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 https://www.osha.gov.

July 5, 1983

Ms. Jeanne E. Fisher
501 West University Parkway
Baltimore, Maryland 21210

Dear Ms. Fisher:

This is in response to your letter of May 11, 1983, to Secretary of Labor, Raymond J. Donovan, requesting a clarification of 29 CFR 1910.141(c). Please accept my apology for the delay in responding.

There are no specific distance or location requirements for toilet facilities in 29 CFR 1910.141(c). An employer is, however, expected to use reasonable judgment in evaluating the proximity of sanitary facilities to employees. If an employer provides the required toilet facilities for all employees in the same building and provides unobstructed free access to them, it appears the intent of the standard would be met; however, one floor serving 20 floors does not appear reasonable or appropriate.

This interpretation is based on the Federal standard for sanitation. The State of Maryland, however, administers its own program of workplace safety and health standards under the authority of Section 18 of the Occupational Safety and Health Act. The Maryland program generally adopts standards identical to the equivalent Federal standards.

For information on the Maryland program you may contact:


Nancy Burkheimer, Deputy Commissioner
Maryland Division of Labor
and Industry
Department of Licensing and Regulation
501 St. Paul Place
Baltimore, Maryland 21202
Telephone: (301) 659-4176

If I may be of further assistance, please feel free to contact me.


Thorne G. Auchter
Assistant Secretary