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50-person crew, all men: can we meet OSHA with just portable urinals?

Marcus B.asked 2 viewsHow Many UnitsOsha 1926 51UrinalStandard unitPortable urinalCrew size

We have a 50-person construction crew, all men, on a tight urban site for a six-week foundation and steel package. The site is a narrow lot with a gravel pad that a vacuum truck can reach. I'm trying to minimize the footprint and cost. OSHA 29 CFR 1926.51 requires one toilet seat and one urinal per 50 workers for a crew of 200 or more, but for our size, it's one toilet seat and one urinal per 40 workers. I'm wondering if we can meet the standard with just portable urinals. They take up less space than a full standard unit. Does the OSHA rule require at least one toilet seat regardless of urinal count? Can a urinal-only setup pass an inspection?

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Carl D.Oklahoma City, OK

No, a urinal-only setup won't pass, because OSHA 1926.51 Table D-1 counts toilet seats and urinals as two separate lines. At 50 workers you're in the 20 or more bracket, so it's one toilet seat and one urinal per 40 workers, and 50 divided by 40 rounds up to 2. That means 2 toilet seats and 2 urinals, not a row of urinals.

We ran about the same crew size on a pinched downtown lot last year and the inspector counted seats first. A urinal is not a seat no matter how many you line up.

What saved us room was putting 2 standard units side by side with the urinals at the end of the row on the gravel pad, all within hose reach of the vacuum truck so the driver could service everything from one spot. Units with a built-in urinal can cover both lines in fewer boxes, as long as your seat count still hits 2.

Get the service schedule in writing too. Fifty guys on a steel package fill tanks a lot faster than a light finish crew does.

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