Water and Sanitation Toolbox Talk
This is the talk nobody gives, about the complaint every crew has. It is also a real standard with real numbers in it, which most people on both sides of the argument do not know.
Print this talk with the sign in lines on it
One page to read from, with space for the job, the date, who led it and twelve signatures. Print it, read it, get it signed, file it.
Free, no signup, no email, no watermark.
The talk, read this out
Two questions. Where is the drinking water on this site, and how many toilets are there for how many people? Somebody count.
An adequate supply of potable water shall be provided in all places of employment. Potable means it meets the drinking water standards of the state or local authority, or the EPA's National Primary Drinking Water Regulations at 40 CFR part 141. Not a hose off the standpipe.
The container rules are specific and they are about disease, not tidiness. A portable container used to dispense drinking water shall be capable of being tightly closed and equipped with a tap, and water shall not be dipped from containers. Any container used for drinking water shall be clearly marked as to its contents and not used for anything else.
And one flat prohibition, four words long: the common drinking cup is prohibited. If single service cups are supplied then there has to be a sanitary container for the clean ones and a receptacle for the used ones, which is the bit everybody forgets.
Nonpotable water, meaning water for industrial or firefighting purposes, gets signs saying clearly that it is unsafe and not to be used for drinking, washing or cooking. And there shall be no cross connection, open or potential, between a potable and a nonpotable system. Potential. A hose that could be swapped over counts.
Toilets, and there is a table. Twenty or fewer employees: one facility. Twenty or more: one toilet seat and one urinal per 40 workers. Two hundred or more: one toilet seat and one urinal per 50 workers. Under temporary field conditions there shall be not less than one toilet facility available, and where there is no sanitary sewer the options are privies where they will not contaminate ground or surface water, chemical, recirculating or combustion toilets.
There is one exception and it gets stretched further than it goes. The toilet requirements do not apply to mobile crews having transportation readily available to nearby toilet facilities. Readily available transportation to a facility that exists. Not a petrol station eight minutes away that somebody might let you use.
Washing facilities. The employer shall provide adequate washing facilities for employees applying paints, coatings, herbicides or insecticides, or in other operations where contaminants may be harmful, in near proximity to the worksite and equipped to actually remove the substance. Lavatories shall be available in all places of employment, with hot and cold running water or tepid running water, hand soap or similar cleansing agent, and individual towels, air blowers or clean sections of continuous cloth toweling.
That last one matters more than it sounds on a job with lead, silica, solvents or pesticides, because the route into somebody is a sandwich eaten with the hands they have been working with. Which is also why no employee shall be allowed to consume food or beverages in a toilet room, nor in any area exposed to a toxic material.
And if a standard requires protective clothing because of contamination with toxic materials, change rooms with separate storage for street clothes and for the protective clothing have to be provided. Separate. The point is that the contaminated kit never touches what somebody wears home to their family.
Point at these before anybody starts
A talk delivered in a trailer is a meeting. Stand where the work is and put a hand on each of these.
- The drinking water: is it potable, is the container tapped and closed, is it marked.
- Cups. A sanitary container for clean ones and a bin for used ones, or neither.
- The head count today against the table, and whether the toilets match it.
- Soap, water and towels at the lavatory, all three, not two of three.
- Where people are eating, and what is in the air or on the ground there.
- For anybody on paint, coating, herbicide or insecticide: somewhere to wash it off, near the work.
The rules that apply
- An adequate supply of potable water shall be provided in all places of employment. The common drinking cup is prohibited. Portable dispensing containers shall be capable of being tightly closed, equipped with a tap, clearly marked and not used for any other purpose, and water shall not be dipped from them.
- Outlets for nonpotable water shall be identified by signs indicating clearly that the water is unsafe and not to be used for drinking, washing or cooking, and there shall be no cross connection, open or potential, between potable and nonpotable systems.
- Toilets shall be provided per Table D-1: one facility for 20 or fewer employees; one toilet seat and one urinal per 40 workers at 20 or more; one toilet seat and one urinal per 50 workers at 200 or more. Under temporary field conditions not less than one toilet facility shall be available.
- The toilet requirements do not apply to mobile crews having transportation readily available to nearby toilet facilities.
- Adequate washing facilities shall be provided for employees applying paints, coatings, herbicides or insecticides or in other operations where contaminants may be harmful, in near proximity to the worksite. Lavatories shall have hot and cold or tepid running water, hand soap or similar cleansing agents, and individual towels or air blowers.
- No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material. Where protective clothing is required because of contamination with toxic materials, change rooms with separate storage for street clothes and protective clothing shall be provided.
Ask the crew
Three questions, answered out loud by name. This is the part that tells you whether anybody was listening.
- How many toilets does a crew of 60 need under the table?
- What are the three things that have to be at a lavatory?
- Who on this site is covered by the mobile crew exception, and who only thinks they are?
Close with this
None of this is a comfort issue. Every line in it is there because something got into somebody.
A talk nobody signed for is a talk that, as far as anybody can later prove, never happened. Use the free toolbox meeting sign in sheet in PDF, Word or Excel, or print the PDF above, which already has the signature lines on it.
Questions people ask
How many toilets does my site actually need?
Table D-1: one facility up to 20 employees, then one toilet seat and one urinal per 40 workers at 20 or more, and per 50 workers at 200 or more. The count is employees on site, so it moves with the job, and a site that grew from 15 to 45 over a month is a site whose provision no longer matches the table.
Does the mobile crew exception cover my van crew?
Only if transportation to nearby toilet facilities is readily available, which means a facility that exists, that the crew can use, and that they can get to without asking. It is written for crews that move between locations all day, not as a general exemption for small crews working one fixed site out of a van.
Is cold water enough at the wash station?
1926.51(f)(3)(ii) requires each lavatory to have hot and cold running water, or tepid running water. Cold alone does not meet it, and on work with lead, solvents or pesticides it also does not work, because the whole purpose of the facility is being able to actually remove the substance.
More toolbox talks
TOOLBOX TALK: WATER AND TOILETS
Attendance
Everybody who was present signs, including subcontractors and anybody visiting the site.