Benzene requirements overview
Subpart Z
Questions & Answers
Under 1910.1028 and 1926.1128, who is covered by the benzene standard (which employees or work activities)?
Employees exposed to benzene during construction activities are covered — the construction standard 1926.1128 makes the full 1910.1028 benzene requirements applicable to construction, so any worker whose tasks involve benzene exposures (use, handling, storage, cleanup, or related operations) must be protected under that rule.
Under 1910.1028, what general employer obligations apply on construction sites where benzene is present?
Employers must comply with the same benzene duties used in general industry — because 1926.1128 adopts 1910.1028 for construction, employers must follow that standard's requirements such as exposure assessment, engineered controls and work practices, respiratory protection when required, medical surveillance, training, labels and signs, and recordkeeping as specified in 1910.1028.
Under 1910.1028/1926.1128, do construction employers have to measure worker exposures to benzene?
Yes — employers must determine employee exposures by monitoring when benzene may be present, as required by the benzene rule adopted for construction in 1926.1128 and set out in 1910.1028. Monitoring tells you who is exposed, the level of exposure, and whether additional controls or medical surveillance are needed.
Under 1910.1028, when must construction employers provide medical surveillance for workers exposed to benzene?
Employers must provide medical surveillance when exposures meet the triggers defined in the benzene standard — the construction citation 1926.1128 adopts the medical surveillance requirements in 1910.1028, so employers must follow the medical exam and follow-up schedules and procedures spelled out there for employees who meet the standard's exposure criteria.
Under 1910.1028/1926.1128, when is respiratory protection allowed for benzene exposures on construction sites?
Respirators may be used only where required by 1910.1028 — since 1926.1128 adopts that rule for construction, employers must use engineering and work practice controls to reduce benzene exposures first and provide respirators in accordance with the standard when controls are not feasible or while they are being implemented, following the respirator program requirements stated in 1910.1028.
Under 1910.1028, what training must employers give construction workers who may be exposed to benzene?
Employers must train workers on benzene hazards and protections — the benzene requirements adopted for construction in 1926.1128 incorporate the training provisions of 1910.1028, so workers need clear, job-specific training on health hazards, exposure routes, protective measures, respiratory use, medical surveillance, and emergency procedures as required by the standard.
Under 1910.1028/1926.1128, does the employer have to establish a written benzene program for construction work?
Yes — when the benzene standard applies, employers must implement the written elements required by 1910.1028, and because 1926.1128 adopts those requirements for construction, you should maintain the program documentation called for by the standard (for example, exposure monitoring records, medical records, control plans and training records).
Under 1910.1028, are construction employers required to set up regulated areas or signs where benzene exposures are high?
Under 1910.1028, what records must construction employers keep when the benzene standard applies?
Under 1926.1128 and 1910.1028, do contractors and subcontractors on the same construction site have shared responsibilities for benzene compliance?
Yes — employers at multi-employer construction sites share responsibility for protecting their employees from benzene exposures because 1926.1128 adopts 1910.1028 for construction; each employer must ensure compliance for its own employees and coordinate with other employers as necessary to implement controls, warnings, and medical surveillance required by the standard.
Under 1910.1028/1926.1128, what steps should a construction employer take if there is a benzene spill or unplanned release on site?
Employers must follow the emergency and exposure-control steps required by the benzene standard — since 1926.1128 adopts 1910.1028 for construction, implement the standard's required emergency procedures: isolate the area, limit access to trained personnel with appropriate PPE, control and clean up the release using approved methods, provide medical evaluation if exposures occurred, and record the incident as needed under the rule.
Under 1910.1028, are employers required to provide and clean protective clothing for workers exposed to benzene on construction projects?
Under 1910.1028/1926.1128, how must employers communicate benzene hazards to workers (labels, SDS, signs)?
Employers must make hazard communication information available and post warnings as required by the benzene standard — because 1926.1128 incorporates 1910.1028, employers must ensure containers and work areas are appropriately labeled, provide Safety Data Sheets, and post any required warning signs or regulated-area notices specified in 1910.1028.
Under 1910.1028, can engineering controls be substituted by administrative controls on construction sites to comply with the benzene standard?
No — where feasible, engineering controls and work-practice controls are the required first choice for controlling benzene exposures; the construction-adopted rule 1926.1128 incorporates 1910.1028, which requires employers to implement engineering and work-practice controls to reduce exposures and use respirators only when those controls are not feasible or are being installed.
Under 1910.1028/1926.1128, what should employers do before allowing employees to enter an area where benzene work is performed?
Employers must ensure employees are protected and informed before entry — because 1926.1128 applies 1910.1028 to construction, employers should confirm required controls are in place, provide required PPE and respiratory protection, post regulated-area warnings where necessary, and verify that workers have received the benzene-specific training and medical clearance required by the standard.
Under 1910.1028, who must perform exposure monitoring and how should employers select the monitoring method for benzene?
A qualified person must conduct monitoring using accepted methods — since 1926.1128 adopts the monitoring requirements of 1910.1028, employers must have competent personnel or contractors measure exposures with validated industrial hygiene methods that represent the worker's breathing zone and the work tasks, as specified in the benzene standard.
Under 1910.1028/1926.1128, are construction employers required to notify employees of their benzene monitoring results?
Under 1910.1028, are benzene exposure and medical records required to be kept after a worker leaves a construction employer?
Under 1910.1028/1926.1128, how does an employer document compliance with benzene testing and protective actions on a construction site?
Employers should keep the records and written program elements required by the benzene rule — because 1926.1128 adopts 1910.1028, document exposure monitoring, medical surveillance, training, engineering control plans, respiratory protection programs, regulated-area postings, and incident reports as specified in the standard to demonstrate compliance.