Sanitation is an essential part of providing employees with a safe and healthy workplace. The number of people regularly using sanitary facilities, the presence and use of toxic substances, and the need to wash hands prior to eating all create sanitation issues in the work environment that employers must address.

The Occupational Safety and Health Administration (OSHA) sanitation requirements at 29 CFR 1910.141 apply to all employers providing permanent places of employment. Employers in the construction industry are instead covered by 1926.51, although most provisions are equivalent.

Note: Mobile crews and normally unattended work locations do not have to comply with the toilet facilities or washing facilities requirements, if employees working at these locations have transportation immediately available to nearby toilet facilities which meet the other requirements of the standard.

In addition, OSHA’s standard at 1910.142 covers the sanitation conditions of temporary labor camps. These are most commonly established at agricultural locations. Examples of temporary labor camp housing for non-agriculture worksites would be for the construction industry and for the oil and gas industry.

Number of employees: The maximum number of employees present at any one time on a regular shift.

Personal service room: A room used for activities not directly connected with the production or service function performed by the establishment. Such activities include, but are not limited to, first-aid, medical services, dressing, showering, toilet use, washing, and eating.

Potable water: Water that either meets the standard for drinking purposes of the State or local authority having jurisdiction or meets the quality standards prescribed by the U.S. Environmental Protection Agency’s National Primary Drinking Water Regulations (40 CFR 141).

Toilet facility: A fixture in a toilet room used for defecation, urination, or both.

Toilet room: A room in or on the premises of a workplace that contains one or more toilet facilities for use by employees.

Toxic material: A material in concentration or amount which exceeds the applicable limit established by a standard, such as 1910.1000 and 1910.1001 or , in the absence of an applicable standard, which is of such toxicity so as to constitute a recognized hazard that causes or is likely to cause death or serious physical harm.

Water closet: A toilet facility in a toilet room used for defecation and urination and that is flushed with water.

Wet process: Any process or operation in a workroom which normally results in surfaces upon which employees may walk or stand becoming wet.

• Employers must ensure that toilet rooms are sanitary and that no food or drink is stored or consumed in toilet rooms.
• Employers must provide potable drinking water and clearly mark outlets of non-potable water.

The Occupational Safety and Health Administration regulates the sanitation conditions of eating and drinking areas, toilet rooms, washrooms, change rooms, and more. Among the requirements with which employers must comply are the following:

• Keep all places of employment clean to the extent that the nature of the work allows;
• Keep restrooms and washrooms clean and sanitary;
• Where wet processes are used, maintain drainage and provide false floors, platforms, mats, or other dry standing places, where practicable, or provide appropriate waterproof footgear.
• Provide body soap or other appropriate cleansing agents convenient to the showers where showers are required;
• Prohibit food or beverages from being stored or consumed in a toilet room or in any area exposed to toxic material;
• Ensure the number, size, and location of food waste receptacles encourages their use and does not result in overfilling; and
• Provide potable water for drinking, washing, and cooking and ensure that all outlets for non-potable water are clearly marked.

Employers must also ensure that every enclosed workplace is constructed, equipped, and maintained, so far as reasonably practicable, to prevent the entrance or harborage of rodents, insects, and other vermin. A continuing and effective extermination program must be instituted where such pests are detected.

Additional requirements specific to the construction industry include the following:

• Portable containers used to dispense drinking water must be capable of being tightly closed, and equipped with a tap.
• Water must not be dipped from containers, and common drinking cups are prohibited.
• Any container used to distribute drinking water must be clearly marked not used for any other purpose.
• When temporary sleeping quarters are provided, they must be heated, ventilated, and lighted.

• Food consumption is prohibited in any work area containing toxic materials.
• An employer’s decision to allow food and drink in other work areas depends on several factors.

All employee food service facilities and operations must be carried out according to sound hygienic principles. In all places of employment where all or part of the food service is provided, the food dispensed must be wholesome, not spoiled, and needs to be processed, prepared, handled, and stored in such a manner to be protected against contamination.

If a work area contains toxic materials, The Occupational Safety and Health Administration (OSHA) prohibits the consumption of food in such area.

Aside from toxic materials, many other questions arise when dealing with food in the workplace. If employees are working around moving parts, would eating or drinking cause a distraction that could be dangerous to themselves or other workers? Could spills or garbage cause slip hazards? It is best to take a practical approach when considering the issue. Also consider:

• Liquids around electrical equipment,
• Pest and vermin attraction,
• Lack of a suitable eating area,
• Company safety and health policies, and
• Machine interference.

Ultimately, an employer must determine whether to allow food and drink in work areas that do not have toxic materials, based on the specific work operation.

• Employers must provide potable drinking water in all workplaces.
• Outlets for non-potable water must be clearly marked as unsafe for washing and consumption.

The Occupational Safety and Health Administration (OSHA) requires that potable drinking water be provided in all places of employment. As OSHA does not specify where the potable water must be provided in relation to production areas or processes, a cafeteria that provides potable water would fulfill this requirement.

Employers may provide additional sources of potable water, but OSHA requires that portable drinking water dispensers be designed, constructed, and serviced so that sanitary conditions are maintained. While a water fountain is not strictly prohibited per the standard (it is not a “portable drinking water dispenser”), an employer may have difficulty maintaining sanitary conditions given the environmental conditions (e.g., dust) of certain work environments. On the other hand, a portable water dispenser, such as a cooler equipped with a tap, would allow an employer to easily provide an additional potable water source to workers in a specific work area. Such a cooler would have to be routinely cleaned to maintain sanitary conditions.

OSHA does not prohibit the use of water bottles, but workers must have individual bottles, as OSHA prohibits the use of a “common drinking cup or other common utensils.” This prohibition also applies to the dispensing of water from a cooler.

Outlets for non-potable water, such as water for industrial or firefighting purposes, must be clearly marked to indicate the water is unsafe and not to be used for:

• Drinking;
• Cooking; or
• Washing food, cooking/eating utensils, food preparation/processing areas, personal service rooms, one’s person, or clothes.

• The number of employees in a workplace determines the minimum number of water closets required.

The Occupational Safety and Health Administration’s (OSHA’s) sanitation standard is intended to ensure that employers provide employees with sanitary and available toilet facilities. The number of restrooms that must be provided depends on the number of employees of each sex as outlined in 29 CFR 1910.141(c)(1). Toilet facilities, in toilet rooms separate for each sex, must be provided in numbers according to the following table:

Each water closet must occupy a separate compartment with a door and walls or partitions between fixtures sufficiently high to ensure privacy.

Where toilet facilities will not be used by women, urinals may be provided instead of water closets so long as the number of water closets is not reduced to less than two-thirds of the minimum specified.

Separate toilet rooms for each sex are unnecessary if:

• Toilet rooms will be occupied by no more than one person at a time,
• Toilet rooms can be locked from the inside, and
• Each toilet room contain at least one water closet.

These single occupancy rooms must count as one water closet.

Employers must also ensure that the sewage disposal method does not endanger the health of employees.

A July 5, 1983, OSHA Letter of Interpretation says there are no specific distance or location requirements for toilet facilities. An employer is, however, expected to use reasonable judgment in evaluating the proximity of sanitary facilities. If an employer provides the required toilet facilities for all employees in the same building and provides unobstructed free access to them, it appears the intent of the standard would be met; however, 1 floor of toilet facilities serving 20 floors of employees would not be reasonable and appropriate.

For employers in the construction industry, the regulation at 1926.51 provides a different table for the number of toilets required, as follows:

• Washing facilities must be kept sanitary and provided with the proper running water, cleansing agents, and drying methods.

Sanitary washing facilities are vital for promoting hygiene and preventing the spread of diseases. The Occupational Safety and Health Administration (OSHA) requires employers to:

• Maintain washing facilities in a sanitary condition;
• Provide lavatories with hot and cold running water, or tepid running water;
• Provide hand soap or similar cleansing agents; and
• Provide, as is convenient to each toilet room, either:
  • Individual hand towels or hand-towel sections made of cloth or paper,
  • Warm air blowers, or
  • Clean individual sections of continuous cloth toweling.

Certain OSHA regulations require employers to provide showers in the workplace. Whenever showers are required by a particular regulation, employers must:

• Provide 1 shower for each 10 employees of each sex or fraction thereof who are required to shower during the same shift;
• Provide body soap or other appropriate cleansing agents convenient to the showers;
• Provide showers with hot and cold water that feed a common discharge line; and
• Provide individual clean towels for employees who use showers.

Change rooms

Whenever employees are required by a particular standard to wear protective clothing because of possible contamination with toxic materials, employers must provide change rooms with storage facilities for street clothes and separate storage facilities for the protective clothing.

• Employers who provide housing at temporary labor camps have unique sanitation responsibilities.
• OSHA inspections of employer-provided housing primarily address conditions most directly related to employee health and safety.

Because temporary labor camp housing is employer-provided, employers of temporary labor camps must address sanitation issues not found in other work environments. For this reason, the Occupational Safety and Health Administration (OSHA) covers the sanitation requirements for temporary labor camp housing in a specific standard, 29 CFR 1910.142. When conducting an inspection of temporary labor camp housing, OSHA officials will be primarily concerned with facilities or conditions that most directly relate to employee safety and health. At minimum, OSHA inspections will address the following concerns.

Site

OSHA officials will check whether the site is:

• Adequately drained from periodic flooding;
• Over 200 ft away from swamps, pools, sinkholes, and other surfaces where water could collect and remain for extended periods;
• Large enough to prevent overcrowding;
• At least 500 ft away from livestock; and
• Clean and sanitary (i.e., free from rubbish, debris, wastepaper, garbage, and other refuse).

Shelter

OSHA officials will check:

• Whether the shelter provides protection against the elements;
• Whether the shelter has the proper floor elevation and floor space;
• Which rooms are used for sleeping, the number of occupants, and the size of these rooms;
• Which rooms are used for combined purposes of sleeping, cooking;
• Whether beds, cots, bunks, and lockers are provided and properly spaced;
• Whether all rooms have proper ventilation and screening;
• Whether sanitary facilities are provided for storing and preparing food;
• What kind of cooking arrangements or facilities are provided; and
• Whether all heating, cooking, and water heating equipment are installed in accordance with state and local codes.

Water supply

OSHA officials will check whether the water supply for drinking, cooking, bathing, and laundry is adequate, convenient, and approved by the appropriate local health authority.

Toilet facilities and sewage disposal

OSHA officials will check:

• The type, number, location, lighting, and sanitary conditions of toilet facilities; and
• Whether All sewer lines and floor drains from buildings connect to public sewers if public sewers are available.

Laundry, handwashing, and bathing facilities

OSHA officials will check:

• The number, kind, locations, and conditions of laundry, handwashing, and bathing facilities;
• Whether there is an adequate supply of hot and cold running water; and
• Whether such facilities have appropriate floors, walls, partitions, and drains.

Lighting

OSHA officials will check whether:

• Electric service is available, and, if so, whether appropriate light levels, number of ceiling-type light fixtures, and separate floor- or wall-type convenience outlets are provided; and
• The light fixtures, floor outlets, and wall outlets are properly grounded and covered.

Refuse disposal and insect and rodent control

OSHA officials will check:

• The type, number, locations, and conditions of refuse disposal containers; and
• Whether there are any infestations of animal or insect vectors or pests.

First-aid facilities

OSHA officials will check whether adequate first-aid facilities are available and maintained for emergency treatment.