beta-Naphthylamine requirements
Subpart Z
Questions & Answers
For a shipyard employer, where should I look for specific exposure limits and control measures for beta‑Naphthylamine under 1915.1009?
Under 1915.1009, does an employer in shipbuilding have to follow the same medical surveillance and recordkeeping rules for beta‑Naphthylamine as general industry?
Under 1915.1009, do shipyard employers have to provide employee training about beta‑Naphthylamine?
Yes — any training requirements for beta‑Naphthylamine in shipyard employment are the same as those in 1910.1003, because 1915.1009 makes the shipyard rule identical to that general industry provision.
- Training topics, frequency, and who must be trained are defined in 1910.1003. Shipyard employers must follow those specifics.
- If you need plain-language items to include in training (hazards, controls, PPE, medical surveillance, and how to read labels/SDS), use the requirements in 1910.1003 as your checklist.
Under 1915.1009, must shipyard employers use the same methods for exposure monitoring of beta‑Naphthylamine as general industry?
Under 1915.1009, are shipyard employers required to implement specific engineering controls for beta‑Naphthylamine, or can they use alternative controls?
Shipyard employers must implement the control measures required in 1910.1003, since 1915.1009 makes the shipyard requirements identical to that section.
- If 1910.1003 specifies engineering controls (ventilation, enclosure, etc.), shipyard employers must meet those requirements under 1915.1009.
- Where 1910.1003 allows equivalent or performance-based alternatives, use those options only if they meet the same level of protection specified in the standard.
Under 1915.1009, do shipyard employers have to follow the same personal protective equipment (PPE) rules for beta‑Naphthylamine as general industry?
Under 1915.1009, when does the shipyard rule apply versus state OSHA plans that may have different rules for beta‑Naphthylamine?
The federal shipyard rule in 1915.1009 applies nationally, but an OSHA‑approved State Plan can have its own requirements that are at least as effective and may be more stringent; where a State Plan is in effect, employers must follow that State's rules if they differ. See the discussion of State Plans in OSHA guidance such as the rim wheel servicing interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01.
- 1915.1009 references 1910.1003 for substance‑specific requirements, but employers in States with OSHA‑approved plans should check their State standards and guidance as they may impose additional obligations.
- If a State Plan has different or stricter requirements for beta‑Naphthylamine, follow the State Plan.
Under 1915.1009, is hazard communication (SDSs and labels) for beta‑Naphthylamine covered by the same general industry rules?
Under 1915.1009, if a shipyard contractor brings materials that may contain beta‑Naphthylamine onto a vessel, who is responsible for compliance?
The employer(s) whose employees are exposed must comply — shipyard employers are responsible for protecting their employees under 1915.1009, which directs them to follow the requirements in 1910.1003.
- If employees of a contractor or the shipyard are exposed, the respective employers must meet their obligations under 1915.1009 and the referenced 1910.1003 rules (training, monitoring, controls, PPE, medical surveillance).
- When multiple employers share a worksite, coordinate hazard communication and protective measures so each employer can meet the duties described in 1910.1003.
Under 1915.1009, can a shipyard employer assume compliance if a supplier's SDS for beta‑Naphthylamine lists controls that differ from [1910.1003]?
No — a supplier SDS is informative but the employer must ensure workplace controls meet the legal requirements in 1910.1003, as applied through 1915.1009.
- Use the SDS to identify hazards and recommended precautions, but implement the monitoring, engineering controls, PPE, training, and medical surveillance required by 1910.1003 when those provisions apply in shipyard work under 1915.1009.
- If an SDS recommends a measure that provides equal or better protection than the specific requirement in 1910.1003, document and justify it as part of your compliance program.
Under 1915.1009, how should a shipyard employer document compliance activities for beta‑Naphthylamine during an OSHA inspection?
Document and present the same records and documentation required by 1910.1003 because 1915.1009 makes the shipyard requirements identical.
- Keep monitoring results, medical surveillance records (subject to applicable privacy rules), training logs, hazard assessments, written procedures, and any PPE or engineering-control maintenance records in the format and retention period specified in 1910.1003.
- Present these records on request to compliance officers; follow the documentation guidance in 1910.1003 during inspections.
Under 1915.1009, does the shipyard rule change how employers must label or restrict areas where beta‑Naphthylamine is used?
No — area controls, posting, and any labeling or access restrictions must follow the requirements in 1910.1003 because 1915.1009 makes the shipyard standard identical to that section.
- If 1910.1003 requires posted warnings, controlled areas, or access restrictions for beta‑Naphthylamine, then shipyard employers must apply the same measures under 1915.1009.
- Confirm the exact posting and area control language in 1910.1003 when creating site signage and lockout of contaminated areas.
Under 1915.1009, are emergency procedures (spill response, decontamination) for beta‑Naphthylamine the same for shipyards as for general industry?
Yes — emergency response and decontamination procedures required for beta‑Naphthylamine in shipyard employment must meet the requirements of 1910.1003 because 1915.1009 makes the rules identical.
- If 1910.1003 specifies spill cleanup procedures, emergency medical actions, or decontamination protocols for beta‑Naphthylamine, those same procedures apply in shipyard settings under 1915.1009.
- Integrate those procedures with shipboard or vessel emergency plans as needed and make sure employees are trained per 1910.1003.
Under 1915.1009, if the text of 1910.1003 is updated, does that automatically change shipyard requirements for beta‑Naphthylamine?
Yes — because 1915.1009 states the shipyard requirements are identical to 1910.1003, any regulatory changes to 1910.1003 will affect shipyard obligations under 1915.1009 once those changes are effective.
- Stay current with updates to 1910.1003 and any official OSHA notices that announce amendments; the shipyard cross‑reference means the same substantive requirements will apply.
- When OSHA issues changes or clarifying letters of interpretation that affect 1910.1003, consider their impact on shipyard programs covered by 1915.1009.