Subpart C
No — Subpart C does not apply to shipbreaking work. The rule for this subpart plainly states that the standards in Subpart C "shall apply to ship repairing and shipbuilding and shall not apply to shipbreaking" (Scope and application of subpart, 1915.31).
Yes — Subpart C applies to ship repairing and shipbuilding activities. The standard text says the standards in this subpart "shall apply to ship repairing and shipbuilding" (1915.31).
Yes — Subpart C applies to the shipbuilding/repairing portions of the operation and does not apply to the shipbreaking portions. The rule plainly limits application to ship repairing and shipbuilding and excludes shipbreaking (1915.31).
No — the physical location does not by itself change applicability; what matters is whether the work is ship repairing or shipbuilding. Subpart C applies to surface preparation and preservation when those activities are part of ship repairing or shipbuilding, per 1915.31. If you are unsure whether an activity is considered ship repairing or shipbuilding, consult the definitions and scope in Part 1915 (Part 1915 overview).
Yes — if the touch‑up painting or preservation is part of ship repairing or shipbuilding, Subpart C applies even for small or one‑time tasks. The subpart's application is based on the type of work (ship repairing or shipbuilding), as stated in 1915.31.
Subpart C applies to surface preparation in ship repairing and shipbuilding, and other OSHA standards may also apply simultaneously — you must comply with all applicable standards. For example, OSHA guidance on respiratory protection and ventilation for abrasive or wet abrasive blasting operations explains when NIOSH‑approved abrasive‑blasting respirators are required and what exposure data or enclosure conditions can affect that determination (Respiratory protection for wet blasting, OSHA interpretation, Aug. 13, 2015). Always check Subpart C together with related standards such as the shipyard Part 1915 rules and general industry standards in Part 1910 (Part 1915 overview).
A competent person at the employer may determine the necessary protection. OSHA has stated that under Part 1915 the competent person is required to be capable of recognizing and evaluating exposures and "specifying the necessary protection and precautions," and may make protection decisions where no OSHA PEL exists (Competent person requirements in shipyards, OSHA interpretation, Apr. 18, 2016). Also consult the general Part 1915 requirements (Part 1915 overview).
Not as a substitution — employers must comply with all OSHA standards that apply to their specific operations. Subpart C applies to ship repairing and shipbuilding surface preparation activities, and other standards (such as general industry or ventilation rules) may also apply in addition to Subpart C. The employer should follow the shipyard requirements in Part 1915 and any other applicable OSHA standards (1915.31 scope; see also related guidance on respiratory and ventilation requirements (Respiratory protection for wet blasting, OSHA interpretation, Aug. 13, 2015).
Possibly — the shipyard beryllium standard applies to occupational exposure to beryllium in shipyards and can apply to surface preparation tasks if they create beryllium exposure. OSHA's interim enforcement guidance explains that the shipyard beryllium standard (29 CFR 1915.1024) applies to beryllium in shipyards except for certain exempted articles and materials (2020 Beryllium Standards Guidance, OSHA memorandum, Apr. 21, 2021). You must evaluate exposures during surface preparation and comply with both Subpart C and any substance‑specific standards that apply (Part 1915 overview).
No — the exclusion in 1915.31 only means Subpart C does not apply to shipbreaking; other OSHA standards outside Subpart C or other parts of the regulations may still apply to shipbreaking operations. The text of 1915.31 specifically limits Subpart C to ship repairing and shipbuilding and excludes shipbreaking (1915.31), but employers must still follow any other OSHA requirements that are applicable to their activities.
Yes — Subpart C applies to surface preparation and preservation work when it is ship repairing or shipbuilding work, regardless of whether the work is performed by the shipyard's employees or by a contractor. The standard applies to the covered activity (ship repairing and shipbuilding) without limiting by employer type (1915.31). Employers and host employers should coordinate compliance obligations under applicable Part 1915 requirements (Part 1915 overview).