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OSHA 1926.51: Does a 10-man crew on a 30-story exterior need a unit on the roof?

Hector V.asked 1 viewConstruction & Job SitesOsha 1926 51High rise unitPlacementConstruction siteService frequency

OSHA 1926.51 does not require a portable toilet on the roof for a 10-man crew doing facade work. The standard is based on total worker count at the site, not the travel time to a ground-floor unit.

OSHA's construction site rule is OSHA 29 CFR 1926.51. It says 20 or fewer workers need one toilet. Your 10-man crew meets that minimum with a single unit. The rule has an exemption for mobile crews with "transportation readily available" to a toilet, but an elevator ride down 30 stories is not considered readily available transportation. You need that ground-floor unit.

The practical need for a roof unit is about productivity and safety. A long elevator ride for a bathroom break costs significant work time on a high-rise project. For a crew working exterior walls all day, placing a standard unit on the working level is a smart move. You avoid downtime. You also need to consider placement for a high-rise unit, secure, level ground on the roof, away from edges, with a crane or hoist for delivery and service.

Service and logistics are the next steps. A roof unit needs weekly service. Coordinate with the crane schedule for the vacuum truck to lift the unit for pumping. Use staking to secure it against wind. The rental company will plan for this. It is an added cost, but it keeps the crew on task.

So no, OSHA does not force you to put a toilet on the roof for 10 workers. But for a 30-story facade job, you should. Anybody run into this with a smaller crew?

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Marcus B.Chicago, IL

OSHA 1926.51 does not require a portable toilet on the roof for a 10-man crew doing facade work. The OSHA construction sanitation standard requires one toilet for 20 or fewer workers, so a single ground-floor unit satisfies the rule. The exemption for mobile crews with readily available transportation does not apply here, as a 30-story elevator ride is not considered readily available.

Placing a standard unit on the roof is a practical decision for productivity and safety. It minimizes downtime from long trips to the ground. Ensure placement on level ground, away from edges, with staking for wind security. Service requires coordination with crane or hoist access for the vacuum truck. Weekly service is standard, but high use or heat may require more frequent visits. The added cost comes from delivery complexity and service logistics, not the unit itself.

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Deb K.Akron, OH

Marcus is right on the OSHA rule, but he missed the service driver's view. A vacuum truck hose reaches about 25 feet. On a roof, the driver needs the unit near the hoist point. If the unit is blocked by materials or too far from the edge, it is a missed service. The crew must keep a clear path. Also, a roof unit gets more wind and sun. The deodorizer breaks down faster in heat. For a 10-man crew, weekly service might not be enough. Check the unit midweek. If it smells, call for an extra pump-out.

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