Cadmium requirements for shipyards

Yes — the cadmium requirements that apply to shipyard employment under 1915.1027 are identical to those in the general industry cadmium standard at 1910.1027. See the explicit note in 1915.1027 that states the shipyard requirements are the same as 1910.1027.

You read the shipyard cadmium requirements by following the shipyard standard link, which points to the identical general industry text; start at 1915.1027 and then review the full cadmium rule at 1910.1027. The 1915.1027 page explicitly notes the requirements are identical to 1910.1027.

Yes — you should implement the compliance elements from the cadmium standard in 1910.1027 for shipyard work because 1915.1027 makes the shipyard requirements identical to that general industry standard. That means air monitoring, medical surveillance, respiratory protection, engineering controls, housekeeping, and training requirements in 1910.1027 apply to shipyard employers under 1915.1027.

Yes — the cadmium standard allows use of valid objective data in place of monitoring where the data accurately characterizes employee exposure for the specific processes, materials, and control methods in use. Because 1915.1027 is identical to 1910.1027, any provisions in 1910.1027 that permit objective data instead of monitoring apply to shipyards. Make sure the objective data matches your operation’s actual conditions and document how it does so in the employer records required by the standard.

Yes — you must check other standards when the work involves hazards covered elsewhere because 1915.1027 only adopts the cadmium requirements from 1910.1027. For example, if your activity also disturbs asbestos-containing materials, OSHA has explained that remediation activities may be covered under the construction asbestos standard 1926.1101 rather than the general industry asbestos rule; see OSHA’s Asbestos remediation protocols letter of interpretation for how OSHA determines which standard applies. In short, use 1915.1027 for cadmium requirements, but evaluate other standards that might also apply to the same job.

Not necessarily — 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 provisions. The cadmium requirements for shipyards are set by 1915.1027 (which mirrors 1910.1027), but OSHA’s letters (for example the tire industry interpretation) remind employers that some States administer their own OSHA-approved State plan and may enforce different rules. If you work in a State Plan state, check that state's OSHA office for any state-specific cadmium requirements or guidance.

It applies to all shipyard employment activities covered by Part 1915 — not just ship-owned vessels — because 1915.1027 states the cadmium requirements for shipyard employment mirror 1910.1027. That means any shipyard work where cadmium exposures can occur (for example plating, welding, cutting, or paint removal) should be evaluated and controlled under the cadmium requirements in 1910.1027 as applied through 1915.1027.

The shipyard employer is responsible for establishing and maintaining the exposure and medical records required by the cadmium standard because 1915.1027 adopts the recordkeeping and medical-surveillance duties set out in 1910.1027. In practice you must keep monitoring data, medical exam results, training records, and related documentation for the timeframes the standard specifies and make them available to employees or their representatives as required by 1910.1027.

Both the host shipyard employer and the contractor have responsibilities to ensure compliance: the contracting shipyard must evaluate and coordinate workplace hazards, and the contractor must follow the cadmium requirements for their employees. Because 1915.1027 adopts the obligations in 1910.1027, employers who control or create cadmium hazards must ensure proper monitoring, controls, training, PPE/respirators, and medical surveillance for affected employees. Effective job coordination, written work plans, and communication of known hazards are essential to comply with the applicable cadmium requirements.

No — employers covered by the cadmium standard must follow the specific requirements of 1915.1027 (which mirror 1910.1027) rather than relying on the General Duty Clause for compliance. The specific standard lists mandatory exposure limits, monitoring, medical surveillance, and controls that directly apply to cadmium hazards in shipyard employment and must be implemented where applicable.

Yes — since 1915.1027 explicitly adopts the cadmium requirements from 1910.1027, shipyards should follow the same compliance elements, enforcement expectations, and official interpretations that apply to 1910.1027. Where OSHA issues letters of interpretation or enforcement guidance concerning the cadmium standard, that guidance is relevant to shipyard employers because the underlying requirements are the same.

Yes — the cadmium standard requires employers to perform monitoring and update controls when workplace processes or conditions change in ways that may increase employee exposures. Because 1915.1027 adopts the provisions of 1910.1027, you must reassess exposures, perform additional monitoring if needed, and implement engineering controls, work practices, and respiratory protection to maintain compliance with the applicable exposure limits in 1910.1027.

The official regulatory text used as the GPO source for the cadmium standard is available on the e-CFR; the 1915.1027 section metadata links to the e-CFR as the GPO source. For the detailed cadmium requirements themselves, the standard points to 1910.1027 which contains the substantive rule language.