Step 11: How to Comply With Site Illumination & Sanitation Requirements

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Hazwoper & Emergency Response |

Sections 1910.120(m) and (n) of Hazwoper deal, respectively, with illumination and sanitation of sites where covered operations take place. Here’s an overview of both sets of requirements.

Illumination Standards


Areas accessible to employees must meet minimum illumination requirements set out in Table H-120.1 of the Standard:


Foot-candles Area or operations


General site areas.


Excavation and waste areas, accessways, active storage areas, loading platforms, refueling, and field maintenance areas.


Indoors: warehouses, corridors, hallways, and exitways.


Tunnels, shafts, and general underground work areas; (Exception: minimum of 10 foot-candles is required at tunnel and shaft heading during drilling, mucking, and scaling. Mine Safety and Health Administration approved cap lights shall be acceptable for use in the tunnel heading.


General shops (e.g., mechanical and electrical equipment rooms, active storerooms, barracks or living quarters, locker or dressing rooms, dining areas, and indoor toilets and workrooms.


First aid stations, infirmaries, and offices.


Sanitation Standards at Temporary Workplaces


The first set of requirements deal with potable, i.e., drinkable water, including:

  • There must be an adequate supply of potable water on the site;
  • Portable containers used to dispense drinking water must be capable of being tightly closed, and equipped with a tap;
  • Water may not be dipped from containers;
  • Any container used to distribute drinking water must be clearly marked as to the nature of its contents and not used for any other purpose; and
  • Where single service cups (to be used but once) are supplied, both a sanitary container for the unused cups and a receptacle for disposing of the used cups must be provided.

Separate requirements apply to non-potable water, e.g., water used to fight fires:

  • Outlets for non-potable water must be identified to indicate clearly that the water is unsafe for drinking, washing or cooking; and
  • There must be no cross-connection, open or potential, between a system furnishing potable water and a system furnishing non-potable water.

Toilets must be provided for employees according to Table H-120.2 of the Standard:


Number of employees Minimum number of facilities
20 or fewer One.

More than 20, fewer than 200

One toilet seat and 1 urinal per 40 employees.

More than 200

One toilet seat and 1 urinal per 50 employees.

Under temporary field conditions, provisions must be made to assure not less than one toilet facility is available.

Hazardous waste sites that don’t have a sanitary sewer, must have the following toilet facilities unless banned by local codes:

  • Chemical toilets;
  • Recirculating toilets;
  • Combustion toilets; or
  • Flush toilets.

Exception: The above requirements for sanitation facilities don’t apply to mobile crews that have transportation readily available to nearby toilet facilities.

Doors entering toilet facilities must have entrance locks controlled from inside the facility.

Other Sanitation Requirements

All food service facilities and operations for employees must meet the applicable laws, ordinances and regulations of the places they’re located.

Temporary sleeping quarters, if provided, must be heated, ventilated and lit.

The employer must provide adequate washing facilities for employees engaged in operations where hazardous substances may be harmful to employees. Such facilities must be:

  • Close to the worksite;
  • In areas where exposures are below permissible exposure limits and under the controls of the employer; and
  • Equipped so as to enable employees to remove hazardous substances from themselves.

Hazardous waste clean-up or removal operations requiring 6 or more months to complete must have on-site showers and change rooms for all employees exposed to hazardous substances and health hazards involved in hazardous waste clean-up or removal operations.

Showers must meet the requirements of the Sanitation standard for general industry, 29 CFR 1910.141(d)(3).

Change rooms must also meet the requirements for change rooms under the Sanitation standard, 29 CFR 1910.141(e).and consist of two separate change areas separated by the shower area. One change area, with an exit leading off the worksite, should provide employees with a clean area where they can remove, store and put on street clothing. The second area, with an exit to the worksite, should provide employees with an area where they can put on, remove and store work clothing and personal protective equipment.

Showers and change rooms must be located in areas where exposures are below the permissible exposure limits and published exposure levels. If this can’t be accomplished, a ventilation system must be provided to supply air that’s below the permissible exposure limits and published exposure levels.

Last but not least, employers must ensure that employees shower at the end of their work shift and when leaving the hazardous waste site.

OSHA Guidelines

Compliance Guidelines (Appendix C)