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 http://www.osha.gov.

November 14, 1988

SUBJECT: Interpretation of OSHA Regulations, 29 CFR
  1910.142(f)(3), Adequate Supply of Hot
  Water in Temporary Labor Camps

In response to you memorandum of September 15, 1988, same subject, the Occupational Safety and Health Administration 29 CFR 1910.142(f)(3) in terms similar to your Atlanta Regional Office. The word "adequate" means that a sufficient capacity of hot water is available based upon the number of actual camp occupants.

In instances where the OSHA standard is performance oriented, the specifications necessary for compliance must be sought from local codes or from industry consensus standards. The minimum acceptable hot water generating and storage equipment necessary at a temporary labor camp may be determined from the data and analytic procedure published by the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) Handbook-1987, Chapter 54. Chapter 54 of that publication addresses "Service Water Heating".

Under the OSHA standard at 29 CFR 1910.(c)(1) and (2), temporary labor camps are required to provide, as a minimum, 35 gallons of water per occupant. Using that basic information and the 1987 ASHRAE Handbook, Chapter 54, our engineering staff have identified the minimum acceptable hot water system to satisfy the requirement of 29 CFR 1910.142(f)(3). This system is less stringent than that identified as the Military Barracks chart, and it is not that the current Corps of Engineers Guide Specifications 15-400 do not include the chart.

Where local codes do not specify more stringent requirements, the minimum hot water system recovery and storage capacities required to meet the OSHA standard at 29 CFR 1910.142 are:

1. The minimum gallons per hour (gph) recovery capacity of the hot water heater or coil is equal to 2.625 times the number of persons served by the system. (2.625 x no. of persons= ___ gph heater cap req'd.)

2. The minimum gallons of hot water storage capacity is equal to 3.28 times the number of persons served by the system. (3.28 x no. persons = ___ gallons tank cap. req'd.)

Hot water system requirements must be evaluated on the basis of the number of persons served by each system installed. Instantaneous type water heaters need not be equipped with a hot water tank but must, as a minimum, provide the gallons per hour delivery capacity as determined from the above equation. It is recommended that the minimum system recovery rate be 10 to 15 percent greater that the calculated values to allow for heat losses.

Should there be any further questions, please feel free to contact Mr. Joseph Bode of my staff at 523-8031.