OSHA 1915.1002
Coal tar pitch volatiles interpretation
Subpart Z
Questions & Answers
Under 1915.1002, where should a shipyard employer look to find the specific duties, exposure controls, and employee protections for coal tar pitch volatiles?
Look to the general industry rule at 1910.1002 because 1915.1002 makes the shipyard requirements identical to 1910.1002. That means the specific duties, permissible exposure limits (if any), required controls, monitoring, and training for coal tar pitch volatiles that apply in shipyards are those written in 1910.1002.
Under 1915.1002, does the phrase “Interpretation of term” create a new or different regulatory requirement for shipyards compared to 1910.1002?
No. The phrase indicates that 1915.1002 interprets and applies the same term and requirements as the corresponding general industry rule; it does not create a separate regulatory regime. The section text states the shipyard requirements are identical to those in 1910.1002, so shipyard employers must follow the same obligations set forth there.
Under 1915.1002, if an employer wants to confirm historical rulemaking or Federal Register citations for the shipyard rule on coal tar pitch volatiles, where does the section point them?
The section identifies the rulemaking history in its metadata and notes that the shipyard provisions mirror the general industry rule. See 1915.1002, which references the Federal Register notices (for example, 58 FR 35554 and 61 FR 31427) and directs users to the corresponding general industry standard at 1910.1002 for the substantive requirements.
Under 1915.1002, does OSHA treat shipyard employees differently than other industries for enforcement of coal tar pitch volatiles requirements?
Under 1915.1002, if a shipyard employer needs official OSHA guidance or interpretations for coal tar pitch volatiles, which standard should they reference when searching OSHA resources?
They should reference and search for guidance tied to 1910.1002, because 1915.1002 adopts the same requirements for shipyards. Official OSHA letters of interpretation, enforcement guidance, and compliance assistance related to coal tar pitch volatiles will generally be issued with respect to 1910.1002 and apply to shipyard work through 1915.1002.
Under 1915.1002, does the standard apply to all shipyard activities (e.g., shipbuilding, repair, conversion, and breaking) that expose workers to coal tar pitch volatiles?
Yes. Because 1915.1002 states the shipyard rule is identical to 1910.1002, any shipyard employment activity that would bring workers within the scope of 1910.1002 (use, exposure, or presence of coal tar pitch volatiles) is covered. Employers should evaluate their specific shipyard tasks against the requirements in 1910.1002 to determine applicable duties.
Under 1915.1002, if an employer in a state-plan state wants to know whether the shipyard coal tar pitch volatiles rule differs from federal OSHA, what should they do?
Confirm the state plan’s adopted shipyard rule, but the federal text clarifies that shipyard requirements mirror 1910.1002 as stated in 1915.1002. State-plan OSHA agencies must have programs at least as effective as federal OSHA, but they may adopt different or more stringent language—so check the applicable State plan’s regulations and consult the State OSHA office if any differences exist.
Under 1915.1002, during an OSHA inspection of a shipyard, what documentation should an employer have to demonstrate compliance with coal tar pitch volatiles rules?
Show documentation that demonstrates compliance with the obligations in 1910.1002, since 1915.1002 makes the shipyard requirements identical. Typical documentation includes exposure monitoring records, training records, control measures implemented, medical surveillance records (if required by 1910.1002), and written procedures or policies addressing coal tar pitch volatiles.
Under 1915.1002, if an employer finds ambiguous language or needs clarification about how a requirement of 1910.1002 applies in a shipyard setting, where can they get an official clarification?
Employers should consult OSHA’s published letters of interpretation, compliance directives, or contact their OSHA regional or State plan office for official clarification; these resources are generally issued in the context of 1910.1002 and apply to shipyards through 1915.1002. If a formal written interpretation is needed, request it from OSHA so the guidance explicitly addresses the applicable provisions.