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OSHA 1926.5

OMB control numbers

Subpart A

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1926.5, what is the purpose of the OMB control numbers table?

The table in 1926.5 lists Office of Management and Budget (OMB) control numbers that show which OSHA paperwork or information-collection requirements have OMB approval. See 1926.5 for the table that maps specific 29 CFR citations to their OMB control numbers.

Under 1926.5, how can I find the OMB control number for a particular construction standard (for example, 1926.33)?

You find the OMB control number by looking up the 29 CFR citation in the table published at 1926.5, which lists each covered paragraph and its OMB control number (for example, 1926.33 is listed as 1218-0065). See 1926.5 for the full mapping.

Under 1926.5, does an OMB control number mean an employer must keep a specific form or submit paperwork to OSHA?

No—an OMB control number simply indicates that a particular OSHA information-collection requirement (such as a required record, form, or reporting element) has been approved by the Office of Management and Budget. The table at 1926.5 identifies which regulatory sections contain those approved information collections; the specific standard text tells employers what records or submissions are required.

Under 1926.1101, does OSHA’s construction asbestos standard apply to property remediation companies doing residential cleanup?

Yes—work that involves asbestos-containing building materials (ACBM) during remediation is covered by the construction asbestos standard, 29 CFR 1926.1101, even if the employer is primarily a property remediation or restoration company. OSHA explains this coverage in its interpretation on asbestos remediation protocols (see Asbestos remediation protocols and the asbestos standard at 1926.1101).

Under 1926.1101, can asbestos-containing materials still be found in homes built before 1980?

Yes—OSHA notes that asbestos-containing materials may still be present in many homes, especially those built before 1980. For practical guidance and examples of common locations of asbestos in buildings, see OSHA’s interpretation on asbestos remediation protocols at Asbestos remediation protocols and the construction asbestos regulation at 1926.1101.

Under 1926.1101(h)(3)(iv), what respirators are required for employees doing Class I asbestos work when exposures exceed 1 f/cc (8‑hour TWA)?

When Class I asbestos exposures exceed 1 fiber per cubic centimeter as an 8-hour TWA, employers must provide full facepiece supplied-air respirators (SARs) operated in pressure-demand mode and equipped with an auxiliary positive-pressure self-contained breathing apparatus (SCBA). See the asbestos standard at 1926.1101 and OSHA’s respirator selection interpretation at Respirator selection for asbestos work for the Agency’s explanation.

Under 1926.1101(h)(3)(iv), if Class I asbestos exposures are at or below 1 f/cc but there is no negative exposure assessment, what respirators must be provided?

If Class I asbestos exposures are at or below 1 f/cc as an 8-hour TWA and the employer has not established a negative exposure assessment, employees must be provided either tight-fitting powered air-purifying respirators (PAPRs) or full facepiece SARs in pressure-demand mode equipped with either HEPA egress cartridges or an auxiliary positive-pressure SCBA. See 1926.1101 and OSHA’s respirator interpretation at Respirator selection for asbestos work.

Under 29 CFR 1910.132 (per OSHA’s PPE hazard assessment interpretation), must an employer perform a workplace hazard assessment and document it when PPE is required?

Yes—if PPE is required, the employer must assess the workplace to determine hazards and must prepare a written certification of the hazard assessment. OSHA explains this requirement and the need for a written certification in its interpretation on PPE hazard assessment at PPE hazard assessment requirements.

Under OSHA guidance in the PPE hazard assessment interpretation, must every hazard assessment be performed by a specially certified or licensed "qualified individual" for every job?

OSHA requires the employer to assess the workplace to determine if hazards are present and to provide a written certification if PPE will be required, but it does not prescribe a single universal license or certification label for the assessor in every situation. The PPE hazard assessment interpretation explains that employers should use competent personnel to perform an initial survey and any needed further analysis and that non-mandatory guidance—such as 29 CFR 1910 Subpart I, Appendix B—can help with assessment and selection.

Under the sanitation LOI, do OSHA sanitation standards apply to railroad track employees or roadway maintenance groups working along railroad tracks?

Yes—OSHA sanitation requirements apply to railroad track employees and roadway maintenance groups working along tracks unless another federal agency has promulgated sanitation regulations for those specific working conditions; OSHA’s interpretation explains that the Federal Railroad Administration has not adopted sanitation regulations covering these workers, so OSHA standards apply. See OSHA’s response at OSHA sanitation standards applicability for details and references to applicable sanitation standards (e.g., 29 CFR 1910.141 and 29 CFR 1926.51 as discussed in the letter).

Under OSHA’s scaffold and fall protection interpretation, are conveyance cars or platforms that use temporary suspension or incomplete guides considered suspended scaffolds subject to Subpart L requirements?

Yes—conveyance cars or platforms that operate with temporary guides, temporary suspension means, or temporary hoist machines meet the definition of a suspended scaffold and are subject to the scaffold safety standard (Subpart L) and its fall protection and falling object protection requirements. See OSHA’s clarification at Scaffold and fall protection clarification for the Agency’s application of 29 CFR 1926.450(b) and related fall-protection rules.

Under the silica inspections memorandum, will OSHA inspections in engineered stone fabrication and installation focus on respirable crystalline silica hazards?

Yes—OSHA established a focused inspection initiative that prioritizes inspections in engineered stone fabrication and installation industries to identify and address respirable crystalline silica hazards, and inspections in those NAICS codes will cover silica hazards. See the initiative memorandum at Silica inspections initiative for the targeted approach and background.

Under the arsenic-treated wood interpretation, does OSHA’s inorganic arsenic standard (29 CFR 1910.1018) cover exposure to arsenic-treated wood dust during carpentry?

No—OSHA explains that inorganic arsenic standard 29 CFR 1910.1018 does not cover arsenic-treated wood, but exposure to dust from arsenic-treated wood is subject to OSHA’s Hazard Communication Standard (HCS), and employers must provide information and training as required by the HCS. See OSHA’s letter on Arsenic-treated wood standard coverage for details (the letter references the HCS and related responsibilities for employers).

Under the noise guidance LOI, can an employer use noise-canceling headphones instead of earplugs or earmuffs to meet OSHA hearing protection requirements?

OSHA’s policy permits employers to rely on hearing protection devices that effectively reduce noise exposure to the required level, and selection should provide attenuation to reach a TWA of 85 dBA; the employer must ensure the chosen device’s attenuation is adequate and that the protector is used correctly. See OSHA’s interpretation on noise and hearing protection at Noise-canceling headphones as protection for discussion of acceptable hearing protectors and reliance on Noise Reduction Ratings (NRR) and hearing conservation program requirements.

Under OSHA’s CPR interpretation, does OSHA require annual CPR retraining for all employers?

No—OSHA does not mandate a specific frequency for CPR retraining for all employers, although OSHA guidance recommends annual instructor-led retraining for life‑threatening emergencies and some specific OSHA standards do require first-aid or CPR training. See CPR retraining and OSHA guidance for OSHA’s position and examples of standards that have specific training requirements.

Under the lead standard update LOI, is OSHA actively reviewing and seeking input to update the Lead standards for general industry and construction?

Yes—OSHA published an Advance Notice of Proposed Rulemaking (ANPRM) in June 2022 to solicit input about updating the Lead standards, including permissible exposure limits and medical removal criteria; the Agency is seeking public comment as part of that rulemaking process. See OSHA’s response at Lead standard update inquiry for details about the ANPRM and its topics of interest.

Under the respirator selection LOI, can an employer rely on representative daily personal sampling to immediately select a lower level of respirator for Class I asbestos work?

No—employers cannot pick a lower level of respiratory protection for Class I asbestos work unless they demonstrate a negative exposure assessment (NEA) showing exposures will be below the PELs; daily sampling alone does not override the asbestos standard’s respirator requirements when exposures exceed prescribed thresholds. OSHA explains this in Respirator selection for asbestos work and the asbestos standard at 1926.1101.

Under OSHA’s asbestos remediation protocols interpretation, if a private-dwelling remediation job may disturb ACBM, which OSHA standard should the contractor follow: construction 1926.1101 or general industry 1910.1001?

Contractors performing remediation work on ACBM should follow the construction asbestos standard, 29 CFR 1926.1101, because OSHA treats asbestos removal and disturbance related to construction and remediation activities as construction work even when performed in private dwellings. See OSHA’s interpretation at Asbestos remediation protocols and the asbestos regulation at 1926.1101.

Under the PPE hazard assessment interpretation, should employers rely only on PPE instead of implementing other controls?

No—OSHA states employers should not rely solely on PPE and should evaluate other controls (engineering or administrative) where feasible as part of the hazard assessment and selection of controls. See OSHA’s guidance in PPE hazard assessment requirements and the non-mandatory guidance referenced there (29 CFR 1910 Subpart I, Appendix B) for recommended practices.