as if it were prescriptive - where it isn't and was never intended to be.

IMO this emergency lighting issue has arisen due to rather ambiguous and poor wording within BS5266 which has been then copied and replicated in HMG Fire Safety Guides

For me, when I come across a dichotomy like this, I try to understand the meaning, the reason, the rationale behind the ‘rules’. 

It’s clear that as EL is needed in larger toilet cubicles and those designed for disabled persons, the rational being that EL is needed where a person could reasonably experience difficulty or a delay is escaping from that space. Common sense isn’t it?

Toilet cubicle sizes start from around 1.5 m2. Presumably these spaces are those annoying type where you have to lean back and fold yourself over the toilet pan to open the door!

Applying common sense rather than guidance, I would expect an abled bodied person in such a small confined space to be able to find the bolt on the door and to be able to release it to open the door and use the borrowed light from the emergency light luminaire outside to escape.

So when assessing the need for EL, why not have regard to the guidance, but use your skills and common sense to look at what is presented to you to find a solution?  Where the door locking mechanism is non standard (or not obvious in its operation), or the loo is in a school where children will have to use the loo, or where able bodied but vulnerable persons might be expected to use it, or in a shopping centre, where the user  may have umpteen shopping bags in the cubicle with them….. etc…. I may opt for EL in a windowless smaller cubicle. If not, I would go for not fitting EL and explain my reasons in the FRA

thanks 6 users thanked Messey for this useful post.
A Kurdziel on 25/01/2023(UTC), Evans38004 on 25/01/2023(UTC), peter gotch on 25/01/2023(UTC), Kate on 25/01/2023(UTC), Andrew_C on 25/01/2023(UTC), Paul S12 on 25/01/2023(UTC)
peter gotch  
#4 Posted : 25 January 2023 13:19:01(UTC)
Rank: Super forum user
peter gotch

Hi Gilby

Sounds to me like the "emergency lighting consultants" are on a sales pitch. 

"you need emergency lighting in 86 wall to ceiling cubicles. By the way we could install these for you."

P

thanks 1 user thanked peter gotch for this useful post.
Kate on 25/01/2023(UTC)
Alan Haynes  
#5 Posted : 25 January 2023 19:05:37(UTC)
Rank: Super forum user
Alan Haynes

Let's look at it from a 'non-legislation point of view. Imagine you are sitting on one of those toilets, halfway through a "messy" unloading operation. The lights go out, and it's pitch dark. How easy is it to get the toilet paper to clean yourself up before readjusting your clothing and finding the door lock and escaping? Now - would you be happy for your partner, child, or granny to undergo such a situation? If not, (and I know they probably wouldn't be on your workste, but it's a rhetorical question), why should you expect workers to do so? So, I'd fit the lights, or find an alternative way of getting light into the cubicle. It a matter of ..... "The law says No, but common decency says Yes", ...... and surely sometimes (often) we should not just look at the Regs as the maximum that needs to be done, but should consider what is good practice to be done.
Messey  
#6 Posted : 25 January 2023 23:17:40(UTC)
Rank: Super forum user
Messey

In the rare circumstances you have outlined, somebody 'caught out' like this may have an awkward time, but with a mobile phone, or cracking the cubicle door open, I am sure they would survive. In any case, it is not something I would ever consider when employed to supply a FIRE risk assessment. If the business wants to provide additional EL for this purpose, it would have to originate from another source but it would certainly not come from me in an official report. Neither would I comment on the width of their toilet paper or quality of the soap supplied. I am preparing a legally binding document, not an entry on Tripadvisor When conducting a FRA, I make no apology in taking the view that emergency lighting is about life saving, not face saving
thanks 3 users thanked Messey for this useful post.
Evans38004 on 26/01/2023(UTC), Roundtuit on 26/01/2023(UTC), achrn on 26/01/2023(UTC)
Roundtuit  
#7 Posted : 26 January 2023 08:45:36(UTC)
Rank: Super forum user
Roundtuit

Of course you could have the doors re-sized trimming top & bottom.

The cubicles you describe sound quite claustraphobic.

This would have the advantage of being able to spot occupancy without necessarily breaking the door lock - peoples medical conditions diabetic shock / epilepsy / heart attack / stroke can manifest at ay time.

Knocking on a closed door may illicit no response from the deaf or those with headphones at high volume.

thanks 2 users thanked Roundtuit for this useful post.
DH1962 on 02/02/2023(UTC), DH1962 on 02/02/2023(UTC)
Roundtuit  
#8 Posted : 26 January 2023 08:45:36(UTC)
Rank: Super forum user
Roundtuit

Of course you could have the doors re-sized trimming top & bottom.

The cubicles you describe sound quite claustraphobic.

This would have the advantage of being able to spot occupancy without necessarily breaking the door lock - peoples medical conditions diabetic shock / epilepsy / heart attack / stroke can manifest at ay time.

Knocking on a closed door may illicit no response from the deaf or those with headphones at high volume.

thanks 2 users thanked Roundtuit for this useful post.
DH1962 on 02/02/2023(UTC), DH1962 on 02/02/2023(UTC)
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