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OSHA 1926.1104

alpha-Naphthylamine requirements

Subpart Z

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1104, what does OSHA require for alpha‑naphthylamine exposure in construction work?

The employer must follow the same alpha‑naphthylamine requirements that apply in general industry under 29 CFR 1910.1003. The construction requirements in 1926.1104 are identical to those set forth in 1910.1003, so you should use the provisions and compliance steps listed in 1910.1003 for exposure limits, monitoring, protective measures, training, and recordkeeping.

Under 1926.1104, where do I find the specific exposure limits and control measures for alpha‑naphthylamine?

The specific exposure limits and required control measures for alpha‑naphthylamine are contained in 29 CFR 1910.1003. Because 1926.1104 makes the construction rules identical to 1910.1003, follow the sections and tables in 1910.1003 for permissible exposure limits, engineering controls, and work practices.

Under 1926.1104, do construction employers need to perform air monitoring for alpha‑naphthylamine?

Yes—employers must comply with the monitoring requirements set out in 1910.1003. Since 1926.1104 adopts the same requirements for construction, follow 1910.1003 for when to conduct exposure monitoring, how to do it, and how to act on results.

Under 1926.1104, what worker training is required for alpha‑naphthylamine in construction?

Construction employers must provide the training required by 1910.1003. Because 1926.1104 makes the construction requirements identical to 1910.1003, training topics, frequency, and documentation follow the procedures in 1910.1003 (for example, hazard communication, safe handling, PPE use, and medical surveillance triggers).

Under 1926.1104, when is medical surveillance required for construction workers exposed to alpha‑naphthylamine?

Medical surveillance rules for alpha‑naphthylamine exposures in construction are the same as those in 1910.1003. Since 1926.1104 mirrors 1910.1003, follow 1910.1003 to determine when to enroll employees in medical surveillance, what exams and frequency are required, and how to handle medical records.

Under 1926.1104, what personal protective equipment (PPE) must construction employers provide for alpha‑naphthylamine work?

Employers must provide and require appropriate PPE as specified in 1910.1003. Because 1926.1104 adopts 1910.1003 for construction, use the PPE selection and use guidance in 1910.1003 (respirators, protective clothing, gloves, eye protection) based on exposure assessment and the standard's requirements.

Under 1926.1104, does an employer need to maintain exposure and medical records for alpha‑naphthylamine?

Yes—recordkeeping obligations for exposure measurements and medical surveillance are those in 1910.1003. Because 1926.1104 makes the construction requirements identical, follow 1910.1003 for how long to keep monitoring and medical records and how to make them available to employees or designated representatives.

Under 1926.1104, how must alpha‑naphthylamine containers be labeled on construction sites?

Labeling requirements for alpha‑naphthylamine containers on construction sites are the same as those in 1910.1003. Since 1926.1104 makes the two standards identical, follow 1910.1003 and the Hazard Communication rules it references for container labels, warnings, and required safety data sheets.

Under 1926.1104, must construction employers establish regulated areas for alpha‑naphthylamine work?

If the conditions in 1910.1003 require a regulated area for alpha‑naphthylamine, construction employers must establish one under 1926.1104 because it adopts the same requirements. Check 1910.1003 for when regulated areas are required, how to mark and limit access, and what controls must be in place inside the area.

Under 1926.1104, how should employers control alpha‑naphthylamine dust or vapor on a construction site?

Employers must use the engineering controls, work practices, and PPE specified in 1910.1003 to control alpha‑naphthylamine dust or vapors. Because 1926.1104 treats construction the same as general industry, implement the controls described in 1910.1003 such as local exhaust ventilation, enclosed processes, and respiratory protection if required by the standard.

Under 1926.1104, do construction subcontractors have to follow the alpha‑naphthylamine requirements in 1910.1003?

Yes—subcontractors performing construction activities that involve alpha‑naphthylamine must comply with the same requirements in 1910.1003 because 1926.1104 makes the construction obligations identical. Each employer on the site (contractor or subcontractor) is responsible for meeting training, monitoring, PPE, and recordkeeping requirements applicable to their employees.

Under 1926.1104, where can I find the legally enforceable text I must follow for alpha‑naphthylamine?

The enforceable construction text is in 1926.1104, which points you to the substantive requirements in 1910.1003. For day‑to‑day compliance (exposure limits, monitoring, medical surveillance, PPE, training, labeling, and records), use the provisions of 1910.1003.

Under 1926.1104, does the construction standard add or change any rules compared with 1910.1003 for alpha‑naphthylamine?

No—1926.1104 states that the requirements applicable to construction are identical to those in 1910.1003, so there are no additional or different construction‑specific rules in 1926.1104 itself; follow 1910.1003 for the substantive obligations.

Under 1926.1104, do construction employers need to provide safety data sheets (SDS) for alpha‑naphthylamine?

Yes—requirements for safety data sheets and hazard communication associated with alpha‑naphthylamine are addressed through the rules referenced in 1910.1003. Because 1926.1104 adopts 1910.1003 for construction, you must provide SDSs and ensure employees can access hazard information as required by the standard and hazard communication regulations.

Under 1926.1104, are decontamination and hygiene measures required for workers exposed to alpha‑naphthylamine on construction sites?

Yes—employers must implement decontamination and hygiene practices where 1910.1003 requires them. Since 1926.1104 makes the construction requirements identical to 1910.1003, follow 1910.1003 for required facilities, change areas, washing facilities, and procedures to prevent worker contamination and take‑home exposures.

Under 1926.1104, how should employers handle disposal or spill cleanup of alpha‑naphthylamine on construction projects?

Employers must follow the handling and cleanup procedures required by 1910.1003. Because 1926.1104 makes construction obligations identical to 1910.1003, use the standard's guidance on spill control, disposal, personal protection during cleanup, and when to involve hazardous materials responders.

Under 1926.1104, who is responsible for ensuring compliance with alpha‑naphthylamine rules on a construction site with multiple employers?

Each employer on a construction site is responsible for compliance for its own employees, and controlling employers must coordinate control measures as required by 1910.1003. Because 1926.1104 adopts 1910.1003 for construction, employers should coordinate hazard communication, training, monitoring, and access to medical surveillance so all affected employees are protected.

Under 1926.1104, can construction employers rely on alternative consensus standards instead of the requirements in 1910.1003 for alpha‑naphthylamine?

No—construction employers must meet the mandatory requirements in 1910.1003 as adopted by 1926.1104; consensus standards can be used as guidance but cannot replace or reduce the obligations in the OSHA regulation. Follow 1910.1003 for the legally required controls and procedures.

Under 1926.1104, what should a construction employer do first if they believe work may expose employees to alpha‑naphthylamine?

The employer should perform an exposure assessment and follow the monitoring and control provisions in 1910.1003. Because 1926.1104 makes construction requirements identical, begin with the steps in 1910.1003: identify sources, measure exposures, implement engineering controls, provide PPE and training, and put in place medical surveillance and recordkeeping as required.

Under 1926.1104, where can I read the authoritative OSHA text that notes the construction rule copies 1910.1003?

The authoritative statement is in 1926.1104. That section explicitly notes that the requirements applicable to construction work under 1926.1104 are identical to those set forth at 1910.1003, so read 1910.1003 for the detailed obligations.