The Inclusive Jobsite: Women's Health Accommodations in Construction

Mar 24

This post was contributed by Mathilde Roux, policy analyst and WSCCE Consultant. Mathilde brings deep expertise to this topic — she co-authored a September 2024 U.S. Department of Labor Women's Bureau report, Let's Talk About It: Menstruation and Menopause at Work, which examined how these experiences affect workers, the legal protections available to them, and what employers can do to improve workplace conditions. As the construction industry works to recruit and retain its workforce, women's health issues are an important part of the conversation that employers can no longer afford to overlook.

Menstruation is a normal part of life for most people with a uterus, but that doesn’t mean managing symptoms is always easy, and experiences can vary dramatically. While some have few symptoms or light bleeding, others face serious disruptions that can make work difficult. When employers fail to understand or accommodate menstruation, they risk losing experienced workers or creating preventable health and safety hazards. The good news? Creating a menstruation-friendly workplace is straightforward and low-cost.

What is Menstruation?

The menstrual cycle is a hormonal process that typically involves monthly bleeding, referred to as menstruation or a “period.” Menstrual cycle length can vary from month to month, but a regular cycle is generally between 24 and 38 days long.[1] During the transition to menopause, cycles may become less regular, and changes in duration and amount of bleeding are common. Symptoms such as painful cramping, headaches, trouble sleeping, or heightened anxiety may also occur during this cycle. For some, symptoms can be severe and cause them to miss work.[2], [3] Certain health conditions, such as endometriosis, uterine fibroids or polyps, ovarian cysts, and polycystic ovary syndrome (PCOS), can cause irregular cycles or more severe symptoms.[4]

The Business Case for Menstruation Support

According to the Bureau of Labor Statistics, women make up 11.2% of workers in the construction industry (which includes office and administrative occupations), and 4.3% of workers in construction and extraction occupations.[5] This means that many workers menstruate while employed in construction. In addition to managing symptoms, workers who menstruate may face stigma and lack of understanding from those around them. This is especially challenging in male-dominated industries where they may have few or no colleagues who understand what they are experiencing. They may also be hesitant to share their experience for fear of being treated like they are unreliable or unable to do their job well because of their period. In reality, they may just need small adjustments to continue to reach their full potential. Some workers have also faced harassment and unwelcome remarks, including jokes, related to their symptoms.[6]

Menstruation and its symptoms can impact people at work, and the work environment and working conditions can impact workers’ menstrual cycles. For example, workers experiencing painful cramps or headaches may have a hard time focusing at work. And stress, cold work environment, strenuous activity and heavy lifting, irregular or unpredictable schedules, night work, and long shifts can all impact the menstrual cycle. And when workers are unable to change their menstrual products frequently enough, they may develop infections, leading to absenteeism to manage symptoms and obtain treatment.

Construction employers should be aware of the symptoms of menstruation. Failing to address menstruation at work can cause absenteeism and retention issues if workers are unable to manage their symptoms at work. It can also increase workers’ risk of injuries or health issues. We can reduce those risks and support people through practical jobsite controls and accommodations, many of which are low or no cost. You may find that many of the jobsite controls and accommodations suggested in this blog are already implemented in your workplace. And implementing them may also benefit workers who are not menstruating.

Legal Considerations

Employers may face legal issues under federal or state law for failing to address menstruation adequately in the workplace. In July 2025, Washington State began enforcing a state law requiring construction employers to provide time and space for workers who menstruate or express breast milk to attend to those needs.[1] The law requires employers to provide access to restrooms and an adequate and convenient supply of menstrual hygiene products at no cost.[2] Specifically:

Access to restrooms:

Minimum size bathroom-equivalent to a standard sized portable chemical toilet;
Internal latch (lock) to prevent inadvertent entry; and
Adequate time to accommodate for multiple layers of clothing while using the room.

Adequate and convenient supply of menstrual hygiene products at no cost to employees:

Products must be located in all gender-neutral bathrooms and bathrooms designated for workers who menstruate, or
Provided in kits for each worker who needs such product.

Washington State also has state paid family and medical leave[1] and paid sick leave laws.[2] In some cases, Washington State’s pregnancy accommodation law may provide additional protections for menstruation as a condition related to pregnancy. [3]

Failing to accommodate menstruation could violate federal laws prohibiting discrimination, including harassment,[4] on the basis of age,[5] sex,[6] disability[7] or a combination of these characteristics. While menstruation is not a disability itself, in some instances symptoms or related health conditions may meet the definitions outlined in federal laws such as the Americans with Disabilities Act (ADA).[8] Employees may also be entitled to accommodations based on the Pregnant Workers Fairness Act.[9] In some cases, individuals experiencing severe symptoms related to menstruation may qualify for leave under the Family and Medical Leave Act.[10] Employees may also be covered by sick leave requirements for federal contractors.[11] The sanitation standards adopted pursuant to the Occupational Safety and Health Act require employers to provide sanitation facilities for workers in construction.[12]

How to Address Menstruation on the Job Site

Menstruation can be unpredictable. Workers may experience unexpected or irregular periods, or heavy bleeding. Failing to change menstrual products frequently enough can lead to leaks or infections. Even when cycles are regular, a period may start without warning. To support employees and create a menstruation-friendly work environment, employers should establish workplace policies related to menstruation and a process for providing workplace accommodations. Employers can solicit input from employees while designing policies to ensure that they are responsive to the varied needs of workers. Once policies are established, they should be widely disseminated, and supervisors should be trained regularly on their implementation.

You can ensure workers can meet their needs with:

Policies allowing employees to take breaks as needed to address menstruation, including to change products or clothing as needed
A sufficient number of restrooms or sanitary facilities at a reasonable distance from work stations, with access to running water and soap for washing hands and reusable products, or changing clothing in case of leaks
A sufficient supply of varied period products in bathrooms or portable kits on job sites (ideally products can be accessed privately and where they are needed and are provided at no cost to workers)
Access to an adequate number of frequently emptied waste disposal units in or near toilet facilities
Clear restroom access plans for remote sites
Uniforms with options in dark colors to hide unexpected bleeding or leaks

Other policies that can be helpful include:

Rest breaks and time to take pain relievers (as appropriate for the worker and the job site)
Scheduling and work flexibilities such as telework (for office and administrative workers), flexible work hours or shift modifications
Regular breaks, including meal breaks
Paid sick leave for menstruation-related reasons (including for related medical appointments or for symptom management)
Training for workers and managers about the symptoms of menstruation and how they can impact employees at work. Training on policies to support workers who are experiencing symptoms
Support services (e.g., connections to appropriate counseling or medical resources) for menstruation in any Employee Assistance Program (EAP) offered
Peer support groups
Coverage for menstruation management and treatments in job-based health insurance

Final Thoughts and Call to Action

Menstruation isn't a niche issue—it's a workforce reality affecting thousands of construction workers right now. The policies and accommodations outlined in this blog are simple and low-cost, but they can make a difference in recruiting and retaining skilled workers. More importantly, they signal that your workplace values all workers' health and dignity. The construction industry has made strides in becoming more inclusive—addressing menstruation is the next logical step.

Employers: Establish a clear process and contact person for requesting support or workplace accommodations, and incorporate menstruation in risks assessments and safety conversations. Train workers and supervisors/forepersons on menstruation and applicable policies and contacts.

Supervisors/forepersons: Learn about menstruation and its symptoms, and employer policies for supporting workers who menstruate. Respond openly to requests for support, focusing on job barriers, safety and health, and potential accommodations. Avoid and discourage jokes/comments related to menstruation.

Workers: Contact HR, supervisor, union rep, or EAP for support if needed. Be prepared with suggestions for accommodations based on your individual symptoms and job type.

Coworkers: Avoid jokes/comments. Respect privacy of colleagues, but offer judgment-free support and respect accommodations.

Unions: Consider the needs of menstruating workers when negotiating contracts and work with employers to ensure compliance with applicable laws (e.g., accommodation measures, access to restrooms and menstrual products, leave and scheduling policies).

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Resources & Citations

Resources on women’s health and safety: USW’s Action Guide for Raising the Bar on Women’s Health and Safety (https://usw.org/get-involved/women-of-steel/usw-action-guide-for-raising-the-bar-on-womens-health-and-safety/)

Legal analysis: Menstruation, Menopause, and the Pregnant Workers Fairness Act by Marcy Karin and Deborah Widiss (https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4991264) ; Addressing Periods at Work by Marcy Karin (https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3436090)

[1] Title 50A RCW: https://app.leg.wa.gov/rcw/default.aspx?Cite=50A

[2] RCW 49.46.210: https://app.leg.wa.gov/rcw/default.aspx?cite=49.46.210

[3] RCW 43.10.005: https://app.leg.wa.gov/RCW/default.aspx?cite=43.10.005; https://www.lni.wa.gov/workers-rights/workplace-policies/pregnancy-accommodations

[4] https://www.eeoc.gov/laws/guidance/enforcement-guidance-harassment-workplace

[5] https://www.eeoc.gov/age-discrimination

[6] https://www.eeoc.gov/sex-based-discrimination

[7] https://www.eeoc.gov/eeoc-disability-related-resources

[8] https://www.eeoc.gov/disability-discrimination-and-employment-decisions; https://askjan.org/publications/consultants-corner/vol09iss01.cfm