CDM Topic: SANITARY DISPOSAL - Little talked about, big problem, big stigma. Period.

“We don’t ever have women on site” “Yet here I am!”

From my many years of visiting construction sites, sadly this is one area of compliance in which I've seen little change. Don’t get me wrong, the ‘big’ projects are often lovely, even providing free feminine hygiene products regularly now, but it isn’t the norm. I can understand why those who only work on larger scale construction sites would perhaps be led to believe it is the norm, but sadly it is reserved for the larger Principal Contractors of the world, and there’s an abundance of construction contractors out there that are not at that level.

But whilst many now excel in providing better break out areas, lockers, drying rooms and means of washing hands, arms and face with drying facilities, this is one area that has struggled to catch up. Many companies are simply not aware of the requirement to provide sanitary disposal on construction sites and, even for those companies that are aware, they can be met with supply issues or simply don’t feel there is enough of a need or demand to warrant taking action.

Longer term, or larger sites appear to be faced with less problems granted, but for those smaller few weeks to 6 month projects where maybe only 1 bin is needed, I've seen the frustration my clients face. Disposal companies won’t supply. They want a contract which far outlives the supply need, or the cost for such a short timeframe is disproportionate.

Now, I'm not fussy. I've been to sites where I've had to hold the door shut with a leg which means I can barely stay on the loo (on a busy A road through Bristol), had to wee whilst Henry is watching (the hoover), had spare timber and PPE to perch over/on for with my knees up round my earholes because it is the only  'trap' in usable condition I'm told (where have the men been going? Wait, don’t answer that…).

But to have to change a pad or tampon and with no Sanitary disposal bin, wrap in tissue and carry it round in your pocket until you get home, I can assure you is not a nice experience. “Just go back out, smile and pretend, there’s a job to get done” you tell yourself. Add to this those occasions where there may be loo roll supply issues or the tap isn't plumbed in... well, they aren’t nice days either let me tell you. Surely we should just carry around an emergency kit of spares for everything that should already be provided?

It is obviously not just me. I see many women in construction cross my path now (one thing that is changing luckily!) and it is most certainly an issue that many women in construction are facing, sometimes silently because they will be met with the 'are you sure we have to do that, I've never heard that before' scenario, which can still commonly exist. One woman on one occasion doesn’t seem enough to warrant providing a loo, and sufficient, legally required provisions so that she can go about her job without the worry of the scenarios above. It’s not worth it, too costly, and it’ll likely never happen anyway, women still don’t frequent construction sites that often... Do they?

Whilst it is not necessary to have separate male and female toilets on site as long as the cubicles can be individually locked, that’s not normally the issue, it’s having any sort of compliant loo and disposal in the first place.

So what do we do?

These issues are easily avoidable, and I have created a simple check guide for anyone planning or managing a construction site. Often it causes an issue because it hasn't been considered when organising a project before it starts. This results in emergency situations that cost a lot more to get a quick turnaround that could have been avoided with the correct project planning.

• Ensure your planning and purchasing teams are aware of the requirements and order all welfare required items in good time. 

  
  

• Whether you have departments, or if it is just you, ensure you know your regulations for what is required.

  
  

• Don't assume there won't be any women on site. You could have visitors, labour and tradeswomen. We work now too(!). The HSE inspector or council inspector visiting may just well be a woman and I don’t think that would go down well.

  
  

• Make sure you know the suppliers that can provide short term supply and empty. 

  
  

• Incorporate onto site checks so that whoever is responsible for checking ensures this is monitored. 

  
  

Welfare requirements are covered twice, with all workplace requirements being covered in the Workplace (Health, Safety and Welfare) Regulations 1992, and then Construction Specific being noted also in the Construction (Design & Management) Regulations 2015 (Schedule 2).

Schedule 2 makes the requirement for sanitary disposal provisions absolute. It is not ‘so far as is reasonably practicable’ meaning you must do it. Then, adequate ventilation and lighting and being kept clean and orderly ARE so far as is reasonably practicable.

Who is Responsible for providing welfare on site?

For Commercial projects, with only 1 contractor - the contractor must provide suitable and sufficient welfare, but the Client also have a duty for ensuring they have done this.

For Commercial projects more than 1 contractor, a Principal Contractor must be appointed. The Principal Contractor (PC) must provide suitable and sufficient welfare, but the Client also have a duty for ensuring they have done this.

For Domestic sector works, the PC, Contractor or Principal Designer (by arrangement) takes on the Client duties.

How do I know if I am a Principal Contractor?

For projects with more than 1 Contractor, there should be a Principal Contractor appointed in writing. This sometimes doesn't happen because the Client having building works done may not be familiar with the requirements. For this reason, under CDM 2015 the Principal Contractor is responsible for ensuring the client is aware of its duties.

This means you should have enough of an understanding of the regulations to know when you may or may not be the PC (and it should be known long before getting to site).

If you do not have another Contractor to report to, sign in with, have an induction from etc. then it is likely there has not been one appointed, or this is you. You should ask the Client to confirm who the Principal Contractor is as this role carries specific duties for the management of site.

The key point here is that this is something that should have been determined way before works started and as part of your dialogue with the Client when you are planning to attend, you should ask at that stage who the Principal Contractor is for the project, or for them to confirm you are the only contractor.

If you are the only contractor then you must provide your own welfare. If you use sub contractors you are responsible for all duties under the Principal Contractor role and need to comply with the planning, management and coordination of the site.

If you need any further assistance in construction site management, feel free to get in touch.

Written by: Hayley Tollervey