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OSHA 1915.1008

bis-Chloromethyl ether requirements

Subpart Z

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1008, are the bis-Chloromethyl ether requirements for shipyard employment the same as those in 1910.1003?

Yes. Under 1915.1008 the requirements applicable to shipyard employment are identical to those set forth at 1910.1003, so shipyard employers must follow the same controls and obligations required in 1910.1003.

Under 1915.1008, who is required to comply with the bis-Chloromethyl ether rules in shipyard workplaces?

Shipyard employers and their employees performing shipyard work are required to comply. 1915.1008 states that the requirements for bis-Chloromethyl ether in shipyard employment are the same as those in 1910.1003, so any obligations in 1910.1003 apply to shipyard operations covered by Part 1915.

Under 1915.1008, does the shipyard standard add any extra requirements beyond 1910.1003 for bis-Chloromethyl ether?

No. 1915.1008 explicitly states the requirements for shipyard employment are identical to those set forth at 1910.1003, so there are no additional shipyard-specific provisions in 1915.1008 beyond what 1910.1003 requires.

Under 1915.1008, if I manage both shipyard and non-shipyard worksites, which standard should I use to meet OSHA obligations for bis-Chloromethyl ether?

Use the Part that covers the work you are doing: follow 1915.1008 for shipyard employment and follow 1910.1003 for general industry. Because 1915.1008 makes the shipyard rule identical to 1910.1003, the compliance measures will be the same where the standards overlap.

Under 1915.1008, where should shipyard employers look for the detailed requirements and compliance steps for bis-Chloromethyl ether?

Shipyard employers should follow the detailed requirements in 1910.1003 because 1915.1008 declares the shipyard requirements identical to that section; employers must implement the procedures, controls, and recordkeeping specified there.

Under 1915.1008, can OSHA inspectors cite shipyard employers under 1915.1008 even though the requirements mirror 1910.1003?

Yes. OSHA enforcement for shipyard employment is done under the shipyard standard citation. Because 1915.1008 makes the requirements identical to 1910.1003, inspectors will cite the appropriate Part 1915 paragraph when issuing violations for shipyard work while expecting compliance consistent with 1910.1003.

Under 1915.1008, are compliance dates or historical notes provided that shipyard employers should be aware of?

Yes. 1915.1008 includes historical Federal Register citations showing when the provision appeared or was amended; however, for current detailed requirements and compliance timelines shipyard employers must refer to 1910.1003, which contains the operative provisions.

Under 1915.1008, do state-plan states have to follow the same bis-Chloromethyl ether requirements for shipyards as federal OSHA?

State-plan states must have standards and enforcement programs that are at least as effective as Federal OSHA, but they may adopt different or more stringent rules. For federal coverage the shipyard rule in 1915.1008 mirrors 1910.1003; employers should confirm whether their State plan has adopted an identical rule or a more stringent variant. OSHA letters note that employers in State plan states must follow that State's requirements when they are more stringent (see discussion of State plans in OSHA interpretations such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01).

Under 1915.1008, where can I find official electronic access to the regulatory text referenced by the shipyard standard?

Consult the regulation citations directly: 1915.1008 identifies the shipyard bis-Chloromethyl ether rule and points to 1910.1003 for the detailed requirements; those pages on OSHA's website provide the official regulatory text and linked references.

Under 1915.1008, can OSHA letters of interpretation help clarify how the bis-Chloromethyl ether requirements apply in specific shipyard scenarios?

Yes. OSHA issues letters of interpretation and enforcement memoranda that clarify how standards apply to particular situations; for shipyard employers the operative text is 1910.1003 (as adopted by 1915.1008), and employers may consult OSHA interpretation letters on related subjects or request a new interpretation for specific scenarios. OSHA's interpretation letters are published at URLs such as https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and others provided by OSHA.

Under 1915.1008, if a shipyard employer finds bis-Chloromethyl ether in a shipboard repair task, which Part and section set the compliance controls they must follow?

The employer must follow the controls set forth in 1910.1003 because 1915.1008 makes the shipyard requirements identical to that general industry section; implement the exposure controls, monitoring, and other obligations specified in 1910.1003 for the shipboard repair task.