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OSHA 1915.158

Personal flotation device requirements

1915 Subpart I

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.158(a)(1), what types of personal flotation devices (PFDs) must employers provide for affected employees?

Under 1915.158(a)(1) employers must provide PFDs that are U.S. Coast Guard (USCG) approved (Type I, II, III, or V) and marked for work, commercial use, or use on vessels. Read the requirement in 1915.158(a)(1); USCG approval is pursuant to 46 CFR part 160.

Under 1915.158(a)(2), how and when must personal flotation devices be inspected?

Under 1915.158(a)(2) each PFD must be inspected prior to each use for dry rot, chemical damage, or other defects that could affect strength or buoyancy. Defective PFDs may not be used. See the inspection requirement in 1915.158(a)(2).

Under 1915.158(a)(2), may a PFD with dry rot or chemical damage be used if it still floats during a quick test?

No. Under 1915.158(a)(2) a PFD with dry rot, chemical damage, or other defects that may affect strength or buoyancy shall not be used—even if it appears to float momentarily. The rule requires inspection before each use and removal of defective devices. See 1915.158(a)(2).

Under 1915.158(b)(1), where must ring life buoys be placed on floating vessels 200 feet or longer?

Under 1915.158(b)(1) a floating vessel 200 feet (61 m) or more in length must have at least three 30-inch USCG-approved ring life buoys with lines attached located in readily visible and accessible places: one forward, one aft, and one at the access to the gangway. See 1915.158(b)(1).

Under 1915.158(b)(2), what ring life buoy requirements apply to floating vessels under 200 feet in length?

Under 1915.158(b)(2) a floating vessel under 200 feet (61 m) must have at least one 30-inch USCG-approved ring life buoy with a line attached located at the gangway. See 1915.158(b)(2).

Under 1915.158(b)(3), are ring life buoys required on staging alongside a floating vessel where work is being done?

Yes. Under 1915.158(b)(3) at least one 30-inch USCG-approved ring life buoy with a line attached must be located on each staging alongside a floating vessel on which work is being performed. See 1915.158(b)(3).

Under 1915.158(b)(4), how much line must be attached to each ring life buoy?

Under 1915.158(b)(4) at least 90 feet (27.43 m) of line must be attached to each ring life buoy. See 1915.158(b)(4).

Under 1915.158, must ring life buoys be U.S. Coast Guard approved?

Yes. The ring life buoys required by 1915.158(b) are specified as U.S. Coast Guard approved 30-inch buoys; the standard repeatedly refers to USCG approval for those ring life buoys. See 1915.158(b)(1) and the general PFD approval requirement in 1915.158(a)(1).

Under 1915.158(b)(5), what ladder requirements apply to floating vessels where work is being performed?

Under 1915.158(b)(5) there must be at least one portable or permanent ladder in the vicinity of each floating vessel on which work is being performed; the ladder must be of sufficient length to help employees reach safety if they fall into the water. See 1915.158(b)(5).

Under 1915.158 and OSHA guidance, who must pay for personal flotation devices provided to employees?

Employers must provide required personal protective equipment (PPE) at no cost to the employee when a standard requires the PPE; PFDs required under 1915.158 are PPE that employers must supply. OSHA's final rule on employer payment for PPE makes clear employers are responsible for paying for PPE required by standards and related OSHA guidance addresses permitted payment methods. See the employer payment discussion in OSHA's Letter of Interpretation, Employee PPE payment methods, and the PFD requirement in 1915.158(a)(1).

Under 1915.158(a)(1), can an employer use a non‑USCG-approved flotation device if it is inspected and records are kept?

No. Under 1915.158(a)(1) PFDs worn by affected employees must be U.S. Coast Guard approved pursuant to 46 CFR part 160 (Type I, II, III, or V) and marked for work, commercial use, or vessel use; inspection and recordkeeping cannot substitute for the required USCG approval. See 1915.158(a)(1) and the USCG specification requirement at 46 CFR part 160.

Under 1915.158(a)(1), does a PFD have to be labeled or marked in a particular way for shipyard use?

Yes. Under 1915.158(a)(1) the PFDs must be USCG approved and marked for use as a work vest, for commercial use, or for use on vessels—so employers should ensure the device carries that marking. See 1915.158(a)(1) and 46 CFR part 160 for USCG approval specifications.

Under 1915.158, who determines which employees are "affected employees" required to wear PFDs on a job?

Under 1915.158 the PFD requirement applies to each "affected employee," and a competent person designated by the employer can evaluate hazards and specify necessary protection for shipyard operations; ultimately the employer is responsible for those decisions. See 1915.158(a) and OSHA's interpretation clarifying that the competent person may specify protections and that the competent person's responsibilities are the employer's responsibilities in Part 1915, Competent person requirements in shipyards.

Under 1915.158, how visible and accessible must ring life buoys be kept?

Under 1915.158(b)(1) ring life buoys must be located in "readily visible and accessible places." That means they must be mounted or stored so workers can see and quickly reach them when needed—not hidden away or locked. See 1915.158(b)(1).

Under 1915.158, how often should ring life buoys and their lines be inspected or maintained?

Section 1915.158 does not set a specific inspection frequency for ring life buoys and lines, but it does require PFDs be inspected prior to each use at 1915.158(a)(2). Employers should therefore implement a regular inspection and maintenance program for ring buoys and lines (including checking the required 90-foot line per 1915.158(b)(4)) consistent with USCG guidance in 46 CFR part 160.

Under 1915.158(a)(1), are inflatable PFDs allowed for shipyard work?

Inflatable PFDs are permitted only if they are U.S. Coast Guard approved as one of the accepted types listed in 1915.158(a)(1) (Type I, II, III, or V) and marked for work or commercial use. Confirm the device's USCG approval and marking per 1915.158(a)(1) and the USCG specifications at 46 CFR part 160.

Under 1915.158(b)(5), what does "sufficient length" mean for ladders provided in the vicinity of floating vessels?

Under 1915.158(b)(5) ladders located in the vicinity of each floating vessel must be of sufficient length to assist employees to reach safety if they fall into the water; in plain terms the ladder must reach from the water or working level up to a safe access point so a person in the water can use it to get out. See 1915.158(b)(5). Employers should select ladders sized to the vessel configuration and working conditions.

Under 1915.158 and employer PPE responsibilities, who is responsible for ensuring multi-employer worksite employees have required PFDs?

The employer who has control over the employee's work is responsible for providing required PPE, including PFDs under 1915.158; contracts and multi-employer situations do not remove the employer's obligation to provide PPE at no cost. See the PFD requirement in 1915.158(a)(1) and OSHA's guidance on employer payment for PPE in the Letter of Interpretation, Employee PPE payment methods.

Under 1915.158, are there any exceptions listed that allow fewer than three ring life buoys on vessels 200 feet or longer?

No. Section 1915.158(b)(1) requires at least three 30-inch USCG-approved ring life buoys with lines attached on floating vessels 200 feet (61 m) or more—one forward, one aft, and one at the gangway—and the standard does not list exceptions that would allow fewer. See 1915.158(b)(1). If you believe special circumstances apply, consult a competent person per OSHA guidance on competent persons in shipyards, Competent person requirements in shipyards.