"But this is a manufacturing facility – we don’t do construction work!" was the reply from a client during a discussion of OSHA’s construction standards: 29 CFR 1926. Even if you are a general industry facility, it is likely you are also performing construction work. OSHA defines construction work in 1910.12 (b) as follows:
"For purposes of this section, Construction work means work for construction, alteration, and/or repair, including painting and decorating…"
Do your employees perform additions to buildings; perform painting; make alterations; or perform demolition work to building structures? If so, this is considered construction work by OSHA and is covered by 29 CFR 1926: OSHA Standards for the Construction Industry. What are your obligations if you utilize contractors to perform construction work? As the host employer, you are still obligated to ensure contractors comply with all OSHA regulations. OSHA’s multi-employer citation policy may be utilized to cite both the contractor and host employer for an OSHA violation. OSHA’s Multi-employer Citation Policy (CPL 2-0.124) states the following:
To ensure OSHA compliance, it is important to understand the differences between the General Industry and Construction standards. As a best practice, regardless of the work task being performed (general industry or construction), the most conservative requirements should be followed. Listed below is a summary of some of the key differences between OSHA’s General Industry and Construction regulations.
|
TOPIC
|
CONSTRUCTION
|
GENERAL INDUSTRY
|
| Bloodborne Pathogens |
Not Included |
Required: 1910.1030
|
| Body Belts |
Allowed only as positioning device:
1926.502 (d)
|
Not discussed |
| Compressed Air Hoses (Greater Than 1/2 Inch ID) |
Safety Device Required To Reduce Pressure:
1926.302 (b)(7)
|
Not Required |
| Crane Suspended Platforms |
Requirements:
1926.550 (g)(1)(i)
|
Not Included |
| Cranes |
Material Hoist Requirements:
1926.552 (b)(1)(i)
|
Not Included |
| Cranes |
Personnel Hoist Requirements:
1926.552 (c)(1)
|
Not Included |
| Dip Tanks |
Not Included |
Required:
1910.122 through 1910.126;
1910.94 (d)
|
| Electrical |
GFCI Or Assured Equipment Conductor Grounding Program:
1926.404 (b)(1)(i)
|
Not Required |
| Excavations |
Subpart P:
1926.650 – 1926.652
|
Not Required |
| Fall Protection |
Full program required:
1926.500 – 1926.503 |
Limited Requirements:
1910.23 (c)(1)
|
| Fall Protection Threshhold |
6 Feet: 1926.501 (b)(1) |
4 Feet: 1910.23 (c)(1)
|
| Fire Protection |
55 Gallon water drum or 1/2 Inch water hose allowed in lieu of fire extinguisher: 1926.150 (c)(1)
|
Not permitted |
| First Aid Supplies |
Individually sealed packaged first aid supplies: 1926.50 (d)(2)
|
Less stringent: 1910.151 (b) |
| Fixed Ladder Fall Protection |
24 Feet: 1926.1053 (a)(19) |
20 Feet: 1910.27 (d)(1)(ii)
|
| Fixed Ladder Minimum Load |
250 Pounds: 1926.1053 (a) |
200 Pounds: 1910.27 (a)(1)
|
General Employee Training
|
Required: 1926.21 (b)(2) |
Not required |
General Safety Inspections
|
Required: 1926.20 (b) |
Not required |
| Hand Tools – Powder Operated |
Train operators of powder actuated tools:
1926.302 (e)(1)
|
Not required |
| Ladders |
Type 1A ladders:
1926.1053 (a) |
Type 1 Ladders: 1910.25 (c)(2)
|
| Ladders |
Training required: 1926.1060 (a)
|
Not required |
| Lockout/Tagout |
Limited (No locks): 1926.417 |
Full program: 1910.147
|
| Liquefied Petroleum Gas (LPG) |
Inside storage allowed:
1926.153 (h)(1) |
Maximum capacity 300 pounds: 1910.110 (f)(4)
|
| Manlifts |
Not permitted: 1926.552 (a)(6)
|
Permitted: 1910.68 |
| Material Handling – Rigging |
Table H-20 for spacing and numbering of wire rope clips: 1926.251 (c)(5)
|
Not included |
| Confined Spaces |
Limited: 1926.21 (b)(6) |
Full program: 1910.146
|
| Personal Protective Equipment |
PFD's, Ring Buoys and Skiffs required over water: 1926.106 |
Not required
|
| PPE Hazard Assessment |
Not required |
Required:
1910.132 (d)
|
| ROPS |
Required: 1926.1000 |
Not required
|
| Safety Container Flashback Arrestor |
Required: 1926.155 (l) |
Not required: 1910.106 (a)(29)
|
| Scaffolds |
New scaffold requirements:
1926.450 through 1926.454 |
Older standard in effect: 1910.28
|
