Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

August 4, 1976

Mr. Richard Kops
Attorney at Law
1110 Lincoln Avenue
Holbrook, New York 11741

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.


Alfred Barden
Regional Administrator
Occupational Safety and Health