OSHA has a different set of regulations for general industry and construction. This is commonly known. What may surprise you is that your employees may actually be performing construction work, even at a regular general industry facility. Here is OSHA's definition of construction:

 

Construction work means work for construction, alteration, and/or repair, including painting and decorating.

 

Many of the activites occur on a regular basis in workplaces outside of construction sites, but will be covered by the construction standard.

 

OSHA further clarifies (if you want to call it that) its position on construction with it's explanation of the replacement of a utility pole.

Construction work is not limited to new construction, but can include the repair of existing facilities or the replacement of structures and their components. For example, the replacement of one utility pole with a new, identical pole would be maintenance; however, if it were replaced with an improved pole or equipment, it would be considered construction.

 

The scope of work also has a lot to do with the classification of construction.

In addition to the concept of one-for-one replacement versus improvement, the scale and complexity of the project are relevant. This takes into consideration concepts such as the amount of time and material required to complete the job. For example, if a steel beam in a building had deteriorated and was to be replaced by a new, but identical beam, the project would be considered a construction repair rather than maintenance because of the replacement project's scale and complexity. Also, if a bridge was to be stripped and re-painted, that would be considered construction work even if the repainting were done on a scheduled basis. Replacement of a section of limestone cladding on a building, though not necessarily a large project in terms of scale, would typically be considered construction because it is a complex task in view of the steps involved and tools and equipment needed to do the work.

Summary

OSHA classification of construction reaches far beyond the construction site. Take a close look at your work, and see if it may be classified as construction.

References

Adoption and Extension of Established Federal Standard - Construction Work

Clarification of Construction vs. Maintenance

Construction vs. Maintenance

Construction

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