Scope and application

No. Under 1915.161, the standards in this subpart apply to ship repairing and shipbuilding and shall not apply to shipbreaking; see 1915.161 (Scope and application of subpart). Employers conducting shipbreaking should not rely on Subpart J for compliance but must follow any other applicable OSHA standards for their operations; see the broader Part 1915 shipyard standards for other requirements that may apply to shipyard employment.

Yes. Under 1915.161, the subpart's requirements apply to ship repairing and shipbuilding activities but do not apply to shipbreaking activities; see 1915.161 (Scope and application of subpart). Practical approach: apply Subpart J to the portions of work that are ship repair or shipbuilding, and do not apply Subpart J to portions that meet shipbreaking operations—while ensuring that shipbreaking work complies with any other relevant OSHA standards in Part 1915 or other parts as applicable.

It depends on whether the activity constitutes shipbreaking. Under 1915.161 (Scope and application of subpart), the subpart applies to ship repairing and shipbuilding and does not apply to shipbreaking. If the work is properly characterized as shipbreaking (dismantling a vessel for scrap or salvage), Subpart J would not apply; if the work is repair or refurbishment of machinery and piping to return the vessel to service, Subpart J would apply. Employers should document how the activity is classified and apply the appropriate OSHA requirements in Part 1915.

Yes. Requirements in shipyard-specific health standards apply to ship repairing and shipbuilding covered by this subpart when those standards address hazards present in shipyard employment. For example, OSHA's interim guidance on the 2020 beryllium rules explains that the shipyard beryllium standard at 29 CFR 1915.1024 applies to occupational exposure to beryllium in shipyards; see the OSHA memorandum, Interim Enforcement Guidance for the 2020 Final Beryllium Standards. Always check the specific substance standard and its scope in addition to 1915.161 (Scope and application of subpart).

Yes. The final rule on employer payment for personal protective equipment requires employers to pay for required PPE in the shipyard standards (Part 1915) unless a specific exception applies. OSHA discussed these Part 1915 provisions in the employer PPE payment interpretation; see OSHA's letter on Employee PPE payment methods and consult the broader Part 1915 standards to determine which PPE items are required for ship repairing and shipbuilding work.

No. For shipyard eye and face protection, "potentially injurious light radiation" refers to intense radiation such as that from electric arc welding or gas torch cutting—not ordinary sunlight. OSHA clarified this in its interpretation of the shipyard eye-and-face protection standard; see the letter, Shipyard eye and face protection. Apply that understanding when enforcing eye/face protection requirements in ship repairing and shipbuilding under Part 1915.

Yes. A competent person in shipyard employment may recognize and evaluate hazardous exposures that lack an OSHA PEL and specify necessary protection and precautions to ensure employee safety. OSHA affirmed this authority in its interpretation on competent person requirements in shipyards; see Competent person requirements in shipyards. Employers performing ship repair and shipbuilding should ensure their competent person meets the applicable Part 1915 definitions and responsibilities as described in Part 1915.

Yes. When abrasive blasting operations occur in ship repair or shipbuilding, employers must follow the applicable abrasive-blasting respiratory protection requirements if exposures can exceed applicable limits. OSHA's interpretation on wet (vapor-) abrasive blasting explains the criteria for when NIOSH-approved abrasive-blasting respirators are required and the needed exposure data and enclosure conditions; see Respiratory protection for wet blasting. Apply those criteria along with the shipyard standards in Part 1915 to determine respirator obligations for ship repair and shipbuilding work.

Yes. Employers must meet applicable first-aid requirements for their industry and the hazards present during ship repair and shipbuilding. OSHA's interpretation on first aid and bleeding control explains that OSHA standards set minimum first-aid requirements and that industry-specific standards (including maritime/shipyard provisions) may require trained on-site first aiders; see First aid and bleeding control. Review the relevant shipyard standards in Part 1915 to determine specific first-aid obligations for the work covered by 1915.161.

No. Employers must ensure the assigned equipment operator is physically able to perform the task without unscheduled interruption that could affect worker safety; an operator should not leave the controls while a load is suspended. OSHA's interpretation addressing crane operator medical conditions states that leaving the controls while a load is suspended is not acceptable; see Crane operator medical condition scenario. Apply that requirement to crane and lifting operations during ship repairing and shipbuilding under Part 1915.

No — 1915.161 governs whether this subpart applies to ship repair and shipbuilding, not the asbestos regulatory thresholds. If asbestos hazards are present during ship repair or shipbuilding, employers must follow the asbestos provisions that apply to shipyards in Part 1915. OSHA's letters on asbestos sampling and analysis make clear that employers must comply with OSHA asbestos requirements and cannot substitute EPA school clearance levels for OSHA exposure assessments; see Asbestos sampling protocol requirements and consult the shipyard asbestos standard within Part 1915 for specific duties.