Benzidine requirements

Under 1926.1110 the benzidine safety requirements for construction work are the same as those in 1910.1003.

• Follow the provisions and compliance obligations found in 1910.1003 because the construction standard explicitly states the requirements are identical to that general industry rule.
• If you need the detailed text of exposure controls, monitoring, medical surveillance, training, and recordkeeping for benzidine, consult 1910.1003.

Yes; under 1926.1110 construction employers must follow the exposure monitoring and control requirements in 1910.1003.

• Because the rule states the requirements are identical to 1910.1003, you must implement the same monitoring schedules, engineering controls, work practices, and respiratory protection steps described there when benzidine is present.
• If you are unsure whether a particular construction task generates benzidine exposure, perform or arrange monitoring as described in 1910.1003.

Under 1926.1110 all affected construction employees must receive the benzidine training and information required by 1910.1003.

• "Affected employees" means anyone who could be exposed to benzidine at work through tasks, cleanup, maintenance, or nearby operations; follow the training topics and frequency specified in 1910.1003.
• Make sure training covers hazards, exposure routes, protective measures, proper use of PPE, and medical surveillance components described in 1910.1003.

Yes; under 1926.1110 construction employers must provide the medical surveillance required by 1910.1003 when employees meet the exposure criteria.

• Because the construction rule is identical to 1910.1003, follow its triggers for initial and periodic medical exams, recordkeeping of medical findings, and confidentiality protections.
• If you are uncertain whether exposure levels trigger surveillance, use the monitoring and action-level guidance in 1910.1003.

Yes; under 1926.1110 employers must comply with the labeling and warning sign requirements in 1910.1003.

• The construction standard explicitly adopts the same requirements as 1910.1003, so containers of benzidine and regulated areas should have appropriate labels and posted warnings per that section.
• Check 1910.1003 for the exact wording, sign placement, and exceptions that apply.

(Refer to 1910.1003 for specific label text and sign designs.)

Under 1926.1110 State-plan states must have standards at least as effective as federal OSHA, so check your State Plan for any differences from 1910.1003.

• The federal construction rule adopts the same requirements as 1910.1003. However, States with OSHA-approved plans may adopt equivalent or more stringent benzidine requirements.
• If you work in a State-plan State, contact the State agency to confirm whether its benzidine rules match or exceed 1910.1003.

Yes; under 1926.1110 the benzidine protections in 1910.1003 apply regardless of whether the work is temporary or intermittent when exposure can occur.

• Because the construction regulation adopts 1910.1003 verbatim for benzidine, employers must protect employees when exposures meet the standard’s triggers, even for short-term tasks.
• Use the monitoring, controls, and PPE requirements in 1910.1003 to determine necessary protections for temporary work.

(When in doubt, conduct exposure monitoring per 1910.1003.)

Under 1926.1110 a contractor must follow the benzidine-related procedures in 1910.1003, including hazard evaluation, exposure controls, and employee notification.

• Treat the discovery as a potential exposure hazard and implement interim controls (e.g., isolate the area, restrict access) while you evaluate exposure per 1910.1003.
• Conduct air monitoring, provide appropriate PPE and training, post required warnings, and arrange medical surveillance if exposures meet the criteria in 1910.1003.
• Document actions and follow the detailed steps and timelines found in 1910.1003.

Yes; under 1926.1110 inspectors and employers should use 1910.1003 as the operative benzidine standard for construction work.

• The construction regulation explicitly states the requirements are identical to 1910.1003, so OSHA compliance officers will measure compliance against the provisions in 1910.1003.
• Keep copies of 1910.1003 guidance and your site-specific documentation available during inspections.

(Refer to 1926.1110 which directs you to 1910.1003.)

Under 1926.1110 the specifics such as exposure limits, action levels, and required medical tests are set forth in 1910.1003.

• Because the construction standard adopts the 1910.1003 requirements, consult that section for numeric limits, sampling methods, and medical surveillance details.
• If you cannot find a specific item in 1910.1003, contact OSHA or your state-plan agency for guidance on compliance expectations.

(Always base your compliance actions on the requirements in 1910.1003 when working under 1926.1110.)

Yes; under 1926.1110 employers performing construction work must follow the written plan and procedural requirements in 1910.1003 when those provisions apply.

• Because the construction standard mirrors 1910.1003, any required written elements (for example, plans for monitoring, medical surveillance, and regulated-area procedures) found in 1910.1003 must be prepared and maintained for construction activities.
• Maintain records and make written plans available to employees and OSHA as specified in 1910.1003.

Under 1926.1110 federal OSHA or your State Plan agency enforces benzidine requirements for construction and will use the provisions of 1910.1003 as the compliance benchmark.

• The enforcement authority will evaluate compliance based on the identical requirements set out in 1910.1003 as incorporated by 1926.1110.
• If your State administers its own OSHA plan, the State agency enforces that plan; check whether the State has any additional or more stringent benzidine requirements beyond 1910.1003.