It’s no joke – toilets are vital to health, safety and wellbeing on our railways

Having access to a toilet is no laughing matter. In the UK, recent research published by the Rail Safety and Standards Board (RSSB) highlighted the very real consequences of insufficient access to the loo. Most strikingly, it found that many railway workers will deliberately limit their fluid intake before their shift to avoid being caught short. This strategy is contrary to general health advice which encourages the drinking of fluids; if taken too far, it can damage a person’s health. Long-term effects can include urinary tract infections and kidney conditions.

In addition to the RSSB report, the Rail Wellbeing Alliance and RSSB published a useful guidance paper, in April 2022, which the Office of Rail and Road (ORR) has commended to all duty holders.

Train drivers often are in a particularly difficult situation since they are unable to leave their driving position for long periods at a time and can find themselves waiting at a remote location for a good while. The recent tragic death of a driver at West Worthing in Sussex, England highlighted the issue. The Rail Accident Investigation Branch (RAIB) investigation found that the driver had intentionally left the cab of his class 313 unit while waiting for his departure time in a turn-back siding. It is not possible to know with certainty why this was. However, RAIB concluded that the need to urinate was a possible explanation.

It also found evidence that train drivers had often found it necessary to urinate into bottles at this location which were then thrown onto the track. RAIB highlighted the fact that drivers of trains that turned round in this siding had limited access to toilet facilities during the working day. Following the accident, the ORR issued an improvement notice to the train operator which stated that it had ‘failed to provide adequate welfare facilities and arrangements for drivers and conductors’.

Inclusive signals?

It’s easy to overlook another factor linked to toilet provision. We all want to attract and retain a diverse workforce but to do this people need to be comfortable in their work environment and feel they are an equal and valued member of the team. How is this possible when faced with a choice between peeing in the bushes or a smelly and filthy portaloo? What message are we sending to a new colleague when it’s obvious the management doesn’t really care, or hasn’t even thought about the basic human needs of its team?

It’s time to more fully recognise that the ease of access to decent welfare facilities can make all the difference to the quality of people’s work experience. RSSB’s research shows that this is particularly valued by many female colleagues, who may well be working as part of a workforce that is predominantly male. We also have an obligation to make reasonable adjustments for people who might have medical conditions that may necessitate more toilet breaks.

Law and guidance

There are a number of UK regulations that require suitable and sufficient toilet provision at work sites. These include the Workplace (Health, Safety and Welfare) Regulations 1992 and the Construction (Design and Management) Regulations 2015. These are reinforced by Britain’s Health and Safety Executive (HSE) guidance which states that:

In the past, Her Majesty’s Railway Inspectorate (HMRI) and HSE issued guidance on the provision of welfare facilities at transient railway infrastructure maintenance and renewals sites (Railway Information Sheet No 1). Although this guide has since been withdrawn, it provided a useful benchmark for assessing the adequacy of such provision. It suggested that if work at any given site is to exceed four hours, toilets should be provided within 10 minutes of the place of work.

Network Rail standard NR/L2/OHS/CP0036 covers the provision of welfare facilities for temporary and transient work activities and explains how the legal requirements should be delivered at such locations.

Finding solutions

Of course, providing toilet facilities is not always that easy to do. There is limited space available for a toilet cubicle inside a UK freight locomotive and consequently they are not specified by prospective owners. It is also the case that limited road access can sometimes make it difficult to provide toilets at some worksites. Then there’s the issue of emptying loos, replenishing them with water and cleaning.

These things really matter. If there’s one thing worse than no loo, it’s a disgusting loo. However, many of the practical problems can be addressed if there’s a real will to do so. The RSSB report highlights a range of potential solutions. Things are moving on and there is a range of high-quality portable units and welfare vehicles on the market that goes a long way to addressing the issues.

A good place to start is for senior managers and leaders to properly assess the adequacy of toilet facilities. We suggest they should:

• focus attention on the basic welfare provision, and be seen to do so – you may be shocked by what you discover, but also surprised at the positive vibes created by being seen to care
• treat any poor access to toilets as a significant risk that must be managed – it’s not a side issue but one that is essential to people’s health, safety and well-being
• ask: could there be scope to cooperate with other companies or find other solutions?
• be sure to make the link between welfare provision and how to encourage a diverse workforce to stay in the rail sector, long into the future.

Resources

• *Guidance on the provision of employee toilet facilities on Great Britain’s railways, Rail Safety and Standards Board (RSSB), March 2022
• Toilets at work – a report on workers’ experience of toilet access and facilities, Trades Union Congress (TUC), November 2024