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OSHA 1915.154

Respiratory protection requirements

Subpart I

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.154, which OSHA standard covers respiratory protection in shipyard employment?

Shipyard respiratory protection is covered by OSHA's general industry Respiratory Protection Standard, 29 CFR 1910.134. See 1915.154 which expressly states that respiratory protection for shipyard employment is covered by 29 CFR 1910.134.

Under 1915.154, do shipyard employers have to meet the medical evaluation, fit testing, and training requirements in 29 CFR 1910.134?

Yes. Employers in shipyard employment must follow 29 CFR 1910.134, including its requirements for medical evaluations, fit testing, and training. The shipyard rule at 1915.154 directs employers to use 29 CFR 1910.134, which contains the detailed provisions for medical evaluations (1910.134(e)), fit testing (1910.134(f)), and training (1910.134(k)).

Under 29 CFR 1910.134, what is an "oxygen-deficient atmosphere" and must it be treated as IDLH?

An oxygen-deficient atmosphere is one with less than 19.5% oxygen by volume, and under the Respiratory Protection Standard such atmospheres must be treated as immediately dangerous to life or health (IDLH) unless an employer can show otherwise under the standard. See 29 CFR 1910.134 (definition and IDLH guidance at 1910.134(d)(2)(iii)). OSHA’s letter of interpretation on HVAC and oxygen-deficient atmospheres also confirms that oxygen-deficient atmospheres are considered IDLH for purposes of the standard; see OSHA’s interpretation, "Oxygen-deficient atmospheres in HVAC" (July 16, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

Under 1915.154, what type of respirator must be used when shipyard workers face an IDLH atmosphere?

When workers face an IDLH atmosphere, employers must provide respirators that ensure the highest level of protection, such as a full-facepiece self-contained breathing apparatus (SCBA) or a combination airline respirator with auxiliary SCBA, consistent with 29 CFR 1910.134. See the equipment and selection requirements in 29 CFR 1910.134, which sets out respirator selection and IDLH protections, and note the discussion in OSHA's "Oxygen-deficient atmospheres in HVAC" interpretation (July 16, 2024) at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

Under 1915.154, can shipyard employers use powered air-purifying respirators (PAPRs) instead of N95s or half-mask respirators?

Yes, employers may use PAPRs when the respirator selection in 29 CFR 1910.134 indicates they are appropriate for the hazard and exposure level, provided the chosen PAPR meets the assigned protection factor and other program requirements. Respirator choice must follow the hazard assessment and the selection rules in 29 CFR 1910.134, including medical evaluation, fit testing where required, training, and maintenance.

Under 1915.154, are civilian workers at Department of Defense shipyards covered by 29 CFR 1910.134?

Civilian employees working at DoD facilities are covered by OSHA when they perform work that is not "uniquely military," so they would be subject to 29 CFR 1910.134 where applicable; military personnel and uniquely military systems are excluded. See OSHA’s July 16, 2024 letter, "Oxygen-deficient atmospheres in HVAC," which explains that OSHA coverage applies to civilian employees on non-unique military operations and references 29 CFR 1910.134 and Part 1960 considerations (https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Under 1915.154, does OSHA require a medical evaluation before an employee can be fit tested for a tight-fitting respirator?

Yes. Employers must complete a medical evaluation to determine an employee’s ability to use a respirator before fit testing or initial use. The medical-evaluation requirement is in 29 CFR 1910.134(e), as adopted for shipyard employment by 1915.154.

Under 1915.154, what respirator program recordkeeping does OSHA require shipyard employers to keep?

Employers must keep records required by [29 CFR 1910.134], such as medical evaluations and fit test records, for the periods specified in the standard. See 29 CFR 1910.134(m) for recordkeeping provisions and refer to 1915.154 which directs shipyards to follow 29 CFR 1910.134.

Under 1915.154, can employers allow voluntary (worker‑requested) use of respirators when exposures are below OSHA limits?

Yes, employers may allow voluntary use of respirators when exposures are below applicable limits, but they must ensure voluntary users receive the information in Appendix D of [29 CFR 1910.134] and must follow applicable provisions for voluntary use (e.g., cleaning, storage). See 29 CFR 1910.134(c)(2) and Appendix D and 1915.154 which incorporates 29 CFR 1910.134.

Under 1915.154, how often must shipyard employers train employees who must wear respirators?

Employers must train employees before they use a respirator in the workplace and then at least annually thereafter. See the training requirements in 29 CFR 1910.134(k), as applied to shipyard employment by 1915.154.

Under 1915.154, how often must fit testing be done for tight-fitting respirators in shipyard work?

Employers must perform fit testing at least annually and whenever a different respirator facepiece is used or facial changes occur that could affect fit. See 29 CFR 1910.134(f) and the incorporation by reference in 1915.154.

Under 1915.154, what are the employer’s responsibilities for respirator maintenance, cleaning, and storage on shipyard worksites?

Employers must ensure respirators are cleaned, inspected, maintained, and stored properly so they remain effective and sanitary. These requirements are in 29 CFR 1910.134(g) and (h), which 1915.154 directs shipyard employers to follow. Practical steps include scheduled cleaning, inspection before use, replacement of damaged parts, and storage in a clean, dry location away from contaminants.

Under 1915.154, when must a shipyard employer have a written respiratory protection program?

A written respiratory protection program is required whenever respirators are required by the employer or used to comply with OSHA standards. See 29 CFR 1910.134(c)(1) and the direction in 1915.154 to follow 29 CFR 1910.134. The written program must include procedures for selection, medical evaluation, fit testing, training, maintenance, and program evaluation.

Under 1915.154, what guidance applies for escape-only respirators aboard vessels in shipyard operations?

Escape-only respirators must meet the limited-use requirements in [29 CFR 1910.134], such as being appropriate for the hazard and providing adequate protection for emergency escape only, and must be integrated into the employer’s written program when provided. See 29 CFR 1910.134 and the incorporation by 1915.154.

Under 1915.154, how should shipyard employers choose cartridges or canisters for gas/vapor hazards?

Cartridge and canister selection must be based on the identified contaminant, concentration, expected work duration, and the filter/cartridge manufacturer’s limitations; employers must follow the respirator selection rules in [29 CFR 1910.134] and the cartridge manufacturer’s change-out or end‑of‑service-life recommendations. See 29 CFR 1910.134 and incorporate those requirements into the shipyard program required by 1915.154. When reliable change schedules are not available, employers must implement end‑of‑service-life indicators or conservative change-out procedures to protect workers.