Subpart Z
Yes. Shipyard employers covered by 29 CFR part 1915 must follow the COVID–19 requirements that are identical to those set out at 29 CFR 1910.501. See 1915.1501 which states the requirements applicable to shipyard employment are identical to 29 CFR 1910.501.
Refer to the full text of the COVID-19 workplace standard in 29 CFR 1910.501 because 1915.1501 makes the shipyard requirements identical to that standard. The shipyard section explicitly directs you to 29 CFR 1910.501 and the shipyard rule itself is available at 1915.1501.
No. The shipyard COVID-19 rule contains no separate or modified text—1915.1501 makes the requirements identical to 29 CFR 1910.501. See 1915.1501 for the statement of identical applicability.
State Plan states must have safety programs at least as effective as federal OSHA, but they may adopt their own standards or enforcement policies that differ in detail. OSHA’s interpretations explain that States administering OSHA-approved State Plans are required to have programs at least as effective as Federal OSHA; see the State Plan discussion in OSHA letters such as the Process Safety Management interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 and the shipyard rule at 1915.1501. If you operate in a State Plan State, check your State agency for any State-specific COVID-19 requirements that apply to shipyards.
OSHA is not enforcing the COVID-19 recordkeeping and reporting requirements adopted under the Healthcare ETS at 29 CFR 1910.502, effective immediately until further notice, but it continues to enforce other recordkeeping requirements under part 1904. See the memorandum, "Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502," at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and note that shipyard COVID rules are set as identical to 29 CFR 1910.501 by 1915.1501.
You should provide records where required by enforceable OSHA recordkeeping standards (for example, 29 CFR part 1904), but OSHA has announced it will not enforce certain COVID-19-specific log and reporting provisions adopted under 29 CFR 1910.502 while the enforcement stay is in effect. See the enforcement-stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and the shipyard applicability in 1915.1501. Employers remain responsible for complying with applicable OSHA recordkeeping rules in 29 CFR part 1904 (as noted in the enforcement-stay memorandum).
OSHA’s memorandum states it will not enforce the COVID-19 recordkeeping and reporting requirements adopted under 29 CFR 1910.502, including the provisions to report COVID-19 fatalities and hospitalizations in that ETS, while the stay is in effect; employers remain subject to general OSHA reporting requirements and to part 1904 recordkeeping as applicable. See the enforcement-stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and the shipyard rule’s direction to the workplace standard at 1915.1501.
The shipyard provision noting identical applicability to 29 CFR 1910.501 was published in the Federal Register on November 5, 2021 (86 FR 61554), and is reflected in the shipyard regulation at 1915.1501.
You must comply with all applicable OSHA standards; 1915.1501 indicates the COVID-19 requirements for shipyards are identical to 29 CFR 1910.501, so follow the applicable provisions in that standard in addition to any other shipyard-specific OSHA requirements found in part 1915. See 1915.1501 for the cross-reference to 29 CFR 1910.501.
No; OSHA letters of interpretation explain how OSHA interprets and applies the standards but do not create new obligations or change the text of the standard itself. Employers must comply with the requirements in the standard, and may use OSHA interpretation letters for clarification. See the shipyard applicability in 1915.1501 and note the general statement in many OSHA interpretation letters that they explain requirements but "do not create additional employer obligations," for example the head protection letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.
OSHA has issued inspection procedures and enforcement guidance for COVID-19 in the past (for example, DIR 2021-02), but specific policies can change; the recordkeeping/reporting portions of some COVID ETS materials have been placed on enforcement stay and related directives may be archived. See the enforcement-stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and consult 1915.1501 for the cross-reference to the workplace standard at 29 CFR 1910.501.
State in your policy that the shipyard follows the COVID–19 requirements applicable to shipyard employment found in 29 CFR 1915.1501, which makes the applicable COVID-19 rules identical to those in 29 CFR 1910.501. That cross-reference makes clear your policy is based on the OSHA shipyard rule.
Yes—because 1915.1501 states the COVID–19 requirements for shipyard employment are identical to 29 CFR 1910.501, an inspector may cite the corresponding 1910.501 provisions as applicable to shipyard employment under 1915.1501.
For official clarifications, consult the text of the standard at 29 CFR 1910.501 (as applied to shipyards by 1915.1501) and look for relevant OSHA letters of interpretation and memoranda. OSHA interpretation letters—published on OSHA’s website—explain how OSHA applies standards to particular situations; for example, the enforcement-stay memorandum is at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05.