Fissionable material use in shipyards

Under 1915.57(a), the NRC's Standards for Protection Against Radiation (10 CFR Part 20) apply whenever shipyard work involves use of or exposure to sources of ionizing radiation, including work on both conventionally powered and nuclear-powered vessels.

• Follow the requirements in 1915.57(a) for activities that involve ionizing radiation.
• Dose limits, monitoring, training, posting, and other radiation-protection obligations will be determined by the applicable provisions of 10 CFR Part 20 as incorporated by 1915.57(a).

Under 1915.57(b), any activity that involves radioactive material must be performed by competent persons who are specially trained in the safe and proper operation of the equipment.

• If the radioactive material is used under an NRC license, only persons actually licensed by the NRC—or competent persons working under the direction and supervision of the licensee—may perform the work, per 1915.57(b).

Under 1915.57(b), "specially trained" means workers must have training that enables them to operate the radioactive equipment safely and to protect themselves and others from radiation hazards; the standard requires specially trained competent persons but does not prescribe a single course curriculum.

• Employers must ensure training is sufficient for the tasks and hazards involved and consistent with the NRC requirements when work is licensed, as referenced in 1915.57(b) and with the radiation protection provisions incorporated by 1915.57(a).
• When activities are performed under an NRC license, the license and 10 CFR Part 20 typically identify specific training, qualification, and supervision requirements to meet the "specially trained" obligation.

Under 1915.57(b), unlicensed workers may perform work involving licensed radioactive material only if they are competent persons working under the direction and supervision of the NRC licensee; otherwise only NRC-licensed individuals may perform the licensed work.

• This means the licensee must ensure adequate supervision and that the non-licensed workers meet the competence and training requirements described in 1915.57(b).
• When in doubt, follow the license conditions and 10 CFR Part 20 requirements referenced by 1915.57(a).

Yes. Section 1915.57(a) explicitly states that the NRC's radiation protection provisions apply to activities involving ionizing radiation on both conventionally powered and nuclear-powered vessels.

• Employers must follow the applicable provisions of 10 CFR Part 20 for protection against occupational radiation exposure regardless of the vessel's propulsion type.

Under 1915.57(b), the employer is responsible for ensuring that radioactive activities are performed by competent, specially trained persons and, where applicable, that NRC licensing and supervision requirements are followed.

• OSHA guidance on competent person responsibilities in shipyards explains that duties assigned to a competent person are treated as employer responsibilities (see OSHA Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18), which supports the employer's duty under 1915.57(b).

Under 1915.57(a), employers must follow the NRC's radiation protection requirements in 10 CFR Part 20 for dose limits, monitoring, and related radiation-protection measures when activities involve ionizing radiation.

• 1915.57(a) incorporates those NRC provisions into shipyard operations, so employers must comply with the applicable 10 CFR Part 20 requirements and any NRC license conditions governing monitoring and dose tracking.

No single definition of "competent person" is spelled out in 1915.57 itself; however, 1915.57(b) requires that activities with radioactive material be performed by competent persons specially trained in safe operation, and OSHA's shipyard competent-person guidance provides details about what being "competent" means in shipyard contexts.

• See 1915.57(b) for the requirement that work be done by competent, specially trained persons.
• For practical criteria and employer responsibilities for competent persons in shipyards, see OSHA's Letter of Interpretation on competent person requirements at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 which explains the attributes and employer responsibilities tied to competent persons.

Under 1915.57(b), portable radioactive devices must be operated by competent persons who are specially trained in their safe use; if the devices are used under an NRC license, operation must be by NRC-licensed individuals or competent persons under the licensee's direction and supervision.

• Employers must ensure operators meet the competence and training expectations in 1915.57(b) and comply with the radiation protection and licensing requirements incorporated by 1915.57(a).

Yes. Section 1915.57(b) applies to any activity involving radioactive material whether or not it is under an NRC license: such activities must be performed by competent persons specially trained in the proper and safe operation of the equipment.

• Even without an NRC license, employers must ensure trained, competent personnel perform the work and follow applicable radiation-safety practices.

No. Under 1915.57(a), OSHA directs employers to follow the Nuclear Regulatory Commission's requirements in 10 CFR Part 20 for occupational radiation exposure rather than setting separate dose limits in Part 1915.

• That means shipyard employers should consult 10 CFR Part 20 for numeric limits, monitoring, records, and other radiation-protection rules that apply to their operations.

Under 1915.57(b) and OSHA's shipyard competent-person guidance, an employer can show a worker is "competent" by documenting training, qualifications, experience, and the worker's ability to recognize and evaluate radiation hazards and to specify and implement protective measures.

• See 1915.57(b) for the requirement that only competent, specially trained persons perform radioactive activities.
• OSHA's Letter of Interpretation on competent persons in shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18 explains that competent persons must be able to recognize and evaluate hazards and specify necessary protections, and that those responsibilities are employer obligations.

Under 1915.57(b), employers must ensure non-licensed workers only perform tasks involving licensed radioactive material under the direction and supervision of the NRC licensee, and that those workers are competent and specially trained for the tasks.

• The licensee's supervision must satisfy the license conditions and 10 CFR Part 20 requirements incorporated by 1915.57(a).
• Employers should document supervisory arrangements and training to demonstrate compliance with 1915.57(b) and applicable NRC license terms.