Issue link: http://psai.uberflip.com/i/1175496
W EEKLY EDITION OCTOBER 9, 2019 "Sa ni ta ry" Porta bl e Sa nita ti on By Karleen Kos, PSAI Executive Director …continued from page 2 While all of these standards address the issue of sanitation and/or portable toilets in some manner, none of them actually defines the term "sanitary" within the standard itself. To get a sense of what government a gencies like OSHA and MSHA mean by the ter m "sanitary," we have to dig a little deeper. In an OSHA guidance letter from 2006 the Agency answers a related question. In that instance, an OSHA administrator with expertise in construction explained that a restroom on a construction site that is not sanitary is not considered "available" and therefore cannot be counted toward the OSHA - required minimums. Within the letter, OSHA references the PSAI' s ANSI - compliant standard Z4.3 - 1995 and noted: Under … the OSHA standard, if there were 20 employees, the employer would need to provide at least one toilet. Applying the ANSI [Z4.3] servicing schedule to a situation where one toilet has been provided for 20 employees, an employer that had the toilet serviced twice per week would likely be providing a toilet in a sanitary condition. Similarly, a toilet for 10 employees, if serviced once per week, would likely be provided in a sanitary condition. Similarly , in 2003 when the Department of Labor issued its final standards for sanitary toilets in coal mines, the accompanying supplementary information again referenced ANSI Z4.3 - 1995. As you may infer from the document number, ANSI Z4.3 - 1995 is the 1995 versio n of the standard. It also does not specifically define the term "sanitary," but does state the following: It shall be the responsibility of the employer to insure [sic] that all toilet rooms and facilities are maintained in a clean and sanitary condition . If toilet facilities are of the type that require periodic service, it shall be the responsibility of the employer to provide sufficient toilet facilities and servicing to prevent the stated capacity of those facilities from being exceeded; the employer shall also assure the ready access to the toilet facilities by the required servicing equipment. On the basis of OSHA's guidance and the information in ANSI Z4.3 - 1995, a portable restroom operator can confidently take the following position related to kee ping portable restrooms in "sanitary condition" as per OSHA and MSHA requirements: P AGE 14 CONTINUED ON PAGE 15