OSHA 1926.51: Do subcontractors count toward our porta potty total?

Yes, subcontractors count toward your total employee headcount for OSHA 1926.51 compliance. The OSHA standard applies to all workers on the construction site, regardless of whether they are your direct employees or subcontractors.

OSHA's definition of employees includes every worker you expose to site conditions. On a construction site with 30 of your employees and 15 subcontractors, you have 45 total workers. OSHA 1926.51(c) requires one toilet for 20 or fewer workers. For 20 to 199 workers, the rule is one toilet seat and one urinal per 40 workers. With 45 workers, you need at least two toilet seats and one urinal, or the equivalent number of standard portable toilets.

Planning your portable toilet rental for a long-term site means adding units based on that total headcount. A single standard unit is not enough for 45 people over a workweek. You should also consider an ADA-compliant unit if you cluster units, due to the ADA cluster rule. Place the cluster on level ground with good truck access for the weekly service visit.

Weekly service is critical with that many users. A vacuum truck will pump the holding tanks, refill the deodorizer, and restock supplies. In summer heat, you might need service more than once a week. Blocked access means a missed service, and that bill still comes.

What's the specific layout of your site? Do you have space for a cluster, or are you considering a restroom trailer?