Subpart Z
Yes — the requirements for 3,3'-Dichlorobenzidine that apply in shipyard employment are the same as those in the general industry rule at 1910.1003. The shipyard rule explicitly states that the requirements applicable to shipyard employment under 1915.1007 are identical to those set forth at 1910.1003. Employers in shipyards should follow the provisions and compliance obligations found in 1910.1003.
The specific requirements are located in the general industry rule 1910.1003, which 1915.1007 adopts for shipyard employment. Because 1915.1007 states the shipyard requirements are identical to 1910.1003, look to 1910.1003 for the details on exposure controls, medical surveillance, training, and recordkeeping.
Yes — compliance with 1910.1003 satisfies the shipyard requirement because 1915.1007 makes the shipyard requirements identical to the 1910.1003 provisions. In practice, apply the policies, procedures, and documentation required by 1910.1003 to shipyard workers exposed to 3,3'-Dichlorobenzidine to meet the obligations under 1915.1007.
Shipyard employers must follow the employer duties spelled out in 1910.1003 for 3,3'-Dichlorobenzidine, because 1915.1007 adopts those requirements for shipyard work. That means you should consult 1910.1003 for specific obligations such as exposure monitoring, medical surveillance, employee training, labeling, and recordkeeping and implement those measures in shipyard operations.
Yes — employers must follow the hazard communication and labeling-related provisions that apply through the requirements in 1910.1003 and other related 1910 standards. Since 1915.1007 adopts the 1910.1003 requirements for shipyards, you must implement the labeling, Safety Data Sheets, and employee information/training that 1910 standards require where they apply.
Yes — any employer with employees exposed to 3,3'-Dichlorobenzidine at a shipyard must meet the requirements adopted by 1915.1007, which point to 1910.1003. Employers who hire contractors or subcontractors in shipyard settings should ensure those contractors follow the obligations in 1910.1003 for training, monitoring, and protective measures when their employees may be exposed.
Shipyard employers must retain the records required by 1910.1003, as 1915.1007 makes the 1910.1003 requirements applicable to shipyards. That means any medical, monitoring, training, or other records specified in 1910.1003 must be created and maintained in accordance with the timelines and retention rules found there.
Yes — employers in states with OSHA-approved State Plans must follow that State's requirements if they are more stringent than the federal rules adopted by 1915.1007. OSHA letters of interpretation note that State Plans may have different or more stringent requirements, so check your State Plan in addition to the federal 1910.1003 obligations that 1915.1007 adopts. For an example discussion of State Plan interactions in other contexts, see the discussion in the Scope of rim wheel servicing letter of interpretation.
Begin by following the program elements and requirements in 1910.1003, since 1915.1007 adopts those provisions for shipyards. Practical first steps include:
Authoritative regulatory text is in 1915.1007 and the identical provisions at 1910.1003; you should consult those provisions first. For interpretive guidance on how OSHA applies standards to specific situations, you can also review OSHA Letters of Interpretation and contact OSHA regional offices. Because 1915.1007 adopts 1910.1003, rely on the regulatory text in those links for compliance obligations and seek OSHA interpretation letters or regional advice for clarifications.
No — stating the shipyard requirements are identical to 1910.1003 means OSHA will evaluate compliance in shipyards using the same substantive provisions found in 1910.1003. Employers should expect inspections and enforcement actions to assess whether the employer has met the obligations set out in 1910.1003 as applied to shipyard operations under 1915.1007.