Vessel radar and communication safety

Yes. Employers must service each vessel's radar and communication systems in accordance with Control of Hazardous Energy, 1915.89.

• Follow the procedures in 1915.89 to isolate energy sources, lock or tag out controls, verify de-energization, and protect workers before starting work on radar or communications equipment.

The system must be secured so it cannot energize or emit radiation before any employee begins work on or in the vicinity of the system, on or in the vicinity of a system with a dummy load, or when work is to be done aloft (such as on a mast or king post).

• Those specific requirements are listed in 1915.85(b) and its subsections 1915.85(b)(1), 1915.85(b)(2), and 1915.85(b)(3).

Yes. 1915.85(b)(2) specifically requires that a vessel's radar or communication system be secured so it cannot energize or emit radiation even when the system is equipped with a dummy load.

• A dummy load does not remove the employer's responsibility to make the system incapable of energizing or emitting radiation before employees start work on or near the system.

Yes. 1915.85(b)(3) requires that radar and communication systems be secured so they cannot energize or emit radiation before any employee works aloft, such as on a mast or king post.

• Before climbing or performing maintenance aloft, employers must isolate the system and render it incapable of energizing or emitting radiation per 1915.85(b)(3).

No. 1915.85(c)(1) requires that when a radar or communication system is being operated, serviced, repaired, or tested, there must be no other work in progress aloft.

• That means you must clear the mast, king post, and other aloft work areas of unrelated workers before operating or testing the system.

An employee must not be closer than the manufacturer's specified safe minimum distance for that type, model, and power of equipment. See and follow the manufacturer's safe-distance guidance.

• If the manufacturer provides a safe minimum distance, the employer must ensure no employee is closer than that distance during operation, service, repair, or testing per 1915.85(c)(2).

No. 1915.85(d) requires employers to ensure that no employee enters an area that the manufacturer designates as hazardous while the system is capable of emitting radiation.

• Employers must post or otherwise control access to manufacturer-designated hazardous areas and prevent entry whenever the equipment can emit radiation.

The requirements do not apply when the radar or communication system is incapable of emitting radiation at levels that could injure workers in the vicinity or incapable of energizing in a way that could injure workers working on or near the system.

• If the equipment cannot produce injurious radiation or cannot energize into an injurious state, the employer need not apply the 1915.85 measures; otherwise, full precautions apply.

Make the system incapable of energizing by following lockout/tagout procedures in 1915.89: isolate energy sources, apply locks or tags, verify de-energization, and control stored or residual energy.

• Steps include: identify energy sources, shut down equipment, isolate and lock/tag power sources, bleed or block stored energy (capacitors, batteries), verify zero energy, and document the actions per 1915.89.

If the manufacturer's safe minimum distance is not available, the employer must ensure employees are protected by using other reliable means—such as consulting a qualified competent person, manufacturer technical support, RF-safety calculations, or engineering controls—to establish and enforce a safe exclusion distance.

• The employer's competent person can evaluate hazards and specify necessary protections; see OSHA's guidance on competent persons who are capable of specifying necessary protection in shipyard operations. See the OSHA Letter of Interpretation on competent person responsibilities at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

Possibly — if the handheld radio cannot emit radiation at levels that could injure workers or cannot energize in a way that could injure workers, then 1915.85(e) allows the exemption.

• The employer should verify that the device's maximum output and use conditions cannot produce injurious radiation and document that determination. If there is any potential for injurious exposure, apply the safeguards in 1915.85.

Yes. When a vessel's radar or communication system is operated, serviced, repaired, or tested, 1915.85(c)(1) requires that there be no other work in progress aloft.

• Employers must clear aloft areas of unrelated personnel and control access for the duration of testing or operation to prevent exposure.

Yes. 1915.85(d) requires employers to ensure that no employee enters an area that manufacturers designate as hazardous while the system is capable of emitting radiation, which implies controlling access — for example by posting signs, barriers, or other controls.

• Use visible signs, physical barriers, and trained attendants to keep personnel out of manufacturer-designated hazardous zones during operation or when the system can emit radiation.

A qualified competent person may determine necessary protections when manufacturer guidance is absent; the employer's competent person must be able to recognize hazards and specify necessary protection as described in OSHA's competent person guidance. See OSHA's Letter of Interpretation on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

• Employers are responsible for ensuring the competent person has the knowledge and authority to set protective measures for radar and communication hazards under 1915.85.

No. The employer (including vessel owners/operators) must ensure the vessel's radar or communication system is secured so it cannot energize or emit radiation before any employee — including contractor personnel — begins work, per 1915.85(b).

• The vessel employer should coordinate lockout/tagout procedures in 1915.89 with contractors and verify de-energization prior to contractor access.

If the transmitter must be energized for testing, employers must ensure no other work aloft is in progress and keep all employees outside the manufacturer's specified safe minimum distance; where the transmitter creates manufacturer-designated hazardous areas, prevent entry per 1915.85(c) and 1915.85(d).

• Establish exclusion zones, use barriers and signage, have attendants to control access, and document that no workers are within the manufacturer's safe distance during energized testing.

"Radiation" in the context of 1915.85 includes the radiofrequency (RF) energy emitted by radar and communication transmitters, not just visible light; the standard addresses any radiation that could injure workers in the vicinity.

• Employers must therefore consider RF exposure hazards and follow the protective measures in 1915.85 (secure equipment, observe safe distances, and control hazardous areas).

Signs and warnings are useful but must effectively prevent entry; 1915.85(d) requires employers to ensure no employee enters an area designated hazardous by the manufacturer while the system can emit radiation.

• Use a combination of controls (signs, physical barriers, lockable gates, attendants, and procedures) to ensure people do not enter a manufacturer-designated hazardous zone during operation.

Before allowing work aloft on an antenna that was recently energized, the employer must make the system incapable of energizing or emitting radiation (for example, via lockout/tagout in 1915.89), verify de-energization, and ensure no other work aloft is in progress per 1915.85(b)(3) and 1915.85(c)(1).

• Also confirm that employees will not be within any manufacturer-specified safe minimum distance if the unit must remain energized for any reason.

The employer is responsible for ensuring that no employee is closer to the system's antenna or transmitter than the manufacturer's specified safe minimum distance, as required by 1915.85(c)(2).

• Employers should train workers, post exclusion zones, and assign a competent person to verify compliance with manufacturer guidance.

The employer must verify that the system is de-energized and incapable of energizing or emitting radiation before work begins, following the verification steps in 1915.89.

• Verification steps include attempting a normal start to confirm the unit will not energize, testing RF output (if appropriate), and ensuring stored energy sources (batteries, capacitors) are controlled. Document the verification as part of the lockout/tagout procedure.

Yes — but with caution: 1915.85(e) allows the requirements to not apply when the system is incapable of emitting injurious radiation or incapable of energizing in a way that could injure workers, but the employer should have reliable evidence (manufacturer data, independent testing, or competent person evaluation) to support that determination.

• Keep documentation (manufacturer statements, test results, or competent person findings) showing the system cannot produce injurious radiation if you choose not to apply the full 1915.85 protections.

Employers must ensure that no one is aloft and that all employees are outside the manufacturer's specified safe minimum distance before temporarily energizing the system for emergency repairs, and they should use the minimum necessary power and controls to limit exposure per 1915.85(c).

• If temporary energizing is necessary, plan the operation: clear aloft, establish exclusion zones, use attendants, document the reason and duration, and re-secure the system immediately after testing or repair.

Yes. While 1915.85 does not list specific training language, employers must ensure employees understand and comply with its requirements — including securing equipment, exclusion zones, and manufacturer-specified safe distances — and the employer's competent person should provide or oversee that training. See OSHA guidance on competent persons who specify necessary protections at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

• Training topics should include lockout/tagout procedures (1915.89), recognition of hazardous areas, manufacturer safe-distance guidance (1915.85(c)(2)), and emergency procedures.

Manufacturers' safe minimum distances must be observed per 1915.85(c)(2); however, employers may implement alternative engineering or administrative controls if they can demonstrate an equal or greater level of protection (for example via qualified RF-safety evaluation by a competent person).

• If an alternative is used, document the evaluation and the competent person’s determination that the alternative control provides equivalent protection. See OSHA competent person guidance at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.