Guarding deck openings and edges

No — 1915.73(a) applies only to ship repairing and shipbuilding operations and explicitly does not apply to shipbreaking. See 1915.73(a).

You must cover or guard flush manholes and similar small openings to a height of at least 30 inches when employees are working in the vicinity, unless using such guards is impracticable because of the work in progress. See the requirement in 1915.73(b).

You must guard the edge of open hatches and other large openings in the working area to a height of 36 to 42 inches when the opening is not protected by coamings at least 24 inches high, unless guards are impracticable because of the work in progress. See 1915.73(c).

Guardrails are required when employees are exposed to unguarded edges more than 5 feet above a solid surface, unless the nature of the work or physical conditions prohibit using or installing guardrails. The rails must meet the requirements of 1915.71(j)(1) and 1915.71(j)(2). See 1915.73(d).

The detailed construction and strength requirements for guardrails referenced in 1915.73(d) are set out in 1915.71(j) and its subparagraphs 1915.71(j)(1) and 1915.71(j)(2). Consult those paragraphs for the required components and performance expectations of guardrail systems.

Employees working near unguarded edges of vessel decks afloat must be protected by personal flotation devices that meet the requirements in 1915.158(a). See 1915.73(e).

Yes — PFDs required by shipyard standards must be provided in accordance with OSHA's employer-payment requirements for PPE that apply to Part 1915. OSHA’s PPE payment guidance explains that, where a standard requires PPE, the employer generally must provide it without cost to employees. See 1915.73(e) and OSHA’s interpretation on employer PPE payment obligations at the letter dated November 13, 2014 (see https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

You must guard sections of bilges from which floor plates or gratings have been removed with guardrails, except where guardrails would interfere with work in progress; if the open sections are in a walkway, at least two 10-inch planks placed side by side (or an equivalent) must be laid across the opening to provide a safe walking surface. See 1915.73(f).

You must barricade the openings with adequate guardrails when sections or ladders are removed from gratings, walkways, or catwalks. See 1915.73(g) and the guardrail requirements in 1915.71(j).

The employer (through a competent person) must determine when guard use is impracticable and must specify appropriate alternative protections. OSHA recognizes that a competent person can evaluate hazards and specify necessary protection; see 1915.73(b)–(d) and OSHA’s Letter of Interpretation on competent person responsibilities (April 18, 2016) at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18. Employers should document the rationale and the alternative controls used.

"Working in the vicinity" means employees are performing tasks close enough to a flush manhole or comparable small opening that the opening presents a fall or trip hazard; in that situation the opening must be suitably covered or guarded to at least 30 inches unless guards are impracticable due to the work in progress. See 1915.73(b).

A suitable cover or guard must prevent employees from falling through the opening and withstand the loads likely to be imposed during use; when simple covers or rails cannot be used, employers must provide an equivalent level of protection. See the guard requirement at 1915.73(b) and consider the guardrail construction expectations in 1915.71(j).

No — if the hatch is protected by a coaming at least 24 inches high, the specific guardrail height requirement in 1915.73(c) for open hatches does not apply; the coaming itself provides the specified protection. However, you must still ensure the coaming and the surrounding area are safe for the work being performed and meet any other applicable requirements such as 1915.71(j).

Yes — when open bilge sections are in a walkway, you must lay at least two 10-inch planks placed side by side, or an equivalent, across the opening to provide a safe walking surface. See 1915.73(f). If using an alternative claimed to be "equivalent," document and justify that it provides equal or better protection, using a competent person assessment (see OSHA competent person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

No — when sections or ladders have been removed from gratings, walkways, or catwalks, the standard requires barricading the opening with adequate guardrails rather than relying only on warning signs. See 1915.73(g) and the guardrail requirements in 1915.71(j).

If guardrail installation is physically impossible, you must provide an equally effective means of protection such as fall restraints, safety nets, or, when working over water, personal flotation devices per 1915.158(a); the determination and specification of alternatives should be made by a competent person and documented. See 1915.73(d) and OSHA’s competent person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

The employer must ensure a competent person evaluates the hazard, approves any temporary removal of guardrails, and specifies necessary protective measures before work begins. OSHA recognizes the competent person’s role in specifying necessary protection under Part 1915; see 1915.73 and OSHA’s competent person letter at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18. Document the assessment and controls.

No — leaving bilge openings unguarded solely because workers are trained or alert is not acceptable unless guardrails would actually interfere with the work; in that case you must use alternative protections (e.g., temporary planking as specified in 1915.73(f)) and document the competent person’s determination. See 1915.73(f) and OSHA competent person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

The employer is responsible for providing and maintaining required guards, covers, guardrails, and personal flotation devices and for ensuring they meet the applicable requirements in Part 1915. See 1915.73 and the PFD requirements in 1915.158(a). Employers should also follow competent person assessments as described in OSHA guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.