Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

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.


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