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OSHA 1915.164

Main engine and propeller safety

1915 Subpart J

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.164(a), what must an employer do before work is performed on the main engine, reduction gear, or connecting accessories?

The employer must make sure the jacking gear is engaged to prevent the main engine from turning and follow the specified lock/tag and posting steps for the jacking gear. Specifically, 1915.164(a) requires engaging the jacking gear, posting a sign at the throttle that the jacking gear is engaged, and then following the applicable secure-and-lock or de-energize-and-lock/tag procedures in paragraphs (a)(2) and (a)(3).

  • For steam-driven jacking gear, the stop valves must be secured and then locked or tagged in accordance with 1915.89.
  • For electrically driven jacking gear, the controlling circuit must be de-energized by tripping the breaker, opening the switch, or removing the fuse (as appropriate), and then locked or tagged in accordance with 1915.89.

Under 1915.164(a)(1), is a sign required at the throttle when the jacking gear is engaged and when can it be removed?

Yes — the employer must post a sign at the throttle indicating that the jacking gear is engaged and must not remove that sign until the jacking gear can be safely disengaged. This is an explicit requirement of 1915.164(a)(1).

  • The sign serves as a positive warning to anyone who might otherwise attempt to start or turn the engine; it must remain in place until it is safe to disengage the jacking gear.

Under 1915.164(a)(2), what must an employer do when the jacking gear is steam driven?

If the jacking gear is steam driven, the employer must secure the stop valves and then lock or tag them in accordance with the lock/tag requirements. 1915.164(a)(2) requires stop valves to be secured and then locked or tagged per 1915.89.

  • If a physical lock cannot be used, tagging is allowed when done consistent with the procedures in 1915.89.

Under 1915.164(a)(3), how must an employer de-energize an electrically driven jacking gear before work?

The employer must de-energize the circuit that controls the jacking gear (by tripping the breaker, opening the switch, or removing the fuse as appropriate) and then lock or tag the de-energized device in accordance with the lock/tag rules. 1915.164(a)(3) sets out the de-energizing options and requires locking or tagging per 1915.89.

  • Choose the de-energizing method appropriate to the installation and ensure the subsequent lock or tag prevents re-energization while work is underway.

Under 1915.164(b)(1) and (b)(2), what checks must be done before the jacking engine is operated?

Before operating the jacking engine, the employer must check that all employees, equipment, and tools are clear of the engine, reduction gear, and connecting accessories, and that all employees, equipment, and tools are free of the propeller. 1915.164(b)(1) and 1915.164(b)(2) require these two distinct clearance checks.

  • Perform a visual sweep and, where appropriate, require a verbal “all clear” from affected workers before operating the jacking engine.

Under 1915.164(c), when and where must a warning sign be hung before working on or near the propeller?

A conspicuous warning sign must be hung in the engine room calling attention to the fact that employees are working on or in the immediate vicinity of the propeller, and it must remain until the work is completed and all employees are clear of the propeller. This requirement is stated in 1915.164(c).

  • Place the sign where watchstanders, operators, or any personnel who could start engines or move the propeller will see it.

Under 1915.164(d), what must be done before the main engine is turned over for warmup or testing?

Before the main engine is turned over (for warming up or testing), the employer must check to ensure all employees, equipment, and tools are free of the propeller. That is the specific requirement of 1915.164(d).

  • Confirm the engine room is clear and that any required warning signs remain in place until everyone is clear.

Under 1915.164, who is responsible for making sure the jacking procedures, lock/tag steps, and warning signs are followed?

The employer is responsible for ensuring the procedures in 1915.164 are followed and must assign or empower qualified personnel (for example, a competent person) to make safety decisions as needed. 1915.164 places the procedural requirements on the employer, and OSHA has explained that, where appropriate, a "competent person" under Part 1915 may be tasked to recognize hazards and specify necessary protection (see OSHA's interpretation on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Ensure supervisors and any designated competent person understand and enforce the lock/tag, posting, and clearance checks required by the standard.

Under 1915.164(a)(1), may the throttle sign be removed before the jacking gear is safely disengaged?

No — the sign at the throttle indicating the jacking gear is engaged must not be removed until the jacking gear can be safely disengaged. That is an explicit rule in 1915.164(a)(1).

  • Removing the sign early could create a false impression that the engine is safe to operate and risk accidental turnover.

Under 1915.164(a)(3), is removing a fuse an acceptable way to de-energize an electrically driven jacking gear?

Yes — removing the fuse is listed as one acceptable method to de-energize the circuit controlling an electrically driven jacking gear, provided it is then locked or tagged in accordance with the lock/tag rules. 1915.164(a)(3) allows tripping the breaker, opening the switch, or removing the fuse, and requires locking or tagging per 1915.89.

  • Use the method appropriate to the installation and ensure the device cannot be re-energized until it is safe to do so.

Under 1915.164(b)(1), how should an employer perform the required clearance checks to ensure people and tools are clear of the engine and propeller?

The employer should conduct positive checks — such as a visual sweep of the area and verbal confirmation from workers — to ensure all employees, equipment, and tools are clear of the engine, reduction gear, and the propeller before the jacking engine is operated. 1915.164(b)(1) requires that a check be made, and practical methods include visual sweeps, two-way communication, and written or posted clearance confirmations.

  • Where multiple crews or contractors are present, use a single point of authority or a permit/checklist to document the clearance.

Under 1915.164(c), can outside contractors hang or remove the propeller-work warning sign, or who should do that?

The employer (or the employer's designated representative such as a competent person or supervisor) must ensure the warning sign is hung and removed only after work is completed and everyone is clear of the propeller. 1915.164(c) requires the sign and its duration; assigning the task to a contractor is acceptable only if the employer ensures the contractor follows the rule.

  • Document who is authorized to place and remove the sign and verify completion before removal.

Under 1915.164, what lock/tag procedures are required and where do I find the details?

1915.164 requires locking or tagging of secured components of the jacking gear and electrical controls, and the details for how to lock or tag are found in 1915.89. 1915.164(a)(2) and 1915.164(a)(3) explicitly require compliance with 1915.89 when locking or tagging stop valves or electrical circuits.

  • Follow the procedures in 1915.89 for who places locks/tags, how they are identified, and how they are removed.

Under 1915.164, does the standard explicitly require training for crew performing jacking and propeller work?

The text of 1915.164 does not spell out a specific training program, but the employer must ensure personnel are able to follow the required safety steps (engage jacking gear, secure/lock/tag, post signs, and make clearance checks), which effectively requires training and supervision. 1915.164 sets procedural requirements the employer must enforce, and OSHA guidance on competent persons notes employers should designate personnel capable of recognizing hazards and specifying protections (see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Practical compliance includes documented training for watchstanders, engineers, and anyone who will apply locks/tags or post/remove signs.

Under 1915.164(b)(2), must tools and equipment be removed from the propeller area before operating the jacking engine?

Yes — the employer must ensure that all employees, equipment, and tools are free of the propeller before the jacking engine is operated. 1915.164(b)(2) requires this clearance check.

  • Secure loose tools by removing them from the area or using tool tethers where removal is not feasible, and document that a clearance check was completed.

Under 1915.164(a)(2), if a stop valve cannot be locked, is tagging acceptable?

Yes — 1915.164(a)(2) requires stop valves to be secured and then locked or tagged in accordance with 1915.89, so tagging is acceptable when locking is not possible but must be done following the procedures in 1915.89.

  • If tagging is used instead of locking, ensure the tag is durable, clearly identifies the person who applied it, and that procedures prevent inadvertent reactivation.

Under 1915.164, what does the phrase "immediate vicinity of the propeller" mean in practical terms?

The standard does not give a specific measurement; "immediate vicinity of the propeller" means the area where employees, tools, or equipment could be struck or affected if the propeller moved — in practice you must define and control that area based on the ship, propeller size, and working tasks. 1915.164(c) requires posting a warning when employees are working on or in the immediate vicinity of the propeller. OSHA's guidance on competent persons supports using a qualified person to evaluate hazards and specify protections (see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Use a competent person to set the physical limits (e.g., distance from the blade, deck areas to be cleared) and document the boundary in a work permit or checklist.

Under 1915.164, what should an employer do if the jacking gear will not engage and work must be done on the engine or propeller?

If the jacking gear will not engage, the employer must take alternative measures to ensure the engine cannot be turned over (for example, by securing other controls, restricting access, implementing additional physical barriers, and using formal permits) and must ensure all the required posting, clearance checks, and lock/tag procedures are followed as applicable. 1915.164(a) requires prevention of engine turnover before work, and where normal jacking gear procedures cannot be used a competent person should determine and document equivalent safe methods (see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Do not start or test the engine until you have a documented, effective method to prevent rotation and you have completed the required clearances and postings.

Under 1915.164, may the main engine be turned over for warmup if the jacking gear is engaged?

Only if turning the engine over is consistent with the engaged condition and the required clearance checks and postings are in place; in general, 1915.164(d) requires that before the engine is turned over (for warmup or testing) you must check that all employees, equipment, and tools are free of the propeller.

  • If the jacking gear prevents rotation, follow the jacking procedures in 1915.164(a); if the engine must be turned, ensure everyone and everything is clear and warning signs remain posted until the operation is complete.

Under Part 1915, does 1915.164 apply to all shipyard engine and propeller work or only to certain vessels?

1915.164 applies within the scope of OSHA's shipyard employment standard (Part 1915) to main engine and propeller safety in shipyard employment and related operations covered by that part. See the Part heading at 1915 and the specific requirements in 1915.164.

  • Determine applicability to a specific vessel or activity by consulting Part 1915 and any State Plan rules that may adopt equivalent or additional requirements.