OSHA 1915.1028
Benzene requirements for shipyards
Subpart Z
Questions & Answers
Under 1915.1028 where can I find the benzene exposure limits and action levels that apply in shipyard work?
The benzene exposure limits and action levels that apply in shipyards are contained in 1910.1028, which 1915.1028 says is identical for shipyard employment. Consult 1910.1028 to find the numeric permissible exposure limits, any short-term limits, and the action level that trigger monitoring and medical programs.
Under 1915.1028 when must a shipyard employer perform exposure monitoring for benzene?
A shipyard employer must perform exposure monitoring whenever employees may be exposed to benzene at or above the levels that trigger monitoring in 1910.1028. The shipyard rule at 1915.1028 points you to 1910.1028 for the specific monitoring triggers, required sampling methods, how to notify employees of results, and the circumstances under which monitoring must be repeated.
Under 1915.1028 when must a shipyard employer establish a regulated area for benzene work?
Under 1915.1028, employers must follow the regulatory requirements in 1910.1028 for establishing a regulated area. In practical terms, a regulated area is required when employee exposures exceed the levels specified in 1910.1028; the standard explains how to limit access, post warnings, and control entry into those areas.
Under 1915.1028 what must shipyard employers do first to control benzene exposures?
Under 1915.1028, shipyard employers must follow the control hierarchy in 1910.1028: implement feasible engineering and work-practice controls first to reduce benzene exposures. Respiratory protection and other personal protective equipment are used only when engineering and work-practice controls cannot reduce exposures to the required levels or while those controls are being installed or implemented.
Under 1915.1028 when are respirators required for benzene in shipyards and what program rules apply?
Respirators are required in shipyards under 1915.1028 when engineering and work-practice controls cannot reduce benzene exposures to the levels required by 1910.1028. When respirators are used, employers must follow OSHA’s respirator program requirements (including fit testing, medical evaluation, and training) in 29 CFR part 1910, as referenced and required by 1910.1028.
Under 1915.1028 who must be included in medical surveillance for benzene in shipyard operations?
Under 1915.1028 shipyard employers must comply with the medical surveillance requirements set out in 1910.1028; generally, that means employees exposed at or above the action level or a specified exposure threshold described in 1910.1028 must be offered medical exams and follow-up as required by the standard. See 1910.1028 for the exact triggers, frequency, and medical exam components.
Under 1915.1028 what training must shipyard employees receive about benzene?
Under 1915.1028, employers must provide the training and information on benzene hazards and protective measures that are required by 1910.1028. That training includes the health hazards of benzene, how to recognize exposures, how controls and PPE protect employees, emergency procedures, and employee rights. Consult 1910.1028 for the specific items and recommended training frequency.
Under 1915.1028 what recordkeeping must shipyard employers maintain for benzene exposures and medical exams?
Under 1915.1028 employers must follow the recordkeeping rules in 1910.1028. That includes maintaining accurate exposure monitoring records and employee medical records as required by the standard, making required records available to employees and former employees, and retaining records for the time periods specified in 1910.1028.
Under 1915.1028 what signage or labeling is required in shipyard areas where benzene exposures are above allowed limits?
Under 1915.1028, employers must follow the posting and labeling requirements in 1910.1028 for regulated areas. Where the standard requires a regulated area, employers must limit access, post warning signs or labels indicating benzene hazards, and take the actions described in 1910.1028 to control entry and protect workers.
Under 1915.1028 can shipyard employers rely only on administrative controls (like rotating workers) to meet benzene exposure limits?
No. Under 1915.1028 employers must give primary emphasis to feasible engineering and work-practice controls as described in 1910.1028. Administrative controls (such as rotating workers) may be used to supplement engineering controls but should not be the first-line replacement when engineering or work-practice controls can feasibly reduce exposures to the levels required by the standard.
Under 1915.1028 what must shipyard employers do in the event of a benzene spill or emergency release?
Under 1915.1028 shipyard employers must follow the emergency procedures and controls required by 1910.1028 for benzene incidents. That includes procedures for evacuation or isolation of affected areas, providing appropriate protective equipment to responders, medical evaluation after significant exposures, and cleanup actions consistent with safe work practices described in 1910.1028.
Under 1915.1028 who is responsible for ensuring that contractors working on a shipyard worksite comply with benzene requirements?
Under 1915.1028 each employer (including contractors) is responsible for complying with the benzene requirements of 1910.1028 for its own employees. Host employers should coordinate with contractors to ensure overall workplace compliance and to protect all employees on the site, while each employer retains responsibility for meeting the obligations of 1910.1028.