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OSHA 1926.51: Does it apply to a remote 5-person surveying crew?

Hector V.asked 1 viewConstruction & Job SitesOsha 1926 51Service frequencyTruck accessMobile crewRural site

OSHA 1926.51 does not require a portable toilet for a remote 5-person surveying crew. The standard exempts mobile crews when transportation is readily available to nearby toilet facilities. The key is the definition of "readily available."

Applying the exception
A 5-person crew is below the 20-worker threshold that triggers the one-toilet minimum. But even for larger mobile crews, the exemption applies if the crew can quickly reach a fixed restroom, like at a gas station, restaurant, or a base camp. For a truly remote crew with no facilities within a reasonable drive, the exemption may not hold. The crew's isolation makes the transportation not readily available.

Practical compliance for a rural crew
For a surveying team working miles from any building, the safest compliance move is to rent a single standard unit. Place it on level ground at a central spot the crew can return to. A deluxe unit with a sink adds handwashing, which is a separate OSHA requirement. The rental company will set a service frequency, typically weekly, but for a small crew in a rural area, you might stretch that.

Enforcement and common sense
An OSHA inspector will ask how the crew is relieving itself. "We drive 20 minutes to the nearest town" is a weak defense if the crew is supposed to be working. Providing a unit eliminates the risk and keeps the crew on task. It is a basic job site cost.

Post your crew's specific setup, how remote, how long on site, truck access, and we can nail down the exact move.

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Tyler R.Columbus, OH

Yes, OSHA 1926.51 applies to a remote surveying crew unless you meet the mobile-crew exemption.

Under 1926.51(c)(4), the toilet rules do not apply when a mobile crew has transportation readily available to nearby toilet facilities. A five-person survey crew that keeps a truck and can reach a real restroom without burning the workday can rely on that. If the crew is parked for hours on rural right-of-way with no practical stop, transportation is not readily available and you fall back under Table D-1, which starts at one toilet for 1 to 15 workers.

On remote jobs we have run, we drop one standard unit at the morning meet point so nobody is guessing about drive time. Keep clear truck access for weekly service and set the unit on firm level ground so it does not tip when the dirt softens. Handwashing is a separate duty under the same standard, so plan soap and water or a station if the unit has no sink.

If you can truly roll to a fixed restroom without killing productivity, document how that works. If you cannot, put the unit on site and skip the argument with an inspector.

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