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50-person crew, 90% men: can we use portable urinals to meet OSHA?

Marcus B.asked 0 viewsHow Many UnitsOsha 1926 51UrinalUnits per personConstruction siteCompliance

We're breaking ground on a two-story office build-out next month. The crew will be about 50 people, and it's almost all men. The site is a flat, gravel lot with easy access for a truck. I'm trying to figure out the minimum setup to stay compliant with OSHA 1926.51. The rule says for 20 to 199 workers, you need one toilet seat and one urinal per 40 workers. For our 50-person crew, that math suggests we need at least two toilet seats and two urinals. Since the crew is mostly men, I'm wondering if we can use two standard portable toilets plus a couple of standalone portable urinals to meet the requirement. Does the urinal count as a full fixture, or do we still need the two toilet seats regardless?

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Tyler R.Columbus, OH

You still need the two toilet seats. Under OSHA 1926.51 the urinal is counted on top of the seat, not in place of it, so for 50 people the table works out to two seats and two urinals. Your math is right because 50 divided by 40 rounds up to 2.

The swap rule people remember, where urinals can stand in for some of the seats as long as seats don't drop below two thirds of the minimum, comes from the general industry standard (1910.141) and it only applies when no women use the facilities. You said almost all men, so even if you leaned on that rule it wouldn't fit your crew.

What we usually do on a crew your size is two standard units that each have the built in urinal, then add a standalone urinal or two if lines build up at break time. That covers the count and keeps the seats free for people who actually need them. Put the cluster on the gravel near the truck path so the service guy isn't dragging a hose across the site, and plan for more than the minimum once framing crews and subs stack up on the busy weeks.

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