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.

October 25, 1996

David LeGrande
Occupational Safety and Health Director
Communications Workers of America
501 Third Street, NW
Washington, DC 20001-2797

Dear Mr. LeGrande:

This is in response to your letter of September 23 to Tom Seymour, Director, Safety Standards in which you asked if telecommunication companies still have to comply with the specific requirements noted in Table J-1 of 29 CFR 1910.141(c).

Paragraph (c) of 1910.141 deals with toilet facilities and Table J-1, as part of that paragraph, shows the number of water closets needed for specific numbers of employees. This standard has not been changed since October 24, 1978, therefore, any employer who is required to be in compliance with this standard must also take Table J-1 into consideration. Table J-1 has not been dropped from the standard.

I hope this is of some assistance to you. If you have any questions, please call Helen Hoban Rogers at (202) 219-8031 ex. 121.


John B. Miles, Jr., Director
Directorate of Compliance Programs