October 17, 2025

When OSHA 1926 Falls Short in Colleges and Universities: A Deep Dive into Materials Handling, Storage, Use, and Disposal

OSHA's 1926 standards on Materials Handling, Storage, Use, and Disposal are designed to ensure safety in construction settings. But what about in academic environments like colleges and universities? Here, we'll explore where these regulations might not apply or could fall short, and what institutions need to know to maintain a safe campus.

Understanding OSHA 1926 Scope

OSHA 1926 primarily focuses on construction work. This means it covers activities such as building, altering, or repairing structures. In a university setting, this might apply to new construction projects or major renovations but not to the day-to-day operations of a campus.

Where 1926 Doesn't Apply

Colleges and universities often engage in activities that don't fall under construction work. For instance, routine maintenance, custodial services, and lab operations are generally outside the scope of 1926. Yet, these activities can still pose significant safety risks.

In my experience, universities often have specialized labs where hazardous materials are handled. These environments require a different set of safety protocols than what's outlined in 1926. For example, the handling and disposal of chemicals used in chemistry labs are governed by OSHA's Hazard Communication Standard (29 CFR 1910.1200) rather than 1926.

Gaps in Coverage

While 1926 provides robust guidelines for construction safety, it may not address specific hazards unique to academic settings. Consider the following:

  • Lab Safety: The unique risks associated with handling research chemicals and biological agents in labs are not covered by 1926. Institutions must look to OSHA's Laboratory Standard (29 CFR 1910.1450) for guidance.
  • Student Housing: Maintenance and repair work in dormitories might fall under 1926, but the day-to-day operations and safety in these living spaces are not addressed by these regulations.
  • Academic Workshops: Workshops for educational purposes, such as woodworking or metalworking classes, are typically not construction sites and thus fall outside 1926's jurisdiction.

Based on available research, individual results may vary, but universities often find that a combination of standards from both OSHA 1910 and 1926, along with additional safety measures tailored to their specific environments, is necessary to ensure comprehensive safety.

What Universities Should Do

To bridge the gaps left by OSHA 1926, universities should:

  1. Conduct thorough risk assessments tailored to their unique operations.
  2. Implement safety protocols that cover all campus activities, including those not addressed by OSHA 1926.
  3. Provide ongoing safety training for all staff and students, focusing on the specific hazards they may encounter.
  4. Regularly review and update safety policies to reflect changes in operations and new regulatory requirements.

By taking these steps, universities can ensure a safer environment for everyone on campus, even where OSHA 1926 does not apply.

For further reading, consider the resources provided by the American Chemical Society on lab safety, and the National Institute for Occupational Safety and Health (NIOSH) publications on educational settings.

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