OSHA States Prompt Access to Nearby Toilet Facilities Important For Mobile Crews

The question of prompt access to toilet facilities has come up several times recently in SSPC audits of certified contractor job sites. In 2002, OSHA addressed this question in a standard interpretation letter that is posted on its web site. In part, the letter reminds contractors of the number of toilet facilities that should be in place on construction job sites and clarifies the procedures that apply to mobile work crews.
OSHA’s construction sanitation standard [29 CFR 1926.51 Paragraph (c) ] states that 20 or less employees require 1 facility; 20 or more employees require 1 toilet seat and 1 urinal per every 40 workers; and 200 or more employees require 1 toilet seat and 1 urinal per every 50 workers.

This standard, however, is “inapplicable to mobile crews having transportation readily available to nearby toilet facilities” as stated in 29 CRF 1926.51 Paragraph (c) (4). When determining whether paragraph (c) (4) applies to a work crew, employers must evaluate the nature of the site and job functions of the crew. Workers who continually or frequently move from job site to job site on a daily or hourly basis would be considered a mobile crew. Workers who report to a conventional construction project, where they work for more extended periods of time (days, weeks, or longer), would not be considered a “mobile crew” for purposes of the sanitation standard.

The requirements of (c) (4) are inapplicable when a mobile crew has transportation readily available to “nearby” toilet facilities. For purposes of the standard, “nearby” means prompt access equivalent to that provided by the general provision for employees at fixed worksites. Read together, the two provisions make clear that mobile crews must have prompt access to nearby toilet facilities. In general, toilets would be considered nearby if it would take less than 10 minutes to get to them.

Source: OSHA Interpretation Letter;
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24369