Inorganic arsenic requirements

Yes — the inorganic arsenic requirements that apply to shipyard employment in 1915.1018 are identical to those in 1910.1018 and shipyard employers must follow them. See 1915.1018 which explicitly states the requirements applicable to shipyard employment are identical to 1910.1018.

You must use the full inorganic arsenic rule at 1910.1018, because 1915.1018 for shipyards points employers directly to the identical requirements in that general industry standard. See 1915.1018 for that cross-reference.

No — 1915.1018 contains no additional shipyard‑specific provisions for inorganic arsenic; it directs employers to the identical requirements in 1910.1018. See the text of 1915.1018 which states the requirements are identical to those set forth at 1910.1018.

Look in 1910.1018 for definitions used to implement the inorganic arsenic requirements for shipyards, because 1915.1018 adopts the same text and definitions as 1910.1018.

Those program elements (exposure monitoring, medical surveillance, training, etc.) are set out in 1910.1018; shipyard employers comply with them via 1915.1018, which states the shipyard requirements are identical to the provisions in 1910.1018.

Use 1910.1018 to find numeric exposure limits, action levels, and related numeric criteria because 1915.1018 points shipyard employers to the identical requirements in 1910.1018.

Yes — OSHA interpretation letters that explain 1910.1018 can be used to understand how the requirements apply in practice to shipyard employment covered by 1915.1018, because the shipyard rule adopts the identical requirements. Note that OSHA letters of interpretation explain requirements and how they apply but do not create additional employer obligations beyond the standards themselves — see the standard cross-reference at 1915.1018 and guidance practice described in OSHA interpretation letters (for example, many letters state they clarify requirements rather than impose new duties).

Yes — employers in OSHA‑approved State plan states must follow state occupational safety standards that are at least as effective as Federal OSHA standards; therefore you should check the State plan's arsenic rule (which typically mirrors Federal requirements) in addition to the Federal text at 1910.1018. OSHA interpretation letters (for example, the Asbestos remediation response) explain that States with OSHA‑approved plans may have different or more stringent requirements and employers must follow the State's rules where applicable. See 1915.1018 and consult your State plan office as advised in OSHA letters discussing State plans.

The administrative history and Federal Register references for the shipyard inorganic arsenic rule are shown in the section header for 1915.1018; the rule cites [58 FR 35597, July 1, 1993; 61 FR 5507, Feb. 13, 1996; 61 FR 31427, June 20, 1996]. For the complete regulatory text and source, refer to 1915.1018 and the identical provisions in 1910.1018.

You must comply with the inorganic arsenic provisions in 1910.1018 (adopted for shipyards by 1915.1018) and any other applicable OSHA standards such as the Respiratory Protection standard and confined space standards. OSHA interpretation letters often cross‑reference other standards (for example, an HVAC letter references respiratory protection requirements under 29 CFR 1910.134), so consult the relevant OSHA standard pages at 1910 and the inorganic arsenic text at 1910.1018 to determine overlapping obligations.

Use the written requirements and elements set out in 1910.1018 as the basis for a shipyard compliance program because 1915.1018 establishes that the shipyard rule adopts the identical requirements in 1910.1018.

Yes — employers or stakeholders may request written interpretations from OSHA to clarify how 1910.1018 applies; those interpretation letters can then inform how the identical shipyard requirement in 1915.1018 should be implemented. Keep in mind OSHA letters explain the standard but do not create new obligations beyond the regulation text, a point reiterated across OSHA interpretation letters.

Enforcement is by Federal OSHA in states without an OSHA‑approved State plan; in states with an OSHA‑approved State plan the State agency enforces its plan standards (which must be at least as effective as Federal OSHA's). For shipyard inorganic arsenic compliance, consult 1915.1018 and check with your State plan office if you are in a State that runs its own OSHA program (OSHA interpretation letters discussing State plans explain this difference).

Yes — recordkeeping and related program record requirements for inorganic arsenic are specified in 1910.1018, which applies to shipyards through 1915.1018. Consult the text of 1910.1018 for the specific record types and retention periods that must be maintained.