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OSHA 1915.16

Warning signs and labels

Subpart B

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.16(a), what does it mean that a sign or label must be "presented in a manner that can be perceived and understood by all employees"?

The employer must make sure signs and labels are placed, written, and designed so every employee can see them and understand their meaning immediately. This means using readable text size and contrast, clear wording or pictograms, languages or translations when needed, and placement where affected employees actually pass or work. See 1915.16(a) for the basic requirement that signs be perceivable and understood by all employees.

Under 1915.16(a), do employers have to provide warning signs and labels in languages other than English?

Yes, if workers cannot read or understand English, the employer must present signs and labels in a form the workers will understand (for example, a translated sign or clear pictogram). The rule requires the sign be presented so all employees can perceive and understand it, which includes addressing language barriers. See 1915.16(a).

Under 1915.16(a), are pictograms or symbols acceptable to meet the comprehension requirement for warning signs?

Yes; standardized pictograms and clear symbols are acceptable if they convey the hazard to all employees and are easily seen and understood. Pictograms are often the best way to communicate across languages or for workers with limited literacy, but the employer must verify that employees actually understand the symbol used. See 1915.16(a).

Under 1915.16(b), when can a single warning sign cover an entire large work area instead of being posted at each tank, compartment, or workspace?

A single conspicuous sign at each means of access may be used if the entire work area has been tested and certified as both "not safe for workers" and "not safe for hot work." In that situation, individual postings at each tank or compartment are not required, but signs must be posted at every access point. See 1915.16(b).

Under 1915.16(b), who can "test and certify" that an entire work area is "not safe for workers" and "not safe for hot work"?

The employer should rely on a qualified person—typically the employer's competent person—who can evaluate atmospheres and hazards and specify protections; that person can perform the testing and sign the certification. OSHA's shipyard competent-person interpretation explains that a competent person is responsible for recognizing and evaluating hazardous atmospheres and specifying necessary protections. See 1915.16(b) and OSHA's letter on competent persons in shipyards (Competent person requirements in shipyards (Apr. 18, 2016)).

Under 1915.16(b), what does the phrase "not safe for hot work" specifically mean for shipyard operations?

"Not safe for hot work" means the area contains hazards that make welding, cutting, brazing or other operations that produce sparks, flames, or heat unsafe until corrected or controls are in place. The posting prohibits hot work in the certified area until the hazard is eliminated or an appropriate hot-work permit and controls are in place. See 1915.16(b).

Under 1915.16(b), where must the large-area warning sign be posted when the entire work area is certified as unsafe?

The sign must be posted conspicuously at each means of access to the certified work area (for example, every hatch, ladder, door, or gangway used to enter). Conspicuous posting at all entrances makes sure anyone entering is warned before they go into the hazardous area. See 1915.16(b).

Under 1915.16(a), if a warning sign is placed inside a tank or compartment instead of at the access point, does that meet the standard?

Not necessarily; the sign must be presented where employees can perceive and understand it. If a sign inside the space is not visible to employees before they enter, the employer must also place warnings at access points so workers see the hazard before entering. See 1915.16(a) and 1915.16(b).

Under 1915.16, what basic information should a warning sign or label convey when used to mark a certified unsafe work area?

A certified-area warning sign should directly state the safety condition (for example, "Not safe for workers" and/or "Not safe for hot work"), show the date of testing/certification, and indicate any restrictions. Including the name or title of the person who certified the area and a contact for questions helps make the sign meaningful and actionable. These content choices support the requirement that signs be perceived and understood. See 1915.16(a) and 1915.16(b).

Under 1915.16(a), are employers required to train employees about the meaning of warning signs and labels?

Yes; the employer must ensure employees can perceive and understand the signs, which commonly requires training or familiarization so workers know what the signs mean and what actions to take. Training is part of meeting the requirement that signs be understandable to all employees. See 1915.16(a).

Under 1915.16, are short-term or temporary tags acceptable to warn employees about a hazard while testing or repairs are ongoing?

Yes—temporary tags are acceptable if they are clearly visible, worded or symbolized so employees understand the hazard, and placed where employees will see them. Temporary devices must still meet the standard's requirement that the sign or label be perceivable and understood by all employees. See 1915.16(a).

Under 1915.16(a), can audible alarms or electronic displays be used instead of physical posted signs?

Yes, electronic displays or alarms can be used if they reliably alert and convey the hazard information to every affected employee and are understandable, but the employer must ensure all employees can perceive and interpret the message. The method used must meet the same comprehension requirement as a posted sign. See 1915.16(a).

Under 1915.16(a), what must an employer do when a warning sign or label becomes faded, dirty, or unreadable?

The employer must promptly repair or replace the sign so employees can perceive and understand it. Maintaining legible, visible signage is part of the employer's responsibility under the standard. See 1915.16(a).

Under 1915.16(b), does "means of access" include ladders, hatches, and gangways?

Yes; "means of access" refers to any entry route used to enter the certified work area—this includes ladders, hatches, doors, gangways, and other access points where a conspicuous sign should be posted. The goal is to warn anyone before they enter. See 1915.16(b).

Under 1915.16, can one sign combine multiple warnings (for example, "Confined Space — Not Safe for Workers — No Hot Work")?

Yes—combining clear, concise warnings on a single sign is acceptable as long as the combined message remains visible and easy for employees to perceive and understand. The employer must ensure the sign's layout, size, and wording do not reduce comprehension. See 1915.16(a).

Under 1915.16, are specific colors or formats (like ANSI sign formats) required for shipyard warning signs?

No specific color or ANSI format is mandated by 1915.16; the requirement is performance-based—the sign must be perceivable and understood by all employees. However, using recognized formats and color codes (for example, OSHA/ANSI conventions) is a good practice because they improve quick recognition and comprehension. See 1915.16(a).

Under 1915.16, if a contractor's employees work in my shipyard, whose responsibility is it to ensure signs are understandable to those workers?

The employer controlling the work area must ensure signs and labels are presented so all employees who may enter—including contractors—can perceive and understand them. If contractors bring their own hazards or need different warnings, coordinate with them so everyone entering the area receives proper notice. See 1915.16(a).

Under 1915.16 and the competent-person guidance, can a competent person rely on non‑OSHA exposure limits (like TLVs) when deciding whether to certify an area "not safe for workers"?

Yes—the competent person may rely on accepted industrial-hygiene criteria (for example, TLVs or other occupational exposure limits) and professional judgment when evaluating hazards and specifying protections, especially where OSHA PELs do not exist. The employer's competent person is expected to recognize and evaluate hazardous atmospheres and determine necessary protective measures. See OSHA's interpretation on competent persons in shipyards (Competent person requirements in shipyards (Apr. 18, 2016)) and 1915.16(b).

Under 1915.16, do these warning-sign requirements apply to confined spaces covered by Subpart B?

Yes; 1915.16 is in Subpart B (Confined and Enclosed Spaces and Other Dangerous Atmospheres in Shipyard Employment), so the sign and label requirements apply to confined spaces and similar hazardous atmospheres covered by that subpart. Employers must ensure signs are perceivable and understandable for those locations. See 1915 and 1915.16.