OSHA 1926.51: does 'readily available transportation' mean a crew truck?
No, a crew truck does not meet the 'readily available transportation' exemption in OSHA 1926.51. The exemption is for a mobile crew that can reach a fixed restroom facility, like one at a main job site or a public facility, during all work hours. A paving crew's truck is not readily available if the crew is actively working and the nearest gas station is a 10-minute drive away.
The OSHA standard is clear. OSHA 29 CFR 1926.51(c) says a toilet must be available. The exemption is narrow. If the crew has to stop work, load up, and drive to use a facility, the transportation is not readily available. The toilet must be on site or immediately accessible without interrupting work.
You need a unit on the paving site. For a mobile paving crew, you place a standard unit at the work location. It goes on level ground where the vacuum truck can reach it for weekly service. If the crew is 20 or fewer, one unit is the minimum. For 20 to 199 workers, it's one toilet seat and one urinal per 40 workers.
Arguing will cost you. An OSHA inspector will see a crew with no on-site toilet and issue a citation. The fine is more than the rental. It also hurts morale. The crew will waste time driving instead of having a unit two minutes from the paver.
Put the unit where they work. Service it weekly. That's the rule. Anybody run into this with a grading or fencing crew?