OSHA 1926.51: do subcontractors count toward our total headcount?

Yes, subcontractors count toward the total headcount for the OSHA 1926.51 toilet requirement. The standard applies to all employees on the construction site, regardless of which company employs them. Your total portable toilet count must include your own crew plus all subcontractor employees present at the same time. OSHA's language is clear. The standard specifies the number of toilets required based on the number of 'employees'. It does not distinguish between general contractor employees and subcontractor employees. If you have 60 people on site from three different companies, you need facilities for 60 people. The only exemption is for mobile crews with immediate access to nearby facilities. Calculate for peak occupancy. You must plan for the maximum number of workers present during any shift. A site with 25 of your employees and 30 subcontractors needs units for 55 people. Under OSHA 1926.51, 36 to 55 workers require a minimum of three toilet facilities. You also need to follow the ADA 5 percent cluster rule if you have a cluster of units. Coordinate with your subs. The general contractor is typically responsible for providing the required sanitation facilities. You should confirm daily headcounts with your subcontractors to ensure your service frequency and number of standard units or ADA-compliant units are adequate. A sudden surge in subcontractor manpower can quickly overwhelm the facilities. Failure to provide the minimums can result in an OSHA citation.