Subpart P
Employers must train employees within the timeframes in 1915.508: current employees were to be trained within 90 days of December 14, 2004; new employees must be trained upon initial assignment; and previously trained employees must be retrained when necessary to maintain proficiency. See 1915.508(a) and the specific subparagraphs 1915.508(a)(1), 1915.508(a)(2), and 1915.508(a)(3).
All employees must be trained on the workplace emergency alarm signals and the primary and secondary evacuation routes to use in the event of a fire. See 1915.508(b) and its items 1915.508(b)(1) and 1915.508(b)(2).
No. 1915.508(b)(2) requires a primary evacuation route for all vessels and vessel sections, but a secondary evacuation route is not required when it is impracticable to provide one. See the evacuation-route requirement in 1915.508(b)(2).
Employees expected to fight incipient stage fires must be trained on how to use extinguishers or hose lines, the hazards of incipient firefighting, hazards of fixed and portable fire protection systems, and how to activate and operate those systems. See the training topics in 1915.508(c) and the specific items 1915.508(c)(1), 1915.508(c)(2), and 1915.508(c)(3).
Employers must have a written training policy stating that fire response employees must be trained and capable of carrying out their duties and responsibilities at all times. See the written-policy requirement in 1915.508(d)(1).
The employer must keep written standard operating procedures that address anticipated emergency operations and must update those procedures as necessary. See the SOP requirement in 1915.508(d)(2).
Employers must review fire response training programs and hands-on sessions before they are used in training to make sure trainees are protected from hazards associated with the training. See the pre-use review requirement in 1915.508(d)(3).
Employers must provide training that ensures fire response employees can carry out duties under the employer's SOPs, and new fire response employees must be trained before they engage in emergency operations. See 1915.508(d)(4) and 1915.508(d)(5).
Fire response employees expected to fight fires must receive training on the written operating procedures at least quarterly. See the quarterly training requirement in 1915.508(d)(6).
Employers must conduct semi-annual drills for fire response employees according to the employer's written procedures, and those drills must cover site-specific operations, occupancies, buildings, vessels and vessel sections, and fire-related hazards. See the drill requirement in 1915.508(d)(9).
Any training that involves live fire response exercises must be conducted in accordance with NFPA 1403-2002, and that incorporation is referenced through the shipyard regulation's incorporation-by-reference rules in 1915.5. See the live-fire training requirement in 1915.508(d)(8) and the incorporation link at 1915.5.
No. 1915.508(d)(10) prohibits the use of smoke-generating devices that create a dangerous atmosphere in training exercises. See the prohibition in 1915.508(d)(10).
Fire response training must be conducted by instructors who are qualified to teach the material; the regulation requires use of qualified instructors but does not give a specific credential list—employers should ensure instructors have appropriate knowledge and experience to protect trainees. See the instructor requirement in 1915.508(d)(7). When determining qualifications for instructors or those making protection decisions, employers can look to the shipyard 'competent person' concept (who can recognize hazards and specify protections) explained in OSHA's interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.
Fire watch personnel must be trained before assignment to fire watch duty, whenever operations change to present new hazards, whenever the employer has reason to believe prior training is inadequate, and at least annually. See the timing rules in 1915.508(e)(1) and its subparts 1915.508(e)(1)(i) through 1915.508(e)(1)(iv).
Fire watch training must cover a range of subjects including fire behavior, classes of fire and extinguishing agents, stages and methods of extinguishing fires, extinguishing live fire scenarios when allowed by law, health effects from fire exposure, physical characteristics of the hot work area, hazards of fire watch duties, required PPE and its use, selection and use of extinguishers and hoses, location and use of barriers, employer-designated means of communication, when/how to start alarm procedures, and the employer's evacuation plan. See the full list in 1915.508(e)(2) and its subitems such as 1915.508(e)(2)(i) and 1915.508(e)(2)(xii).
A fire watch must alert others to exit the space when the fire watch perceives an unsafe condition, perceives that a worker performing hot work is in danger, when the employer or employer's representative orders an evacuation, or when an evacuation signal (such as an alarm) is activated. See these alerting triggers in 1915.508(e)(3) and its subparts 1915.508(e)(3)(i) through 1915.508(e)(3)(iv).
Employers must keep records demonstrating that employees received the required training, and those records must include the employee's name, the trainer's name, the type of training, and the date(s) of training; records must be kept for one year from the time they were made or until replaced with a new record, whichever is shorter, and made available to OSHA on request. See the record content requirement in 1915.508(f)(1) and the retention and availability rule in 1915.508(f)(2).
Employers can conduct live-fire extinguishing training when local and federal law allow it, but any live-fire training must follow NFPA 1403-2002 requirements as referenced by the shipyard standard and must also meet the employer's review and safety protections before use. See the allowance in 1915.508(e)(2)(ii), the NFPA requirement in 1915.508(d)(8), and the incorporation reference at 1915.5.
Training for employees expected to fight incipient fires must include the hazards associated with fixed and portable fire protection systems they may use or be exposed to during discharge, and how to activate and operate those systems. See 1915.508(c)(2) and 1915.508(c)(3).
Training on written operating procedures for employees expected to fight fires must be provided at least quarterly, while full drills for fire response employees must be conducted at least semi-annually and follow the employer's written procedures. See the quarterly training rule in 1915.508(d)(6) and the semi-annual drill requirement in 1915.508(d)(9).
Employers must train fire watches in the means of communication designated by the employer for fire watches, so they can summon help, start alarm procedures, or coordinate evacuations as needed. See the communication training requirement in 1915.508(e)(2)(x) and the timing/qualification requirements in 1915.508(e)(1).
Fire watches must be trained on the personal protective equipment (PPE) needed for fire watch duties and how to use that PPE. See the training elements in 1915.508(e)(2)(vi) and 1915.508(e)(2)(vii). Employers are generally required to provide required PPE at no cost to the employee under OSHA's employer-payment rule as explained in OSHA's interpretation on employee PPE payment methods at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.
Training must ensure employees understand the emergency alarm signals used in the workplace, including system discharge alarms and employee evacuation alarms, so they know how to respond when an alarm sounds. See the alarm-signal training requirement in 1915.508(b)(1).
Employees hired after December 14, 2004 must be trained upon initial assignment, per the new-employee requirement in 1915.508(a)(2); the 90-day deadline in 1915.508(a)(1) applied to employees working on December 14, 2004.
It means employers must provide training (including hands-on where appropriate), supervision, and resources so fire response employees can follow the employer's written SOPs safely and effectively during emergencies. See the capability requirement in 1915.508(d)(4) and the related requirements for SOPs and training in 1915.508(d)(2) and 1915.508(d)(3).
Employers should evaluate hazards before training, use safe props or simulators, monitor atmospheric conditions, require appropriate PPE, limit live-fire use to NFPA-compliant evolutions, and have emergency medical support available. These protections are required by the pre-use review and training-safety rule in 1915.508(d)(3), and live-fire protections must follow NFPA 1403-2002 as referenced in 1915.508(d)(8) and 1915.5. Employers may consult OSHA guidance about competent persons in shipyards for determining who can specify protections at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.
Training should cover how to select and use any fire extinguishers and fire hoses likely to be used by a fire watch in the work area, including which agents are appropriate for different fire classes and safe operating procedures. See this requirement in 1915.508(e)(2)(viii).
Each training record must include the employee's name, the trainer's name, the type of training, and the date(s) on which the training took place. See the record-content list in 1915.508(f)(1).
Training records must be kept for one year from the time they were made or until replaced with a new training record (whichever is shorter), and employers must make them available for inspection and copying by OSHA on request. See the retention and availability rule in 1915.508(f)(2).
Fire watches must be trained to recognize the adverse health effects from fire exposure and the hazards associated with fire watch duties, including smoke inhalation, thermal injury, and hazards specific to the hot work area. See the health- and hazard-recognition items in 1915.508(e)(2)(iii) and 1915.508(e)(2)(v).
The technical standard for live-fire training is NFPA 1403-2002, and employers must conduct live-fire training in accordance with that standard as incorporated by reference through the shipyard regulation's incorporation rule in 1915.5; see 1915.508(d)(8).