Portable Sanitation Association International

Association Insight July 26 2017

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W EEKLY EDITION JULY 26, 2017 CONTINUE D ON PAGE 4 PAGE 3 Question of the Week: What is OSHA's definition of "sanitary"? ...continued By Karleen Kos, PSAI Executive Director In an earlier 2003 Mine Safety and Health Administration (MSHA) opinion published when the Department of Labor issued its final standards for sanitary toilets in coal mines, government officials had also referenced ANSI Z4.3 - 1995. The fact that multiple go vernment sources cite this standard gives its contents legitimacy and provides an excellent point of reference. As you may infer from the document number, ANSI Z4.3 - 1995 was published in 1995 , reaffirming text from 1987. The text does not specifically d efine 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 requ ire 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 toi let 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 keeping portable restrooms in "sanitary conditi on" as per OSHA and MSHA requirements: • The number of restrooms provided must minimally meet OSHA's 1:20 rule • If servicing occurs at least twice a week under these conditions, the OSHA standard for "sanitary condition" will likely be met. • If servicing will occur only weekly, units should be provided on the ANSI - standard basis of 1 unit per 10 workers. • A unit that is too full or otherwise too unkempt to use does not "count" toward the required number of units. With this in mind, it would benefit portable re stroom operators to use decals such as the PSAI's 1:10 work site stickers to ensure you are visibly stating the capacity of the units. You can also use the above information to help you in sales and quality control conversations with contractors and other employers.

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