OSHA AI Agent
Get instant answers to any safety question.
Request Demo
OSHA 1915.86

Lifeboat safety requirements

Subpart F

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.86(a), what does "secure the lifeboat independently from the releasing gear" require an employer to do before employees work in or on a stowed or suspended lifeboat?

You must secure the lifeboat with an independent device so it cannot fall or capsize before any employee works in or on a stowed or suspended lifeboat.

This means the employer must use a separate securing method (not the lifeboat releasing gear) to hold the boat stable and prevent a drop or roll. Practical examples include independent lashings, dedicated safety lines, chocks plus secondary restraints, blocking or other positive supports. The rule is explicit: see 1915.86(a).

Under 1915.86(a), who should determine how to secure a stowed or suspended lifeboat before employees work in or on it?

The employer must ensure a qualified person determines and implements the independent securing method before employees work in or on a stowed or suspended lifeboat.

While 1915.86(a) requires the lifeboat be secured independently, Part 1915 and OSHA guidance on shipyard competent persons make clear that the employer is responsible for assigning a person capable of recognizing hazards and specifying protections. See 1915.86(a) and OSHA's letter explaining the role and responsibilities of a competent person in shipyard employment at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

  • The competent person should evaluate the lifeboat, the work to be done, and select appropriate securing devices.
  • Document decisions and procedures so workers know what controls are required before entering or working on lifeboats.

Under 1915.86(b), may employees be inside a lifeboat while it is being hoisted or lowered during routine maintenance or training on board?

No; employees are not allowed to be in a lifeboat while it is being hoisted or lowered except when it is necessary for operational tests or drills over water or an actual emergency.

The rule plainly prohibits being in the boat during hoisting or lowering unless one of those limited exceptions applies. See 1915.86(b).

  • If you plan a drill that requires personnel in the boat during a hoist, it must be an operational test or drill conducted over water and the employer must be able to justify the necessity.
  • For routine maintenance or land-based training, personnel should not be in the boat while it is being hoisted or lowered.

Under 1915.86(b), can employees ride in a lifeboat during a hoist or lower while the exercise is conducted over land or the ship's deck (not over water)?

No; 1915.86(b) only permits employees to be in a lifeboat while it is being hoisted or lowered when the employer demonstrates it is necessary for operational tests or drills over water, or in an emergency.

Because the exception specifically mentions "over water," routinely hoisting personnel in a lifeboat over land or the deck is not allowed under that exception. See 1915.86(b).

  • If an employer believes a land-based operation is essential, they should treat it as a higher-risk circumstance and consult competent-person guidance and documented safety procedures before proceeding (see Part 1915 general provisions).

Under 1915.86(c), may employees work on the outboard side of a lifeboat that is stowed on chocks if the lifeboat is not secured by gripes or another device?

No; employees may not work on the outboard side of a lifeboat stowed on chocks unless the lifeboat is secured by gripes or another device that prevents it from swinging.

The standard requires a restraint (for example, gripes) that prevents the boat from swinging when workers are on the outboard side. See 1915.86(c).

  • Use adequate gripes, lashings, straps, chains, or blocking designed to prevent motion.
  • Confirm the securing device is properly installed and inspected by a competent person before allowing workers to access the outboard side.

Under 1915.86(c), what are acceptable "gripes or another device" to prevent a stowed lifeboat from swinging while employees work on its outboard side?

Acceptable devices include gripes (dedicated restraining lines or fittings) or any other physical restraint that reliably prevents the lifeboat from swinging while employees work on its outboard side.

The standard does not list specific hardware but requires a device that accomplishes the safety function. See 1915.86(c).

Under 1915.86(a), when exactly must the lifeboat be secured independently — before people get on it, before maintenance, or both?

The lifeboat must be secured independently from the releasing gear before any employee works in or on a stowed or suspended lifeboat.

That means securing is required both before personnel enter the boat and before work (maintenance, inspection, or other tasks) is performed on it while it is stowed or suspended. See 1915.86(a).

  • Do not allow entry or work until the independent securing device is installed and verified.
  • Verification by a competent person is a prudent step to ensure the securing method is effective for the specific situation.

Under 1915.86(b), in an actual emergency (not a drill), may employees be in a lifeboat while it is being hoisted or lowered?

Yes; 1915.86(b) allows employees to be in a lifeboat while it is being hoisted or lowered in the event of an emergency.

The standard explicitly lists emergencies as an exception to the general prohibition on occupying a lifeboat during hoisting or lowering. See 1915.86(b).

  • Even in emergencies, use all available safe practices and trained personnel to minimize risk.
  • After-action reviews and documentation of emergency use and lessons learned are recommended to improve future safety.

Under 1915.86, does the standard require employers to keep written records proving they demonstrated necessity for crew to be in a lifeboat during an over-water test or drill?

No; 1915.86(b) does not itself require employers to keep written records of the demonstration that it was necessary to have employees in a lifeboat for an over-water operational test or drill.

The standard states the condition (that employees may be in the lifeboat when the employer demonstrates necessity) but does not establish a formal recordkeeping requirement. See 1915.86(b).

Under 1915.86, does the regulation specify exact hardware, materials, or strength ratings for devices used to secure lifeboats or prevent swinging?

No; 1915.86 does not specify exact hardware, materials, or strength ratings for securing devices — it requires only that the lifeboat be secured independently or restrained from swinging as needed.

The standard sets performance requirements (prevent falling, capsizing, or swinging) but leaves the selection of specific methods and equipment to the employer and competent person. See 1915.86(a) and 1915.86(c).

Under 1915.86, may employees work beneath a suspended lifeboat?

Section 1915.86 does not explicitly address working beneath a suspended lifeboat, but it requires that a suspended lifeboat be secured independently from the releasing gear to prevent falling or capsizing, which implies the employer must prevent hazards to workers below.

See 1915.86(a). Employers retain the general duty to provide a workplace free from recognized hazards, so working beneath a suspended lifeboat would be allowed only if the lifeboat is secured and the employer has assessed and controlled the risk.

  • Best practice: prohibit work under a suspended lifeboat unless engineering controls and positive restraints are in place and a competent person has authorized the work.
  • Use barriers, exclusion zones, and secondary supports; document the hazard assessment and controls.

Under 1915.86, who is responsible for deciding that it is "necessary" to have personnel in a lifeboat during an over-water drill or operational test?

The employer is responsible for demonstrating that it is necessary to have personnel in a lifeboat during an over-water drill or operational test.

Section 1915.86(b) places the burden on the employer to show the exception applies for operational tests or drills over water. See 1915.86(b).

  • The demonstration should be based on a documented safety rationale and risk assessment prepared or reviewed by a competent person. See OSHA guidance on competent persons for shipyards at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.
  • If the employer cannot show necessity, personnel should not be allowed in the lifeboat during hoisting/lowering.

Under 1915.86, what safe steps should an employer follow when preparing to let employees work on a stowed lifeboat's outboard side?

Before employees work on the outboard side of a stowed lifeboat, the employer must secure the boat so it cannot swing and ensure the lifeboat is independently secured if workers will be in or on it.

These actions implement the requirements of 1915.86(c) and 1915.86(a). Practical steps include:

Under 1915.86, does the lifeboat standard require specific worker training for lifeboat work or drills?

Section 1915.86 does not itself specify required training content or frequency for workers involved with lifeboats; it focuses on securing and when personnel may be in lifeboats during hoisting/lowering.

See 1915.86. However, because the standard requires safe securing and limits on when personnel may be aboard during hoisting, employers should provide training so employees and competent persons know procedures, hazards, and controls for lifeboat work and drills.