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80 2019 INDUSTRY RESOURCE DIRECTORY The short answer to this question is "it depends." The right answer in one situation is not necessarily the best answer for another; the unique circumstances of each event or location will carry the day. First, let's look at hand washing with soap and water versus hand sanitizer from a purely scientific point of view. We can probably all agree that providing the means for hand washing is important for promoting public health as well as for bolstering the revenue of portable sanitation companies. The critical issue then is this: can we demonstrate that one or the other of these methods is more likely to have a positive impact on public health? At this point in time, the scientific community does not yet agree on whether hand sanitizer delivers the same results as soap and water. For example the US Centers for Disease Control (CDC) say hand sanitizers don't kill all kinds of germs, and they might not remove other substances from hands that would be detrimental to health. 1 Meanwhile, a study from the National Institutes of Health (NIH) says hand sanitizers are sometimes more effective than soap and water. 2 Because of the absence of scientific consensus—and the sluggish nature of lawmaking in general—whether it is "legal" to use hand sanitizer instead of soap and water varies from circumstance to circumstance and jurisdiction to jurisdiction. In the United States, the US Code of Federal Regulations addressing sanitation on construction sites provides language that is quite specific about requiring hot and cold running water (see for example 29CFR 1926.51(f)(3)(ii) here). This same section does suggest that hand sanitizer could be used in lieu of soap (29CFR 1926.51(f)(3)( iii), but the presences of sanitizer does not eliminate the need for hot and cold running water. Laws for sanitation in agricultural settings are even more precise, and as with all US guidelines, states, counties, and municipalities may require more than the federal minimum. In Canada the laws are set provincially and they vary. Ontario, for example, also specifically requires hot and cold running water while Nova Scotia simply requires some provision for hand washing. Every year the PSAI handles dozens of inquiries from portable restroom operators (PROs), government officials, and members of the public regarding some aspect of our industry. A common question has to do with hand sanitizer. Specifically, PROs want to know whether it is acceptable to substitute hand sanitizer for hand wash stations. Some customers prefer hand sanitizer, and it is certainly less messy at an event site. But is it legal? Case Study: Hand Sanitizer vs Soap and Water 1 www.cdc.gov/handwashing/show-me-the-science-hand-sanitizer.html 2 www.ncbi.nlm.nih.gov/pmc/articles/PMC2813169/ Cleaning Procedures For Portable Sanitation Equipment Better worksites. Better weekends. Better world. EXCLUSIVE MEMBERS-ONLY CONTENT REDACTED Join us now at www.psai.org for access to this valuable information.