Fire protection responsibilities

The purpose is to require employers to protect all employees from fire hazards in shipyard employment, including those engaged in fire response activities. This means employers must identify fire hazards, put in place controls and rules, and make sure employees are protected while doing ship repair, modification, or related land-side operations as described in 1915.501(a).

• See the overall scope in 1915.501(b) for who is covered.
• Where a competent person is required to evaluate hazards and select protections, employers must ensure that person can specify necessary protections (see OSHA interpretation on competent persons for shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

The subpart covers employers with employees engaged in shipyard employment aboard vessels and vessel sections, and on land-side operations regardless of geographic location. In other words, any employer whose workers perform shipyard tasks on or off the vessel falls within 1915.501(b).

• This is a broad scope: it applies to shipyards, contractors working on ships, and related land-side operations.

Employers must provide ways for employees or employee representatives, or both, to participate in developing and periodically reviewing programs and policies adopted to comply with this subpart. That means workers should have a real opportunity to help create and review fire safety plans and rules as required by 1915.501(c).

• Practical methods include safety committees, toolbox talks, written comments, and formal review meetings. The standard requires participation but does not prescribe a specific method or frequency—only that participation be provided and reviews be periodic.

Multi-employer worksites require a division of duties into host and contract employer responsibilities so fire hazards are identified, communicated, and controlled. The rule sets out separate duties for host employers and contract employers in 1915.501(d).

• Host employers must inform others about the fire safety plan, assign safety responsibilities, and communicate with other host employers when multiple hosts are present.
• Contract employers must tell the host about the hazards of their work and advise the host if they find new fire-related hazards.

A host employer must inform all employers at the worksite about the content of the fire safety plan, including hazards, controls, fire safety and health rules, and emergency procedures. In short, hosts must share the plan details so everyone knows the hazards and how to respond, as required by 1915.501(d)(1)(i).

• Effective ways to meet this include written copies of the plan, pre-job briefings, posted procedures, and emergency drills.

A host employer must make sure the safety and health responsibilities for fire protection are assigned as appropriate to other employers at the worksite. That means the host must clearly allocate who will do what for fire prevention and response, per 1915.501(d)(1)(ii).

• Examples: assigning hot-work permit control to a contractor doing welding, designating who maintains fire extinguishers, or assigning emergency evacuation leadership.
• Clear written assignments, briefings, and coordination meetings help avoid gaps or duplication.

A vessel owner or operator becomes a host shipyard employer when they direct the work of the ship's crew on repair or modification of the vessel or hire contractors directly, and when they do so they must comply with the host employer duties in this section. In other words, when a vessel owner controls repair work or hires contractors, they must inform others about the fire safety plan, assign responsibilities, and communicate hazards as required by 1915.501(d)(1)(iii).

• Practical implication: vessel owners acting in this role must coordinate plans and emergency procedures with shipyard contractors and crews.

Contract employers must make sure that the host employer knows about the fire-related hazards associated with the contract employer's work and what the contract employer is doing to address them. That means contractors must disclose hazards and their control measures to the host, as required by 1915.501(d)(2)(i).

• Useful items to share: hot work locations, fuel sources, ignition-control measures, fire watches, and the contractor's emergency procedures.

Contract employers must advise the host employer of any previously unidentified fire-related hazards that they identify at the worksite. In short, contractors must promptly report new hazards to the host so appropriate controls can be applied, as stated in 1915.501(d)(2)(ii).

• Reporting promptly lets the host reassign responsibilities or change the fire safety plan to protect all workers.

The standard requires the content of a fire safety plan to be known to employers at the worksite, which in practice means employers should have a documented plan they can share, brief on, and use for coordination as implied by 1915.501(d)(1)(i).

• Although 1915.501 does not explicitly state the word “written” in every clause, having a written plan is the practical way to ensure the host can inform others about hazards, controls, rules, and emergency procedures.
• Use written plans, briefing records, and sign-in sheets to demonstrate compliance during multi-employer coordination.

Host employers must communicate relevant information about fire-related hazards to other host employers, which includes coordinating emergency procedures when more than one host is present. That means hosts should share and align emergency response plans and notify each other of hazards, per 1915.501(d)(1)(iii).

• Practical steps: joint emergency drills, shared evacuation routes, common muster points, and written agreements on who leads response in overlapping work areas.

No—contract employers have their own responsibilities: they must make sure the host knows about the fire-related hazards from their work and how they are addressing them, and they must advise the host of any new hazards they discover, as required by 1915.501(d)(2).

• While the host assigns and coordinates responsibilities, contractors must communicate hazards and controls and take action to control hazards in their own operations.

A competent person who meets the Part 1915 definition may recognize and evaluate hazards and is capable of specifying necessary protections and precautions to ensure employee safety, including for exposures that lack an OSHA PEL; employers must ensure such a competent person is available as explained in [1915.501] (https://www.osha.gov/laws-regs/regulations/standardnumber/1915/1915.501) and the OSHA interpretation on competent persons for shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

• The OSHA interpretation clarifies that where a PEL is absent, the competent person may use other occupational exposure limits or professional judgment to set protective measures.

The standard requires employers to provide ways for employees to participate in developing and periodically reviewing programs and policies, but it does not set a specific review frequency; it only requires that reviews be periodic as stated in 1915.501(c).

• Best practice: review when work scope changes, after an incident, and at regular intervals such as annually to ensure plans remain effective.

Either method can meet the requirement so long as the host effectively informs all employers about the plan's content—hazards, controls, rules, and emergency procedures—as required by 1915.501(d)(1)(i).

• Practical options include written plans distributed to contractors, pre-job briefings or toolbox talks, posted procedures, and emergency drills; choose methods that reliably reach all affected employers and workers.

If a contract employer identifies increased or new fire hazards, they must advise the host employer so the host can update assignments and controls; this is required by 1915.501(d)(2)(ii).

• After notification, the host should revise the fire safety plan, reassign responsibilities if needed, and communicate changes to all employers on site.

The host must inform other employers about the fire safety plan content including hazards, controls, fire safety and health rules, and emergency procedures—so information about contractor activities should cover the specific hazards they create, the controls they will use, and how their work affects emergency response as stated in 1915.501(d)(1)(i).

• Useful items to include: hot-work permits, locations of ignition sources, flammable materials storage, required fire watches, and evacuation/muster points.