Standard Interpretations - Table of Contents
• Standard Number: 1910.142(f)(3)

November 14, 1988

MEMORANDUM FOR: PAULA V. SMITH, ADMINISTRATOR
  EMPLOYMENT STANDARDS ADMINISTRATION
 
FROM: THOMAS J. SHEPICH, DIRECTOR
  DIRECTORATE OF COMPLIANCE PROGRAMS
 
SUBJECT: Interpretation of OSHA Regulations, 29 CFR
  1910.142(f)(3), Adequate Supply of Hot
  Water in Temporary Labor Camps

In response to you memorandum of September 15, 1988, same subject, the Occupational Safety and Health Administration 29 CFR 1910.142(f)(3) in terms similar to your Atlanta Regional Office. The word "adequate" means that a sufficient capacity of hot water is available based upon the number of actual camp occupants.

In instances where the OSHA standard is performance oriented, the specifications necessary for compliance must be sought from local codes or from industry consensus standards. The minimum acceptable hot water generating and storage equipment necessary at a temporary labor camp may be determined from the data and analytic procedure published by the American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) Handbook-1987, Chapter 54. Chapter 54 of that publication addresses "Service Water Heating".

Under the OSHA standard at 29 CFR 1910.(c)(1) and (2), temporary labor camps are required to provide, as a minimum, 35 gallons of water per occupant. Using that basic information and the 1987 ASHRAE Handbook, Chapter 54, our engineering staff have identified the minimum acceptable hot water system to satisfy the requirement of 29 CFR 1910.142(f)(3). This system is less stringent than that identified as the Military Barracks chart, and it is not that the current Corps of Engineers Guide Specifications 15-400 do not include