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OSHA 1926.1127AppE

Cadmium workplace air sampling

Subpart Z

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1127 App E, are the cadmium workplace air sampling requirements for construction the same as those in appendix E to 1910.1027?

Yes — Under 1926.1127 App E the cadmium workplace air sampling requirements that apply to construction are identical to those set forth in appendix E to 1910.1027. See Appendix E to 1926.1127 and the identical Appendix E to 1910.1027 for the full procedures and guidance.

Under 1926.1127 App E, where do I find the official cadmium air sampling and analytical procedures to use on a construction site?

Under 1926.1127 App E the official cadmium air sampling and analytical procedures for construction work are found in appendix E to 1910.1027; you must follow the methods and instructions there. See Appendix E to 1910.1027 and note the cross-reference in Appendix E to 1926.1127.

Under 1926.1127 App E, if I need the cadmium exposure limits (action level and PEL) to interpret sampling results on a construction site, where should I look?

Look to the cadmium standard itself — Under 1926.1127 App E the exposure limits (Action Level and Permissible Exposure Limit) and their meaning are provided in the cadmium standard at 1910.1027 (and mirrored in 1926.1127). Consult 1910.1027 for the numeric limits and related definitions, and remember Appendix E to 1910.1027 contains the sampling guidance referenced by construction employers via Appendix E to 1926.1127.

Under 1926.1127 App E, who is responsible for performing cadmium air sampling on a construction site?

The employer is responsible — Under 1926.1127 App E, construction employers must follow the monitoring and sampling requirements set out in the cadmium standard and its appendix; that means the employer must arrange for and ensure required air monitoring is performed. See the employer monitoring duties in 1910.1027 and the sampling procedures in Appendix E to 1910.1027 as applied through Appendix E to 1926.1127.

Under 1926.1127 App E, does a construction employer use the same rules for when to start medical surveillance based on cadmium air sampling results?

Yes — Under 1926.1127 App E construction employers must follow the same medical-surveillance trigger rules tied to cadmium air monitoring that appear in 1910.1027: when employee exposure meets or exceeds the Action Level (or other criteria in the standard), the employer must provide medical surveillance as required by the cadmium standard. See 1910.1027 and the cross-reference in Appendix E to 1926.1127.

Under 1926.1127 App E, if air sampling shows exposures above the PEL on a construction site, what steps must the employer take?

Take corrective action required by the cadmium standard — Under 1926.1127 App E, employers must implement the same hierarchy of controls and required protections listed in 1910.1027 when monitoring shows exposures above the PEL: use engineering and work-practice controls to reduce exposure, provide appropriate respirators where controls do not lower exposures sufficiently, and follow other protective measures in the standard. See 1910.1027 and the sampling guidance in Appendix E to 1910.1027, as applied by Appendix E to 1926.1127.

Under 1926.1127 App E, can a construction employer rely on general-industry cadmium sampling results or methods?

Yes — Under 1926.1127 App E, construction employers rely on the same sampling methods and interpretation provided in appendix E to 1910.1027, so general-industry methods in that appendix are the applicable methods for construction jobs covered by 1926.1127. See Appendix E to 1910.1027 and the cross-reference in Appendix E to 1926.1127.

Under 1926.1127 App E, where should a construction employer place citations or references when documenting that they followed OSHA’s cadmium sampling methods?

Document the applicable appendix and standard — Under 1926.1127 App E employers should cite that they followed the procedures in Appendix E to 1910.1027 (as adopted for construction by Appendix E to 1926.1127) and retain sampling records as required by the cadmium standard at 1910.1027.

Under 1926.1127 App E, does the appendix change any protective measures required by the cadmium standard for construction work?

No — Under 1926.1127 App E the appendix does not change the protective measures; it states the requirements applicable to construction are identical to appendix E to 1910.1027. All protections, monitoring, and procedures in 1910.1027 and its Appendix E apply to construction as adopted by Appendix E to 1926.1127.

Under 1926.1127 App E, how do I access the text that explains cadmium sampling steps and lab procedures for compliance audits?

Use the appendix text for your audit — Under 1926.1127 App E the cadmium sampling steps and laboratory procedures used for compliance are those in Appendix E to 1910.1027. You can cite that appendix and the cadmium standard at 1910.1027 when documenting compliance for construction via Appendix E to 1926.1127.

Under 1926.1127 App E, if a construction employer has questions about how Appendix E sampling procedures apply to a specific construction task, where should they look for official guidance?

Follow the appendix and the main cadmium standard — Under 1926.1127 App E employers should consult Appendix E to 1910.1027 for sampling procedures and 1910.1027 for regulatory requirements; Appendix E to 1926.1127 confirms that those documents are the authoritative guidance for construction. If uncertainty remains, employers can seek clarification from OSHA regional offices or request a written interpretation.