School Toilets – Best Practice Guidance for Primary and
Secondary Schools in Wales
Consultation on Draft Guidance document
Consultation
Response Form
Your name: Sarah Thomas
Organisation (if applicable): Children in Wales
e-mail/telephone number:
[email protected] 029 20342434
Your address:25 Windsor Place, CARDIFF. CF10 3BZ
Guidance for Current and Continuous Good Standards
Question 1
Do you agree that the guidance sets out best practice
for school toilets in primary and secondary schools?
YES
NO

Any comments
The long awaited guidance sets out useful best practice, however, there are a
few points that need to be more specific or strengthened.
School Toilet Policy pg 6
 The policy should be approved by governors, communicated to the
whole school and reviewed ANNUALLY with the participation of pupils
 Additionally , should be reviewed by representative of the Healthy
Schools Network
Access, Security and Supervision pg 8
CCTV – strongly disagree that the use of this should fall under ‘best practice’.
Using this as a last resort suggests a failing on the part of the school to
implement an effective toilets policy. If there is a need to refer to the use of
CCTV then it would be better placed in the main body of this section, with the
added comment that cameras should be placed outside the toilet block
doorway in order to observe who is entering and exiting the block and not
inside the main toilet area.
Structural Issues pg 9
‘Most pupils toilets need cleaning twice a day’ – who will do this as presently
most school cleaners come in at the end of the day?
Toilet Facilities pg 12/13
 Toilet paper – needs to be accessible for small children, often
commercial sized supplies can be difficult for small children to manage.
Washbasins, Water and Hand Hygiene pg 15
 Again, consideration must be given to height of the child.
 The body of the text states ‘it is best to use liquid soap’, There should
be a directive statement in best practice eg. ‘liquid soap is to be
used.’ Given that ‘bars of soap and towels can spread germs’
Toilet Hygiene pg 18
 Point 1 - Cleaning of toilets at end of each day and during a non-break
time dring the day. Excellent best practice but who will be doing this?
 Point 4 – Frequent hand contact sites cleaned and disinfected
‘regularly’ . How often is regularly? There should be a more explicit
instruction eg. End of each day.
Management and Maintenance pg 20
 Point 3 – Complaints should also be recorded.
 Final point – Good idea to keep on agenda for Governors meetings.
Additionally, reported briefly in the annual report.
 Healthy Schools Network representative should also have a duty to
inspect school policy and implementation.
Example Policy pg 24
Provision of indoor social areas to discourage toilets from being used for such
purposes is a good idea, these areas would still need to be
supervised/monitored by staff.
Question 2
Do you agree the guidance will help inform the school
Governing Bodies and Head Teachers on an audit
process for school toilets?
YES
NO

Any comments
As previously mentioned, Healthy Schools Network Representative should
also be kept informed and has a responsibility to ensure implementation of
school policy. PTA’s, School councils and staff meetings should all have
agenda items for their meetings. In order for issues to be taken forward it
must be clear who has lead responsibility within the school.
Question 3
Do you agree the guidance will encourage pupils to
look after their own health and aid in reducing infection
and the spread of disease?
YES
NO

Any comments
Yes – together with regular PSE classroom sessions.
Question 4
Do you agree the guidance will encourage schools to
seek the participation of pupils, and write a school
toilet policy?
YES
NO

Any comments
Again, keeping school toilets on the agenda for school councils, governors,
PTA’s and staff meeting demonstrates the value and respect placed on the
policy and therefore the pupils.
Question 5
We have asked a number of specific questions. If you have any related issues
which we have not specifically addressed, or suggestions as to anything that
has been missed or could be usefully added to the guidance, please use this
space to advise us:
Please enter here:
Monitoring and auditing is paramount to ensure the success of this guidance.
The Welsh Assembly Government should set dates to monitor impact and
effectiveness of the guidelines, especially in light of the E.coli outbreak of
2005. Continued monitoring and auditing should be undertaken as suggested
by the Health Protection Agency report – A Children’s Environment and
Health Strategy for the UK, section 2 Water, Sanitation and Health, provides
an example of suggested interventions to improve sanitation and access to
water in schools and childcare settings.
... Develop guidance for school inspectors (e.g. Ofsted/Estyn) on minimum
standards for sanitation and access to water in schools and inspect against
these standards.
Add provision and maintenance of toilets to the National Healthy Schools
Programme National Audit Criteria (Healthy Schools 2007) and corresponding
schemes in the devolved countries.
Finally, as an extra incentive, a ‘School Toilet Award’ could be developed with
accompanying website that outlines key points of the guidance and share best
practice from schools across Wales.
Question 6
If you have anecdotal or photographic examples of good practice regard
school toilets in Primary and Secondary Schools you are willing to share
please detail and/or attach to your response.
We would also welcome examples of survey forms, to help promote good
practice.
Please enter here:
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Government staff dealing with the issues which this consultation is about. It
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