Soap Issue Continues to Be Slippery

   As you may know, I installed a soap dispenser in the Ladies Room at Lees Ferry this summer. In less than 24 hours, I was asked to remove it by the Park Service. This has been an on going THING with me. Why are the Concessioners expected to follow Federal Regulations and the National Parks seem exempt?

Patty Ellwanger

   January 8, 1993

   Allison Good, Safety Manager
   Glen Canyon National Recreation Area

   Dear Allison, After attending the Seminar at the South Rim on Safety and Health for Grand Canyon Concessioners I realized you may be helpful in solving a potential health problem for those of us who frequently use the restroom facilities at Lees Ferry.

   Commercial Guides as well as the many visitors to Glen Canyon have been asking the Rangers for soap to be available in the public restrooms since they have been constructed. In July 1992 a letter was written to the River Unit concerning this matter. The letter was referred to Superintendent Lancaster, who stated, “…reasons why we do not, which includes improved personal sanitation, the maintenance of soap dispensers, added cost of soaps, liability of soap products, vandalism to dispensers, theft of bar soap, etc."

   Isn’t all that irrelevant when the Code of Federal Regulations states, “Hand soap or similar cleansing agents shall be provided.” Please refer to 29 CFR 1910.141 (c) (2) (iii); concerning this matter.

   Sincerely’

   Patty Ellwanger

   March 11, 1993

   Dear Ms. Ellwanger,

   This letter is written in response to your correspondence dated January 8, 1992, requesting handsoap in the Lees Ferry restroom facilities. You stated that commercial guides as well as Glen Canyon visitors have asked rangers for soap to be available in the public restrooms.

   Problems such as the maintenance of soap dispensers, added cost of soaps, liability of soap products, vandalism to dispensers, theft of bar soap, and effect on a leach field that is at capacity are factors which have lead to our policy decision.

   In Addition, you cited 29 CFR 1910.141 (c) (2) (iii) as the regulation that requires handsoap be made available. This is the Occupational Safety and Health Administration regulation which governs industrial operations. The Lees Ferry restrooms are for public use, and our personnel do not use these facilities to address their sanitation needs. It is our recommendation that if commercial guides consistently request soap to be available, that they carry soap on their trucks to be used at their convenience.

   We hope you understand our position on this matter, and we appreciate your continued interest in Lees Ferry.

   Sincerely,

   John O. Lancaster
   Superintendent