Washroom facilities on construction sites
On October 1, 2024, amendments to the Occupational Health and Safety (OHS) Regulation relating to washroom facilities at construction sites came into effect. These changes mean that employers at “specified” construction sites must provide flush toilets, handwashing facilities, and clean, well-maintained washrooms. A “specified” construction site is defined as a construction site where 25 or more workers will be present during the project.
By Steven Gilstead
These changes were made to ensure that workers on specified construction sites are provided with clean, well-maintained, flush toilets where practicable.
“Over the next few months, Prevention Officers will take a consultative approach to ensure affected employers are aware of the new requirements,” says Suzana Prpic, director, Prevention Field Services. “This will allow employers time to evaluate the new provisions, source facilities, and modify their worksites.”
What it means for employers
Employers will need to determine at the start of a project if they will have 25 or more workers on site at any time during the project.
“If so, the new requirements will apply throughout the project’s duration, and the employer will need to plan accordingly,” Prpic says. “The 25-worker threshold excludes short-term visitors like delivery drivers, emergency responders, and regulators.”
On multi-employer workplaces, health and safety is the prime contractor’s responsibility. This responsibility includes determining the practicability of flush toilets and installing them as appropriate.
Flush toilets must be plumbed or connected to a holding tank. Employers may only provide chemical or other types of toilets if they can demonstrate it is not practicable to comply with the requirement to provide flush toilets.
Washrooms must be well maintained, cleaned, and sanitized regularly, with handwashing facilities in or near the toilets. Cleaning and maintenance records may be handwritten or digital, but they must be kept for at least 30 days and available for inspection.
Assessing practicability
“While the OHS Regulation defines practicable as meaning that which is reasonably capable of being done, it depends on the circumstances of each workplace and is site specific to each construction site,” Prpic explains.
There are two elements employers must consider when determining what is practicable:
- What is capable of being done under the circumstances
- Whether it is reasonable in the circumstances to do all that is capable of being done
Due to the dynamic nature of construction projects, employers must constantly reassess the practicability of flush toilets by regularly reviewing the construction project.
For example, while excavating a site, there may be no fixed location to install flush toilets. However, once this phase is complete, there should be an area where flush toilets could be installed.
Worker participation
Where possible, the employer should regularly consult with their joint health and safety committee and all workers when implementing the new requirements.
“Creating and managing a safe and healthy workplace involves everyone,” says Prpic. “Where possible, the employer should regularly consult with their joint health and safety committee and affected workers during the course of the construction project when determining the practicability of flush toilets. Consultation with workers at a particular workplace is an important means of obtaining relevant information in determining practicability.”
For more information
WorkSafeBC has developed guidelines and resources to support employers in implementing the new requirements. For more information, visit worksafebc.com:
- Occupational Health and Safety Regulation
- OHS Guideline G20.3.2 Washroom facilities required at specified construction sites
- Regulatory amendment: A primer on washroom facilities at construction sites
- Washroom facilities at construction sites: Frequently asked questions
This information originally appeared in the Winter 2024 issue of WorkSafe Magazine. To read more or to subscribe, visit WorkSafe Magazine.
Please help us understand how WorkSafe Magazine can serve you best by completing our online survey.