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 https://www.osha.gov.

August 24, 1995

Ms. Suzanne Beamer
Vice President-Communications
National Electric Sign Association
801 North Fairfax Street, Suite 205
Alexandria, Virginia 22314

Dear Ms. Beamer:

This is in response to your letter of March 15, to the Occupational Safety and Health Administration (OSHA) in which you inquired as to which OSHA standards, general industry or construction, does the sign industry fall under.

Unfortunately, this is a cumbersome question to answer, because it depends on so many variables. For example, during the manufacturing of a sign in a manufacturing facility, general industry standards apply. If the manufactured sign is then just attached to a building or existing structure, general industry standards still apply. If billboards are being maintained, such as when lights are replaced, general industry standards apply. General industry standards also apply if a new message is being applied to an existing billboard.

If a manufactured sign being installed has to have structural members built for it on the installation site, OSHA's construction standards apply during the installation.

If billboards are being constructed on site, then the construction standards apply. Similarly, if the billboard is being repainted or repaired, the construction standards apply.

I am sure that you can think of many other examples that may need clarification. If you have any questions, please call me or Dale Cavanaugh of my staff at (202) 219-8136.


Roy. F. Gurnham, P.E., J.D.
Office of Construction and Maritime
Compliance Assistance