Choosing the Right Standard: 1910 vs. 1926
Which part applies
Part 1926 governs construction work: construction, alteration, repair, painting, decorating, and demolition. Part 1910 governs general industry, such as manufacturing, warehousing, and service operations. The same company can do both: a maintenance crew using 1910 standards inside an operating plant must follow 1926 when it performs construction work, such as modifying a wall or installing a new process line that is construction rather than routine maintenance.
Overlap and multi-employer sites
Construction-specific standards control where they address the hazard. Subpart C, 1926.20 through 1926.35, provides baseline duties: programs, frequent and regular inspections by a competent person, training, first aid, housekeeping, illumination, PPE, egress, and emergency action plans. On multi-employer sites, OSHA may cite the creating employer, the exposing employer, the correcting employer, and the controlling employer under the multi-employer citation policy.
Worked example
A contractor is replacing the roof membrane on a commercial building. Because this is alteration/repair of a structure, 1926 applies, including Subpart M fall protection at 6 feet. If the building owner’s own maintenance employee later unclogs a roof drain using a ladder, that routine maintenance task is generally general industry and 1910 applies.
Traps
Do not assume that a “general industry” site means 1910 for every task; construction contractors still follow 1926. Do not cite both 1910 and 1926 for the same hazard without analyzing which part governs. The controlling employer’s duty is to exercise reasonable care, not to supervise every subcontractor task.