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Planning guide

Job Site Restroom Requirements

Federal OSHA sets the minimum number of toilets on a construction site by the number of employees. Virginia enforces an identical construction standard through its own program.

Short answer

  • 20 or fewer employees: at least one toilet.
  • More than 20: one toilet seat and one urinal per 40 workers; 200 or more: one of each per 50 workers.
  • Lavatories with hot and cold or tepid running water, soap and towels must be available, apart from mobile crews.
Two portable restrooms and a hand-wash station beside a site trailer

The OSHA table

29 CFR 1926.51(c)(1) says toilets shall be provided for employees according to this table:

Number of employeesMinimum number of facilities
20 or less1
20 or more1 toilet seat and 1 urinal per 40 workers
200 or more1 toilet seat and 1 urinal per 50 workers

A plain reading for planning

Rounding each ratio up to the next whole facility gives the following. The site safety lead decides how the table applies to a given project; this is a planning aid, not a compliance ruling.

CrewSeats and urinals
1 to 201 toilet
21 to 401 seat and 1 urinal
41 to 802 seats and 2 urinals
81 to 1203 seats and 3 urinals
121 to 1604 seats and 4 urinals
161 to 1995 seats and 5 urinals
2004 seats and 4 urinals
201 to 2505 seats and 5 urinals

At 200 workers the table switches to one of each per 50, which gives fewer facilities than at 199, so confirm the reading with the safety lead. Many standard units contain both a seat and a urinal, so one such unit covers one pair.

Other parts of the rule

  • Temporary field conditions. Paragraph (c)(2) requires provisions so that at least one toilet facility is available.
  • Sites without a sewer. Paragraph (c)(3) requires privies that will not contaminate water, chemical toilets, recirculating toilets or combustion toilets, unless local codes prohibit them. A rented portable toilet is a chemical toilet.
  • Mobile crews. Paragraph (c)(4) says the toilet requirements do not apply to mobile crews that have transportation readily available to nearby toilet facilities.

Washing facilities

Paragraph (f)(3) says lavatories shall be made available in all places of employment. The exception covers mobile crews and normally unattended work locations whose employees have transportation readily available to nearby washing facilities. Paragraph (f)(1) adds washing facilities near the worksite for employees applying paints, coatings, herbicides or insecticides, or doing other work where contaminants may be harmful, equipped so they can remove those substances. All washing facilities must be kept sanitary. A hand-wash station is the usual way to meet the lavatory rule on a site without plumbing.

Accessible units on job sites

The 2010 ADA Standards exempt portable toilets provided exclusively for construction personnel. A site with a sales office, public walkway or visiting clients should plan an accessible unit.

Before the first delivery

Record the crew count used, the unit locations and the service day with the project safety file, and revisit them when the crew grows or a new phase starts. For recurring placements, see monthly and long-term rentals.

Common questions

Does a two-person crew need a portable toilet?

The table starts at one toilet for 20 or fewer employees, so a small crew working at one site is covered. The mobile-crew exception applies when the crew has transportation readily available to nearby toilet facilities, as with a crew that drives between short jobs. A two-person crew spending weeks on one renovation normally needs a unit or usable restrooms on site.

Does a urinal count as a toilet under the OSHA table?

Above 20 employees, the table lists toilet seats and urinals as separate items, so a urinal does not replace a seat. For 20 or fewer, the table simply calls for one facility. When ordering, ask your rental contact whether each standard unit includes a urinal, since that changes how many units cover the required pairs.

Are Virginia's construction sanitation rules different from federal OSHA?

Virginia runs its own Virginia Occupational Safety and Health program, and its construction regulation, 16VAC25-175, is titled Federal Identical Construction Industry Standards. The toilet table and washing-facility rule are therefore the same as the federal text. Check the Virginia Administrative Code for any later amendment.

What must a job-site lavatory include?

Paragraph (f)(3) requires hot and cold running water or tepid running water, hand soap or a similar cleansing agent, and individual towels of cloth or paper, air blowers or clean sections of continuous cloth toweling near the lavatory. A cold-water foot-pump station may not meet the tepid-water wording, so ask your rental contact which stations deliver warm water.

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