Issue link: http://psai.uberflip.com/i/1184096
Cold Weather: Hand Wash Units or Hand Sanitizer? By Karleen Kos, PSAI Executive Director Because there is no scientific consensus—and because lawmaking in general is a sluggish affair—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 uses language that quite specifically requires hot and cold running water (see for example 29CFR 1926.51(f)(3)(ii)). This same section does suggest that hand sanitizer could be used in lieu of soap (29CFR 1926.51(f)(3)(iii)). However, the presence of sanitizer does not eliminate the need for hot and cold running water according to the law. Laws for sanitation in agricultural settings are even more precise. As with all US guidelines, various states, counties, and municipalities may require more than the federal minimum. In Canada the laws are set provincially, and they also vary from place to place. Ontario, for example, specifically requires hot and cold running water while Nova Scotia simply requires some provision for hand washing. There are no federal-level laws in the US or Canada regarding sanitation at events. The US Federal Emergency Management Agency (FEMA) provides non-binding guidance to its local-level event planners that includes language about "hand-washing stations" and "sinks." It does not address the issue of water vs sanitizer. One could not be blamed for inferring that the language implies the need for soap and water, but that is not specifically stated. None of the laws at any level in the US address differing requirements or make allowances for cold weather as far as the PSAI is aware. All that said, the use of hand sanitizers is widespread. Because the portable sanitation industry has found that hand sanitizers simplify many parts of providing service, regardless of the weather—and since there are no federal laws about hand cleansing at events in North America—hand sanitizer stations have proliferated. In addition, many northern providers of portable sanitation on work sites have begun providing hand sanitizer in lieu of the required hot/cold running water as a standard practice, especially during cold weather. WEEKLY EDITION NOVEMBER 13, 2019 PAGE 6 CONTINUED ON PAGE 7