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Toilet facility access and location

Summary An attorney asked OSHA to clarify workplace toilet-facility requirements. The regional office described the then-applicable toilet and lavatory counts, said the rule set no specific distance or location, and considered the described U-Haul arrangements consistent with its intent while noting weather hazards. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1976-08-04
Date issued
August 4, 1976
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 4, 1976
Mr. Richard Kops
Attorney at Law
[Recipient address omitted]
Dear Mr. Kops:
This is in response to your letter requesting clarification of OSHA standards for toilet facilities.
The OSHA Standard 29 CFR 1910.141 on page 23673 of the Federal Register dated June 24, 1974 Volume 39 #125 requires that toilet facilities shall be provided for each sex separately with one facility for each 15 to 20 persons (see Table J1). There shall be one lavatory for each three toilet facilities (OSHA Program Directive 100-42 dated November 18, 1975). There are no specific distances or location requirements. Therefore reasonableness in evaluating the availability of sanitary facilities will be the rule.
Based upon the preceding, it appears that U-Haul complies with the intent of the OSHA Standard. However, we would call attention to the hazards of weather, its effect on employee health and the dangers of icy walks and similar exposures.
We have mailed several OSHA brochures including the above noted Federal Register under separate cover.
Sincerely,
Alfred Barden
Regional Administrator
Occupational Safety and Health

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