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Safety Articles

General Industry versus Construction

By W. Jon Wallace, CSP, MBA

"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:

"On multi-employer worksites, more than one employer may be citable for a hazardous condition that violates an OSHA standard."

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)

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

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, "The Safety Guru", at 919.933.5548 or by