Construction Site Sanitation Requirements: OSHA 1926.51

Water that isn't safe to drink, like a tank used for mixing, cleaning or dust control, has to be marked as unsafe for drinking, washing or cooking, and it can't be connected to the drinking water system. On a site with both, the labels are what keep someone from filling a bottle at the wrong spigot.

OSHA's table sets the minimum: one toilet for 20 or fewer workers; for 20 or more, one toilet seat and one urinal per 40 workers; for 200 or more, one toilet seat and one urinal per 50 workers. Under temporary field conditions, there has to be at least one toilet available. Sites without a sewer use chemical toilets, recirculating toilets, combustion toilets or privies where local codes allow. Mobile crews with transportation readily available to nearby toilets are exempt.

OSHA has also said in its interpretations that a toilet in unsanitary condition doesn't count toward the required number, and that toilets have to be close enough to reach without undue delay. That's why service schedules and placement are part of compliance, not extras. On a tower, it's why units go on the upper floors; see High-Rise Porta Potty Rental.

Where a site has food service, it has to follow sound hygienic principles. Most Philadelphia job sites don't run a kitchen, but a large project with a catered lunch area or a food truck that sets up every day brings this section into play, along with the city's own food rules for the vendor.

If a site provides temporary sleeping quarters, they have to be heated, ventilated and lighted. It's rare on city jobs and more common on remote projects, but it's part of the same standard.

Where crews apply paints, coatings, herbicides or insecticides, or work with other substances that could harm them if left on the skin, the employer has to provide adequate washing facilities near the work, equipped so workers can actually remove what's on their hands.

On a Philadelphia job that means concrete, mortar and stucco crews, painters, tapers and anyone working with sealants or treated lumber. Hand sanitizer doesn't take off any of those. A hand wash station by the restrooms and another by the mixing or finishing area covers most residential and small commercial jobs.

Nobody can eat or drink in a toilet room or in an area exposed to toxic materials. On a site with lead paint removal, a contaminated basement or heavy dust, that means a clean spot set aside for lunch, away from the work and the units.

Enclosed workplaces have to be built, equipped and maintained, as far as practicable, to prevent rodents, insects and other vermin. On an old rowhome with an open foundation or a site with food trash left in open bins, it's a real issue. Closed trash containers and regular dumpster swaps help; a dumpster that overflows with lunch trash invites the problem.

Where workers are required to wear protective clothing because of toxic materials, the employer has to provide change rooms with storage for street clothes and separate storage for the protective clothing. Abatement jobs and some coating work fall under this.

Walk the site with this list before the inspector or the owner's rep does.

Most sanitation problems on a construction site aren't about the rule; they're about the site outgrowing the setup. A job starts with one unit for six workers, and three months later twenty-five people from five trades are sharing it. The fixes are simple once someone notices:

On most Philadelphia jobs, several employers share one site: the general contractor and every subcontractor working under it. In practice, the general contractor usually provides the toilets and washing facilities for everyone on the site, and the count is figured from the total headcount of all the trades, not just the general contractor's own crew. When the site plan changes, as a new trade arrives or a phase ends, the count should change with it.

Put the restroom count and the service schedule in the site logistics plan at the start of the job, and revisit it at each phase. It's one of the easiest things to get right and one of the most visible when it's wrong. See job site rentals for contractors for how we size a site's setup.