OSHA portable toilet requirements for construction, under 29 CFR 1926.51.

Which sanitation standard applies

29 CFR 1926.51 is the construction sanitation standard. OSHA publishes the same section at osha.gov. 29 CFR 1910.141(a)(1) says the general-industry sanitation standard applies to permanent places of employment. A jobsite uses the construction section. A fixed plant, warehouse, or office uses the general-industry section. The same construction section also covers potable water, food handling, and temporary sleeping quarters. This page is about toilets, washing, access, and the rules that change the count.

Table D-1: toilets per worker

Section 1926.51(c)(1) says toilets shall be provided for employees according to Table D-1. The table below is the text in the eCFR on the review date.

The rows overlap. The table prints both “20 or less” and “20 or more,” and both “20 or more” and “200 or more.” The section does not say which row controls at 20, or at 200 and above. OSHA’s May 17, 2006 letter, discussing a crew of 20, says the employer would be required to provide at least one toilet.

The second row states a ratio: one toilet seat and one urinal per 40 workers. The third row states one toilet seat and one urinal per 50 workers. Applied to headcounts that divide evenly, those ratios produce:

At 200, the second row’s ratio is five seats and five urinals, and the third row’s ratio is four and four. The section does not choose between them. It also publishes no rounding rule for a remainder. The construction table does not say a urinal may replace a toilet seat. The general-industry table does, and that footnote is quoted below.

Section 1926.51 does not define whether “number of employees” means the peak on site or a daily average. The count guide sizes a placement to peak headcount as an operating practice. That practice is separate from the table.

Under temporary field conditions, 1926.51(c)(2) requires not less than one toilet facility. On a jobsite with no sanitary sewer, 1926.51(c)(3) requires one of these, unless a local code prohibits it: a privy, where its use will not contaminate ground or surface water; a chemical toilet; a recirculating toilet; or a combustion toilet. Section 1926.51(c)(4) says paragraph (c) does not apply to mobile crews that have transportation readily available to nearby toilet facilities. The 2002 letter on that exception is in the access section below.

Sanitary condition and service frequency

The regulation states no pump interval. The duty is in the word “provided.” OSHA’s May 17, 2006 letter answers whether an unsanitary toilet counts toward Table D-1. The answer is no. The letter says the purpose of the standard is to keep employees from the health effects of unavailable toilets, and that a toilet in an unsanitary condition is unusable and therefore has not been provided under 1926.51(c)(1).

The letter gives one way to meet that obligation: use the servicing schedule in ANSI Z4.3-1995, Section 3, as a guide. It says the ANSI standard calls for a toilet used by up to 10 people to be serviced a minimum of once per week. It defines servicing, in the ANSI standard, as emptying the waste and cleaning the toilet facility. Applied to Table D-1, the letter says that where one toilet has been provided for 20 employees, servicing it twice per week would likely provide a toilet in a sanitary condition, and that a toilet for 10 employees serviced once per week would likely be in a sanitary condition. A footnote in the letter says 1926.51(c) does not require the facility to be immaculate to be considered sanitary.

Those intervals are the letter’s examples of the ANSI guide. They are not a number added to the Code of Federal Regulations. A crew larger than the example, a hot week, or a unit that fills early can need a shorter cycle and still sit inside the same “sanitary condition” duty. The letter is explicit that ANSI is a guide the employer may use, which is a different thing from OSHA incorporating the ANSI standard by reference.

To apply a headcount to a placement, use the portable toilet count guide. Ordering the units is on the portable toilet rental page. Service frequency is part of the price. Published contract and bid prices, by place and year, are on the portable toilet rental cost guide. Those figures are not a Detritus quote. The quote is where a crew size, a service interval, and the hand-wash stations are priced together.

Hand washing under 1926.51(f)

Paragraph (f)(1) requires adequate washing facilities for employees engaged in the application of paints, coating, herbicides, or insecticides, or in other operations where contaminants may be harmful to the employees. The facilities shall be in near proximity to the worksite and equipped so employees can remove those substances. OSHA’s June 12, 2006 letter reads “other operations” as a broad clause, past the four named tasks. Where the materials are harmful, the letter says the employer must provide adequate washing facilities, including soap and potable water. The letter points to the safety data sheet as the source for whether a chemical is harmful.

Paragraph (f)(2) says washing facilities shall be maintained in a sanitary condition.

Paragraph (f)(3) is separate from the contaminant rule. Lavatories shall be made available in all places of employment. The exception covers mobile crews and normally unattended work locations if employees there have transportation readily available to nearby washing facilities that meet the rest of the paragraph. Each lavatory shall be provided with hot and cold running water, or tepid running water. Hand soap or similar cleansing agents shall be provided. Individual hand towels, or sections of cloth or paper, air blowers, or clean individual sections of continuous cloth toweling, convenient to the lavatories, shall be provided.

The section sets no ratio of stations to toilets. It does require running water that is hot and cold, or tepid, plus soap and a way to dry hands, for the lavatories in (f)(3). A station that does not meet that sentence is a different product from the lavatory the paragraph describes. Hand wash stations are ordered as their own line.

Showers are required by (f)(4) only when a particular standard requires showers. When that is the case, the section requires one shower for each 10 employees of each sex, or fraction thereof, who are required to shower during the same shift, with body soap, hot and cold water feeding a common discharge line, and individual clean towels. Shower trailers are on the restroom trailer page. That page is the product. It is not a statement that a given trailer meets (f)(4).

Distance, access, and privacy

Section 1926.51 states no maximum walking distance in feet. Access is part of whether a toilet has been provided.

OSHA’s June 7, 2002 letter interprets 1926.51(c)(4), the mobile-crew exception. A mobile crew is workers who continually or frequently move from jobsite to jobsite on a daily or hourly basis. Workers who report to a conventional project for days, weeks, or longer are not a mobile crew for this standard. For the crews who are mobile, “nearby” means prompt access, sufficiently close that employees can use the toilets when they need to. The letter says that, in general, toilets would be considered nearby if it would take less than 10 minutes to get to them.

OSHA’s February 23, 2005 letter applies the same idea to a fixed construction jobsite under 1926.51(c)(1). The question was a crew on the tenth floor, with toilets only on the ground floor and stairs as the only access. OSHA did not decide that layout. It said the test is whether employees have prompt access, and that, in general, the starting point is whether it takes less than 10 minutes to reach a toilet. The 2006 sanitation letter repeats the same point: toilets that take too long to get to have not been provided, and one purpose of the headcount table is that employees not wait in long lines.

Privacy is specified in the general-industry rule, in a sentence the construction rule does not contain. 29 CFR 1910.141(c)(2) says each water closet shall occupy a separate compartment with a door and walls or partitions between fixtures sufficiently high to assure privacy. On a construction site without a sewer, the toilet types in 1926.51(c)(3) are the privy, the chemical toilet, the recirculating toilet, and the combustion toilet. The construction section does not add a lock or a compartment dimension on top of those types.

ADA units

Table D-1 sets no accessible-unit count. The 2010 ADA Standards are a different instrument, and they have a construction exemption.

Section 201.3 of the 2010 ADA Standards says the requirements apply to temporary and permanent buildings and facilities. Section 203.2 then says structures and sites directly associated with the actual processes of construction, including construction trailers, are not required to comply. The portable-toilet sentence in 203.2 is specific: portable toilet units provided for use exclusively by construction personnel on a construction site shall not be required to comply with section 213 or to be on an accessible route.

Where the standards do apply, section 213.2 says that where toilet rooms are provided, each toilet room shall comply with section 603. Exception 3 covers a cluster: where multiple single-user portable toilet or bathing units are clustered at a single location, no more than 5 percent of the toilet units and bathing units at each cluster shall be required to comply with 603. Portable toilet units and bathing units that comply with 603 shall be identified by the International Symbol of Accessibility. The advisory describes a cluster as a group of toilet rooms proximate to one another, generally within sight of or adjacent to one another.

Exception 3 is a cap on how many units the standards require to comply. It does not say “at least one,” and it states no rounding rule for a fraction of a unit. It is also written for multiple units. A single portable toilet is outside that exception’s wording. Section 603 is the technical standard for the toilet room that does have to comply. This page does not restate those dimensions.

A unit used by the public, or a unit at a facility the standards cover, is outside the “exclusively by construction personnel” sentence. A contract, a permit, or a local code can require an accessible unit on a crew-only site even though 203.2 does not. The count guide records how accessible units have been placed on delivered orders. It is the operational record. It is not a restatement of 203.2.

General industry: 29 CFR 1910.141

Permanent places of employment use Table J-1 of 29 CFR 1910.141(c). The number of facilities for each sex is based on the number of employees of that sex. “Number of employees” in this section means the maximum number present at any one time on a regular shift, unless the section says otherwise. Where a toilet room will be occupied by no more than one person at a time, can be locked from the inside, and contains at least one water closet, separate rooms for each sex are not required. In a single-occupancy room with more than one fixture, only one fixture counts toward Table J-1.

Footnote 1 to Table J-1: where toilet facilities will not be used by women, urinals may be provided instead of water closets, except that the number of water closets shall not be reduced to less than two-thirds of the minimum specified. Paragraph (c)(1)(ii) excepts mobile crews and normally unattended work locations when transportation is immediately available to nearby toilet facilities that meet the rest of the paragraph. Lavatories under 1910.141(d) follow the same water, soap, and drying list as 1926.51(f)(3). The general-industry section states no weekly service interval for a portable toilet.

State rules can be stricter

OSHA’s State Plan page, read October 26, 2026, counts 22 State Plans that cover private-sector and state and local government workers, and seven that cover only state and local government workers. A State Plan must be at least as effective as federal OSHA. A state may write a tighter sanitation rule. California and Washington are the two examples below, because both publish a construction toilet table that differs from Table D-1. The other State Plan states are not summarized here.

A program that crosses a State Plan state and a federal-OSHA state has a different floor at each site. Who holds the customer contract when the local provider changes is covered on waste broker vs hauler. Construction site services is the program page for placing sanitation with the rest of the site.

California: Title 8, section 1526

8 CCR 1526, read October 26, 2026, requires a minimum of one separate toilet facility for each 20 employees or fraction thereof of each sex. The facilities may include toilets and urinals, provided the number of toilets is not less than one half of the minimum required number of facilities. Where there are fewer than five employees, one single-user toilet facility designated for all-gender use is sufficient. A single-user all-gender facility can count toward the required number only when the total meets subsection (a), every single-user facility is designated all-gender, and multi-user separate facilities are provided in equal number to each sex.

Under temporary field conditions, not less than one toilet shall be available. Where water closets are not feasible because there is no sanitary sewer or no adequate water supply, the section allows privies that will not contaminate surface or underground water, chemical toilets, recirculating toilets, or combustion toilets, unless a local regulation prohibits them. Facilities shall be kept clean, maintained in good working order, designed and maintained in a manner which will assure privacy, and provided with an adequate supply of toilet paper. Mobile crews with readily available transportation to nearby toilet facilities are excepted. Section 1526 states no distance in feet and no weekly service number.

Washington: WAC 296-155-140

WAC 296-155-140, read October 26, 2026, requires toilets for construction employees according to Table B-1. When flush toilets are used, WAC 296-800-230 applies instead of this table. The table below is the construction table.

Toilets must be maintained in clean, sanitary, and functional condition, with internal latches to secure the units from inadvertent entry. Where there are 20 or more employees consisting of both sexes, facilities for each sex are required. The location must be as close as practical to the highest concentration of employees. On multistory structures, facilities must be furnished on every third floor. At all sites they must be located within 200 feet horizontally of all employees. Those distance rules do not apply to mobile crews or normally unattended locations that have transportation immediately available to nearby facilities. For that exception, the section defines a nearby facility as a sanitary facility within three minutes’ travel by the transportation provided.

Wash water is its own subsection. The employer must provide clean, tepid wash water, between 70 and 100 degrees Fahrenheit, at all construction sites, plus individual hand towels and hand soap, industrial hand cleaner, or similar cleansing agents. Gasoline or solvents for personal cleaning are prohibited. The mobile-crew exception applies to wash water as well.

Subsection (6) covers workers who menstruate and expression of milk, at fixed and mobile construction locations. It requires a bathroom, accessible on the worksite, equivalent to a standard-size chemical toilet and fitted with an internal latch, plus an adequate supply of menstrual hygiene products at no cost to the worker. On notice from the worker, it requires a private location to express milk that is not a bathroom or a portable toilet, refrigeration for the milk, and potable water to wash hands and equipment. The section also requires a service schedule, a shift-start inspection, and waste disposal under local health rules. Those duties are in the linked text.

Checklist

Print this page to keep the list. Each line is a pointer to a rule cited above. The list is not a compliance certificate, and it is not a substitute for the standard or for counsel.

1. Decide which standard applies: 1926.51 for construction, 1910.141 for a permanent place of employment.
2. Write down the headcount the table uses. Construction does not define peak versus average. General industry uses the maximum present at one time on a regular shift.
3. Apply Table D-1 or Table J-1. Show the arithmetic. Flag a fraction, and flag a headcount where two construction rows both read as if they apply.
4. On a construction site with no sanitary sewer, use a privy, chemical toilet, recirculating toilet, or combustion toilet, unless a local code prohibits it. Under temporary field conditions, provide at least one toilet.
5. If the crew is mobile, record whether transportation is readily available to a nearby toilet. OSHA’s 2002 letter uses less than 10 minutes as the general figure for “nearby.”
6. On a fixed site, record the time from the work to the toilet. OSHA’s 2005 letter uses less than 10 minutes as the general starting point under 1926.51(c)(1). The federal section states no distance in feet.
7. Set a service schedule that keeps every counted toilet sanitary. The 2006 letter points to ANSI Z4.3-1995, Section 3, as one guide: at least weekly for a toilet used by up to 10 people, and twice a week as a likely sanitary schedule for one toilet serving 20 employees.
8. For harmful contaminants, provide washing facilities in near proximity to the work, including soap and potable water, under 1926.51(f)(1) as the June 12, 2006 letter reads it.
9. Provide the lavatories in 1926.51(f)(3), including hot and cold or tepid running water, soap, and towels or an air blower, unless the mobile or unattended exception applies. Keep washing facilities sanitary under (f)(2).
10. If showers are required by another standard, apply the one-per-10 ratio in 1926.51(f)(4).
11. Read ADA section 203.2 before counting accessible units. Crew-only construction toilets are exempt from section 213. If a cluster is covered, exception 3 of 213.2 caps the requirement at 5 percent of the units in that cluster, marked with the International Symbol of Accessibility.
12. Check the state. California 8 CCR 1526 and Washington WAC 296-155-140 are stricter than Table D-1. Other states are not listed here.
13. Read the contract and the permit. Either one can require more units, a shorter service cycle, or an accessible unit.

Common questions

Rule changes

Last reviewed October 26, 2026 against the eCFR text of 29 CFR 1926.51 and 29 CFR 1910.141. The source note on 1926.51 lists amendments through 76 FR 33611 (June 8, 2011). The source note on 1910.141 lists amendments through 76 FR 33607 (June 8, 2011). No later amendment appears in those source notes. This is the first edition of this page, so there is no earlier rule text to compare.

• October 26, 2026. Checked the eCFR text of 29 CFR 1926.51 and 29 CFR 1910.141, the four OSHA letters cited above, California Title 8 section 1526, Washington WAC 296-155-140, the OSHA State Plan count, and sections 201.3, 203.2, and 213.2 of the 2010 ADA Standards. No rule-text change to record against a prior edition.

What changed

• October 26, 2026. First published.

Every count, interval, distance, and temperature on this page is taken from the linked standard or interpretation letter. The page quotes no Detritus price and no search volume.

Sources

• 29 CFR 1926.51, Sanitation, eCFR, reviewed October 26, 2026. OSHA’s copy: 1926.51.
• 29 CFR 1910.141, Sanitation, eCFR, reviewed October 26, 2026.
• OSHA interpretation, May 17, 2006, sanitary condition and the ANSI Z4.3-1995 servicing guide.
• OSHA interpretation, June 7, 2002, mobile crews and the less-than-10-minutes figure for nearby toilets.
• OSHA interpretation, February 23, 2005, prompt access on a fixed construction jobsite.
• OSHA interpretation, June 12, 2006, washing facilities under 1926.51(f)(1).
• OSHA State Plans, reviewed October 26, 2026.
• California Code of Regulations, Title 8, section 1526, reviewed October 26, 2026.
• Washington Administrative Code 296-155-140, reviewed October 26, 2026.
• 2010 ADA Standards, Chapter 2, sections 201.3, 203.2, and 213.2, U.S. Access Board.