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OSHA 1915.1004

alpha-Naphthylamine requirements

Subpart Z

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1004, are the alpha-naphthylamine requirements for shipyard employment different from the general industry requirements?

Yes — the alpha-naphthylamine requirements for shipyard employment are identical to the general industry requirements found at 1910.1003. The rule text explicitly states that the requirements applicable to shipyard employment under 1915.1004 are identical to those set forth at 1910.1003 of this chapter.

Under 1915.1004, where should a shipyard employer look for the detailed compliance obligations for alpha-naphthylamine?

A shipyard employer should follow the detailed provisions in 1910.1003, because 1915.1004 directs that the shipyard requirements are identical to that general industry section. Use the text and obligations in 1910.1003 for specifics on exposure controls, monitoring, labeling, medical surveillance, and training.

Under 1915.1004, does citing 1915.1004 alone satisfy documentation when explaining alpha-naphthylamine requirements to shipyard workers or inspectors?

No — when explaining the detailed requirements you must reference the substantive provisions in 1910.1003, because 1915.1004 simply states that shipyard requirements are identical to that section. In communications and compliance documents, point to the specific paragraphs of 1910.1003 for obligations such as exposure monitoring, labeling, and medical requirements.

Under 1915.1004, do letters of interpretation for 1910.1003 apply to shipyard employers dealing with alpha-naphthylamine?

Yes — letters of interpretation and official guidance that clarify 1910.1003 apply equally to shipyard employers because 1915.1004 makes the shipyard requirements identical to 1910.1003. When seeking clarifications about how a provision applies in practice, consult the interpretive letters associated with 1910.1003.

Under 1915.1004, does the shipyard standard for alpha-naphthylamine create any additional obligations beyond 1910.1003?

No — 1915.1004 does not create additional obligations; it states the shipyard requirements are identical to 1910.1003. Employers must comply with the duties and procedures found in 1910.1003 for alpha-naphthylamine in shipyard workplaces.

Under 1915.1004, if a shipyard employer needs the official regulatory text and history for alpha-naphthylamine, where can they find it?

Find the official regulatory text and the Federal Register history by consulting 1915.1004 for the shipyard reference and 1910.1003 for the substantive provisions. The 1915.1004 page also lists the Federal Register citations showing the rulemaking dates and notices of applicability.

Under 1915.1004, who enforces the alpha-naphthylamine requirements in shipyards — federal OSHA or a state plan?

Enforcement is by the authority that normally covers the workplace: federal OSHA enforces federal standards in OSHA jurisdiction but an OSHA-approved State Plan enforces equivalent or more-stringent state standards in that state. The 1915.1004 requirement follows 1910.1003, and if your state operates an OSHA-approved State Plan, that State Plan enforces the standard locally; see OSHA general guidance on State Plans at https://www.osha.gov/stateplans (refer to State Plan rules when applicable).

Under 1915.1004, can shipyard employers follow compliance tools or checklists developed for 1910.1003 without modification?

Yes — compliance tools and checklists developed for 1910.1003 are appropriate for shipyard employers because 1915.1004 makes the shipyard requirements identical. Always confirm that any checklist matches the specific paragraphs of 1910.1003 that apply to your operations.

Under 1915.1004, does the cross-reference to 1910.1003 change recordkeeping or reporting obligations for alpha-naphthylamine in shipyards?

No — recordkeeping and reporting obligations for alpha-naphthylamine in shipyards follow the requirements set in 1910.1003 because 1915.1004 makes the standards identical. If you need clarity on specific recordkeeping elements, consult the text of 1910.1003 and any applicable interpretive letters.

Under 1915.1004, does the statement that requirements are "identical" to 1910.1003 mean shipyards can ignore other shipyard-specific regulations in Subpart I or Subpart Z?

No — saying the alpha-naphthylamine provisions are identical to 1910.1003 does not remove other shipyard-specific obligations. Shipyard employers must comply with all applicable shipyard regulations in Part 1915, including other provisions of Subpart Z and any shipyard-specific requirements, while using 1910.1003 for the alpha-naphthylamine specifics per 1915.1004.

Under 1915.1004, what should a shipyard safety manager do first when they discover alpha-naphthylamine may be present at their workplace?

The first action is to consult 1910.1003 and apply its requirements to your shipyard because 1915.1004 states shipyard requirements are identical to that section. That means reviewing the specific provisions in 1910.1003 on hazard identification, exposure controls, monitoring, training, and medical surveillance and implementing those measures in the shipyard workplace.