Kevin Lindley, FRSA-SIF Safety Rep - December 2025
Anyone who has spent time on a construction site knows that nature doesn’t always wait for a convenient moment. The need to use a restroom can arise suddenly, yet for many field workers, especially those in remote or difficult locations, suitable facilities may not be available. This seemingly simple issue can have serious implications for worker health, safety and dignity. It also raises an important question: what are an employer’s responsibilities regarding restroom access on jobsites and what does OSHA require?
OSHA addresses sanitation requirements for the construction industry under 29 CFR 1926.51. Subpart A of this section covers drinking water standards, while Subpart C specifically outlines the requirements for “toilets at construction jobsites.” According to OSHA, one toilet is required for every jobsite with 20 or fewer employees. As crew size increases, the
number of toilets required increases per the table provided within the OSHA regulation. Where permanent plumbing is unavailable, OSHA allows for portable toilets that meet certain sanitary standards. However, the regulation makes an exception for “mobile crews having transportation readily available to nearby toilet facilities.”
Workers who continually or frequently move from jobsite to jobsite on a daily or hourly basis would be considered a “mobile crew.” This definition easily applies to many field construction crews. The phrase “readily available” is defined as “easy to get, find or use without difficulty or delay.” The key question then becomes: what constitutes “without difficulty or delay?”
If a worker must ask a coworker who is the driver for transportation, this could create difficulty, especially if the driver is busy or uncooperative. If accessing the restroom depends on the availability of transportation or the schedule of others, delays are likely. In such cases, OSHA’s “readily available” condition may not be met.
If restroom facilities are within a short walking distance, ideally ten minutes or less, workers can reasonably excuse themselves to get there on foot. Otherwise, employers should ensure that onsite toilets are provided.
Providing restroom access is not only about regulatory compliance – it’s about respecting employees’ dignity, protecting their health and maintaining company integrity. Requiring workers to relieve themselves in wooded areas or behind structures poses numerous risks. There are potential legal and reputational issues if such acts are observed by the public, clients or nearby residents. Health risks may also arise, including dehydration, urinary tract infections and other medical issues caused by delaying restroom use. Productivity losses are another concern, particularly when workers must leave the site or rely on others for transportation. When two employees are required for a restroom trip, lost time doubles.
Roofing and construction are demanding trades. Workers already face enough physical challenges and hazards. Ensuring access to a clean, private restroom is a small but essential gesture – one that supports health, morale and professionalism. Providing a toilet isn’t just an OSHA requirement, it’s a reflection of respect for your crew and a commitment to doing
business the right way.
Interested in obtaining workers’ comp insurance? Contact Alexis at BrightFund at 800-767-3772 ext. 206 or alexis@brightfund.com.