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OSHA 1926.1152

Methylene chloride requirements

Subpart Z

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.1152, does the methylene chloride standard for construction work differ from the general industry standard at 1910.1052?

Yes. Under 1926.1152 the requirements for methylene chloride in construction are identical to those in 29 CFR 1910.1052, so employers should follow the provisions found in 1910.1052 when complying for construction work.

Under 1926.1152, where do I find the specific limits, monitoring, and control requirements for methylene chloride exposure?

Use the requirements in 29 CFR 1910.1052 because 1926.1152 adopts the same provisions for construction; all specifics about exposure limits, monitoring, engineering controls, respiratory protection, and medical surveillance are set out in 1910.1052.

Under 1926.1152, who must comply with the methylene chloride requirements on a construction site?

All employers at a construction worksite where workers may be exposed to methylene chloride must comply. 1926.1152 makes construction coverage identical to 1910.1052, so any employer whose activities can cause worker exposures to methylene chloride must follow the duties and protections in that standard.

Under 1926.1152, can an employer rely on objective data to show that exposure to methylene chloride is below the standard's limits instead of performing monitoring?

Yes, but only if the objective data meet the criteria in the methylene chloride provisions of 29 CFR 1910.1052. 1926.1152 incorporates the same allowance and conditions for using objective data in place of exposure monitoring that are found in 1910.1052.

Under 1926.1152, when must employers perform initial exposure monitoring for methylene chloride?

Employers must perform initial exposure monitoring as required by the monitoring provisions in 29 CFR 1910.1052; because 1926.1152 is identical to 1910.1052, the same timing and conditions for initial monitoring apply to construction worksites.

Under 1926.1152, what engineering and work-practice controls are required to limit methylene chloride exposure?

Employers must implement the engineering and work-practice controls specified in 29 CFR 1910.1052 to reduce exposures to the levels required by the standard; 1926.1152 adopts those same control requirements for construction work. If controls cannot keep exposure below the required limits, the employer must provide proper respiratory protection in accordance with the standard.

Under 1926.1152, when are respirators required for workers exposed to methylene chloride?

Respirators are required when engineering and work-practice controls cannot reduce exposures to the levels required by 29 CFR 1910.1052, or during procedures such as initial monitoring, maintenance, or emergencies specified in that standard; 1926.1152 requires the same use of respiratory protection in construction as set in 1910.1052.

Under 1926.1152, what training must employers provide to employees who work with or may be exposed to methylene chloride?

Employers must provide the training elements and frequency required by 29 CFR 1910.1052, because 1926.1152 adopts the same training requirements for construction; this includes hazard information, proper work practices, emergency procedures, and use of PPE and respirators.

Under 1926.1152, are employers required to provide medical surveillance for workers exposed to methylene chloride?

Yes. Employers must follow the medical surveillance provisions in 29 CFR 1910.1052, and 1926.1152 requires the same medical surveillance for construction workers who meet the exposure or respirator-use criteria set out in 1910.1052.

Under 1926.1152, how should employers communicate methylene chloride hazards and protective measures to contractors and subcontractors on a construction site?

Employers must coordinate and communicate the methylene chloride hazard information and protective measures as required in 29 CFR 1910.1052; because 1926.1152 mirrors 1910.1052, host employers and contractors on construction sites must share hazard information, work plans, and control measures so all affected workers are protected.

Under 1926.1152, are employers required to post signs or establish regulated areas for methylene chloride?

Yes, employers must establish any regulated areas and post warning signs as required in 29 CFR 1910.1052; 1926.1152 requires the same posting and controlled-area practices for construction activities involving methylene chloride.

Under 1926.1152, what personal protective equipment besides respirators might be required when using methylene chloride?

Employers must provide and require use of the PPE specified in 29 CFR 1910.1052 — for example, protective clothing and compatible gloves — where exposures, skin contact, or splashes could occur; 1926.1152 imposes the same PPE duties for construction work.

Under 1926.1152, what recordkeeping and medical records must employers keep for methylene chloride exposure?

Employers must keep the exposure measurement records, medical surveillance records, and other records required by 29 CFR 1910.1052; because 1926.1152 is identical to 1910.1052, those same recordkeeping requirements apply to construction employers.

Under 1926.1152, what should an employer do if a worker has an acute overexposure or a spill of methylene chloride on a construction site?

Employers must follow the emergency response, first-aid, and medical evaluation procedures required by 29 CFR 1910.1052; 1926.1152 requires the same immediate steps for construction — secure the area, provide appropriate first aid and decontamination, get medical attention, and document the incident per the standard.

Under 1926.1152, can employers substitute less protective controls for the engineering controls listed in the methylene chloride standard?

No. Employers must implement the engineering and work-practice controls required in 29 CFR 1910.1052 to the extent feasible; since 1926.1152 adopts the same provisions, employers cannot substitute less protective measures unless the standard explicitly permits an alternative and the employer documents equivalence as required.

Under 1926.1152, how do the hazard communication and labeling requirements interact with the methylene chloride standard on construction sites?

Employers must meet both the methylene chloride-specific requirements in 29 CFR 1910.1052 and the general Hazard Communication obligations in 29 CFR 1910; because 1926.1152 points to 1910.1052, construction employers should ensure containers, SDSs, and labels address methylene chloride hazards and reference the control measures required by the methylene chloride standard.

Under 1926.1152, do the methylene chloride requirements apply to short-term, occasional tasks on a construction site?

Yes. Any task that could expose workers to methylene chloride must be evaluated and controlled under the requirements of 29 CFR 1910.1052, and 1926.1152 requires the same protections for occasional or short-term activities on construction sites.

Under 1926.1152, who enforces methylene chloride requirements on a construction site and where do I find enforcement guidance?

Federal OSHA enforces the construction methylene chloride requirements as set out in 1926.1152, which adopts the provisions of 1910.1052; for enforcement policies and interpretations, consult OSHA’s interpretations and regional guidance available on the OSHA website and the specific standard links above.

Under 1926.1152, does a construction employer need to post a copy of the methylene chloride standard or make it available to employees?

Employers must make applicable standards and information required by 29 CFR 1910.1052 available to employees as required by OSHA; because 1926.1152 is identical to 1910.1052 for construction, employers should provide access to the standard, training materials, and exposure records to affected employees.

Under 1926.1152, does the methylene chloride standard apply differently in State-plan states?

State-plan states must have standards and enforcement programs at least as effective as Federal OSHA; therefore the methylene chloride protections of 1926.1152 and 1910.1052 may be enforced by the State agency, and in some cases the State may have more stringent or additional requirements — check your State-plan agency for any extra obligations.