DB-8 163(a)
U. S. DEPARTMENT OF LABOR
OFFICE OF THE SOLICITOR
WASHINGTON 25
July 17, 1961
MEMORANDIM #23
TO: - AGENCTES ADMINISTERING STATUTES REFERRED TO IN 29 CFR,
SUBTITLE A, PART 5.
FROM: Charles Donahue
Solicitor of Labor
SUBJECT: Application of the Labor Standards Requirements of the
Davis-Bacon Act to Steam and Sand Blast Cleaning of
Buildings or Works Including, but not Limited to, Build-
ings, Monuments and Statues.
In defining the work within the ambit of the statute, the
pertinent part of Section 1 of the Davis-Bacon Act reads as follows:
"... for construction, alteration, and/or repair, including painting
and decorating, of public buildings or public works of the United
States ...".
Steam and sand blast cleaning operations performed on public
buildings or works are authorized for the purpose of renewing the
original appearance of these buildings or works and are performed
for the same purpose as painting and decorating which were cited as
examples of construction, alteration and repair covered by the Davis-
Bacon Act as indicated above.
The classifications of employees and the equipment used
in the performance of such work are those traditionally employed in
the construction industry. The work is not of a regular or recurring
nature so as to raise the question of the possibility of its being
considered as noncovered maintenance work.
Various federal agencies here, as a matter of course, regu-
larly included the labor standards provisions of the Davis-Bacon Act
and the Eight Hour Laws in contracts let for the steam and sand blast
cleaning of public buildings and public works.
Recently, in connection with a Government contract requiring
steam and sand blast cleaning and bird proofing, the question of
whether such work was subject to the Davis-Bacon and related Acts



















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was raised. In view of the absence of a prior opinion directly in
point, it has been brought to my attention that the general circu-
lation of this Department's ruling that the performance of steam
and sand blast cleaning work under Government contracts of the re
quisite jurisdictional amounts would be subject to the provisions
of the Davis-Bacon and related Acts would be appropriate and helpful
in the maintenance of the labor standards required on Federal and
Federally assisted construction.