OSHA Construction vs General Industry: Which Do You ...

Employers are also responsible for adding task-specific training for each worker according to their duties. It's worth noting that the type of work dictates the training you need, not the type of employer.

If you ask a maintenance worker to perform construction or repair, you're legally responsible for making sure they know how to safely complete that work.  Sometimes there's a fine line between maintenance and construction.  The scale and complexity of the job matters.

What is OSHA Construction Training?

OSHA Construction training addresses the specific safety needs of construction sites.  It covers 29 CFR 1926 (the construction-specific standards) and some of 1910 (general standards).

Who Needs OSHA Construction Training?

You need OSHA Construction training if you're a construction worker or a contractor.  Entry-level workers need OSHA 10-Hour Construction Safety Outreach Training.  Workers may need additional training for specialized work.

Anyone with supervisory responsibilities should take OSHA 30-Hour Construction Safety Outreach Training.  That includes foremen, engineers, supervisors, project managers, and safety specialists.

What Topics Does OSHA Construction Training Cover?

OSHA 10-Hour courses typically cover general topics like Introduction to OSHA, General Safety and Health Provisions, and Hazard Communication.  Then they focus on construction-specific concerns: Cranes and Rigging, Electrical Safety, Struck-By, Caught In/Between, Fall Protection, Power Tools, Scaffolding, and Ladders, as well as the personal protective equipment needed to keep workers safe.

OSHA requires specific training before employees perform specialized work, including Confined Space Entry, Concrete and Masonry, Use of Explosives, or Excavation Safety.  Most heavy equipment requires its own training, as well. Those topics don't appear in the 10-Hour course, but they're often rolled into 30-Hour courses since supervisors are responsible for workers with a range of duties.

What is OSHA General Industry Training?

OSHA has specific standards for Construction, Maritime, and Agriculture. Any other employer or worker falls into the catchall of "General Industry." That means the category covers everyone from manufacturing to office work. OSHA General Industry training covers standards in 29 CFR 1910.

Who Needs OSHA General Industry Training?

The broad nature of "General Industry" makes this one a little more difficult to answer. All employers have to conduct some basic workplace safety training. In low-risk industries, that won't involve anything as extensive as a 10-Hour course.

There are no universal rules for who requires 10-Hour or 30-Hour courses (sometimes known as a "DOL Card"). Certain states or types of employers require it, so check local and industry practices.  Generally speaking, workers in higher-risk fields need OSHA 10-Hour General Industry Outreach Training. That includes healthcare, factory operations, manufacturing, and warehousing.

Any workers that perform specialized tasks regulated under 1910 will need additional coursework. Foremen, engineers, supervisors, project managers, and safety specialists will need OSHA 30-Hour General Industry Outreach Training.

What Topics Does OSHA General Industry Training Cover?

OSHA 10-Hour courses largely cover universal topics: Introduction to OSHA, General Safety and Health Provisions, Emergency Plans, Personal Protective Equipment, and Hazard Communication.  A few of the topics are general to industrial work like Electrical and Machine Guarding Safety.

Topics that require additional training are as varied as Bloodborne Pathogens, Ionizing and Non-Ionizing Radiation, Confined Spaces, Welding and Cutting, and Petroleum Refining.  Most heavy equipment requires its own training, as well.

Those topics don't appear in the 10-Hour course, but they're often rolled into OSHA 30-Hour courses since supervisors are responsible for workers with a range of duties.

Are There Other OSHA Standards?

There are two other industry-specific standards, aside from Construction: Maritime and Agriculture.

What are OSHA Maritime Standards?

OSHA Maritime standards cover shipyards (29 CFR 1915), marine terminals (1917), and longshoring (1918). Gear certification standards (1919) apply to all three. Like Construction and General Industry, Maritime Outreach Training programs are available from authorized providers in the form of 10-Hour and 30-Hour courses.

You'll notice we didn't mention coverage of things like fishing vessels or oil tankers. That's because the U.S. Coast Guard (USCG) protects the safety and health of employees on most maritime vessels. OSHA's anti-discrimination and whistleblower provisions still apply. But specific safety standards and inspections are the USCG's responsibility.

What are OSHA Agriculture Standards?

OSHA Agriculture standards are laid out in 29 CFR 1928.  They address agriculture-specific hazards like the use of farm equipment and exposure to inhalants.  General Industry standards (1910) also apply.

No agriculture-specific Outreach Training program exists. Instead, OSHA has a list of recommended resources. Some OSHA-authorized training providers offer adapted versions of General Industry training, as well.

Anything Else?

OSHA also authorizes Disaster Site Worker Outreach Training, though no separate standards exist.  The training addresses the specific dangers of natural or man-made disasters.

In the same way that the USGS regulates maritime vessels, a few other industries are regulated by specialized federal agencies instead of OSHA. This includes the Department of Energy and the Mine Safety and Health Administration. 

Employers in those industries still have to educate workers about their rights under OSHA, but the other agencies handle specific safety standards and inspections.

What About Other Health & Safety Threats?

The General Duty Clause of the Occupational Safety and Health Act says employers have to protect workers from all "recognized hazards." This means they're duty-bound to minimize risks that OSHA hasn't spelled out, once they're aware they exist.

This allows OSHA to hold employers responsible for health and safety issues that aren't technically a violation of any particular standard.

Bottom Line

OSHA training is crucial to legal compliance and your workforce's safety. These days, you can provide workers with online OSHA coursework instead of classroom training. It offers flexible scheduling and a self-paced experience for individual workers. It's also more efficient, consistent, and cost-effective. 

We're a leading OSHA-authorized provider with over fifteen years of experience. We can also handle your other safety training needs, like DOT and MSHA.  And we offer whole-business solutions to make training compliance simple. Contact us today!

Determining when OSHA general industry or construction standards are applicable in your facility can be one of the more complicated regulatory compliance questions to answer. Does painting part of your facility fall under construction or general industry? What about a repair or a demolition? Because these standards can be used to regulate the same hazards, deciding when to use the general industry vs. the construction standard can be confusing.

The construction industry standard in 29 CFR 1926 covers construction workplace hazards and addresses the responsibilities of construction industry employees. The general industry standard in 29 CFR 1910 refers to all industries not included in construction, agriculture or maritime. However, even with these differentiations, determining where your hazards fall can be tricky.

OSHA General Industry vs. Construction Standards

While the general industry and construction standards can have similarities, it’s important to note that these standards cannot be used interchangeably. Even when both general industry and construction standards can regulate the same hazard, they are likely to have significant differences:

• Cranes. While the construction standard addresses requirements for crane suspended platforms, material hoists and personnel hoists, the general industry regulations do not include these requirements.
• Electrical. The construction standard requires ground fault circuit interrupters (GFCIs) or an assured equipment conductor grounding program on all 120-volt outlets used by employees that are not part of permanent wiring. GFCIs and assured grounding programs are not addressed in the general industry standards.
• Material Handling – Rigging. The construction standard contains a table for requirements in spacing and numbering wire rope clips, while this is not included in the general industry regulations.

Some standards, such as Hazardous Waste Operations and Emergency Response (HAZWOPER) and the Hazard Communication Standard, are duplicated in the general industry and construction standards. Determining which of these duplications to use will need to be made on a case-by-case basis.

Determining Where Your Work Falls

Workplaces classified as a general industry facility might still have activities OSHA can classify as construction work. Under the 1910 general industry standard, OSHA describes construction work as “work for construction, alterations, and/or repair, including painting and decorating.” If you have facility projects such as additions to buildings, painting, making alterations or demolition work, they are considered construction work by OSHA and therefore citable under the 1926 construction standard.

If you are trying to determine if your work falls under general industry or construction, there are guidelines that may help:

• Non-construction companies can perform work that OSHA will classify as construction work.
• Construction work is not limited to new construction. It includes the repair of existing facilities.
• Maintenance is not usually considered construction. While OSHA does not provide a specified definition for maintenance, maintenance activities can be defined as making or keeping a structure, fixture or foundation in proper condition in a routine, scheduled or anticipated fashion. This definition implies keeping equipment working in its existing state. However, evaluating whether a maintenance activity will fall under construction regulations must be on a case-by-case basis.
• Using a company’s own employees or an outside contractor is not relevant. It is the classification of the work that matters, not who is performing it.
• Scale and complexity of the job can make a difference. The more involved an operation is, the more likely OSHA is to view it as construction and not maintenance.

Researching the standards will be necessary to make your determination. The specific differences between construction and general industry standards must be considered. OSHA also publishes compliance directives and letters of interpretations that may be helpful.

Get OSHA Support

For an employer, there are no clear-cut rules for determining when to apply OSHA general industry vs. construction standards. While OSHA provides guidelines, the burden of deciding which standard to apply falls on the employer and will often need to be made on a case-by-case basis.

There will be cases when, even after careful consideration, the classification of work will still be uncertain and a judgement call will need to be made. When in doubt, a good practice is to comply with the standard with the stricter requirements.

For help in determining your OSHA general industry vs. construction compliance burdens, contact Tetra Tech’s health and safety experts at [email protected]. Tetra Tech can help you reduce your workplace hazards and make determinations about your compliance.