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OSHA 1915.181

Electrical safety for shipyards

1915 Subpart L

15 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.181(a), does the electrical safety rule apply to shipbreaking work?

No — 1915.181(a) applies to ship repairing and shipbuilding and explicitly does not apply to shipbreaking. Employers engaged in shipbreaking should follow any other applicable OSHA standards that govern their specific activities.

Under 1915.181(b), must a circuit always be deenergized before an employee works on it?

Yes — 1915.181(b) requires that, before an employee is permitted to work on an electrical circuit, the circuit must be deenergized and checked at the point where the work will be done, except when the circuit must remain energized for testing and adjusting. If you must leave a circuit energized for testing or adjusting, additional precautions (see next questions) apply.

What does "checked at the point at which the work is to be done" mean under 1915.181(b)?

It means you must verify absence of voltage right where the employee will be working. 1915.181(b) requires testing at the work location (for example, the conductor, terminal, or device being serviced) with an appropriate voltage tester to ensure the circuit is actually deenergized before starting work. Use a tester rated for the system voltage, verify the tester on a live source before and after the check, and follow safe test procedures.

If a circuit must remain energized for testing and adjusting, what footing protection is required under 1915.181(b)?

You must stand on approved insulating material when working on energized circuits for testing or adjustments. 1915.181(b) requires use of a rubber mat, duck board, or other suitable insulation underfoot where an insulated deck does not exist. That insulation must be appropriate for the voltage and conditions encountered.

How must a circuit be deenergized according to 1915.181(c)?

Use the proper switching device and then lock or tag it out. 1915.181(c) says deenergizing shall be accomplished by opening the circuit breaker, opening the switch, or removing the fuse — whichever is appropriate — and then the breaker, switch, or fuse location shall be locked out or tagged in accordance with 1915.89.

Is removing a fuse enough to deenergize a circuit, and what else must be done?

Yes, removing the fuse can deenergize the circuit, but you must also lock or tag and verify the circuit is deenergized. 1915.181(c) permits removing the fuse to deenergize; it then requires locking out or tagging in accordance with 1915.89. After removal, test at the work point to confirm the absence of voltage per 1915.181(b).

Who should perform lockout/tagout and how does 1915.89 relate to 1915.181(c)?

Authorized employees should perform lockout/tagout following the shipyard lockout/tagout rules. 1915.181(c) requires that after deenergizing you lock or tag the device "in accordance with 1915.89." That means employers must follow the procedures, training, and authorization requirements in 1915.89 for who may apply and remove lockout/tagout devices.

Under 1915.181(d), what must be done when working next to or behind an energized open-front board?

You must cover the board or provide an equally safe barrier to prevent contact with energized parts. 1915.181(d) requires that when work is performed immediately adjacent to an open-front energized board or in back of an energized board, the board shall be covered or other equally safe means used to prevent contact with any energized parts.

What are acceptable "equally safe means" to protect workers from exposed energized parts per 1915.181(d)?

Acceptable methods include physical insulating barriers or covers that prevent accidental contact with energized parts. 1915.181(d) allows covering the board or using other equally safe methods — for example, nonconductive shields, temporary blanking panels, or secure insulating guards sized and positioned so workers cannot touch live parts. Whatever method you use must effectively prevent contact with energized parts.

If multiple circuits are present and only one needs work, do you have to deenergize every adjacent circuit?

You must deenergize the circuit being worked on and take steps to prevent contact with other energized parts. 1915.181(b) requires deenergizing and testing at the work point for the circuit being worked on; 1915.181(d) requires covering energized boards when work is adjacent. If adjacent energized circuits pose a contact hazard, you must use covers, barriers, or additional deenergizing/lockout to protect employees, consistent with 1915.181(c) and (d).

Also see OSHA's guidance on the role of a competent person who can evaluate hazards and specify protections in shipyards at Competent person requirements in shipyards.

Do the 1915.181 rules require testing equipment or procedures to be documented?

The 1915.181 text does not prescribe specific documentation requirements for testing; it requires that the circuit be deenergized and checked at the work point. 1915.181(b). Employers should document their procedures and training to demonstrate compliance with deenergizing, testing, and lockout/tagout practices in 1915.181(c) and the related 1915.89 requirements for program elements and training.

Can an unqualified worker test or work on electrical circuits under 1915.181?

No — employers must ensure only qualified and authorized persons perform electrical testing and work. 1915.181(b) requires testing at the work point before work begins, and 1915.181(c) requires lockout/tagout in accordance with 1915.89, which mandates employer-established procedures and authorized employees. OSHA’s shipyard guidance on competent persons explains that a competent person must be capable of recognizing hazards and specifying protections: see Competent person requirements in shipyards.

If a worker must adjust equipment that needs the circuit energized, what steps should the employer take under 1915.181(b)?

Allow the energized work only when necessary for testing or adjusting, provide insulating footing, and control contact hazards. 1915.181(b) permits leaving a circuit energized for testing and adjusting but requires use of a rubber mat, duck board, or other suitable insulation underfoot where an insulated deck does not exist. Employers should also limit energized work to what is strictly necessary and use additional barriers, insulated tools, and qualified personnel consistent with safe work practices and 1915.89.

Does 1915.181 say how to verify a voltage tester works before and after testing?

The standard does not spell out tester-check steps, but it requires checking the circuit at the work point. 1915.181(b) requires verifying a circuit is deenergized at the point of work, which industry practice implements by proving the tester on a known live source before and after testing. Employers should adopt a tester-check procedure as part of their authorized employee training under 1915.89.

When performing work in the back of an energized board, does 1915.181(d) require permanent covers or temporary protections?

Either permanent or temporary protections are acceptable as long as they prevent contact with energized parts. 1915.181(d) requires the board be covered or protected by some other equally safe means when work is performed immediately adjacent to or in back of an energized board. Employers can use permanent covers, removable insulating shields, or temporary guards so long as they effectively prevent contact with live parts.