Simplifying NCC Requirements
Inclusive Sanitary Facilities in Community Buildings
NCC 2022, Volume One
Area of NCC Requirements:
- Section F – Health & Amenity
- Part F4 – Sanitary & Other Facilities
- F4P1 – Personal Hygiene Facilities
The Challenge
Community and assembly buildings often serve a wide and diverse user base, with occupant numbers and demographics changing significantly depending on the event or time of use. In this project, alterations were proposed to sanitary facilities serving a multi-use hall within a Class 9b building.
The design intent was to move away from traditional gender-segregated toilet facilities. However, the NCC’s Deemed-to-Satisfy (DTS) provisions assume separate male and female amenities in most Class 9 buildings. As a result, the proposal did not align with the prescriptive pathway, raising questions around compliance, privacy, accessibility, and equitable access for all occupants.
Without a performance-based justification, the design risked rejection despite its alignment with contemporary expectations for inclusive and universally accessible facilities.
What This Really Means
The NCC’s sanitary provisions are focused on outcomes, not labels. Facilities must support hygiene, privacy, safety, and accessibility in a manner appropriate to the building’s function, occupant numbers, and user needs.
Where DTS provisions do not accommodate evolving design approaches—such as inclusive or all-gender facilities—the NCC allows performance solutions to demonstrate that the same (or better) outcomes are achieved in practice.
The Solution
A performance-based assessment was undertaken to evaluate whether the proposed sanitary facilities achieved the intent of the NCC’s health and amenity requirements.
The assessment considered:
- How privacy and dignity are maintained for all users
- Whether facilities are provided equitably, regardless of gender or ability
- How the layout supports safe circulation and appropriate supervision
- The suitability of the facilities for varying occupant loads and event-based use
- Alignment with accessibility principles and relevant Australian Standards
- Whether the overall user experience is equivalent to, or better than, a traditional DTS arrangement
Rather than relying solely on gender separation, the assessment focused on how the facilities function for real users in a community setting.
Why This Matters
The final report confirmed that the proposed sanitary facilities satisfy the relevant NCC performance requirements for personal hygiene facilities. Despite departing from DTS provisions, the design was shown to deliver safe, dignified, and inclusive outcomes appropriate to the building’s use and occupant profile.
This project demonstrates how performance solutions enable community buildings to adopt inclusive design principles while maintaining full regulatory compliance—supporting both social outcomes and approval certainty.
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