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Reference

What the law requires a welfare unit to contain

Twenty four requirements across five duties, from Schedule 2 of the Construction (Design and Management) Regulations 2015, each mapped to the physical thing it asks for in a towable unit.

Welfare units are usually sold by length and by photograph. The duty is written in terms of function, condition and accessibility, so a buyer comparing two units on size has no way to tell whether either of them discharges it.

Paraphrased from the instrument, read 2026-09-05, with every paragraph named so it can be checked rather than believed. It is not legal advice and it is not a substitute for reading Schedule 2.

Sanitary conveniences · Washing facilities · Drinking water · Changing rooms and lockers · Facilities for rest

Who it binds

Three duty holders at once

Schedule 2 is given effect by Regulation 4(2)(b), 13(4)(c) and 15(11). Each of those regulations names a different party, and none of them discharges the others.

Regulation 4(2)(b)The client
Must ensure the facilities required by Schedule 2 are provided in respect of any person carrying out construction work.
Regulation 13(4)(c)The principal contractor
Must ensure facilities that comply with the requirements of Schedule 2 are provided throughout the construction phase.
Regulation 15(11)A contractor
Must ensure, so far as is reasonably practicable, that the requirements of Schedule 2 are complied with so far as they affect that contractor or any worker under that contractor's control.

The five duties

And what each one asks a unit to have

Sanitary conveniences

Paragraph 1
What the instrument requiresWhat that means in a towable unit
Suitable and sufficient, at readily accessible placesPan count follows from the crew and the shift rather than from the length of the unit, and readily accessible is a question about where the unit stands rather than about the unit
Adequately ventilated and lit, so far as reasonably practicableMechanical extraction in the compartment, and lighting on a protected circuit rather than a work light
Kept clean and orderlySurfaces that survive being cleaned quickly and often. This is a specification decision at build, not a cleaning rota
Separate rooms for men and women, unless each convenience is in its own room with a door lockable from insideA single lockable compartment satisfies it. Two shared cubicles behind one door do not

Washing facilities

Paragraph 2
What the instrument requiresWhat that means in a towable unit
Suitable and sufficient, including showers where the work or health reasons require themShowers are conditional on the work rather than optional on price, which is the judgement that decides whether a welfare unit or an ablution unit is the right product
In the immediate vicinity of every sanitary convenience, and in the vicinity of any changing roomLayout, not equipment. A hand wash basin at the far end of the unit from the WC fails this even though both exist
Clean hot and cold, or warm, running water so far as reasonably practicableWater heating sized to the crew, and a heated water supply that is still heated at the end of a shift rather than at the start
Soap or other suitable means of cleaning, and towels or other means of dryingDispensers fitted and specified, not left to the site
Sufficiently ventilated and lit, and kept clean and orderlySame as paragraph 1, and the same specification decisions
Separate facilities for men and women, unless in a lockable single occupancy roomDoes not apply to facilities for washing hands, forearms and face only

Drinking water

Paragraph 3
What the instrument requiresWhat that means in a towable unit
An adequate supply of wholesome drinking water at readily accessible and suitable placesPotable grade tank, pipework and fittings throughout. A unit plumbed with non-potable fittings cannot discharge this duty whatever is put in the tank
Conspicuously marked where necessary for health or safetySignage at the point of supply
A sufficient number of suitable cups or vessels, unless the supply is a drinking jetA jet removes the consumable, which is a specification decision with a running cost behind it

Changing rooms and lockers

Paragraph 4
What the instrument requiresWhat that means in a towable unit
Suitable and sufficient changing rooms where a worker has to wear special clothing and cannot reasonably change elsewhereThis is the duty most often missed, because it is conditional and the condition is common
Separate rooms, or separate use of rooms, for men and women where necessary for proprietyA single changing area used in turn can satisfy it. The arrangement has to be decided rather than assumed
SeatingFixed seating in the changing area, which is a layout constraint before it is a fit out item
Where necessary, facilities to dry special clothing and personal clothing and effectsThe heated drying area. Hanging space, heat and a floor that can be hosed
Suitable and sufficient lockable facilities for special clothing not taken home, own clothing not worn at work, and personal effectsLockers, sized and counted against the crew

Facilities for rest

Paragraph 5
What the instrument requiresWhat that means in a towable unit
Suitable and sufficient rest rooms or rest areas at readily accessible placesThe mess area, and readily accessible again means where the unit stands
An adequate number of tables and adequate seating with backs, for the number likely to use them at any one timeSeating with backs is explicit in the instrument. Bench seating without backs does not discharge it, and the count is the break headcount rather than the site headcount
Where necessary, suitable facilities for a pregnant worker or nursing mother to rest lying downA conditional duty that a fixed bench layout can make impossible to satisfy later
Suitable arrangements to ensure meals can be prepared and eatenPreparation surface, and the power to run what is on it
The means for boiling waterA specified appliance on a calculated circuit rather than a kettle on a socket
Maintained at an appropriate temperatureHeating in the mess area, sized for the season the unit works in

No ratios

The instrument sets no numbers

Schedule 2 says suitable and sufficient. It does not say one WC per seven workers, it does not give a floor area per person, and it does not give a shower ratio. Anybody quoting a ratio as though it came from CDM is quoting something else, or nothing.

What follows from that is uncomfortable for a trade that sells by size. Two units of identical length can sit on opposite sides of the duty, because the duty is about function, condition and accessibility rather than about dimensions. A twelve foot unit with bench seating and no backs fails paragraph 5(2)(a) while a ten foot unit with proper seating passes it.

It also means the assessment is the duty holder's and it cannot be bought. A supplier can tell you what a unit contains. Whether that is suitable and sufficient for your crew, your shift pattern and your site is a judgement the client, the principal contractor and each contractor make, and regulations 4, 13 and 15 put it on all three of them at once.

The table usually quoted

Where the numbers do come from, and why they do not apply here

The usual table is the wrong one on a construction site. The numbers people quote come from the Approved Code of Practice to the Workplace (Health, Safety and Welfare) Regulations 1992, published free by HSE.

Regulation 3(1)(b) of those Regulations excludes a workplace where the only activities being undertaken are building operations or works of engineering construction within section 176 of the Factories Act 1961. So on a site where that is all that is happening, the table below is not the legal requirement. Schedule 2 of CDM 2015 is, and it gives no numbers at all.

That does not make the table useless on a site. It makes it guidance rather than law, and it is a reasonable starting point for what suitable and sufficient looks like. What it is not is something to cite at an inspector as the requirement.

Mixed use, or women only

Number of people at workToiletsWashbasins
1 to 511
6 to 2522
26 to 5033
51 to 7544
76 to 10055

Used by men only

Number of men at workToiletsUrinals
1 to 1511
16 to 3021
31 to 4522
46 to 6032
61 to 7533
76 to 9043
91 to 10044

The number of people at work in column one is the maximum likely to be in the workplace at any one time. Source: HSE, how many toilets should a workplace have, reproduced under the Open Government Licence v3.0. The underlying source is L24, Workplace health, safety and welfare, approved code of practice and guidance. The exclusion is at regulation 3 of the Workplace Regulations.

Events

Events, which are a third case again

An event site is neither an ordinary workplace nor a construction site once it is running, and the law splits along a line most organisers do not expect. Crew are at work, so the workplace duties reach them. The public are not, so they do not.

Regulation 3(2) of the Workplace Regulations is the relevant part. At a temporary work site, the requirements in regulations 20 to 25, which are the welfare ones, apply so far as is reasonably practicable rather than absolutely. An event build is a temporary work site.

For the public there is no national number. Provision is a condition of the premises licence and the licensing authority sets it, which is why two comparable festivals in different districts can be held to different figures. The ratios the industry uses come from the Purple Guide, which the Events Industry Forum sells. We are not reproducing it here and neither should anybody quoting it at you for free.

The practical consequence for anybody specifying a unit: ask the licensing authority for its condition before sizing the tanks, because the tanks follow the number and the number is theirs to set.

HSE on welfare for event employees.

Using this

It is free, and attribution is the only ask

Quote it, reproduce a row, set it as reading, or hand it to a site team. If it is useful in a trade publication, a members' bulletin or a toolbox talk, take it and say where it came from.

If a row is wrong, tell us and it is corrected. Corrections are dated and published on the corrections page with what changed, rather than edited away quietly.

Citing this

MODUWRIGHT. "What the law requires a welfare unit to contain." Read 2026-09-05. http://127.0.0.1:8812/welfare-facilities-cdm

Free to quote, reproduce or set as reading, in whole or in part, on one condition: name the source and link to it. If a row is wrong, tell us and it is corrected.

Set this as an exercise

Construction management, occupational safety, quantity surveying
  1. Schedule 2 is given effect by regulations 4(2)(b), 13(4)(c) and 15(11), each naming a different party. Explain why none of the three discharges the others, and who is liable when a unit on site is inadequate.
  2. Schedule 2 states no ratios: no number of closets per worker and no washbasins per shift. Given that, explain what a principal contractor actually uses to decide how many, and what they would produce if challenged.
  3. Welfare units are usually sold by length and by photograph. Write the three questions a buyer should ask instead, each one traceable to a paragraph of Schedule 2.

Free to set as coursework, print, adapt or put on a slide, on one condition: name the source and link to it. What else is free to teach from.

Related reference: what changed and when, which approval route applies, and what has to exist, and when.