Shipyard employment standards adoption

Under 1910.15(a) the OSHA standards in part 1915 that were in effect on April 28, 1971, are adopted and apply to ship repair, shipbreaking, shipbuilding, and related employment. Employers must follow those adopted shipyard standards as occupational safety and health standards as described in 1910.15(a).

• Employers should consult the adopted part 1915 requirements for specific shipyard hazards because 1910.15(a) makes those shipyard rules applicable under part 1910.

Reference: Adoption and extension of established safety and health standards for shipyard employment in 1910.15(a) and the adopted shipyard standard source at part 1915.

Under 1910.15(a) every employer engaged in ship repair, shipbreaking, shipbuilding, or a related employment must comply with the appropriate adopted shipyard standards to protect their employees. The provision explicitly requires each employer to protect the employment and places of employment of each of his employees by complying with the standards in 1910.15(a).

• This obligation is an employer duty—if the work is ship repair, shipbreaking, shipbuilding, or related employment, the employer must follow the applicable adopted shipyard rules.

Reference: 1910.15(a).

Under 1910.15(b)(1) 'ship repair' includes any repair of a vessel and specifically covers alterations, conversions, installations, cleaning, painting, and maintenance work. The definition is intentionally broad to capture the many repair activities that occur on vessels, as stated in 1910.15(b)(1).

• If a task on a vessel involves fixing, modifying, installing, cleaning, painting, or routine maintenance, it fits the 1910.15(b)(1) definition of ship repair.

Reference: 1910.15(b)(1).

Under 1910.15(b)(2) 'shipbreaking' means breaking down a vessel's structure for scrapping, including removing gear, equipment, or any component of a vessel. The definition covers the deliberate dismantling and component removal activities associated with scrapping, per 1910.15(b)(2).

• Shipbreaking includes cutting up the hull, removing machinery and fittings, and stripping out components during scrapping operations.

Reference: 1910.15(b)(2).

Under 1910.15(b)(3) 'shipbuilding' means constructing a vessel and includes installation of machinery and equipment during that construction. The definition is meant to encompass the full vessel construction process, including outfitting, as specified in 1910.15(b)(3).

• Any employment involved in building and outfitting a vessel qualifies as shipbuilding under this definition.

Reference: 1910.15(b)(3).

Under 1910.15(b)(4) 'related employment' means any work performed as an incident to or in conjunction with ship repair, shipbreaking, or shipbuilding, and explicitly includes inspection, testing, and employment as a watchman. Thus inspectors, testers, watchmen, and other incidental workers are covered when their duties are tied to shipyard work, per 1910.15(b)(4).

• If a worker's role supports ship repair, shipbreaking, or shipbuilding (even if not directly on the hull), that worker typically falls under the adopted shipyard standards.

Reference: 1910.15(b)(4).

Under 1910.15(b)(5) a 'vessel' includes every description of watercraft or other artificial contrivance used, or capable of being used, as a means of transportation on water, and also includes special purpose floating structures not primarily designed for transportation on water. This broad definition is in 1910.15(b)(5).

• Examples include boats, ships, barges, and floating work platforms or other special-purpose floating structures.

Reference: 1910.15(b)(5).

Under 1910.15, asbestos encountered during ship repair that involves building- or construction-type remediation would generally be subject to OSHA's construction asbestos standard rather than the general industry standard. OSHA has explained that remediation activities involving asbestos-containing building materials are covered by the construction standard at 29 CFR 1926.1101, as described in the asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

• If shipyard work is demolition, renovation, or other activities that disturb asbestos-containing building materials, follow the requirements in OSHA’s construction asbestos standard as stated in the cited interpretation.

References: 1910.15 and the asbestos letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

Under 1910.15, OSHA standards apply to civilian employees working on equipment, systems, or operations that are not uniquely military, even on Department of Defense facilities; military personnel and uniquely military systems are excluded. OSHA explained this civilian coverage in the HVAC/DoD interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

• If a civilian contractor performs ship repair or related work on DoD property and the work is comparable to private-sector shipyard activities, the adopted shipyard standards in 1910.15(a) can apply.

References: 1910.15(a) and OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

Under 1910.15, shipyard operations that include on-site storage of a Category 1 flammable gas in quantities meeting or exceeding the PSM threshold can be covered by the PSM standard; OSHA has explained that storage of pre-charged equipment with Category 1 flammable gas in one location can trigger PSM coverage in the PSM flammable gas aggregation interpretation.

• If the aggregate weight of the flammable refrigerant on site in one location meets or exceeds the PSM threshold (10,000 pounds for certain flammables), the activity can be treated as a PSM-covered process (storage and on-site movement are included in the definition of a process), per the cited interpretation.

References: 1910.15(a) and OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

Under 1910.15, if a crane operator in a shipyard is exposed to overhead hazards that could cause head injury from falling objects, the employer must require head protection for those employees. OSHA's head protection interpretation clarifies that employers must provide helmets where there is potential for head injury, including during lifting operations, as explained in https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

• Employers should assess the workplace hazards (per general PPE obligations) and require helmets that meet applicable ANSI consensus standards when overhead hazards exist.

References: 1910.15(a) and the head protection interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

Under 1910.15, stepping from a ladder onto a low-slope roof and walking directly to a work area 25 feet from the edge does not automatically require fall protection, but fall protection rules may apply once work exposes an employee to heights near the edge. OSHA’s fall protection interpretation explains that walking from a ladder to a low-slope roof work area generally does not trigger a specific fall-protection requirement unless the worker performs work at distances that meet the standard’s trigger points, as discussed in https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1.

• Employers must evaluate the task: if the work is performed less than 6 feet from the roof edge or involves walking/working at heights covered by the applicable fall-protection provisions adopted for shipyard work, employer must provide appropriate fall protection.

References: 1910.15(a) and OSHA fall protection interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1.

Under 1910.15, the requirements for mobile ladder stands and mobile ladder stand platforms apply where employers use those devices in shipyard work to access elevated work surfaces; OSHA’s mobile ladder stand interpretation summarizes the step, width, handrail, and guard requirements that apply to such platforms in https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

• For example, mobile ladder stands must meet step rise, tread depth, and step width minimums; platform heights determine whether handrails, midrails, or guardrails and toeboards are required as described in the interpretation.

References: 1910.15(a) and OSHA mobile ladder stand interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

Under 1910.15, when shipyard servicing requires temporary re-energization for testing or positioning and the minor-servicing exception does not apply, OSHA permits temporary removal of lockout/tagout devices only when necessary and only if employers implement specific procedures to protect employees during re-energization. OSHA explains these requirements and the required sequence of actions in the lockout/tagout interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

• Employers must follow 1910.147(f)(1) steps: clear tools/materials, remove employees from danger zones, remove devices as specified, energize for testing with effective employee protection, then de-energize and reapply lockout/tagout if further servicing is needed, as explained in the cited interpretation.

References: 1910.15(a) and the LOTO interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

Under 1910.15, when measuring standard stair width the handrails are not considered vertical barriers or obstructions to the required minimum width; OSHA explains that stair width is measured between vertical barriers (rails, guardrails, walls), not between handrails, in the stair-width interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17.

• Employers should measure stair width between vertical barriers and may exclude handrails from being counted as obstructions when complying with stair-width requirements.

References: 1910.15(a) and the stair-width interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17.