Ship's deck machinery requirements

The employer must ensure three specific steps are taken before work on the anchor windlass or any of its attached accessories: make the devil claws (chain stoppers) fast to the anchor chains, set the riding pawls in the engaged position, and if neither devil claws nor riding pawls are present, secure the anchor chains to a suitable fixed structure of the vessel. See 1915.165(a) and its subparagraphs 1915.165(a)(1), 1915.165(a)(2), and 1915.165(a)(3).

You must secure the devil claws so they are fastened to the anchor chains and prevent unintended chain movement while work is performed. The standard requires that “the devil claws (also known as chain stoppers) shall be made fast to the anchor chains” before work begins. See 1915.165(a)(1).

Riding pawls must be positioned so they engage the chain or ratchet mechanism and prevent the chain from running out while work is being done. The standard specifically requires that “the riding pawls shall be in the engaged position” before work on the windlass or accessories. See 1915.165(a)(2).

If devil claws and riding pawls are absent, you must secure the anchor chains to a suitable fixed structure of the vessel before work begins. The standard provides this as the alternative protective step. See 1915.165(a)(3).

The employer is responsible for ensuring the prescribed steps are taken before work on the anchor windlass or attached accessories. The rule begins with “Before work is performed ... the employer shall ensure that the following steps are taken.” See 1915.165(a). In addition, a competent person designated by the employer may evaluate the situation and specify necessary protections as discussed in OSHA’s interpretation on competent person responsibilities in shipyards (see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Yes. When devil claws and riding pawls are not present the standard requires the chains be secured to a suitable fixed structure of the vessel, and a competent person may determine what is a suitable means of protection. The rule allows securing the chain to the vessel as the alternative 1915.165(a)(3), and OSHA’s interpretation of competent person duties explains that a competent person may specify necessary protections and precautions in shipyard operations (see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

No. The standard requires devil claws and engaged riding pawls, or—in their absence—securing the chains to a suitable fixed structure of the vessel before work is performed. Relying solely on the windlass brake does not satisfy the specific steps listed in 1915.165(a).

Yes. The standard requires that these steps be taken before work is performed on the anchor windlass or its attached accessories, without limiting the requirement to particular chain conditions. The employer must ensure the devil claws are made fast, riding pawls engaged, or the chain secured to a suitable fixed structure before work begins. See 1915.165(a).

The standard states the devil claws “shall be made fast to the anchor chains,” which requires securing the anchor chains involved in the work. Employers should apply the requirement to the anchor chains that could affect the safety of the work being done. See 1915.165(a)(1).

You should visually confirm that the riding pawls are in the engaged position before work begins; the standard requires they “shall be in the engaged position.” The employer or a competent person should perform that verification as part of ensuring the step is completed. See 1915.165(a)(2) and OSHA’s guidance on the role of the competent person in shipyards (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

The standard requires the anchor chains be secured to a suitable fixed structure of the vessel when devil claws and riding pawls are absent; it explicitly references a structure of the vessel. See 1915.165(a)(3).

The standard does not define “suitable” in technical detail; suitability must be determined by the employer or a competent person who can evaluate hazards and specify necessary protection. See 1915.165(a)(3) and OSHA’s interpretation explaining that a competent person may specify necessary protections and precautions in shipyard operations (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

No written-record or tagging requirements are specified in 1915.165 itself; the standard states the employer shall ensure the listed steps are taken but does not require documentation in this section. Employers should, however, use whatever verification and recordkeeping practices are necessary to meet their safety management and compliance needs. See 1915.165(a).

The standard requires the employer to ensure the listed steps are taken but does not spell out specific training or job titles in 1915.165 itself. Employers should assign these tasks to qualified personnel and may rely on a competent person to recognize hazards and specify protections, as described in OSHA’s competent person interpretation for shipyards (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18). See 1915.165(a).

Yes. The standard applies to work performed on the anchor windlass or any of its attached accessories; that language explicitly brings accessories into the scope of the requirement. See 1915.165(a).

If devil claws or riding pawls are absent or unusable (for example, damaged or malfunctioning), the standard requires that the anchor chains be secured to a suitable fixed structure of the vessel before work begins. See 1915.165(a)(3).

The standard requires the employer to ensure the listed steps are taken before work is performed; it does not provide an exception for emergencies in the text of 1915.165. Employers should therefore follow the steps unless another applicable regulation or emergency procedure provides a lawful alternative, and they should use competent-person judgment in urgent situations. See 1915.165(a) and OSHA guidance on competent person responsibilities (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

While 1915.165 itself sets the required steps, failure to comply may subject the employer to OSHA enforcement action or citations for violating the standard. OSHA has stated in other shipyard enforcement contexts that employers can be cited if they fail to meet applicable safety requirements. See 1915.165(a) and related OSHA enforcement discussion (for example, OSHA letters interpreting employer responsibilities and potential citation exposure, such as https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13).