Vinyl chloride requirements

No — the vinyl chloride requirements that apply to construction are identical to those set out for general industry. See 1926.1117, which explicitly states the requirements for construction work are the same as 1910.1017.

You must follow the detailed requirements in the general industry vinyl chloride standard, 1910.1017, because 1926.1117 makes the construction rules identical to it. Consult 1910.1017 for numeric exposure limits, monitoring frequencies, medical surveillance, and required procedures.

Yes — the employer must comply with the training and medical surveillance requirements found in 1910.1017, because the construction standard at 1926.1117 adopts those same requirements for construction work. This means the employer is responsible for providing required employee training, maintaining medical surveillance where triggered, and keeping required records in accordance with the standard.

They come from the general industry standard because 1926.1117 makes construction requirements identical to 1910.1017. Follow the engineering control, ventilation, and PPE provisions in 1910.1017 when planning controls for vinyl chloride at construction sites.

If the work is construction, demolition, or remediation-type work, the construction vinyl chloride rule applies and is identical to 1910.1017 by virtue of 1926.1117. OSHA has previously explained that construction standards apply to remediation and similar activities even when performed by companies not typically considered construction firms; see OSHA's interpretation on asbestos remediation that explains how construction standards apply to remediation activities Asbestos remediation protocols. Use 1910.1017 for the specific vinyl chloride controls and requirements.

Labeling, warning signs, and hazard-communication obligations for vinyl chloride on construction sites are governed by the same requirements adopted from 1910.1017 under 1926.1117. In practice, employers should follow the hazard communication, warning-sign, and regulated-area provisions described in 1910.1017.

Follow the recordkeeping rules set out in 1910.1017 because 1926.1117 adopts those same requirements for construction. That means keeping exposure monitoring results, medical surveillance records, and any other records required by 1910.1017 for the time periods specified there.

Apply the construction-standard text to construction activities and the general-industry standard to general-industry operations, but both sets of requirements are the same for vinyl chloride because 1926.1117 makes the construction requirements identical to 1910.1017. In mixed operations, ensure you meet the portions of 1910.1017 that apply to the specific tasks being performed.

The official construction provision that links to the general industry standard is 1926.1117, which states the construction requirements are identical to 1910.1017. You can review 1910.1017 for the complete regulatory text on exposure limits, controls, medical surveillance, and other obligations.

Yes — State-plan states may adopt and enforce requirements that are as effective as, or more stringent than, federal OSHA rules. When a State administers its own OSHA-approved state plan, employers in that State must follow the State's requirements where they are more stringent. Several OSHA interpretation letters note that State plans may have different enforcement policies; see the discussion about State plans in OSHA's rim wheel servicing interpretation Scope of rim wheel servicing. Also see 1926.1117 referencing the federal standard 1910.1017.

OSHA enforcement of vinyl chloride on construction sites follows the construction regulation 1926.1117, which adopts the substantive requirements of 1910.1017. During an inspection, employers should expect OSHA compliance officers to verify that you have implemented the controls, monitoring, training, medical surveillance, signage, and recordkeeping required by 1910.1017. Be prepared to show exposure monitoring results, training logs, and medical and exposure records specified by the standard.

You can request an official OSHA interpretation or contact your regional OSHA office for clarifications; the construction requirement 1926.1117 points you to the substantive text at 1910.1017. OSHA provides written letters of interpretation that explain how standards apply to particular situations (for example, see several interpretation letters in OSHA's online repository such as Asbestos remediation protocols). If you have a unique scenario, request guidance from OSHA so you have an official interpretation.