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OSHA 1915.15

Maintenance of safe conditions

Subpart B

21 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.15(a), what must I do to prevent hazardous materials from entering a space certified “Safe for Workers” or “Safe for Hot Work”?

Under 1915.15(a) you must disconnect, blank off, or otherwise block pipelines by a positive method so hazardous materials cannot be discharged into the certified space. Employers must use physical measures (for example, disconnecting lines, installing blind flanges or positive blanks) rather than relying solely on procedural controls.

(These measures are mandatory whenever a pipeline could carry hazardous materials into a certified space.)

Under 1915.15(b), when must work stop if an existing condition in a tested confined or enclosed space changes?

Under 1915.15(b) you must stop work immediately when a change occurs that could alter conditions within a tested confined or enclosed space or other dangerous atmosphere, and you may not resume until the area is visually inspected and retested and found to comply with the applicable standards.

Under 1915.15(c), how often must a competent person inspect and test a space that has been certified “Safe for Workers” or “Safe for Hot Work”?

Under 1915.15(c) a competent person must visually inspect and test each space certified “Safe for Workers” or “Safe for Hot Work” as often as necessary to ensure atmospheric conditions remain within those established by the certificate.

Under 1915.15(d), what must happen if a competent person finds atmospheric conditions in a certified space no longer meet the standards?

Under 1915.15(d) work in the certified space must be stopped and may not resume until a Marine Chemist or Coast Guard authorized person retests the space and issues a new certificate under 1915.14(a).

Under 1915.15(e), after a competent person declares a space safe to enter, must testing and inspections continue while workers are inside?

Yes. Under 1915.15(e) a competent person must continue to test and visually inspect the space as often as necessary after initially determining it is safe for entry to ensure atmospheric conditions are maintained.

Under 1915.15(f), what must be done if a competent person later determines conditions in a space they previously declared safe no longer meet the required standards?

Under 1915.15(f) work must be stopped immediately until the tested space's conditions are corrected to comply with [1915.12, 1915.13, and 1915.14], as applicable.

Under 1915.15, which specific standards set the testing and entry criteria I must use when retesting or inspecting spaces?

Under 1915.15, you must use the testing and entry criteria set out in 1915.12, 1915.13, and 1915.14 when retesting or inspecting confined/enclosed spaces and other dangerous atmospheres.

  • These sections describe hazards, required tests, and certification procedures that apply before work may begin or resume.
  • See 1915.12, 1915.13, and 1915.14 for details.

Who may perform the ongoing visual inspections and testing required by 1915.15(c) and (e)?

Under 1915.15(c) and (e) a "competent person" must perform the ongoing visual inspections and tests to ensure conditions are maintained.

  • The shipyard standards define a competent person and require that person to be capable of recognizing and evaluating hazardous atmospheres and specifying necessary protections; see OSHA's interpretation on Competent person requirements in shipyards.
  • For certified spaces, a Marine Chemist or Coast Guard authorized person issues certificates but the competent person must still inspect and test spaces as required by 1915.15(c) and 1915.15(e).

If a space was certified "Safe for Hot Work" by a Marine Chemist, can my competent person allow hot work to continue after discovering a leak without a Marine Chemist retest?

No. If a competent person finds that atmospheric conditions in a space certified by a Marine Chemist or Coast Guard authorized person no longer meet the requirements, work — including hot work — must stop and may not resume until the space is retested and a new certificate is issued by a Marine Chemist or Coast Guard authorized person under 1915.14(a), as required by 1915.15(d).

  • See 1915.15(d) and 1915.14(a).
  • A competent person can and must stop work per 1915.15(f) but cannot reauthorize certified hot work without the Marine Chemist/Coast Guard retest and certificate.

Under 1915.15(a), are temporary measures such as closing one valve enough to prevent hazardous materials entering a certified space?

Under 1915.15(a) temporary measures may be acceptable only if they provide a positive method to prevent discharge (for example, disconnecting or blanking off); simply closing a single valve is not necessarily sufficient unless it provides a positive block.

  • The rule requires pipelines that could carry hazardous materials to be "disconnected, blanked off, or otherwise blocked by a positive method," see 1915.15(a).
  • When in doubt, use a physical positive barrier (e.g., blind flange or double block-and-bleed) consistent with the standard to ensure there is no discharge into the space.

Under 1915.15(b), must I always stop work if a nearby manhole or closure is opened, even if it seems unrelated?

Yes. 1915.15(b) requires stopping work when a change occurs that could alter conditions within a tested confined or enclosed space; opening a manhole or other closure is explicitly listed as an example and therefore warrants stopping work until the space is inspected and retested.

What testing methods or checks are required when a competent person inspects a space under 1915.15?

When a competent person inspects a space under 1915.15 they must perform the visual inspections and atmospheric tests required by 1915.12, 1915.13, and 1915.14, including checks for flammable vapors, toxic atmospheres, and oxygen levels as applicable.

  • The specific instruments, tests, and pass/fail criteria are described in 1915.12–1915.14.
  • If the space is originally certified by a Marine Chemist, the competent person must still monitor conditions as required by 1915.15(c).

Does 1915.15 allow a competent person to set exposure limits or protective measures when there is no OSHA PEL for a chemical?

Yes. While 1915.15 requires testing and inspections, a competent person may specify necessary protections for hazardous exposures even when there is no OSHA PEL, provided they meet the definition and responsibilities of a competent person under Part 1915.

Under 1915.15, when a competent person stops work because conditions changed, can they reopen the space after correcting conditions without a Marine Chemist retest?

It depends: if the space was previously certified by a Marine Chemist or Coast Guard authorized person and their certificate was invalidated by the change, a Marine Chemist or Coast Guard authorized person must retest and issue a new certificate before reopening per 1915.15(d). For spaces initially judged safe by a competent person (not Marine Chemist-certified), the competent person must correct and re-test and may resume work only when the space meets the applicable requirements in [1915.12–1915.14], per 1915.15(f) and 1915.15(e).

Under 1915.15, do competent persons need to document tests and inspections, or is continuous informal monitoring enough?

Section 1915.15 requires competent persons to visually inspect and test spaces "as often as necessary," but it does not prescribe a specific documentation format in this paragraph; nonetheless, employers should maintain clear records of inspections and tests to show compliance with [1915.12–1915.14] and to demonstrate that monitoring occurred as required.

Under 1915.15, if I find a small odor or trace of vapor in a certified space, must I stop work and call a Marine Chemist immediately?

Under 1915.15, any finding by a competent person that atmospheric conditions fail to meet the applicable requirements requires stopping work; if the space was Marine Chemist- or Coast Guard-certified, you must stop work and obtain retesting and a new certificate from a Marine Chemist or Coast Guard authorized person per 1915.15(d).

  • See 1915.15(d) and 1915.15(f).
  • If the space was declared safe by a competent person (not Marine Chemist-certified), correct the condition and re-test per 1915.15(f).

Under 1915.15, what is the relationship between a Marine Chemist's certificate and a competent person's ongoing monitoring?

Under 1915.15, a Marine Chemist or Coast Guard authorized person issues a certificate declaring a space "Safe for Workers" or "Safe for Hot Work," but a competent person must continue visual inspections and testing to ensure conditions remain within the certificate's requirements; if a competent person detects a failure, work must stop and the Marine Chemist must retest and reissue the certificate per 1915.15(c) and (d).

Can an employer rely solely on a Marine Chemist's certificate all day without additional checks by a competent person under 1915.15?

No. Even when a Marine Chemist has issued a certificate, 1915.15(c) requires a competent person to visually inspect and test the space as often as necessary to ensure the certificate conditions are maintained; reliance on a certificate alone without ongoing checks is not sufficient.

Under 1915.15, what should a competent person do if testing instruments indicate marginally elevated levels but not clearly above limits?

Under 1915.15, if a competent person finds atmospheric conditions that do not clearly meet the applicable requirements, they must stop work if the conditions fail to meet the standards; because 1915.15(c),(e),(f) require testing "as often as necessary," conservative action (stop, correct, and retest) is appropriate when readings are questionable.

Under 1915.15, if a pipeline was physically blocked but later found to be leaking, who is responsible for determining corrective action and when work can resume?

Under 1915.15, the competent person is responsible for inspecting and testing the space and must stop work if they find a leak or unsafe atmosphere; if the space had been Marine Chemist-certified and the certificate is affected, a Marine Chemist or Coast Guard authorized person must retest and issue a new certificate before work resumes per 1915.15(d). For other competent-person-controlled spaces, work can only resume after correction and retesting show compliance with [1915.12–1915.14], per 1915.15(f).

Under 1915.15, does opening an isolation device on a pipeline that feeds a certified space always require a Marine Chemist retest?

Under 1915.15(b), opening or adjusting closures or valves that could alter the atmosphere requires stopping work and retesting; if the space was originally certified by a Marine Chemist or Coast Guard authorized person, a retest by that authorized person and a new certificate under 1915.14(a) will be required before resuming work per 1915.15(d).