National Assembly for Wales / Cynulliad Cenedlaethol Cymru
Health and Social Care Committee / Y Pwyllgor Iechyd a Gofal Cymdeithasol


Public Health (Wales) Bill / Bil Iechyd y Cyhoedd (Cymru)


Evidence from One Voice Wales – PHB 63 / Tystiolaeth gan Un Llais Cymru – PHB 63


Public Health (Wales) Bill


Part 6: Provision of Toilets:


Questions listed in the consultation document for Part 6:


- What are your views on the proposal that each local authority in Wales will be under a duty to prepare and publish a local toilets strategy for its area?


One Voice Wales agrees with the need for local authorities to prepare local toilet strategies. Each authority will have its own particular range of needs and priorities, although there is a question over the continued relevance of such a local strategy once the imminent local government reorganisation exercise results in changed regions and boundaries. But, basically, the principle of requiring a well thought through strategy, towards which members of local communities have been encouraged to contribute, is a sound and positive philosophy.


- Do you believe that preparing a local toilet strategy will ultimately lead to improved provision of public toilets?


Yes – hopefully, although much will depend upon the overall level of public funding resources that will be available in the future. “Improved provision” will depend upon “quality” as well as “quantity” in terms of toilet provision, and future public sector budgets will have an important part to play in this agenda. One Voice Wales questions the way in which the four basic options have been considered during the early stages of developing this Bill. The “do nothing” option is agreed to be unsatisfactory, but there are some merits to the other three options and One Voice Wales wonders whether the preferred option of requiring local strategies (only) will in itself provide sufficient momentum to generate the improvements desired. There was much merit in the former Public Facilities Grant scheme, and One Voice Wales has called for its reintroduction in order to help tackle the lack of public conveniences in many areas of Wales. Furthermore, the option of imposing a duty on local authorities to carry out a full implementation of their new strategies would surely give members of the public more confidence that the public engagement exercises leading to the formation of these strategies were indeed meaningful. Therefore, One Voice Wales would ask the Welsh Government to think again about the preferred option (which is in general supported) as to whether there might be room for manoeuvre in terms of more strict guidelines over the availability of funding for partnership initiatives (in line with the former Public Facilities Grant scheme) and, again, in terms of giving local authorities a stronger message with regard to the need to put their strategies into full implementation.


- Do you believe the provision in the Bill to ensure appropriate engagement with communities is sufficient to guarantee the views of local people are taken into account in the development of local toilet strategies?


One Voice Wales calls on the Welsh Government to ensure that any such consultation exercise introduced in order to facilitate engagement with stakeholders would be robust and wide enough to provide confidence that all appropriate voices will be heard. The current thinking for the Bill is that there should not be a prescribed format for the consultation process, but this aspect could well be strengthened via guidance, as mentioned in the response to the next question. It is considered absolutely essential that local community and town councils should need to be formally engaged as a part of this process, and that their voices should be heard as well as being encouraged to consider potential solutions in areas with critical needs. Many local councils have already taken on public toilet provisions that were traditionally within the domain of unitary authorities. The fact that the latter authorities are struggling financially (hence, leading to these transfers) should signal a cautionary note to the Welsh Government as it faces up to this particular agenda of ensuring adequate public toilet provision across Wales.


- Do you have any views on whether the Welsh Ministers’ ability to issue guidance on the development of strategies would lead to a more consistent approach across local authorities?


The issuing of Welsh Ministers’ guidance could well prove useful in the drive for consistency across Wales in this matter. The guidance would need to take into account all reasonable aspects of the challenge, including how local authorities should have to liaise with community and town councils within their borders when considering the details of the strategy. Such guidance would also be potentially useful in driving a stronger implementation regime, as mentioned in the answer to the second question above.


- What are your views on considering toilet facilities within settings in receipt of public funding when developing local strategies?


One Voice Wales would support any sensible arrangements for making public toilets available and these could include housing the facilities within different types of settings, such as public buildings, private enterprises and so on.


- Do you believe including changing facilities for babies and for disabled people within the term ‘toilets’ is sufficient to ensure that the needs of all groups are taken into account in the development of local toilet strategies?


Yes – provided that all other equalities aspects are incorporated within the guidelines for the local strategies, such as any specific needs, use of bilingual signage and so on.


- Do you believe the proposals relating to toilet provision in the Bill will contribute to improving public health in Wales?


Yes – along the lines outlined in the explanatory memorandum.


Dr. Del Morgan

Swyddog Datblygu/Development Officer

Un Llais Cymru/One Voice Wales