Inorganic arsenic requirements

Under 1926.1118 employers must comply with the same inorganic arsenic requirements that are set out in the general industry standard, 29 CFR 1910.1018. The text of 1926.1118 states that the requirements applicable to construction work are identical to those in 1910.1018. For practical compliance, use the procedures, exposure limits, monitoring, medical surveillance, training, and engineering and work-practice controls described in 1910.1018.

• Primary references: 1926.1118 and 1910.1018.

Yes. Under 1926.1118, construction employers must use the numeric exposure limits, monitoring requirements, and control measures in 1910.1018 because 1926.1118 makes the construction requirements identical to that general industry standard. Follow the specific elements (engineering controls, work practices, respiratory protection, medical surveillance, training, and recordkeeping) as detailed in 1910.1018.

The specific requirements for exposure monitoring and medical surveillance for inorganic arsenic on construction sites are located in 1910.1018, because 1926.1118 directs construction employers to follow the identical provisions in that general industry standard. Consult 1910.1018 for detailed procedures on how to perform air monitoring, medical examinations, biological monitoring, and related recordkeeping.

Yes. Under 1926.1118 the inorganic arsenic requirements apply to construction activities that may expose workers to inorganic arsenic; the rule makes construction obligations identical to those in 1910.1018. If demolition, renovation, or other construction tasks create a potential exposure to inorganic arsenic, employers must follow the exposure controls, monitoring, and training in 1910.1018. For similar coverage questions in other hazardous-material standards (for example asbestos), OSHA has explained when remediation work is treated as construction in its interpretation on asbestos remediation protocols (see Asbestos remediation protocols).

Yes. Under 1926.1118 construction employers may and should use the written program layouts, procedures, and forms from 1910.1018 because 1926.1118 makes the construction requirements identical to that general industry standard. Using the same templates helps ensure you include required elements such as exposure assessments, engineering controls, medical surveillance, training, and recordkeeping as specified in 1910.1018.

OSHA will cite the construction standard 1926.1118 for construction-site violations; however, because 1926.1118 states that its requirements are identical to 1910.1018, the specific provisions and criteria used during inspection will match those set forth in 1910.1018. Inspectors commonly reference the construction section for citations while applying the substantive rules found in 1910.1018.

Yes. Under 1926.1118, employers in States with an OSHA-approved State plan must follow that State's requirements when they are at least as effective as federal OSHA and may be more stringent. OSHA has explained this principle in other interpretations (for example in the asbestos remediation letter, see Asbestos remediation protocols). Therefore, check both the federal construction standard 1926.1118 (and 1910.1018 for substantive details) and your State-plan rules to confirm any additional or different requirements.

Yes, but only if the alternative method provides equal or greater protection for workers. Because 1926.1118 makes construction requirements identical to 1910.1018, employers may implement different control measures or procedures when they demonstrably achieve the same or better protection for workers—provided those alternatives meet the objectives and specific requirements in 1910.1018. Document your rationale, testing, and validation so you can show equivalence during inspections.

Yes. Under 1926.1118 construction employers must provide the same training required by 1910.1018. Because 1926.1118 makes the construction requirements identical to the general industry standard, training elements such as hazard communication about arsenic, use of respiratory protection, work practices, medical surveillance, and emergency procedures should follow the content and frequency described in 1910.1018.

The inorganic arsenic construction rule 1926.1118 incorporates the general industry provisions and cites its Federal Register history as part of the rulemaking: 58 FR 35233 (June 30, 1993); 61 FR 5507 (Feb. 13, 1996); and 61 FR 31427 (June 20, 1996). Those references appear in the preamble to help track the rule's development and finalization; see 1926.1118 for the official citations.

Read 1910.1018 first for detailed compliance steps because 1926.1118 makes the construction requirements identical to that general industry standard. The substantive provisions—how to perform exposure monitoring, install engineering controls, conduct medical surveillance, and manage medical removal—are laid out in 1910.1018. Use those sections as the working checklist for construction compliance.