4-Aminodiphenyl requirements

Yes — employers performing construction work involving 4‑aminodiphenyl must follow the same requirements that apply in general industry under 29 CFR 1910.1003. The text of 1926.1111 states that the requirements for construction work are identical to those set forth at 1910.1003.

Follow 1910.1003 for detailed obligations such as hazard communication, monitoring, regulated areas, exposure controls, medical surveillance, training, and recordkeeping.

You must consult the construction rule and the identical general industry rule; the detailed requirements are in 29 CFR 1910.1003, and 1926.1111 makes those requirements applicable to construction.

Read 1910.1003 for specifics on exposure assessment, engineering and work-practice controls, personal protective equipment, medical surveillance, training, and recordkeeping that you must implement on construction sites.

Yes — when construction activities such as renovation or demolition involve exposure to 4‑aminodiphenyl, the employer must comply with the requirements made applicable by 1926.1111 and the substance-specific provisions in 1910.1003.

If the work creates or can create worker exposure to 4‑aminodiphenyl, use the monitoring, regulated-area controls, engineering and work-practice controls, PPE, medical surveillance, and training measures described in 1910.1003.

No — the permissible exposure limits and monitoring requirements for 4‑aminodiphenyl in construction are the same as those in general industry because 1926.1111 makes the requirements identical to 1910.1003.

To determine the exact exposure limit values, monitoring frequency, and acceptable monitoring methods you must implement, refer to the text of 1910.1003.

Follow your State Plan if it has an OSHA‑approved program that covers workplace safety and is at least as effective as federal OSHA; otherwise, follow the federal requirements made applicable by 1926.1111 and 1910.1003. Federal OSHA has explained in other interpretations that States with OSHA‑approved plans must maintain programs at least as effective as federal OSHA and may be more stringent (see the asbestos remediation interpretation, which discusses State Plans and their effect on applicability: https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

If your State Plan has more protective or specific requirements for 4‑aminodiphenyl, you must comply with the State Plan rules in that State.

No — 1926.1111 explicitly states that the requirements applicable to construction work under that section are identical to those set forth at 1910.1003.

Therefore, construction employers should implement the same controls, programs, and recordkeeping required by 1910.1003 without expecting extra construction‑only obligations from 1926.1111 itself.

Act promptly and follow the control and notification actions specified in 1910.1003, because 1926.1111 makes those requirements applicable to construction.

Key immediate steps include:

• Establishing regulated areas and limiting access as required by 1910.1003;
• Performing exposure monitoring per 1910.1003 to determine worker exposures; and
• Implementing engineering controls, work‑practice controls, and appropriate PPE until exposures are controlled, following the provisions in 1910.1003.

For case‑specific questions or enforcement concerns, contact your OSHA Regional Office; regional guidance may help you apply 1910.1003 on the construction site.

Federal OSHA enforces the construction requirements in 1926.1111; in States with OSHA‑approved State Plans, the State agency enforces its own plan (which must be at least as effective as federal OSHA) as explained in other OSHA interpretations such as the asbestos remediation letter (https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

If you need clarification about a specific enforcement or jurisdictional question, contact the appropriate OSHA Regional Office or your State Plan agency.

Yes — construction employers must follow the procedures in 1910.1003, because 1926.1111 makes those provisions applicable to construction without modification.

When adapting those procedures for mobile or temporary construction conditions, ensure the required elements of 1910.1003 are still met (for example, monitoring, regulated areas, training, protective equipment, and medical surveillance). Document how controls and procedures satisfy the specific paragraphs of 1910.1003.

It depends — OSHA coverage on military installations is limited. Civilian employees and contractor personnel on military sites are generally covered by OSHA standards (including those made applicable by 1926.1111 and 1910.1003), but uniquely military personnel and certain military operations are excluded as explained in OSHA's interpretation about Air Force facilities (https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

If work with 4‑aminodiphenyl occurs on a military site, confirm whether the affected workers are civilian employees or contractors covered by OSHA; if they are, apply 1910.1003 as required by 1926.1111.

Start by reviewing the text of 1926.1111 and the detailed provisions in 1910.1003. For tailored guidance, contact your OSHA Regional Office or State Plan agency, and consider requesting a written Letter of Interpretation from OSHA if you need an official interpretation; OSHA provides interpretive letters (for example, see other subject letters at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

Keep records of communications and cite the specific regulatory paragraphs in 1910.1003 and 1926.1111 when seeking enforcement or compliance clarification.