Vinyl chloride requirements

Yes. The rule at 1915.1017 explicitly states that the vinyl chloride requirements for shipyard employment are identical to those set forth at 1910.1017. Employers in shipyards must therefore comply with the provisions, definitions, monitoring, controls, and medical requirements found in 1910.1017.

• Follow the specific exposure, monitoring, and medical provisions in 1910.1017.
• Treat any guidance, compliance schedules, or enforcement related to 1910.1017 as applicable to shipyard operations covered by 1915.1017.

Look to 1910.1017, because 1915.1017 makes the shipyard requirements identical to that general industry rule. The shipyard standard does not restate the technical provisions; it incorporates them by reference to 1910.1017.

• Use 1910.1017 for procedures on monitoring, medical exams, and controls.
• Ensure your written programs for shipyard tasks involving vinyl chloride reflect the language and requirements in 1910.1017.

Yes. Because 1915.1017 adopts the requirements of 1910.1017, employers must follow the respirator-related requirements that appear in that standard and any other applicable OSHA standards (for example, employer respiratory program duties found in the general 1910 rules).

• If respirators are used for vinyl chloride tasks, implement a written respirator program consistent with OSHA requirements referenced in 1910.1017.
• Train employees and conduct medical clearance and fit testing as required by applicable OSHA respirator rules cited by 1910.1017.

Yes. 1915.1017 makes shipyard requirements identical to 1910.1017, so any medical surveillance, recordkeeping, and physician/medical removal provisions contained in 1910.1017 apply to shipyard employees.

• Ensure you implement the medical exams, employee notifications, and medical records practices described in 1910.1017.
• Coordinate with medical providers who understand the requirements in 1910.1017 when setting exam frequency and follow-up.

Yes—state-plan programs must have standards and enforcement at least as effective as federal OSHA, so they must meet the federal requirements for vinyl chloride, though they may adopt more stringent rules. The 1915.1017 note points to 1910.1017 as the substantive source, and OSHA has explained in practice that State Plan States must provide programs at least as effective as federal OSHA (see similar guidance in OSHA interpretation letters discussing State Plan obligations, e.g., https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01).

• If you operate in a State Plan State, check that state’s rules and enforcement guidance to confirm any additional or more stringent requirements.
• When in doubt, follow the federal 1910.1017 obligations as a baseline for compliance.

Yes. OSHA issues letters of interpretation and other guidance that explain how OSHA standards apply in particular situations, and those documents can help clarify how 1910.1017 (which is incorporated into 1915.1017) applies to specific workplace scenarios. For examples of how OSHA explains standard application, see OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 (scope questions) or other letters in OSHA’s interpretation archive.

• Use OSHA letters of interpretation as clarifying guidance, but remember that they explain existing obligations rather than create new requirements.
• If a complex or novel situation arises, consider requesting an interpretation from OSHA or consult compliance assistance resources that reference 1910.1017.

You must determine applicability using the definitions and thresholds in the other OSHA standards and apply them where they fit; 1915.1017 points you to 1910.1017 for vinyl chloride requirements, but other OSHA standards (for example, Process Safety Management requirements under the general 1910 framework) may also apply if their criteria are met. OSHA interpretation letters explain how aggregation and thresholds are applied in practice (see the PSM aggregation discussion at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06).

• Review the specific language and threshold quantities in the other OSHA standards that may apply to vinyl chloride (for example, PSM if vinyl chloride is a listed highly hazardous chemical and thresholds are exceeded).
• Document your analysis and, if needed, get expert help to determine whether additional standards besides 1910.1017 apply.

Yes. Because 1915.1017 makes the shipyard requirements identical to 1910.1017, employers must maintain the same written programs, training records, and medical records described in 1910.1017.

• Keep monitoring records, training documentation, and medical surveillance files as required by 1910.1017.
• Ensure access and confidentiality requirements for medical records are followed, per the cited standard.

Those Federal Register citations in 1915.1017 simply identify the rulemaking history and publication dates for the standard; they do not change the fact that shipyard requirements are the same as those in 1910.1017. The citations document when the rule was published and amended in the Federal Register.

• Treat the cited Federal Register entries as historical record; compliance obligations come from the text incorporated by reference (i.e., 1910.1017).
• If you need to review the rulemaking background for context, the FR citations point to those published rule notices.

Yes. Guidance, compliance assistance, and OSHA interpretations that explain 1910.1017 are applicable to shipyard employers because 1915.1017 makes the requirements identical. OSHA interpretation letters routinely clarify how a standard applies to particular activities and can be used to inform shipyard compliance decisions (see examples of OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01).

• Use the same official guidance that OSHA provides for 1910.1017 when developing shipyard programs under 1915.1017.
• Where guidance is unclear or facts are novel, document your rationale and consider requesting an OSHA interpretation.

The employer should apply the requirements of 1910.1017 to the extent practicable, document the hazard evaluation and control decisions, and, if needed, seek clarification from OSHA via an interpretation or consult compliance assistance resources. OSHA frequently responds to technical questions with interpretation letters that explain application of standards to unique situations (for examples, see OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01).

• Perform a written hazard assessment comparing your activity to the language in 1910.1017.
• Keep records of your decision-making and controls, and consult OSHA interpretation resources or request an interpretation when the facts are novel.