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OSHA 1915.1050

Methylenedianiline requirements

Subpart Z

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.1050, are the methylenedianiline requirements for shipyard employment different from those in general industry?

Yes. The methylenedianiline requirements that apply to shipyard employment under 1915.1050 are identical to the requirements set forth at 1910.1050 for general industry, so shipyard employers must comply with the same provisions as general industry employers.

Under 1915.1050, where should a shipyard employer look for the full text of the methylenedianiline standard and its specific requirements?

Look to 1910.1050 for the full text and details because 1915.1050 states that the shipyard requirements are identical to the provisions in 1910.1050.

Under 1915.1050, does an employer in shipyard employment need to follow exposure limits and control measures established in 1910.1050 for methylenedianiline?

Yes. Because 1915.1050 makes the shipyard requirements identical to 1910.1050, shipyard employers must meet the exposure limits and control measures contained in 1910.1050.

Under 1915.1050, who in a shipyard must comply with the methylenedianiline standard?

All employers engaged in shipyard employment where methylenedianiline hazards are present must comply with the standard; 1915.1050 directs shipyard employers to meet the identical requirements in 1910.1050.

Under 1915.1050, does the standard provide any history or Federal Register references I should know?

Yes. The 1915.1050 entry notes its Federal Register history: 58 FR 35701 (July 1, 1993), 61 FR 5507 (Feb. 13, 1996), and 61 FR 31427 (June 20, 1996), which record publication and amendment actions related to the standard.

Under 1915.1050, where is the official electronic source for the shipyard methylenedianiline standard?

The official electronic version is available through the e-CFR link shown in the standard metadata; see 1915.1050 which cites the e-CFR as its GPO source.

Under 1915.1050, if I need a checklist of actions to comply with methylenedianiline rules in a shipyard, can I rely on 1910.1050 as the checklist?

Yes. Use 1910.1050 as the compliance checklist because 1915.1050 makes the shipyard requirements identical to the general industry rule.

Under 1915.1050, could a State OSHA plan impose different or additional methylenedianiline requirements for shipyards?

Yes. States with OSHA-approved State plans must have standards and enforcement programs at least as effective as federal OSHA, and they may be more stringent; employers should check their State-plan agency for any additional or differing methylenedianiline requirements (see discussion of State plans in OSHA interpretations such as Scope of rim wheel servicing).

Under 1915.1050, if I have a specific compliance question about applying a provision of the methylenedianiline standard in my shipyard, can I rely on OSHA letters of interpretation for guidance?

Yes—OSHA letters of interpretation can explain how OSHA interprets a standard, but they do not create new obligations beyond the regulation; for example, OSHA letters consistently state that interpretation letters explain requirements but do not add obligations (see OSHA letters such as Head protection for crane operators). Always follow the language of 1915.1050 and 1910.1050 first, and use interpretation letters for clarification.

Under 1915.1050, if a shipyard employer is already meeting the requirements of 1910.1050 in its shop areas, is additional action needed because the workplace is a shipyard?

No additional regulatory text is required simply because the work is in a shipyard; 1915.1050 makes the shipyard requirements identical to 1910.1050, so compliance with 1910.1050 satisfies the shipyard requirement, subject to any applicable State-plan variations.

Under 1915.1050, who should I contact if I need enforcement or compliance clarification about methylenedianiline in a shipyard?

For federal enforcement or clarification, consult OSHA and the text of 1915.1050 together with 1910.1050; for state-specific issues, contact your OSHA-approved State-plan agency as state plans may have different enforcement guidance (see the state-plan discussion in OSHA interpretation Scope of rim wheel servicing).