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General industry vs construction: which OSHA toilet rule applies to a warehouse renovation?

Luis A.asked 1 viewRules, Permits & ADAOshaConstruction siteOsha 1926 51ContractorsWarehouse

I'm the facilities manager for a large, occupied warehouse. We're starting a three-month interior renovation with a crew of about 25 contractors working a standard eight-hour day. There are no food or alcohol sales. The existing permanent restrooms are in a separate section of the building, and I'm not sure if the crew can use them. The contractors will be working inside, but their vehicles are parked nearby. The ground outside is level gravel, and a vacuum truck can easily access the placement spot. I'm trying to figure out which OSHA toilet rule applies here. Is it the construction standard, OSHA 1926.51, or the general industry standard, OSHA 1910.141? The crew isn't a mobile crew with immediate transport, but they are on an occupied industrial site. Which rule governs the number of portable toilets I need to rent?

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Jules T.Sacramento, CA

The construction standard, OSHA 1926.51, applies to your warehouse renovation. For a crew of 25 contractors, OSHA 1926.51(c) requires one toilet and one urinal. The rule applies because the contractors are performing construction work inside an existing building. The presence of permanent restrooms in another section does not exempt you, as the standard requires toilets to be readily accessible to employees. Since the crew is not a mobile crew with immediate transportation to the existing facilities, you must provide temporary units.

You should rent one standard portable toilet and one portable urinal, or two standard units if urinals are not available. If the renovation is in a public area or the site is open to other visitors, you may need an ADA-compliant portable toilet under the 5 percent cluster rule. For a three-month project, weekly service visits are standard. The rental cost is driven by the unit types, rental duration, and service frequency. Your described placement on level gravel with good truck access is ideal for servicing.

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