Substance Safety Data Sheet

Yes — they are the same: the appendix explicitly states that the requirements applicable to construction work under 1926.1127 App A are identical to those set forth in appendix A to 1910.1027.

• Practical effect: an SDS that meets the content and format expectations in 1910.1027 App A will satisfy the construction appendix requirements in 1926.1127 App A.

Yes — construction employers can rely on supplier-provided SDSs prepared to meet the appendix content because 1926.1127 App A states the requirements are identical to appendix A to 1910.1027.

• Practical tip: confirm the SDS includes the elements expected by 1910.1027 App A (manufacturer ID, composition, hazard information, protective measures, emergency procedures, etc.) so it clearly serves your construction workplace needs.

No — the appendix does not change employer duties; it provides the substance safety data sheet guidance consistent with the general industry appendix. The text of 1926.1127 App A states the requirements for construction are identical to appendix A to 1910.1027, which is intended as guidance for SDS content.

• Practical effect: follow the main duties in 1926.1127 for worker protection and use 1910.1027 App A as the modeled SDS content.

Yes — if the work involves asbestos-containing building materials (ACBM) the construction asbestos standard applies, and you must follow the construction-specific requirements in 29 CFR 1926.1101 rather than treating asbestos solely under general-industry rules. OSHA has clarified that remediation activities involving ACBM are covered by the construction asbestos standard 29 CFR 1926.1101, not the general-industry standard 29 CFR 1910.1001, as explained in OSHA’s letter on asbestos remediation protocols (see https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

• Practical note: while 1926.1127 App A aligns SDS requirements with 1910.1027 App A, asbestos work must also comply with the specific controls and notifications in 1926.1101 as discussed in OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

The federal appendix is applicable where Federal OSHA standards apply, but OSHA-approved State Plans may have their own requirements if they are more stringent. 1926.1127 App A mirrors 1910.1027 App A, but employers in States with OSHA-approved State Plans should check state rules because those States may adopt more stringent or additional requirements.

• If you operate in a State Plan state, contact your State Plan agency to confirm whether the State has modifications to the SDS guidance.

Yes — the appendix requirement is about content equivalence, not a mandated layout: 1926.1127 App A states construction requirements are identical to 1910.1027 App A, which focuses on the information an SDS must convey.

• Practical guidance: you may use a different visual format so long as the SDS contains all required information and is clear and accessible for workers and emergency responders, consistent with the expectations in 1910.1027 App A.

No — you do not need separate manufacturer SDSs for each site if the supplier’s SDS already contains the required information; 1926.1127 App A is identical to 1910.1027 App A, so a single supplier-provided SDS that meets the appendix content will generally be acceptable at multiple workplaces.

• However, employers must ensure workplace-specific information (such as exposure controls, monitoring results, and emergency procedures) is communicated to and accessible by employees at that construction site and updated as necessary.

The appendix text itself states the requirements mirror 1910.1027 App A, but it does not specify onsite versus electronic storage in the excerpt provided. Employers should follow the general records and access expectations in the applicable hazard communication and substance standards and ensure employees can promptly access SDS information at the worksite as required by those standards.

• Practical action: maintain SDSs so they are readily accessible to employees during their work shift — if you use electronic SDS management, ensure reliable on-site access (e.g., devices, printed copies, or other means) consistent with the employer’s duty to communicate hazards.

The appendix text provided states that the requirements for construction are identical to appendix A to 1910.1027, which is the document that lays out the SDS content elements.

• Practical step: consult 1910.1027 App A for the specific content elements to include on an SDS to ensure compliance with the construction appendix in 1926.1127 App A.

Yes — because 1926.1127 App A explicitly states construction requirements are identical to 1910.1027 App A, changes to the guidance or clarifications in the general industry appendix would inform how the construction appendix is interpreted and applied.

• Practical recommendation: monitor updates to 1910.1027 App A and to the main standards to stay current with any changes that affect SDS content or employer obligations under 1926.1127 App A.

Yes — OSHA letters of interpretation provide agency guidance and practical clarification that can help apply the standards; for example OSHA’s asbestos remediation interpretation explains how construction-specific standards apply in practice (see https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

• Caveat: letters of interpretation reflect OSHA’s view but do not create new legal requirements; always confirm that the interpretation applies to your specific circumstances and follow the underlying standards such as 1926.1127 App A and 1910.1027 App A.