Construction Site Toilets in Memphis and the OSHA Sanitation Standard

What does the federal sanitation rule require?

The OSHA construction sanitation standard requires toilet facilities on a construction site and ties the number to the crew size, so it is the federal baseline for the job.

The construction sanitation standard sits in the federal workplace safety rules, at 29 CFR 1926.51. It requires toilet facilities on construction sites and ties the number of toilets to the number of workers. Those tiers are the part to check against the current text rather than a summary, because the numbers are what a contractor is held to on inspection.

State and local rules can add to the federal baseline, and a project owner or general contractor may set a higher standard in its own specification. The provider's job is to supply the count the site needs and keep the units serviced. The contractor's job is to know the count and hold the plan to it. Both should have the same number on paper.

How does crew size set the count?

The count rises with the crew, and the crew figure should come from the contractor's own schedule rather than a guess.

The standard works on headcount, so the number to bring to the provider is the peak number of people on the site on any day, not the company's total staff. A site with a large crew for three weeks and a small one for the rest needs the plan for the peak, with a clear step-down when the crew shrinks. Ask the contractor for the crew schedule by week.

Put the crew schedule into the booking as a table, not a note. A provider that quotes a count from the company's total headcount, rather than the peak on the site, has not understood the rule.

A crew schedule is most useful when it is reviewed with the contractor once a week. Crews grow when a phase starts and shrink when it finishes, and a plan written at the start of the job is often wrong by the middle of it. Agree a review point, and let the provider adjust the count at the same time as it adjusts the servicing pattern, so the two stay in step.

Remember that subcontractors count too. A site with several trades on it has a peak that is the sum of their crews on any one day, not the largest single trade. Ask the general contractor for the combined peak, and not only the figures for its own staff.

Are crew-only units exempt from the accessibility guidance?

Crew-only units on a construction site are generally treated differently from the public units at an event, which is why the two plans are kept separate.

The federal accessibility guidance that applies to events asks for accessible single-user units in clusters. The general reading is that crew-only construction units are exempt from that event guidance. That is a general reading, not a legal opinion. A site with a public-facing element, such as a visitor area or a site tour, should not assume the exemption covers that part.

Keep crew units and any public units on separate plans, with separate counts. ADA accessible portable toilets describes the accessible unit a public area may need, and that unit is quoted apart from the crew count.

Where should units go on a Memphis job site?

Placement follows the work sequence and the access route, and it should move as the site moves.

A downtown renovation, a suburban subdivision and a highway job all have different placement needs. Downtown, the unit needs a closed lane or a lot and a route the truck can use without blocking traffic. In a neighbourhood with older houses, the curb room can be tight enough that the unit has to sit on the work side of a fence. On a highway job the unit moves along the work zone and is set well away from live traffic.

Set the unit where the crew can reach it in a minute from the work area, not where it is easiest for the truck. A unit at the far edge of a lot will be used less, and a site where crews walk far to a unit ends up with a worse problem than a short walk would have caused. Highway and bridge crew restrooms covers the work-zone layouts.

Keep a clear path for the servicing truck and a route for the crew that does not run through the work zone. A unit that is hard to service or hard to reach is a unit that gets used less and cleaned less, which is the worst result for a site. A short planning walk with the foreman, before the unit is placed, prevents most of the problems that show up in the second week.

How often must a site unit be serviced?

Servicing is a schedule that runs as long as the crew is on the site, and it should be agreed in writing before the first unit is delivered.

A working unit is cleaned and pumped on a schedule that depends on use, and a construction site usually has heavier daily use than a weekend event. The provider should state the visit pattern, what each visit includes and what triggers an extra visit. Keep the agreed pattern in the site file so the crew and the contractor both know what to expect.

Ask also how a unit is checked on a busy day. A supervisor who sees a unit that has not been serviced will call the provider; a supervisor who does not know the schedule has no basis to make that call. Portable toilet servicing and pumping describes the visit types.

The servicing plan should also say what happens during a shutdown, such as a holiday break or a weather stoppage. A unit left on a site with no service for two weeks in the heat will be unpleasant when the crew returns. Agree whether the units are serviced before the break, whether they stay in place or are moved, and what the cost line looks like if the stoppage is extended.

What about handwash and water on the site?

Handwash facilities are a separate requirement from the toilets, and they are often left off the plan until a crew asks for them.

Crews working with dust, concrete, paint or wet materials need somewhere to wash before eating and after the work. A handwash station near the work area, with water refilled through the day, is the simplest way to meet that need. It belongs on the plan with the toilets and should have its own line on the booking, so that the crew is not left to wash at a garden hose.

Handwash station rental covers the options. In the Memphis heat the water in a station warms quickly, and a shaded placement helps the crew use the station rather than skip it.

What does a highway or bridge job change?

A highway or bridge crew moves along the work zone, and the restroom plan has to move with it.

Large state highway projects have been reported across the Memphis area, and a regional road plan is one of the sources of construction work here. This guide names no project and no figure. What matters for the plan is the pattern: a crew that moves along a corridor needs units that can be relocated on a schedule, and the relocation should be booked as a service, not improvised.

Work-zone placement is also a safety question. Units set within reach of live traffic need protection that a quiet site does not. Ask the contractor's traffic plan before placing units, and keep them outside the closed lane and the work zone's buffer.

What should the booking say?

The booking should name the peak crew, the phases, the access, the servicing pattern, the handwash plan and the relocation terms, and the figure is confirmed before work starts.

Write the crew schedule in weeks, with the peak count and the phases. Add the site map, the access route and the work-zone plan if there is one. Name the servicing visits and the trigger for an extra visit. Include the handwash stations and any relocation terms.

The price is confirmed with a technician against that information before work starts, and no figure on this page is a quote. Call (888) 351-0294 with the crew schedule and the site map, and the technician sets out the plan.

A good booking is one the foreman can read without a call. It should say how many units are on the site, where each one sits on the site map, when each one is serviced and who to call if one needs attention. That record protects the contractor on inspection and protects the provider when a crew asks why a unit was moved.