OSHA 1915.1010
Benzidine requirements
Subpart Z
Questions & Answers
Under 1915.1010, where should I look to find the technical requirements (exposure limits, monitoring, medical surveillance) for benzidine?
Under 1915.1010, does the benzidine rule only apply to shipyard employees, or to all work aboard vessels and contractors working on shipyard property?
The subject of applicability under 1915.1010 is shipyard employment and, per that section, the benzidine requirements mirror 1910.1003. In practice, this means employers engaged in shipyard employment (including contractors working on shipyard sites) must follow the benzidine protections found in 1910.1003. For work performed by non-OSHA-covered federal military personnel, see the federal-employee coverage discussion in OSHA’s interpretation about Department of Defense facilities at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.
Under 1915.1010, if my company operates in a State with its own OSHA-approved State Plan, which benzidine rule applies?
Under 1915.1010 the benzidine requirements are the same as 1910.1003, but employers in States with OSHA-approved State Plans must follow their State’s rules if those rules are more stringent. OSHA has explained that State Plans are required to have standards and enforcement at least as effective as federal OSHA and that State Plans may adopt more protective requirements (see points made in OSHA interpretations such as https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06). Check your State Plan regulations for any additional or stricter benzidine requirements.
Under 1915.1010, can an employer rely on OSHA Letters of Interpretation to change how they meet benzidine requirements?
No—Letters of Interpretation explain OSHA requirements but do not create new regulatory obligations or replace the standard text. Under 1915.1010 you must comply with the benzidine requirements as written (which are identical to 1910.1003); OSHA letters (for example, the head-protection interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2) provide clarifying guidance but cannot be used to alter employer obligations.
Under 1915.1010, does OSHA enforce benzidine requirements differently in shipyards than in other workplaces?
Under 1915.1010, if I need to write a shipyard safety procedure for benzidine, which standard language should I quote and cite in my program?
Cite the shipyard section and the general industry section together: reference 1915.1010 and the substantive requirements at 1910.1003. Because 1915.1010 expressly makes the requirements identical to 1910.1003, quoting the compliance obligations in 1910.1003 in your written program satisfies the citation requirement for shipyard employment.
Under 1915.1010, who should I contact if I need clarification on how benzidine rules apply to a specific shipyard task or situation?
Begin by reviewing 1915.1010 and 1910.1003 for the applicable requirements; for official clarification you can request an OSHA Letter of Interpretation or contact your local OSHA regional or State Plan office. Remember that OSHA letters clarify but do not create new obligations, as noted in OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.
Under 1915.1010, are there any historical Federal Register notices or rulemaking entries that explain the benzidine rule's adoption for shipyards?
Yes. 1915.1010 includes Federal Register citations in its history: see the notices at 58 FR 35570 (July 1, 1993) and later entries (61 FR 5507; 61 FR 9227; 61 FR 31427). These entries document the promulgation and amendments that confirm the shipyard benzidine requirements are identical to 1910.1003.
Under 1915.1010, if a contractor working in a shipyard discovers benzidine-containing material, which standard should their site supervisor follow immediately?
The site supervisor should follow the benzidine protections set out in 1910.1003 because 1915.1010 makes those requirements applicable to shipyard employment. The supervisor should immediately implement the exposure control, notification, and any medical or work-practice measures specified in 1910.1003 while coordinating with the shipyard employer and any applicable State Plan guidance.
Under 1915.1010, does OSHA allow different engineering controls or work practices for shipyards than those listed in 1910.1003 for benzidine?
No—1915.1010 states the shipyard requirements are identical to 1910.1003, so any alternative engineering controls or work practices must achieve at least the same level of protection required by 1910.1003. If an employer believes an alternative provides equivalent protection, document the basis and be prepared to show equivalence during inspection; remember OSHA interpretation letters can clarify implementation but do not supersede the standards (see https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2).