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OSHA 1926.1127AppB

Cadmium technical guidelines

Subpart Z

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1127AppB, are the cadmium technical guidelines for construction the same as those in general industry 1910.1027 Appendix B?

Yes. The appendix explicitly states that the requirements applicable to construction work under 1926.1127AppB are identical to those in appendix B to 1910.1027.

  • Use the text in either appendix as the technical guidelines for cadmium when you are doing construction activities covered by the construction standard.
  • For the full cadmium standard and related requirements, refer to 1926.1127 and 1910.1027 as needed.

Under 1926.1127AppB, where should I look for practical guidance on monitoring cadmium exposure and control measures on a construction site?

Refer to the technical guidelines in the cadmium appendix that provide monitoring and control guidance; the construction appendix points you to the same material in general industry appendix B to 1910.1027 and is available under 1926.1127AppB.

  • The appendices contain practical information on exposure assessment, engineering controls, work practices, and respiratory protection that employers commonly use to comply with the cadmium standard.
  • Use the guidance in the appendix together with the mandatory provisions in 1926.1127 to build your compliance program.

Under 1926.1127AppB, does the appendix text create new legal requirements for construction employers beyond the main standard?

No; the appendix provides technical guidelines rather than adding separate regulatory obligations—construction employers must follow the mandatory provisions in 1926.1127, and 1926.1127AppB points to the guidance in appendix B to 1910.1027.

  • Use the appendix guidance to help meet the mandatory duties in the standard (for example, exposure monitoring, medical surveillance, and controls), but the enforceable duties come from the regulatory text in 1926.1127.
  • Where the appendix and the standard differ, follow the mandatory language of the standard.

Under 1926.1127AppB, if my company is not a construction contractor but performs demolition that disturbs cadmium-containing materials, which cadmium standard applies?

If the activity is construction-type work (for example, demolition or renovation), the construction cadmium provisions apply; 1926.1127AppB makes the construction appendix identical to appendix B to 1910.1027.

  • OSHA has previously explained for asbestos that the standard that applies depends on the nature of the work (construction vs. general industry), not just the type of employer; see the asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 for the same activity-based approach.
  • So, when demolition or renovation disturbs cadmium-containing materials and the work is construction-type, apply the 1926.1127 requirements and the corresponding appendix guidance.

Under 1926.1127AppB, can I use the guidance in [1910.1027AppB] to design a medical surveillance program for workers exposed to cadmium in construction?

Yes. The construction appendix states that its cadmium technical guidance is identical to appendix B to 1910.1027, so you can use the medical surveillance guidance there to design your program while ensuring you meet the mandatory elements of 1926.1127.

  • Use the appendix guidance for details such as baseline and periodic medical exams, tests, and recordkeeping practices.
  • Confirm that your medical surveillance meets the specific requirements and timelines stated in the enforceable provisions of 1926.1127.

Under 1926.1127AppB, where is the official government source for the cadmium technical guidelines text?

The appendix cites the Government Publishing Office electronic Code of Federal Regulations; the document metadata shows the GPO source as e-CFR and the construction appendix is published at 1926.1127AppB which references appendix B to 1910.1027.

  • For the authoritative regulatory text, use the OSHA pages for 1926.1127 and 1910.1027 and the appendix links above.

Under 1926.1127AppB, if a construction employer follows the technical recommendations in [1910.1027AppB], does that automatically mean they are in compliance with the mandatory cadmium standard?

Following the technical recommendations in appendix B to 1910.1027 is strong evidence of good practice, but compliance must be judged against the mandatory language in 1926.1127.

  • The appendix gives practical means to achieve compliance (monitoring, controls, medical surveillance), but the enforceable duties are in the standard text of 1926.1127.
  • If there is any difference between a chosen method and a specific mandatory requirement, the employer must meet the mandatory requirement in the standard.

Under 1926.1127AppB, if my project spans both construction and long-term maintenance work, which cadmium appendix should I consult?

Consult the construction appendix 1926.1127AppB for construction-phase activities and the general industry appendix 1910.1027AppB for non-construction maintenance activities, recognizing that 1926.1127AppB states the construction appendix is identical to the general industry appendix.

  • The applicable mandatory standard depends on the nature of the work (construction vs. general industry). See 1926.1127 and 1910.1027 to determine which regulatory section applies at each phase.

Under 1926.1127AppB, can small construction employers rely solely on the appendix guidance to choose respiratory protection for cadmium hazards?

Employers can use the respiratory protection recommendations in appendix B to 1910.1027 as practical guidance, but they must ensure their respiratory program meets any mandatory requirements in 1926.1127 and the general Respiratory Protection standard when applicable.

  • The appendix provides respirator selection guidance based on exposure levels; however, employers must also comply with the applicable mandatory respirator program requirements (for example, those in 29 CFR 1910.134 where applicable).
  • Always verify that chosen respirators and program elements meet the enforceable standards cited in the regulatory text.

Under 1926.1127AppB, does OSHA provide cross-references to other cadmium requirements such as exposure limits and monitoring procedures?

Yes. The construction appendix points to the same technical guidance and cross-references as appendix B to 1910.1027, and the mandatory exposure limits and monitoring duties appear in the main standards 1926.1127 and 1910.1027.

  • Use the appendix for practical monitoring methods and control options, and the main standard text for the specific permissible exposure limits (PELs), action levels, and required monitoring schedules.

Under 1926.1127AppB, who should I contact or where should I go for interpretation help about how the cadmium appendix applies to a specific construction task?

For interpretive help, consult OSHA guidance and, if needed, request an interpretation from OSHA; begin by reviewing 1926.1127 and its appendix at 1926.1127AppB and the corresponding general industry appendix at 1910.1027AppB.

  • OSHA’s letters of interpretation (for example, the asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14) illustrate how OSHA applies activity-based coverage and can help you understand parallels.
  • If the guidance is not clear for your situation, contact your local OSHA regional office or submit a formal interpretation request through OSHA.