Toilets & Sanitation - Cal/OSHA

Toilets are the least talked-about item on a job site and one of the most noticed. A crew that has to wait, walk across the site, or use a unit that hasn't been serviced in days notices — and so does the woman who finds out the only unit on site is shared with forty men. This Cal/OSHA Toilets & Sanitation Toolbox Talk covers California's construction sanitation rules in Title 8, Sections 1526 and 1527: how many toilets, for whom, how they are kept, and where people wash their hands.

Where the boundary of this talk sits#

This talk covers toilets and washing stations on California construction sites. Drinking water during hot weather belongs to the Cal/OSHA heat illness talk; handwashing to remove lead belongs to the Cal/OSHA lead talk; personal hygiene habits belong to the personal hygiene talk.

The anchor#

Here is the distinction that carries this whole talk: California counts toilets by headcount and by sex, not by crew — one separate toilet facility for each 20 employees or fraction of 20 of each sex — so the number is set by who is actually on site today, not by what was ordered at mobilization; a 21st worker, or the first woman to join the crew, can change what the site has to provide, and "we've always had one porta-potty" is a count that was right only until the roster changed.

How many toilets#

Section 1526(a) requires a minimum of one separate toilet facility for each 20 employees or fraction thereof of each sex. Two things follow from that sentence.

First, "or fraction thereof" means the count rounds up. Twenty employees of one sex need one facility; twenty-one need two.

Second, the count runs separately for each sex. A site with 25 men and 5 women needs two facilities for the men and one for the women — three in total — even though 30 workers could share two units under a simple head count.

Toilets and urinals can be combined, but Section 1526(a) says the number of toilets must not be less than one half of the minimum required number of facilities.

Compare the federal rule, 29 CFR 1926.51(c)(1). Its table requires one facility for 20 or fewer employees; for 20 or more, one toilet seat and one urinal per 40 workers; and for 200 or more, one toilet seat and one urinal per 50 workers. The federal construction sanitation rule does not address separating facilities by sex. California's count is both tighter and split by sex.

Small crews and all-gender single-user toilets#

Section 1526 has two provisions that simplify the count where they fit.

Where there are fewer than five employees, one single-user toilet facility designated for all-gender use is sufficient.

For larger sites, each single-user toilet facility designated for all-gender use counts as one of the required separate facilities if all three conditions are met: the total number of facilities meets the ratio in subsection (a); all single-user facilities on the site are designated for all-gender use; and all multi-user facilities are provided in equal number to each sex. On most construction sites, where toilets are single-user portable units, that means a site can meet the rule with all-gender units, as long as every one of them is designated all-gender and the total equals what subsection (a) requires — still counted per sex, so 25 men and 5 women still means three units, not two.

Keep them usable#

A unit that exists but can't be used doesn't do its job. Section 1526 requires toilet facilities to be kept clean, maintained in good working order, designed and maintained in a manner that assures privacy, and provided with an adequate supply of toilet paper. A door that won't latch is a privacy problem; a full tank is a working-order problem; an empty roll is a violation in its own right. The service schedule should match the crew size, not the rental contract's default.

Where water closets are not feasible because there is no sanitary sewer or not enough water, Section 1526(c) requires nonwater-carriage facilities: unless local regulations prohibit them, these may include chemical, recirculating, or combustion toilets, or privies where their use will not contaminate surface or underground waters. Under temporary field conditions, not less than one toilet must be available. And the rule does not apply to mobile crews that have readily available transportation to nearby toilet facilities — which means the crew actually has a vehicle and the time to use it, not just a gas station somewhere down the road.

Washing stations: one for every 20#

Section 1527(a) adds the other half of sanitation. A minimum of one washing station is provided for each twenty employees or fraction thereof. Each station is maintained in a clean and sanitary condition, with an adequate supply of water for effective washing, a readily available supply of soap or other suitable cleansing agent, and a readily available supply of single-use towels or a warm-air blower. And washing stations are located and arranged so that any time a toilet is used, the user can readily wash.

Where washing stations go with non-water-carriage toilets — the usual portable unit — the rule requires a sign or equivalent notice that the water is for washing, and requires the station to be located outside the toilet facility and not attached to it. The one exception: where there are fewer than five employees and only one toilet facility, the washing facility may be located inside the toilet.

Section 1527 also covers the work itself. Where employees apply paints or coatings, or do other work involving substances that may be harmful, washing facilities must be provided near the work with enough water for effective removal, soap, and — where necessary to remove the substance — special cleansing compounds designed to remove it from the skin. On a job with wet cement, coatings, or lead-containing materials, a jug of water and a bar of hand soap may not meet that standard.

Where the duty sits#

8 CCR 1526 sets the toilet count — one per 20 or fraction of each sex — the urinal limit, the small-crew and all-gender provisions, and the rules for cleanliness, privacy, toilet paper, temporary field conditions, and mobile crews. 8 CCR 1527 requires one washing station per 20 employees or fraction, located so every toilet user can readily wash, with special cleansing compounds for harmful substances. For contrast, federal 29 CFR 1926.51(c) uses a looser ratio and does not address separation by sex.

What can go wrong?#

• One porta-potty serves a crew that grew from 15 to 30.
• Two women join the crew and nobody changes the toilet setup.
• Units are serviced weekly on a site with 40 workers.
• The washing station has water but no soap or towels.
• The painting crew has only a water jug to clean coatings off their hands before lunch.

How do we manage this properly?#

• Count by today's roster — one per 20 or fraction, for each sex.
• Recount when the crew changes — new trade, new shift, first woman on site.
• Use all-gender single-user units correctly — all of them designated, total count still met.
• Keep them usable — clean, working, private, stocked with paper, serviced to crew size.
• Wash station per 20 — water, soap, towels, next to the toilets.
• Right cleanser for the job — special compounds where people handle harmful substances.

Before you start#

Count today's crew by sex and compare it with the number of units. Check that every unit locks, is serviced, and has paper. Walk to the washing station and check water, soap, and towels.

Talk it over#

• Is there always a usable toilet close enough when you need it?
• Has anyone skipped drinking water to avoid a bad toilet?
• Who do you tell when a unit is full, broken, or out of paper?

The bottom line#

California counts job-site toilets at one per 20 employees or fraction for each sex, not one per crew. Fewer than five workers can share one all-gender single-user unit; larger sites can use all-gender single-user units if every one is designated that way and the total meets the ratio. Keep them clean, private, working, and stocked, and put a washing station with water, soap, and towels next to them — one for every 20 workers.

Frequently asked questions about Cal/OSHA jobsite toilets#

How many toilets does a California construction site need?

At least one separate toilet facility for each 20 employees or fraction thereof of each sex, under Section 1526(a). Where there are fewer than five employees, one single-user all-gender facility is sufficient.

Can we use all-gender portable toilets instead of separate men's and women's units?

Yes, if each is single-user and designated for all-gender use, all single-user units on the site are designated that way, and the total meets the ratio. Any multi-user facilities must be provided in equal number to each sex.

Does a crew that moves from site to site need its own toilets?

Not always. Section 1526 says its requirements do not apply to mobile crews that have readily available transportation to nearby toilet facilities, and Section 1527 has the same exception for washing facilities. The key words are "readily available" and "nearby": the crew needs a vehicle it can actually use and a facility close enough to reach without leaving the work for long. Where that is not true, the site needs its own toilets and washing station.

Download the Cal/OSHA toilets and sanitation toolbox talk PDF#

Download this Cal/OSHA Toilets & Sanitation Toolbox Talk as a printable PDF in English and Spanish, and recount the units every time the roster changes.

Related toolbox talks#

• Personal Hygiene
• Hydration
• Housekeeping
• Skin Hazards

Sources#

• Cal/OSHA, Title 8 CCR §1526 — Toilets at Construction Jobsites ((a) one separate toilet facility for each 20 employees or fraction thereof of each sex; toilets not less than one half of required facilities where urinals are used; fewer than five employees — one all-gender single-user facility; conditions for counting all-gender single-user facilities; clean, working order, privacy, toilet paper; alternatives where water-carriage toilets are not feasible; temporary field conditions; mobile crews exception; amended 3-3-2020, operative 7-1-2020): https://www.dir.ca.gov/title8/1526.html
• Cal/OSHA, Title 8 CCR §1527 — Washing Facilities, Food Handling, and Temporary Sleeping Quarters ((a) one washing station for each 20 employees or fraction thereof; clean, water, soap, single-use towels or warm-air blower; located so toilet users can readily wash; sign and location outside non-water-carriage toilets; may be inside where fewer than five employees and only one toilet facility; special cleansing compounds for harmful substances): https://www.dir.ca.gov/title8/1527.html
• OSHA, 29 CFR 1926.51(c) (federal: 1 facility for 20 or fewer; 1 toilet seat and 1 urinal per 40 for 20 or more; per 50 for 200 or more; temporary field conditions; mobile crews): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.51

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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