Field sanitation requirements

The Field Sanitation standard applies where eleven (11) or more employees are engaged on any given day in hand-labor operations in the field. See Scope in 1928.110(a).

• This threshold is counted for any single day of work in the field — if 11 or more hand-laborers are working that day, the standard applies.
• The standard is limited to agricultural settings performing hand-labor in the field, not to unrelated industries.

An "agricultural employer" is any person, corporation, association, or other legal entity that (i) owns or operates an agricultural establishment, (ii) contracts in advance and exercises substantial control over production, or (iii) recruits and supervises employees or is responsible for management and condition of the agricultural establishment. See the Definitions in 1928.110(b).

• This definition is broad and can include joint-employer situations where more than one entity recruits, supervises, or controls production.

"Hand-labor operations" are agricultural activities performed by hand or with hand tools and include tasks done in the field like hand-cultivation, hand-weeding, hand-planting, hand-harvesting, and hand-packing of produce; they do not include logging, care/feeding of livestock, or hand-labor performed in permanent structures. See the Definitions in 1928.110(b).

• The standard also clarifies that work done on the ground, on a moving machine, or in a temporary packing shed in the field counts as hand-labor.
• Activities outside field hand-labor or inside permanent buildings are excluded from this particular standard.

Employers must provide potable water placed in locations readily accessible to all employees, suitably cool and in sufficient amounts (considering temperature, humidity and work), and dispensed in single-use drinking cups or by fountains. See Potable drinking water requirements in 1928.110(c)(1).

• "Potable water" is defined in 1928.110(b) as water meeting state/local drinking standards or EPA standards; OSHA has also clarified that bottled water or non-piped sources are acceptable if they meet the potable definition (Potable water definition LOI).
• Employers must consider environmental conditions (heat, humidity) and the nature of the work when determining how much cool water to provide.

No — the standard prohibits common drinking cups or dippers; water must be dispensed in single-use drinking cups or by fountains. See 1928.110(c)(1)(iii).

• This requirement helps prevent disease transmission and maintain hygiene in the field.

An employer must provide one toilet facility and one handwashing facility for each twenty (20) employees or fraction thereof. See 1928.110(c)(2)(i).

• "Fraction thereof" means that any remaining number of employees after dividing by 20 still requires an additional facility (for example, 21 employees require two toilets and two handwashing facilities).

Toilet facilities must be adequately ventilated, appropriately screened, have self-closing doors that can be closed and latched from the inside, and be constructed to ensure privacy. See 1928.110(c)(2)(ii).

• These features are intended to provide sanitary, private, and usable facilities for workers in the field.

Facilities must be located within a one-quarter-mile walk of each hand laborer's place of work in the field; if terrain makes that infeasible, facilities must be located at the point of closest vehicular access. See 1928.110(c)(2)(iii) and 1928.110(c)(2)(iv).

• The rule balances prompt worker access (quarter-mile) with practical limits of terrain by allowing the closest vehicular access when necessary.

No — toilet and handwashing facilities are not required for employees who perform field work for a period of three (3) hours or less during the day, including transportation time to and from the field. See 1928.110(c)(2)(v).

• If work in the field exceeds three hours total (including travel), the facility requirements apply.

Employers must maintain potable drinking water and toilet/handwashing facilities in accordance with public health sanitation practices: drinking water containers must maintain water quality, be refilled daily or as needed, covered, and regularly cleaned; toilets must be operational and kept clean and sanitary; handwashing facilities must be refilled with potable water and kept clean; and waste disposal must not cause unsanitary conditions. See 1928.110(c)(3) and its subsections (c(3)(i)–c(3)(iv).

• OSHA has also advised that a portable unit’s design alone does not guarantee compliance; the unit must be properly used, serviced, and maintained to meet the standard (Portable toilet compliance LOI).

Employers must notify each employee of the location of sanitation facilities and water and allow reasonable opportunities during the workday to use them; they must also inform employees about key hygiene practices (use facilities for drinking/handwashing/elimination, drink frequently especially on hot days, urinate as needed, wash hands before/after using toilets, and wash before eating or smoking). See 1928.110(c)(4) and subparts (c(4)(i)–c(4)(v).

• OSHA’s general sanitation guidance also emphasizes that employers may not impose unreasonable restrictions on restroom use and must allow employees to use facilities when needed (Toilet facility access memo).

Employers had specific startup dates: potable drinking water under paragraph (c)(1) by May 30, 1987; handwashing and toilet facilities under paragraph (c)(2) by July 30, 1987; maintenance under paragraph (c)(3) by July 30, 1987; and assurance of reasonable use under paragraph (c)(4) by July 30, 1987. See 1928.110(d)(2) and its subparts (d(2)(i)–d(2)(iv).

• These are historical effective dates; the requirements themselves are currently enforceable when the standard applies.

No — employers generally may not substitute waterless hand cleaners for the handwashing facilities required by the standard because OSHA concluded that soap-and-water facilities are necessary to remove biological and chemical contaminants; waterless substitutes typically do not meet that standard. See 1928.110(b) definition of handwashing facility and the Washing facilities requirements LOI and Waterless handcleaning LOI which explain that moist towelettes or waterless cleaners are not adequate substitutes for soap and water in many agricultural situations.

• OSHA’s rulemaking record and subsequent interpretations found that running potable water with soap and single-use towels best reduces pesticide and biological risks and helps in flushing eyes/skin when exposures occur.

Entities that recruit, supervise, exercise substantial control over production, or are otherwise responsible for management and condition of an agricultural establishment can be treated as agricultural employers and may be jointly responsible for compliance. See the agricultural employer definition in 1928.110(b) and the Field Sanitation applicability LOI which explains joint-employer liability based on the facts of who recruits, supervises, or controls the work.

• Whether an entity is a joint employer depends on actual control and supervision, so employers and contractors should evaluate their roles and responsibilities to ensure compliance.

Yes — bottled water or non-piped water is acceptable as "potable water" if it meets the drinking-water quality standards of the state/local authority or EPA; OSHA does not require that potable water be piped or routinely tested by the employer. See the potable water definition in 1928.110(b) and the Potable water definition LOI.

• Employers must ensure whatever source they provide meets applicable drinking water standards.

Employers must provide one toilet per 20 employees (or fraction thereof), and if a portable toilet has a small capacity it must be serviced as often as necessary to accommodate the number of employees using it. See 1928.110(c)(2)(i) and the Portable toilet compliance LOI which states that service frequency must match use.

• In practice this means employers can use smaller portable units only if they increase servicing frequency so that availability and sanitary conditions meet the standard.

Yes — toilet and handwashing facilities must be accessibly located and in close proximity to each other. See 1928.110(c)(2)(iii).

• This requirement supports hygiene by making it practical for workers to wash hands immediately before and after using the toilet.

Drinking water containers must be made of materials that preserve water quality, refilled daily or more often as necessary, kept covered, and regularly cleaned. See 1928.110(c)(3)(i).

• Employers should adopt cleaning and refill schedules appropriate to environmental conditions (heat, dust) and worker numbers to ensure water remains potable.

When terrain makes it not feasible to locate facilities within a one-quarter-mile walk of each worker, the employer must locate the facilities at the point of closest vehicular access. See 1928.110(c)(2)(iv).

• Employers should document why quarter-mile placement is infeasible (steep terrain, impassable areas) and ensure facilities at the vehicular access point are serviced and accessible during work hours.

Employers must inform employees to drink water frequently and especially on hot days. See 1928.110(c)(4)(ii).

• This is part of the employer's duty to notify workers of hygiene practices to reduce heat-related illness and dehydration during field work.