Diet, medication use, and medical condition are among the factors that can affect the frequency of defecation. Medical studies show the importance of regular urination, with women generally needing to void more frequently than men. This is particularly significant because the field sanitation standard arose out of the only OSHA rulemaking to address explicitly the question of worker need for prompt access to toilet facilities. The language and structure of the general industry sanitation standard reflect the Agency's intent that employees be able to use toilet facilities promptly. Similarly, a clear intent of the requirement in Table J-1 that adequate numbers of toilets be provided for the size of the workforce is to assure that employees will not have to wait in long lines to use those facilities.
Timely access is the goal of the standard.
This provision was obviously intended to provide these employees with protection equivalent to that the general provision provides to to employees at fixed worksites. Read together, the two provisions make clear that all employees must have prompt access to toilet facilities. OSHA has also made this point clear in a number of letters it has issued since the standard was promulgated. In light of the standard's purpose of protecting employees from the hazards created when toilets are not available, it is clear that the standard requires employers to allow employees prompt access to sanitary facilities. Restrictions on access must be reasonable, and may not cause extended delays.