Building Approval for Factory Projects
Chapter 8 of 10 · 10 min read
Sanitary facilities and access for people with a disability
Count toilets, urinals and basins with the NCC tables, see how a documented workforce figure changes the answer, and plan accessible facilities and access to the mezzanine.
Toilets and basins are the part of the building code that every owner understands and almost every owner underestimates. The tables are simple. The difficulty is the input: how many people are you designing for, and who decides? The answer changes the fixture count by a factor of three or four in the running case.
This chapter counts sanitary facilities for the office and workshop under Part F4 of NCC 2022 Volume One, adds the accessible facilities, and then looks at the wider access requirements in Part D4, including the awkward question of a storage mezzanine.
Where the occupant number comes from
F4D3 sets the basis for the count. The number of occupants is taken from D2D18, the same table used for exits in Chapter 5, if it cannot be determined more accurately by other means. Unless the premises are used predominantly by one sex, the facilities are based on equal numbers of males and females. A unisex facility for people with a disability, other than one provided under F4D12, counts once for each sex. A unisex facility is one closet pan, one washbasin and a means of disposal of sanitary products.
“If it cannot be determined more accurately” is the key phrase. For exits, the table number protects future occupants, so owners rarely argue with it. For toilets, the number of workers is something an employer usually knows, and a documented figure is commonly accepted. The figure must be credible and recorded, because it will appear in the approval and it limits what the building can later be used for without more fixtures.
The tables for offices and factories
F4D4 requires separate facilities for males and females in Class 3 and 5 to 9 buildings, with exceptions. One exception, in F4D4(3), allows a unisex facility to be used instead where not more than 10 people are employed. Female facilities need a means of disposal of sanitary products, and at least one washbasin is required wherever closet pans or urinals are provided.
The number of fixtures comes from tables. Table F4D4a covers Class 3, 5, 6 and 9 buildings other than schools; Table F4D4b covers Class 7 and 8 buildings. For employees, they differ only in the washbasins.
The tables say “1 more per 20” and similar. Where the number of people beyond a band is not an exact multiple, read the increments the way the certifier does, and record it. This chapter uses the cautious reading that any part of a further increment adds a fixture, and says so wherever it matters.
The running case: an inherited toilet
This is an illustration. The building came with one unisex toilet and basin beside the old warehouse office. The previous owner had employed fewer than ten people, so a single unisex facility was enough under the exception in F4D4(3). The new owner’s first plan was to keep it and add a second unisex toilet in the office.
The certifier’s first question was “how many people will you employ?”. The answer, 42, ends the unisex exception at once: it applies only where not more than 10 people are employed. The new use needs separate male and female facilities. This was detected at the first meeting because the certifier asked for the input before looking at the drawings, which is the order every sanitary check should follow.
Counting from the documented workforce
The owner documented the maximum number of people on site at any one time: 30 in the workshop on the busiest shift and 12 in the office. The workforce is mixed, so the count uses equal numbers.
Workshop, Class 8, Table F4D4b: 30 people, so 15 males and 15 females.
- Male closet pans: 15 is within 1 to 20, so 1.
- Urinals: 15 is within 11 to 25, so 1.
- Male washbasins: 15 is within 1 to 20, so 1.
- Female closet pans: 15 is within 1 to 15, so 1.
- Female washbasins: 15 is within 1 to 20, so 1.
Office, Class 5, Table F4D4a: 12 people, so 6 males and 6 females.
- Male closet pans 1, urinals none (6 is within 1 to 10), male washbasins 1.
- Female closet pans 1, female washbasins 1.
Because the fire wall separates the office and workshop, each has its own bank of toilets, so staff do not need to pass through a fire door to reach one.
The “predominantly one sex” temptation
F4D3(2) bases the count on equal numbers of males and females unless the premises are used predominantly by one sex. In a machine shop with a mostly male workforce, it is tempting to argue for a male-weighted count and fewer female facilities. The running case’s owner raised it and then dropped it, for three reasons.
First, the saving is small. At 30 people, an equal split already needs only one female closet pan and one female basin; a male-weighted split would add urinals and male fixtures while removing almost nothing. Second, it builds a hiring constraint into the building: a workforce that becomes more balanced would need more fixtures, possibly in a layout with no room for them. Third, it invites an argument with the certifier about what “predominantly” means, for no real gain. Equal numbers keep the design simple and future-proof, which is usually worth more than one fixture.
The building code is not the only rule about amenities
The NCC sets the minimum facilities a building must contain. Work health and safety law sets what an employer must provide for workers, and Safe Work Australia’s model code of practice on managing the work environment and facilities gives guidance on toilets, washing facilities, change rooms, drinking water and eating areas. Those requirements can go further than the building code, particularly for dirty work, where workers may need showers and change rooms. A machine shop using coolants and a fabrication area producing grinding dust are both candidates.
The running case added a shower and lockers to the workshop amenities for that reason. The building code did not require them; the owner’s WHS assessment did. Designing them in during the fit-out cost far less than adding them later, when the amenities block would already have been built around the minimum.
Getting the layout right
Fixture counts are only half of the sanitary design. Common layout faults in industrial fit-outs include toilet doors opening directly onto a production floor or forklift route, accessible compartments placed where the approach is cluttered with trolleys, and amenities located so that workers must cross a hazardous area to reach them. The workshop bank in the running case opens off the west end of the workshop, beside exit P3, away from the forklift routes and with a clear approach for the accessible compartment. The detailed dimensions of accessible and ambulant compartments come from AS 1428.1, as called up by the NCC, and the designer worked from that standard rather than from a supplier’s typical layout.
What the table numbers would have required
If the owner had not documented a workforce, the count would fall back to D2D18. The workshop’s 144 persons from Chapter 5 would mean 72 males and 72 females. Using the cautious reading of the increments:
- Male closet pans: 1 for the first 20, plus 52 more people in three part-increments of 20: 4.
- Urinals: 2 for 26 to 50, plus 22 more people, one part-increment of 50: 3.
- Male washbasins: 1 plus three part-increments of 20: 4.
- Female closet pans: 1 for the first 15, plus 57 more people in four part-increments of 15: 5.
- Female washbasins: 4.
The difference is fifteen fixtures, with the floor space, plumbing and cleaning that go with them. It shows why the occupant basis is the most important decision in this chapter, and why it must be recorded. If the workshop later runs two overlapping shifts or adds staff beyond 30, the fixture count must be revisited.
Accessible sanitary facilities
Where a building must be accessible, F4D5 and F4D6 add accessible facilities. In outline, for Class 5 to 9 buildings:
- Where F4D4 requires closet pans, at least one accessible unisex sanitary compartment is required on every storey that contains sanitary compartments. Where a storey has more than one bank of male and female compartments, at least 50% of those banks need one (F4D6).
- At each bank of toilets, other than an accessible unisex compartment, there must be at least one ambulant compartment for males and one for females (F4D5(3)).
- An accessible unisex compartment contains a closet pan, a washbasin, a shelf or bench top and a means of disposal of sanitary products, and must be entered without passing through an area reserved for one sex. Circulation spaces, fixtures and fittings comply with AS 1428.1 (F4D5).
The running case has two banks on its one storey, so at least one accessible unisex compartment is required. Because the fire wall separates the banks, the owner provides one in each, so that nobody has to pass through a fire door to reach an accessible toilet. Each bank’s male and female toilets are built as ambulant compartments. Under F4D3(3), each accessible unisex compartment can count once for each sex in the totals, which the certifier may take into account when checking the fixture numbers.
Access to and within the building
Part D4 sets the wider access requirements. Under D4D2(6), Class 5, 6, 7b, 8 and 9a buildings must provide access to and within all areas normally used by the occupants. Under D4D3, an accessway is required from the main points of pedestrian entry at the allotment boundary, from any accessible carparking on the allotment, and from any connected accessible building. D4D5 exempts areas where access would be inappropriate because of the particular purpose for which they are used, areas that would pose a health or safety risk for people with a disability, and any path of travel that serves only such areas.
For the running case, that means an accessway from the street entrance and the accessible carpark to the office entrance, and access to and within the office and the workshop’s normally used areas, including the workshop amenities. Machine-specific operator platforms and the compressor room are typical candidates for the D4D5 exemptions, and the certifier decides each case.
Access is easy to lose in the details. A 20 mm step at a door threshold, a heavy door with a strong closer, a ramp that is slightly too steep or a carpark space without the required shared zone can each defeat an otherwise accessible route. AS 1428.1 sets the details, and the cheapest time to get them right is on the drawings, before slab levels and door hardware are fixed. The running case’s designer walked the route from the street to the accessible toilet on the drawings, step by step, and listed every door, level change and surface along it.
The mezzanine question
The storage mezzanine is the hard case. It is reached by a stair, and providing a lift or ramp would cost more than the mezzanine. Does D4D2(6) require access to it?
The owner’s designer put a written case to the certifier: the mezzanine holds heavy tooling and fixtures loaded by forklift through a gate in the barrier, and is visited by stores staff handling those items, with risks the designer described. The certifier’s decision, with its reasons, became part of the approval record. If the mezzanine were ever converted to an office or training room, as Chapter 6’s exercise contemplates, the access question would return in a much stronger form, because offices are areas normally used by occupants.
Exercise: the workshop grows to 40
The owner expects the busiest workshop shift to grow to 40 people. What does Table F4D4b require, using the cautious reading of the increments?
Worked answer. Forty people means 20 males and 20 females.
- Male closet pans: 20 is within 1 to 20, so 1.
- Urinals: 20 is within 11 to 25, so 1.
- Male washbasins: 20 is within 1 to 20, so 1.
- Female closet pans: 20 is over 15, so 1 plus one part-increment of 15 for the 5 extra people: 2.
- Female washbasins: 20 is within 1 to 20, so 1.
The only change is a second female closet pan. If the certifier reads the increments as whole increments only, 5 extra people would not add one, so this is exactly the kind of point to settle in writing. The owner should also update the documented workforce figure in the approval record, because the approval was given on the basis of 30.