The International Sign Association asked OSHA whether commercial sign installation falls under the construction standards (29 CFR part 1926) or general industry standards (29 CFR part 1910), particularly for crane operator certification. OSHA started from the definition: construction work is "work for construction, alteration, and/or repair, including painting and decorating" (29 CFR 1926.32), and the construction standards apply to every employment and place of employment of every employee engaged in construction work.
The dividing line is the maintenance-versus-construction distinction. Work that is "anticipated, routine and done on a regularly scheduled/periodic basis to help maintain the original condition" points toward maintenance, though scale must also be considered. For replacements, the analysis turns on whether the job involves extensive repairs or an improved type of equipment. Scale and complexity matter: OSHA gave the example that replacing a section of limestone cladding on a building would typically be construction because it is a complex task.
Applied to signs: like-in-kind replacements require case-by-case analysis, but routine removal and replacement of billboards designed for that purpose typically is not construction. Stadium scoreboard replacement is generally construction due to its large scale and complexity, even when the new unit is nearly identical. New installations and upgrades, including awning installation, electrical retrofits, and new scoreboard installation, are typically construction activities. OSHA's overall conclusion is that most routine sign removal and replacement is not construction, but the determination is fact-specific and rests on multiple factors, not any single element.