Portable Sanitation Association International

PSAI COVID-19 Guidelines for Portable Sanitation

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11 COVID-19 GUIDELINES FOR PORTABLE SANITATION © Copyright 2020 by the PSAI. All rights reserved. Sources 1 See, for example, Part 1910.141 – OSHA Standards, General Environmental Controls, Sanitation, Part 1910.142 – OSHA Standards, General Environmental Controls, Temporary Labor Camps , and Part 1928.110 – OSHA Standards, General Environmental Controls, Field Sanitation among others at https://osha.gov, as well as ANSI/PSAI Z4.3-2016 Sanitation - Nonsewered Waste-Disposal Systems – Minimum Requirements at https://ansi.org. 2 See https://www.cdc.gov/coronavirus/2019-ncov/community/organizations/construction-workers.html 3 See https://www.osha.gov/laws-regs/oshact/section5-duties 4 This twice a week minimum standard is required by state-level OSHA requirements and is also supported by the Association of General Contractors (AGC) in some areas (see https://osha.oregon.gov/covid19/Pages/covid-19-contractors.aspx and https://www.agc.org/sites/default/files/Files/Safety%20%26%20Health/COVID%2019%20job-site%20practices.pdf for example). In other areas, AGC does not specify frequency beyond saying contractors should "request additional/ increased sanitation" of portable restrooms over pre-COVID-19 levels (see, for example, https://www.agcwi.org/covid-19.html). Regardless, both CDC and OSHA are clear that more frequent cleaning of toilets is required than usual. Thus the prior once a week standard must be increased to at least twice a week to meet the spirit of the CDC/OSHA guidance. 5 See https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2-covid-19 6 See https://www.osha.gov/Publications/OSHA3990.pdf 7 Enigma Research 2020 Return to Live Events Survey https://www.fairsandexpos.com/files/galleries/ReturnToLiveEventsSurvey.pdf 8 See CDC's guidance on mass gatherings at https://www.cdc.gov/coronavirus/2019-ncov/downloads/Mass- Gatherings-Document_FINAL.pdf and https://www.cdc.gov/coronavirus/2019-ncov/community/large-events/ considerations-for-events-gatherings.html 9 See PSAI resources at https://psai.org/renting-portable-units/ 10 See https://www.osha.gov/laws-regs/regulations/standardnumber/1928/1928.110 and https://www.govinfo.gov/content/pkg/ CFR-2019-title40-vol26/xml/CFR-2019-title40-vol26-sec170-411.xml 11 See ANSI/PSAI Z4.3-2016 American National Standard for Sanitation-Fields and Temporary Labor Camps – Minimum Requirements at https://ansi.org. 12 See CDC guidance at https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-agricultural-workers. html?deliveryName=USCDC_2082-DM30458#cleaning 13 See PSAI Good Agricultural Practices related to portable sanitation https://psai.org/wp-content/uploads/2020/06/GAP- updated-6-2020.pdf 14 Both CDC and OSHA are clear that more frequent cleaning of toilets is required than usual. Thus the prior once a week standard must be increased to at least twice a week to meet the spirit of the CDC/OSHA guidance. 15 See https://www.epa.gov/pesticide-registration/list-n-disinfectants-use-against-sars-cov-2-covid-19 2626 E. 82nd Street, Suite 175 · Bloomington, Minnesota 55425 · 952.854.8300 · psai.org

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