Occupational health controls

Yes — 29 CFR 1926 Subpart D covers a range of workplace health and environmental controls for construction, including sanitation, environmental exposures, and related protections for workers. See the general title and scope in 29 CFR 1926 Subpart D.

• This Subpart identifies OSHA authority and the purpose of those sections in the construction standards.
• For specific topics (for example, sanitation, respiratory protection, lead, asbestos) you must consult the individual rules and applicable guidance within Part 1926 and related standards.

(Reference: 29 CFR 1926 Subpart D.)

Yes — OSHA sanitation requirements apply to railroad track employees and roadway maintenance groups working along tracks when another federal agency has not issued sanitation rules covering those working conditions. See the explanation in OSHA's letter regarding sanitation standards applicability at https://www.osha.gov/laws-regs/standardinterpretations/2024-05-14.

• OSHA explained that the Federal Railroad Administration (FRA) has not promulgated sanitation regulations for roadway workers along the right-of-way, so OSHA requirements still apply.
• Employers must provide sanitation facilities in accordance with the applicable OSHA sanitation standards (for example, the construction sanitation rule cited in that letter).

(Reference: OSHA letter, OSHA sanitation standards applicability.)

Employers must assess the workplace for hazards that require PPE and must prepare a written certification of that assessment when PPE will be required. See OSHA's interpretation on PPE hazard assessment at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.

• The OSHA letter explains that an initial survey should be done by the employer to determine whether hazards are present or likely to be present that necessitate PPE.
• When PPE is required, OSHA guidance calls for a written certification documenting the hazard assessment and naming the person(s) who performed it.
• Employers should follow the hierarchy of controls (elimination, substitution, engineering, administrative, then PPE) and use Appendix B (or equivalent guidance) when selecting PPE.

(Reference: OSHA letter, PPE hazard assessment requirements.)

The construction asbestos standard, 29 CFR 1926.1101, applies to asbestos work performed during remediation and similar activities, even for companies that are not traditional construction contractors. OSHA confirmed this in its asbestos remediation protocols letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

• OSHA explained that remediation activities involving ACBM are covered by the construction asbestos standard (29 CFR 1926.1101), not the general industry standard (29 CFR 1910.1001), when the work fits within the construction scope.
• Employers performing such remediation must follow the requirements of 29 CFR 1926.1101 (for example, exposure assessments, work practices, respiratory protection, and training).

(Reference: OSHA letter, Asbestos remediation protocols.)

Employers must provide full facepiece supplied-air respirators (SARs) operated in pressure-demand mode with an auxiliary positive-pressure self-contained breathing apparatus (SCBA) when Class I asbestos work yields exposures exceeding 1 fiber/cc as an 8‑hour TWA. OSHA explained this requirement in the respirator selection letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04.

• If exposures are above 1 f/cc TWA, the construction asbestos rule requires pressure-demand SARs with SCBA backup for Class I work.
• If exposures are at or below 1 f/cc TWA and a negative exposure assessment (NEA) is not established, employers must still provide at least tight-fitting PAPRs or full facepiece SARs with HEPA egress cartridges or SCBA backup as specified by the asbestos standard.

(Reference: OSHA letter, Respirator selection for asbestos work.)

No — an employer may not rely only on prior project exposure data to lower respiratory protection for a current Class I asbestos job unless the employer conducts the required exposure monitoring and can demonstrate a valid negative exposure assessment for the current job. OSHA addressed this in the respirator selection letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04.

• The asbestos rule requires initial exposure monitoring representative of current operations; if monitoring shows exposures exceed 1 f/cc TWA, the higher level SAR+SCBA backup is required.
• Prior data from a different project can inform planning but does not substitute for monitoring on the current job unless it legitimately supports an NEA under the standard.

(Reference: OSHA letter, Respirator selection for asbestos work.)

Yes — if exposures are at or below 1 f/cc as an 8‑hour TWA (and a negative exposure assessment is not established), employers must provide either tight-fitting PAPRs or full facepiece SARs operated in pressure-demand mode with HEPA egress cartridges or SCBA backup for Class I work. OSHA clarified this in the respirator selection letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04.

• When exposures are at or below 1 f/cc TWA, PAPRs are an allowable option (but filtering facepiece respirators are prohibited for asbestos work unless an NEA permits selection under 29 CFR 1910.134 Table I).
• If an NEA is shown, the employer may follow the respirator options in Table I of the Respiratory Protection standard, with specific prohibitions (for example, no filtering facepieces for asbestos).

(Reference: OSHA letter, Respirator selection for asbestos work.)

Employers must include a worker in a hearing conservation program when the worker's noise exposure equals or exceeds the action level specified in the OSHA hearing conservation rule (traditionally an 8‑hour TWA of 85 dBA for general industry or applicable construction guidance), and provide the program elements such as monitoring, audiometry, training, and hearing protection. OSHA discussed hearing conservation and protection policy in its letter about noise control at https://www.osha.gov/laws-regs/standardinterpretations/2023-03-06.

• OSHA emphasizes engineering and administrative controls first, but recognizes that properly selected and used hearing protectors and a hearing conservation program are acceptable when they reduce exposure to the required level.
• The hearing conservation program must include monitoring, baseline and annual audiograms, training, and provision of hearing protectors at no cost.

(Reference: OSHA letter, Noise-canceling headphones as protection.)

Possibly — OSHA allows employers to use hearing protection devices (including active noise-canceling devices) that provide sufficient attenuation and are accepted and worn correctly by the worker, so long as the protection reduces exposure to the required TWA; OSHA discussed this policy in its noise letter at https://www.osha.gov/laws-regs/standardinterpretations/2023-03-06.

• The device chosen must provide adequate noise reduction to lower the worker's exposure to the target TWA (typically 85 dBA for hearing conservation programs).
• Employers should verify attenuation (for example using the device's NRR or fit-testing methods), provide training and fit/training as needed, and ensure the device is acceptable to and consistently used by workers.

(Reference: OSHA letter, Noise-canceling headphones as protection.)

No — OSHA does not mandate a specific retraining interval for CPR across all employers; however, OSHA guidance recommends annual instructor-led retraining for life‑threatening emergency skills such as CPR, and some specific OSHA standards do require first aid/CPR training for certain operations. See OSHA's letter on CPR retraining at https://www.osha.gov/laws-regs/standardinterpretations/2023-02-23.

• OSHA's Best Practices guide recommends at least annual retraining for CPR/AED, but the agency does not impose a universal regulatory interval.
• Specific standards (for example confined space, logging, electrical power operations, certain construction activities) may require first aid/CPR training at defined frequencies.

(Reference: OSHA letter, CPR retraining and OSHA guidance.)

No — OSHA's Inorganic Arsenic standard does not currently cover arsenic-treated wood, but exposures to dust from arsenic-treated wood are regulated under OSHA's Hazard Communication Standard and employers must provide training and information to exposed workers. OSHA explained this in its arsenic-treated wood standard coverage letter at https://www.osha.gov/laws-regs/standardinterpretations/2023-05-03.

• OSHA noted that the Hazard Communication Standard (29 CFR 1910.1200) requires employers to provide information, Safety Data Sheets (SDSs), and training to downstream users exposed to treated wood dust.
• Employers should treat wood dust hazards (treated or untreated) as part of their hazard communication and exposure control programs.

(Reference: OSHA letter, Arsenic-treated wood standard coverage.)

Yes — OSHA has a focused inspection initiative that prioritizes enforcement and compliance efforts for respirable crystalline silica hazards in engineered stone fabrication and installation industries, as explained in the silica inspections initiative memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2023-09-22.

• The initiative directs regional offices to emphasize inspections and cover silica hazards in the targeted NAICS codes for stone fabrication and material wholesaling.
• Employers in these industries should expect targeted inspections and ensure compliance with silica controls, monitoring, and protective measures.

(Reference: OSHA memorandum, Silica inspections initiative.)

Yes — a conveyance operating with temporary guides, temporary suspension cables, or temporary hoist machines can meet OSHA's definition of a suspended scaffold and thus be subject to the scaffold standard (29 CFR 1926 Subpart L). OSHA clarified this in its letter about scaffolds and fall protection at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

• OSHA's guidance explains that such conveyances meet the definition of a suspended scaffold when they are temporary platforms suspended by non-rigid means.
• Where the conveyance is considered a suspended scaffold, employers must comply with the fall protection requirements in 29 CFR 1926.451(g) and the falling object/overhead protection requirements in 29 CFR 1926.451(h).

(Reference: OSHA letter, Scaffold and fall protection clarification.)

Employees working from suspended scaffolds must be protected by the fall-protection measures in 29 CFR 1926.451(g) and by overhead and falling object protections in 29 CFR 1926.451(h), as OSHA clarified for conveyances and suspended scaffolds in its December 2023 letter at https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05.

• Fall protection for suspended scaffold workers typically includes personal fall arrest systems, guardrails, or other measures required by 1926.451(g).
• Overhead and falling object protection measures include toeboards, screens, debris nets, or hard hats as required by 1926.451(h) to protect employees below and on the scaffold.

(Reference: OSHA letter, Scaffold and fall protection clarification.)

Each employer on site is responsible for assessing hazards that affect its own employees and for selecting and providing appropriate PPE, even when multiple work parties are present; OSHA explains employer responsibilities for PPE hazard assessment in its March 28, 2024 letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.

• The letter emphasizes that each employer must conduct a hazard assessment (and provide written certification when PPE is required) for the workplace conditions their employees face.
• Host employers and controlling contractors should coordinate hazard information and controls so all employers on site understand potential exposures and required protections.

(Reference: OSHA letter, PPE hazard assessment requirements.)

Employers should assume materials in older buildings may contain asbestos and follow the construction asbestos standard (29 CFR 1926.1101) requirements, including treating suspected materials as asbestos until properly assessed, as explained in OSHA's asbestos remediation protocols letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

• OSHA notes ACBM is more likely in structures built before about 1980 and recommends treating suspect materials as asbestos-containing until sampling and assessment are completed.
• Employers must comply with the asbestos in construction standard requirements for exposure assessment, work practices, respiratory protection, and training when working with or disturbing suspect materials.

(Reference: OSHA letter, Asbestos remediation protocols.)

Yes — employers are expected to use the hierarchy of controls (elimination, substitution, engineering controls, administrative controls) before relying on PPE, and OSHA's PPE hazard assessment letter reiterates that employers should not rely solely on PPE and should first evaluate other feasible controls (see https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

• The letter points employers to OSHA's Recommended Practices for Safety and Health Programs and indicates that engineering and administrative measures should be considered and implemented where feasible.
• PPE remains necessary when other controls do not fully eliminate hazards or while permanent controls are being implemented.

(Reference: OSHA letter, PPE hazard assessment requirements.)