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• Standard Number: 1910.12(b)

October 25, 1983

Mr. Richard A. Kappel, Jr.
Director - Safety Engineering
JLG Industries, Inc.
JLG Drive
McConnellsburg, Pennsylvania 17233

Dear Mr. Happel:

This is in response to your letter of September 29, 1983, addressed to Mr. John K. Barto, requesting a clarification of whether General Industry or Construction Safety Standards apply to maintenance painting being done in and around a manufacturing plant.

29 CFR 1910.12(b) defines "construction work" as work for construction, alteration, and/or repair, including painting and decorating. Thus, the Construction Safety Standards are enforced for maintenance painting of the building or structure at a manufacturing plant.

If I may be of further assistance, please feel free to contact me.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations

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