OSHA 1926.51: Does it apply to our 6-person road crew?

OSHA 1926.51 does not require a porta potty for a six-person road crew if they have a truck and immediate access to a nearby toilet facility. The standard's mobile crew exemption applies to your situation. Your crew must be able to leave the job site and reach the facility in the truck without significant delay.

The mobile crew exemption is in OSHA 1926.51(c). It says the toilet requirements do not apply to mobile crews with transportation readily available to nearby toilet facilities. "Readily available" means the truck is on site and the facility is close enough that using it does not take an unreasonable amount of work time. A gas station a few minutes down the road usually qualifies.

When the exemption fails is when the crew cannot practically leave. If the work zone is in a remote area with no facilities for miles, or if traffic control makes leaving and returning a 30-minute trip, you lose the exemption. Also, if any worker cannot use the transportation due to a disability, you may need to provide an accessible unit on site.

The practical choice is often to rent a single standard unit anyway. It keeps the crew on site, which saves more time than you think. A weekly service visit keeps it clean. For a long-term job, the convenience outweighs the rental cost.

If your gas station is truly nearby and accessible all day, you are compliant without a unit. If there's any doubt, put one on site. It's cheaper than an OSHA citation. Questions on placement or service for a road crew? Post them below.