Acrylonitrile requirements

Yes. Under 1915.1045 the requirements applicable to shipyard employment for acrylonitrile are identical to those in 1910.1045, so shipyard employers must comply with the provisions and obligations found in 1910.1045.

• The practical effect is that exposure limits, monitoring, medical surveillance, training, respiratory and personal protective equipment, and recordkeeping rules that appear in 1910.1045 apply in shipyards as if written in 1915.1045.
• When in doubt about a specific requirement, consult 1910.1045 for the full text.

The acrylonitrile standard applies whenever acrylonitrile is present in shipyard employment and workers can be exposed to it; because 1915.1045 adopts the requirements of 1910.1045, employers must follow the scope and application provisions in that standard to determine coverage.

• That means any use, storage, handling, or other activity in shipyard operations that could create employee exposures to acrylonitrile must be evaluated under 1910.1045.
• Consult the definitions and application sections in 1910.1045 to determine whether a particular operation is covered.

The employer is responsible for identifying and performing any required exposure monitoring for acrylonitrile in shipyard employment in accordance with the requirements adopted from 1910.1045 as referenced by 1915.1045.

• Employers must evaluate employee exposures and arrange for air monitoring where the standard calls for it; the procedures, sampling strategy, and triggers for periodic monitoring are specified in 1910.1045.
• Employers should document monitoring results and retain records as required by the standard.

If monitoring shows exposures above the standard's permissible limits, the employer must promptly implement controls to reduce exposures and follow the corrective action provisions in 1910.1045, as adopted by 1915.1045.

• The employer must use feasible engineering and work-practice controls to reduce exposures; if those do not adequately reduce exposure, the employer must provide appropriate respiratory protection and other personal protective equipment per the standard.
• The employer must also notify affected employees of monitoring results and update medical surveillance, training, and written plans as the standard requires; see the specific control and notification steps in 1910.1045.

Yes. Under 1915.1045 employers must follow the medical surveillance requirements in 1910.1045, which require medical exams and testing for employees when exposure conditions in the standard trigger surveillance.

• The specific triggers (for example, exposure at or above action levels or other conditions) and the required medical exams, tests, and frequency are set out in 1910.1045.
• Employers must provide the required medical exams at no cost to the employee and retain medical records per the retention rules in the standard.

Shipyard employers must provide the hazard communication and job-specific training required in 1910.1045 to employees who work with or may be exposed to acrylonitrile.

• Training must cover the health hazards of acrylonitrile, safe work practices, use of controls and personal protective equipment, emergency procedures, and how to read labels and safety data sheets, as described in 1910.1045.
• The employer must ensure training is understandable to employees (language and literacy appropriate) and provide retraining when conditions or procedures change.

Yes. When engineering and work-practice controls cannot reduce acrylonitrile exposures to acceptable levels the employer must provide and enforce the use of appropriate respiratory protection as required in 1910.1045 and applicable respiratory protection program requirements in part 1910.

• The standard calls for respirators that fit the exposure scenario and for employers to implement a respiratory program that includes fit testing, training, and medical evaluation; see 1910.1045 and the general 29 CFR 1910 requirements for respiratory protection.
• Respiratory protection is a supplement to, not a substitute for, feasible engineering controls unless the standard allows temporary reliance on respirators under specific circumstances.

Shipyard employers must establish emergency procedures and provide appropriate emergency equipment (for example, eyewash stations and showers) consistent with the requirements in 1910.1045 as adopted by 1915.1045.

• The standard specifies types of emergency planning, employee emergency training, and the availability of decontamination and first-aid facilities when acrylonitrile exposures or spills are a hazard; see the emergency response provisions in 1910.1045.
• Employers must also ensure quick access to medical attention and maintain communication and evacuation procedures appropriate for the shipyard worksite.

Yes. Under 1915.1045 employers must comply with the labeling and signage requirements specified in 1910.1045, which include marking regulated areas and providing hazard warnings where appropriate.

• Warning signs, labels, and other markings must communicate the presence of acrylonitrile hazards and restricted access where the standard requires.
• Employers should also follow the Hazard Communication provisions found within 1910.1045 for container labeling and employee access to safety data sheets.

Shipyard employers must keep exposure monitoring and medical surveillance records as required by 1910.1045, which is adopted by 1915.1045.

• The standard identifies the records to retain, the retention period, and employee access rights to those records; consult the recordkeeping section of 1910.1045 for the specific retention periods and requirements.
• Employers must also make required records available to employees and, in some cases, to OSHA inspectors upon request.

No. Shipyard employers must follow the control hierarchy in 1910.1045 and use feasible engineering and work-practice controls first; PPE and respirators are required when those controls do not fully eliminate a hazard or are not feasible.

• The standard directs employers to implement engineering controls and safe work practices to reduce exposures; PPE is used as an additional layer of protection when exposures cannot be reduced sufficiently by other means. See 1910.1045 for details.
• When PPE is required, employers must provide it, train employees in its use, and maintain it according to the standard.

Yes. Under 1915.1045, the employer controlling the worksite must ensure compliance with the adopted 1910.1045 requirements, and contractors performing covered work must follow the standard's provisions.

• Host employers and contractors should coordinate to ensure exposure monitoring, training, protective equipment, and emergency procedures are in place and that each party understands their responsibilities under 1910.1045.
• When multiple employers are present, the controlling employer must communicate hazards and control measures to all affected employees consistent with the standard.

No. Eating, drinking, and smoking are prohibited in areas where acrylonitrile exposure may contaminate hands, clothing, or food and create an ingestion or increased exposure risk; follow the housekeeping and personal hygiene provisions in 1910.1045 as adopted by 1915.1045.

• Employers must provide clean break areas separated from contaminated work areas and ensure employees clean up before eating or drinking.
• See the hygiene and housekeeping sections of 1910.1045 for specific duties and prohibited practices.

Employers must provide protective clothing that prevents skin contact where acrylonitrile skin exposure is possible, consistent with the PPE and protective clothing provisions in 1910.1045 adopted by 1915.1045.

• The standard requires appropriate, impermeable gloves, protective suits, and other garments when tasks could lead to dermal exposure; employers should select PPE based on a hazard assessment described in 1910.1045.
• Employers must train employees on proper removal and decontamination of protective clothing to prevent secondary contamination.

Shipyards must label acrylonitrile containers and make safety data sheets (SDSs) available to employees in accordance with the hazard communication elements incorporated in 1910.1045.

• Labels must clearly identify the chemical and its hazards; employers must ensure that SDSs are accessible to workers for each acrylonitrile product used on site as described in 1910.1045.
• The standard also expects employers to train employees on how to read labels and SDSs and to use the information in safe work practices.

A shipyard manager can find the exact exposure limits, action levels, sampling methods, and other technical requirements in 1910.1045; 1915.1045 adopts those requirements for shipyards.

• Consult the numeric limits, defined action levels, and monitoring/testing procedures directly in 1910.1045 to ensure correct compliance.
• If you need interpretive guidance beyond the standard text, consider contacting OSHA or reviewing relevant OSHA letters of interpretation for clarifications.

The acrylonitrile standard requires employers to follow the control and procedure requirements in 1910.1045; any temporary practices or alternative methods must still achieve the protective outcomes required by the standard and be consistent with its provisions.

• As a general rule, employers must implement feasible engineering and administrative controls first and may only rely on alternatives (such as temporary respirator use) where allowed by the standard or where controls cannot reasonably achieve compliance; see 1910.1045 for the permitted sequencing and exceptions.
• For operational exceptions or non-routine situations, consult the precise language in 1910.1045 or seek OSHA interpretation.

No; 1915.1045 adopts 1910.1045 in full for acrylonitrile, and where 1910.1045 references other 29 CFR part 1910 standards (for example, respiratory protection or medical recordkeeping), those referenced requirements apply to shipyards as well.

• In practice that means shipyard employers must comply both with the acrylonitrile-specific provisions of 1910.1045 and with the general requirements in 29 CFR part 1910 that the acrylonitrile standard references; see 1910.1045 for all cross-references.
• Where standards overlap, follow the more protective requirement.

A shipyard employer should first evaluate the job to identify potential acrylonitrile exposures and then consult the requirements in 1910.1045 (as adopted by 1915.1045) to plan monitoring, control measures, PPE, training, and emergency procedures.

• Conduct a hazard assessment, review existing controls, and determine whether engineering or administrative controls can eliminate or reduce exposures before relying on PPE; the standard's planning and control expectations are described in 1910.1045.
• Document the assessment and corrective actions and ensure workers receive appropriate training and medical evaluation as required by the standard.