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OSHA 1915.6

Commercial diving operations

Subpart A

11 Questions & Answers
10 Interpretations

Questions & Answers

Subject: Under 1915.6 (Commercial diving operations), which OSHA regulations apply to shipyard diving work?

Yes — commercial diving work in shipyard employment is governed by OSHA's commercial diving rules found in Subpart T of part 1910, specifically 1910.401 through 1910.441. See 1915.6 which directs that "commercial diving operations shall be subject to subpart T of part 1910, 1910.401-1910.441 of this chapter."

Subject: Under 1915.6, does a shipyard employer need to follow shipyard standards in part 1915 or Subpart T in part 1910 for diving?

Follow Subpart T in part 1910 for diving — when employees perform commercial diving in shipyard employment, employers must apply the commercial diving requirements in 1910.401–1910.441, as stated by 1915.6. This means the diving-specific provisions in Subpart T of part 1910 control the safe-work rules for diving activities in shipyards.

Subject: Under 1915.6, where can a shipyard safety manager find the detailed diving requirements they must follow?

Look in Subpart T of 29 CFR part 1910 — the detailed commercial diving requirements are in 1910.401 through 1910.441. The directive in 1915.6 explicitly points employers to those sections for the full set of requirements governing commercial diving operations.

Subject: Under 1915.6, does following Subpart T satisfy the shipyard employer’s obligations for commercial diving operations, or are there additional 1915 rules to apply?

Yes — complying with Subpart T (29 CFR 1910.401–1910.441) provides the specific regulatory requirements for commercial diving in shipyards as stated in 1915.6. Employers must also remain aware of other generally applicable OSHA requirements (for example, hazard communication, PPE, etc.) where they apply, but the commercial diving specifics are governed by Subpart T as referenced in 1915.6.

Subject: Under 1915.6, do state-plan states have different requirements for shipyard diving operations?

Possibly — while 1915.6 directs that commercial diving in shipyards follows Subpart T of part 1910, OSHA-approved State Plan states may adopt and enforce their own standards that are at least as effective as federal OSHA. Employers in those states must follow the State Plan’s requirements if they are more stringent than federal rules. (See the general discussion of State Plans in the OSHA guidance cited in interpretation letters such as the asbestos letter that references State Plans.) For federal reference see 1915.6.

Subject: Under 1915.6, are civilian contractors working on military vessels covered by the Subpart T diving rules?

Yes — civilian employees and private contractors performing work that is not uniquely military are covered by OSHA standards, so shipyard diving performed by civilian contractors would be subject to Subpart T (29 CFR 1910.401–1910.441) as directed by 1915.6. OSHA explains how coverage applies on military sites in the interpretation about HVAC/DoD facilities, noting that while some military-unique activities are excluded, civilian contractor work on non-unique systems is covered (see the OSHA letter on oxygen-deficient atmospheres in HVAC at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16).

Subject: Under 1915.6, where should a shipyard keep records of training or inspections for diving if Subpart T requires them?

Keep records per the requirements in Subpart T — 1915.6 points shipyards to Subpart T of 29 CFR part 1910 for commercial diving requirements, and any recordkeeping obligations for training, medical exams, or equipment inspections will be found in those sections (1910.401–1910.441). Follow the recordkeeping locations and retention periods specified in the applicable Subpart T paragraphs.

Subject: Under 1915.6, if a shipyard wants to adopt more protective practices than Subpart T prescribes for diving, is that allowed?

Yes — employers may adopt more protective measures than the standard requires, and doing so does not conflict with 1915.6 which directs the applicable standard; OSHA’s enforcement typically allows employers to implement stricter protections so long as they do not conflict with mandatory requirements. As always, follow the specific procedures and any employer policies consistently, while ensuring compliance with the mandatory provisions in 1910.401–1910.441.

Subject: Under 1915.6, who is responsible for ensuring compliance with Subpart T when shipyard diving operations are subcontracted?

The host employer and controlling contractors must ensure diving operations comply with Subpart T — 1915.6 directs that Subpart T applies to shipyard diving, and OSHA responsibility principles require the employer who controls the worksite and contractors to coordinate compliance and ensure applicable regulations are followed. Contracting parties should document responsibilities and ensure subcontractors meet the requirements in 1910.401–1910.441.

Subject: Under 1915.6, does an employer need to consult the text of Subpart T when planning an emergency response for diving incidents?

Yes — emergency planning for diving must follow the requirements in Subpart T; 1915.6 directs shipyards to Subpart T of part 1910 for commercial diving operations, so employers must consult and implement the emergency response and rescue requirements detailed in 1910.401–1910.441.

Subject: Under 1915.6, who can I contact for questions about how Subpart T applies at my shipyard?

Contact your OSHA regional office or consult OSHA standards — since 1915.6 points you to Subpart T (1910.401–1910.441), your regional OSHA office can provide guidance on how those requirements apply to your specific operations, and OSHA issues Letters of Interpretation that address nuances (for example, see various interpretation letters at https://www.osha.gov/laws-regs/standardinterpretations/).'