Construction means, "work for construction, alteration, and/or repair, including painting and decorating." 29 CFR 1926.32(g)

Without actually seeing the work that is being performed, I'd say that this is more than likely within the scope of "construction."

Take a look at the following letter of interpretation from OSHA, particularly question and answer #1. While it does not specifically address your question, it does discuss some of the criteria used to differentiate between "construction" and "maintenance."

Hope this helps.

Edited to add link to letter of interp. (oops.) http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=247 89

[This message has been edited by safetygem (edited 04-25-2005).]