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Guide

OSHA Toilet Rules for El Paso Construction Sites

The OSHA toilet table by crew size, the sanitary and distance interpretations, and the I-10 and Loop 375 road jobs that bring crews to El Paso.

Illustration for the guide "OSHA Toilet Rules for El Paso Construction Sites" (El Paso, TX)
Short answer

OSHA's toilet table in 29 CFR 1926.51(c)(1) sets toilet numbers by crew size: one facility for 20 or fewer workers, then one seat and one urinal per 40 workers above that, and per 50 at 200 or more. The federal table applies in El Paso and across both states. El Paso Porta Potty Rental connects you with a local provider who sets units to the crew.

Key takeaways

  • The table in 29 CFR 1926.51(c)(1) sets toilet numbers by crew size.
  • The printed tiers overlap at 20 workers, so the count is agreed with the crew foreman.
  • An OSHA interpretation dated 17 May 2006 says an unsanitary toilet does not count toward the minimum, though the standard does not require it to be immaculate.
  • Mobile crews may use toilets nearby under the standard's transport provision, which should be written down rather than assumed.
  • I-10 and Loop 375 road projects bring crews to El Paso; their current status was not sourced.

How many toilets does a crew need under the table?

The table counts toilets by crew size: one facility for 20 or fewer workers, one seat and one urinal per 40 workers above 20, and one per 50 at 200 or more.

The printed tiers overlap at 20 workers. For that reason this guide does not state the boundary as a single rule, and the crew foreman and the provider should agree the number together.

A crew that works in one place needs the count for that place. A crew that moves between sites needs the count and the arrangement for each one.

Toilet count by crew size (29 CFR 1926.51(c)(1))
Crew sizeRequirement
20 or fewer workersOne toilet facility
More than 20 workersOne toilet seat and one urinal per 40 workers
200 or more workersOne toilet seat and one urinal per 50 workers

What does 'sanitary' mean for a unit on site?

An OSHA interpretation dated 17 May 2006 says an unsanitary toilet does not count toward the minimum, but the standard does not require it to be immaculate.

A unit that is not kept in usable condition may not count toward the minimum. A provider's servicing schedule is therefore part of the compliance plan, not only a cleaning task.

The same interpretation does not require a toilet to be spotless. Ask the provider for the servicing interval in writing, and for a unit to be emptied before it fills.

How far can a crew be from a toilet?

A separate OSHA letter treats reaching a toilet in under about ten minutes as the starting test, and the mobile-crew provision allows transport to nearby toilets.

The sources reviewed describe reaching a toilet in under ten minutes as the starting test. The standard's provision for mobile crews allows transport to nearby toilets.

A crew that moves between lots or road sections should have the arrangement written down. A unit at each work zone is the simplest way to meet the test on a road job.

Do the El Paso road projects change the count?

TxDOT's I-10 West widening, the Loop 375 work and the I-10 Connect project bring crews to El Paso, but their current status was not sourced, so the count follows the crew actually on site.

A February 2026 report said I-10 West Phase I was due to finish by the end of March, with Phase II lane switches and closures to follow. Loop 375 closures were scheduled for January and July 2026. The I-10 Connect project is where US 54 meets I-10.

Describe this work as work in recent years. Ask the provider for the current schedule rather than assuming a project is under way.

Frequently asked questions

Does the OSHA table apply in New Mexico?

Yes. The federal table applies to construction sites across both states, so a Sunland Park or Santa Teresa job uses the same count by crew size.

Does one toilet per 20 workers match the table?

No. Some contractor guides say that, but it does not match the table in 29 CFR 1926.51(c)(1), which is the source to use.

Who is responsible for toilets on a job site?

The standard applies to the employer on the site. Agree the count and the servicing schedule with the provider in writing.

Can a unit be placed far from the crew?

Only where the mobile-crew provision allows it. Write the arrangement down, and place a unit near each work zone where you can.

Sources

  1. OSHA – 29 CFR 1926.51 Sanitation
  2. Texas Department of Transportation

This guide is general information for El Paso County homeowners, not a substitute for an on-site inspection. Prices are estimates. See our disclaimer.

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