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Report seeks to relieve British railway workers

Ed Hodson, Chair of the IOSH Railway Group, has recently worked with the Rail Safety and Standards Board (RSSB) and the rail industry to produce guidance on improving and providing better staff toilet facilities on the railways

The British billionaire, entrepreneur, world record balloonist and commercial astronaut, Richard Branson, never gave sounder advice: “If you’re embarking around the world in a hot-air balloon, don’t forget the toilet paper.”

It’s one of those sayings that gently convey the message without, thankfully, going into too much detail. However, the reality is that there are few more distressing things than needing to go, but not having the opportunity to do so. Imagine being in this predicament not only when you’re working remotely for long hours, but when that work is driving a train. This how it is for some workers.

I led the technical research for a project with RSSB’s Principal Strategy Implementation Manager, Darryl Hopper and in collaboration with RSSB’s Rail Wellbeing Alliance's (RWA). This culminated in the production and publication of the guidance document, ‘Guidance on the provision of employee toilet facilities on Great Britain’s Railways’.

The Management of Health and Safety at Work Regulations 1999 requires that significant risks be assessed and this includes that the planning of work should take personal needs breaks into consideration. My report, however, shows that such needs are not always met on our railways. There are three areas of ‘significant risk’ caused by a lack of access to toilet facilities for those working on the railways:

Safety risks and consequences

  • Drivers leaving locomotives for emergency relief while it’s not safe to do so
  • Issues of personal security in isolated locations
  • Adverse hot weather and the threat of dehydration from having to limit fluid intake
  • Anxiety and distraction caused by not being able to go to the toilet.


  • Biological – menstrual cycle, pregnancy
  • Managing disability
  • Medical conditions – restricting fluid intake can lead to kidney and urinary tract infections
  • Stress through the loss of personal dignity.

Equality and diversity

  • Railways have an older workforce – we all need to go to the toilet more often as we get older
  • A lack of toilet facilities is made even worse for women during their menstrual cycle.

In researching the report, it became clear that many drivers still have to use a bag or bottle for an emergency ‘comfort’ break. Some admitted to urinating from a cab and others to using the side of the track (in Germany, a train driver was found dead with his trousers open, several hundred metres from the train, after he was thought to have fallen out of the locomotive on opening the door to relieve himself from the train as it travelled at 70mph). A hard hat was used when no other receptacle was available. This kind of ‘making do’ impacts railway workers in a variety of ways:

Emotional and physical (occupational health)

  • Stress and anxiety through a loss of dignity and self-esteem
  • Unnatural eating and drinking practices leading to health issues, including urinary infections and dehydration
  • Exacerbation of existing health conditions.


  • The risk of misjudgement or poor decision making
  • A lack of management support (either direct or indirect) damages morale
  • Loss of focus and concentration.


  • Breaking rules to meet personal needs.

The Office of Rail and Road (ORR) states that, “It is our responsibility to ensure that those responsible make Britain’s railways safe for passengers and provide a safe place for staff to work.” Most rail employers recognise circumstances when the lack of toilet facilities is an issue but work on their organisational culture in this regard is required in some cases. An ageing, mostly male workforce has become used to the lack of provision and learnt to ‘get by’ rather than demand better facilities for all.

Employees should be encouraged to report their concerns over toilet facilities and to use the existing channels to do this – through their line management, safety representatives or the confidential reporting service for transport and infrastructure, CIRAS.

Written policies and procedures won’t solve the problem on their own, but they will at least show that the lack of toilet facilities has been recognised. Organisations need to monitor provision and address observations through an assurance system such as ORR’s Risk Management Maturity Model (RM3), and practical solutions should be sought for the present, medium term and future.

Some innovative solutions have been identified but they need to be shared across the sector. The industry needs to work together more and avoid working in isolation through multi-contractual arrangements in a fragmented infrastructure. Positive collaboration is taking place in RSSB groups like the Rail Wellbeing Alliance, all supporting the “Leading Health and Safety on Britain’s Railway” strategy, and so tapping into the fruits of their labour is essential. More can be done to design-in solutions with suppliers. For example, locomotive manufacturers do not make provision for toilet facilities, unless these are specified.

Workers with additional needs or disabilities must also be considered and reasonable adjustments made, recognising of course that not all disabilities are visible. Provision must be made for all workers in the industry as it promotes equality and diversity no matter how remote they may be working.

Notwithstanding the commercial benefits, the advantages from access to permanent, mobile and on-board toilet facilities cannot be underestimated in a progressive rail industry. Most things are negotiable – the use of a toilet (and remembering the toilet paper) is surely not.

Edward Hodson
Chair, IOSH Railway Group

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Jeremy Waterfield
Content Officer +44 (0)116 257 3632
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