W EEKLY EDITION JULY 26, 2017
Question of the Week:
What is OSHA's definition of "sanitary"? ...continued
By Karleen Kos, PSAI Executive Director
Our response: The US Occupational Safety and Health Administration has several standards that touch
on requirements for portable restrooms and hand washing stations. These include:
• 29CFR 1910.141 General Environmental Controls - Sanitation
• 29CFR 1910.142 General Environmental Controls - Temporary Labor Camps
• 29CFR 1915.88 Occupational Safety and Health Standards for Shipyard Employment - Sanitation
• 29CFR 1917.127 Marine Terminals - Terminal Facilities - Sanitation
• 29CFR 1918.95 Safety and Health Regulations for Longshorin g - General Working Conditions -
Sanitation
• 29CFR 1926.51 Occupational Safety and Health Standards for Construction - Sanitation
• 29CFR 1928.110 Occupational Safety and Health Standards for Agriculture - Field Sanitation
• 30CFR 75.1712 Mine Safety and Health Standar ds for Underground Sanitary Facilities - Bathhouses
and Toilet Facilities
While they all 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 OSHA means by the
term "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 con struction 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 woul d 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.
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