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French Labour Code R.4228 and Site Sanitary Facilities

7 min read

On a construction site in France, sanitary facilities fall under the Code du travail (French Labour Code): the general rules in articles R.4228-1 onwards, supplemented by a section specific to construction (articles R.4534-137 onwards). Compliance is checked by the labour inspectorate. Under article L.4741-1, an employer or their delegate who breaches these rules through personal fault faces a criminal fine of up to €10,000, applied as many times as there are employees affected. Below is what the rules say and where a waterless urinal fits in.

How many toilets and urinals

Article R.4228-10 sets the minimum: one toilet and one urinal per twenty men, two toilets per twenty women. The headcount is the maximum number of workers present at the same time. At least one toilet must have a water point. Where men and women work together, toilets are separate, and those for women include a bin for sanitary products.

So the urinal comes in addition to the toilet, not instead of it: a crew of forty men needs two toilets and two urinals. On structural or roofing work, where crews are mostly male, the urinal takes much of the load at peak times – the start of a shift and the lunch break.

What each toilet must provide

The following articles set out the fit-out:

  • R.4228-11: toilets do not open directly onto enclosed work areas, give off no odour, have a flush and are supplied with toilet paper;
  • R.4228-12: they are ventilated and adequately heated;
  • R.4228-13: floors and walls are made of impermeable, easy-to-clean materials, and toilets and urinals are cleaned and disinfected at least once a day;
  • R.4228-14: doors are solid, with an inside lock that can be released from outside;
  • R.4228-15: waste is disposed of in line with health regulations.

Rules specific to construction sites

For sites lasting four months or less, article R.4534-137 allows departures from the general sanitary rules, R.4228-10 included, provided the construction section is followed. That section requires, among other things:

  • toilets that comply with articles R.4228-11 to R.4228-15 (R.4534-144);
  • enough drinking water for personal hygiene; without running water, a drinking-water tank connected to the washbasins; on these short sites, one washbasin tap per ten workers (R.4534-141);
  • fresh drinking water, at least three litres per worker per day where there is no running water (R.4534-143);
  • if the layout of the site does not allow toilets to be installed, premises or a spot nearby offering at least equivalent conditions (R.4534-145).

The client has duties too. Under article R.4533-1, a building project worth more than €760,000 must have drinking water, electricity and a wastewater outlet in place before contractors arrive, so that staff facilities can comply.

The PPSPS and its hygiene section

On sites that require a general coordination plan, every contractor, subcontractors included, draws up a PPSPS (plan particulier de sécurité et de protection de la santé – site-specific health and safety plan) before work starts and hands it to the safety coordinator (article L.4532-9). Under article R.4532-67, the plan describes hygiene measures for working conditions and staff facilities, giving for each installation its location on site and its expected date of commissioning.

For this section, Pi-Pi provides a manufacturer’s statement (material, country of manufacture), the product specification sheet, a photo of an installed urinal and a diagram of the connection to the tank. The documents are sent by email.

The OPPBTP, the construction industry’s prevention body, advises companies and publishes practical guidance on these facilities. Inspection is the job of the labour inspectorate.

Winter on site

Article R.4228-12 requires heated toilets, but the equipment itself goes through the cold: transport, loading, outdoor installation. Sites run all year, including in the Grand Est, Hauts-de-France and the mountains. Polypropylene homopolymer becomes brittle around 0 °C. Pi-Pi’s LLDPE stays flexible down to −40 °C.

Connecting to the tank

The Pi-Pi urinal mounts on the wall of a portable toilet cabin or inside a sanitary unit, with no plumbing work. Its stepped outlet, Ø24/32/40 mm, takes hoses and connectors of these diameters. A sample lets you check the fit on your own cabins’ tanks.

What the urinal does not cover

Pi-Pi is one part of the sanitary unit, not a complete answer to the Labour Code. You still need toilets, washbasins, drinking water, lighting and heating; the cabin and the emptying contractor take care of the rest. Pi-Pi handles one thing: urinating standing up, collected separately.

Conclusion

One toilet and one urinal per twenty men: apart from the exemption for short sites, that is what article R.4228-10 requires. The Standard or Standard Plus urinal is usually fixed to the wall of an existing cabin in 5–7 minutes and works without water; it stays flexible down to −40 °C, and its smooth surface makes it easy to clean.

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Pi-Pi Products

Waterless Urinals

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Wall-mounted waterless urinal for cottages, allotments, and homes without plumbing: model with a closed top or with a Ø70 mm port for connection to a composting toilet. No water, no flushing.

from £33.90 + shipping £3.90

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Durable plastic sink for the same cottage, garage, and workshop: impact-resistant, withstands frost down to −40 °C, mounts to the wall without a plumber, water drains into a bucket or canister.

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Have Questions?

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Mart Tamm

Mart Tamm

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