Ezel / Labor Guidance / US
Back to Federal guidance

Construction rules for maintenance painting at a plant

Summary A manufacturer asked whether general industry or construction safety standards govern maintenance painting around its plant. OSHA cited the construction work definition, which includes painting and decorating, and said it enforced construction standards for maintenance painting of a building or structure there. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1983-10-25
Date issued
October 25, 1983
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1926 Construction Maintenance Coverage
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 25, 1983

Mr. Richard A. Kappel, Jr.
Director - Safety Engineering
JLG Industries, Inc.
[Recipient address omitted]
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

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace