OSHA Has ALWAYS Required Hand Washing Facilities

Posted By: Karleen Kos, CAE Covid-19 Resources , Standards and Regulations ,

OSHA Standards Have ALWAYS Required Hand Washing Facilities

In some parts of the country it is reported that inspectors are entering job sites and requiring them to have hand washing facilities for workers. This new awareness of hand washing during the COVID-19 pandemic is contributing to the current shortage of hand wash units available. It is frustrating for everyone.

Suppliers of hand wash stations are ramping up production of these units and expect deliveries soon. Meanwhile, portable sanitation operators have gotten creative about building temporary stations and modifying existing equipment, and they are finding all sorts of ways to meet their customers’ needs.

Though the day may seem a long way off right now, it is certain that the supply of hand wash units will ultimately align with demand. In the process, a big question for operators buying more hand wash units is this: “Will I still need all this equipment when COVID-19 is over?”

The short answer is, “Yes, you absolutely should be able to up your hand washing game considerably from now on.” That’s because – even though the Occupational Safety and Health Administration (OSHA) has issued new COVID-19 guidance for preparing workplaces -- the requirement for handwashing facilities is not new. It has always been in OSHA standards, as the PSAI has reported in numerous publications. (Check out our Industry Resource Library for some of them.)

The current shortage of hand wash facilities is not because of a new rule. It’s because there is increased awareness on the part of workers who are now demanding the hand washing facilities to which they’ve always been entitled under the law. It is also due to increased enforcement on the part of officials in some areas. So make note of the following, because it will help you choose hand washing stations now and going forward.

 

Standard

Covers

Toilets Required

Hand Wash Required

ANSI/PSAI Z4.3-2016

Anywhere nonsewered sanitation is needed

1 unit per 10 workers if serviced once a week

1 station per 10 toilets

OSHA 1926.51

 

Construction sites

1 unit per 20 workers which must be maintained in a sanitary condition

Each lavatory shall be provided with hot and cold running water or tepid running water, hand soap or similar cleansing products, and paper or cloth towels or a blow dryer

OSHA 1915.88

 

Shipyards

Units on a scale beginning with a 1:15 ratio

One unit at or adjacent to each toilet equipped as above

OSHA 1918.95

 

Longshore workers

No specific number; the standard just states toilet facilities must be “sufficient for the sanitary requirements of employees shall be readily accessible at the worksite”

 

No specific number; the standard just states, washing facilities must be “sufficient for the sanitary requirements of employees shall be readily accessible at the worksite” and equipped as above

 

As you can see, the PSAI/ANSI standard requires more than OSHA requires – and that is something to shoot for. It does not have the force of law. In 2020-21 we will begin the regular 5-year required update of the ANSI/PSAI standard which could well increase the hand washing requirements in the ANSI/PSAI standard. All that said, all OSHA standards do currently have the force of law. So at a minimum, you should always be able to promote the levels of equipment and service listed in the existing standards which you can read in full from this page of the PSAI website.Prior to the COVID-19 emergency, portable sanitation companies sometimes got push-back from customers because the OSHA standards do have some “outs” that make them think they don’t need to provide portable facilities. These mostly apply to mobile crews who can easily drive to sanitation facilities -- typically a group of workers on the move throughout their day, perhaps inspecting lines. It does not generally apply to job sites where everyone is in the same place. In fact, the existing OSHA rules specifically say these are the requirements on the job sites in most cases. And where toilets are provided, the OSHA standards also require hand wash stations.

In short, facilities for hand washing is not a new OSHA requirement, and when COVID-19 has passed, the need will still be there. The awareness the pandemic has raised about this issue may be one of the better outcomes of this difficult time