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Back to Part 1915
OSHA 1915SubpartC

Surface preparation and preservation

Subpart C

15 Questions & Answers
Official OSHA text

Questions & Answers

Under 1915SubpartC, what is the scope of Surface Preparation and Preservation?

The scope of Surface Preparation and Preservation covers measures and practices for preparing and protecting ship surfaces during shipyard employment, including activities like cleaning, coating, and corrosion prevention. See the official Surface Preparation and Preservation requirements in 1915SubpartC for the full regulatory scope and specifics.

Under 1915SubpartC, who must comply with the Surface Preparation and Preservation rules?

Employers and personnel engaged in shipyard employment where surface preparation and preservation tasks occur must comply with the Subpart C rules. The obligations and affected parties are described in the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, what types of work activities are generally addressed by this subpart?

Subpart C generally addresses surface preparation and preservation activities such as cleaning, paint removal, coating application, rust and scale removal, and other measures to protect and prepare ship surfaces. For authoritative listing and detail, consult the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, what basic employer responsibilities are implied for surface preparation operations?

Employers are responsible for implementing safe procedures, training workers, and controlling hazards associated with surface preparation and preservation operations. The overarching obligations and expectations are outlined in the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, how should employers find specific procedures or rules that apply to a particular surface preparation task?

Employers should review the specific paragraphs and tables within Subpart C to match the rules to the particular surface preparation task being performed. Start by consulting the Surface Preparation and Preservation requirements in 1915SubpartC and follow any referenced sections for task-specific requirements.

Under 1915SubpartC, what role does hazard assessment play for surface preparation and preservation work?

A hazard assessment identifies risks from chemicals, dust, fumes, noise, and physical hazards so appropriate controls can be selected for surface preparation and preservation tasks. The need to evaluate and control hazards associated with shipyard surface work is covered under the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, where should employers look for overlapping requirements with other shipyard standards?

Employers should cross-check Subpart C with other applicable shipyard standards in Part 1915 to ensure they meet all overlapping requirements for things like respiratory protection, fall protection, or confined spaces. The full set of shipyard standards including Subpart C is available at 1915 Subpart C – Surface Preparation and Preservation.

Under 1915SubpartC, are training and instruction requirements indicated for workers performing surface preservation tasks?

Yes—Subpart C expects employers to provide appropriate training and instruction so workers can perform surface preparation and preservation tasks safely. See the specific training provisions and related requirements in the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, how should employers handle materials and waste generated by surface preparation work?

Employers should manage materials and waste from surface preparation and preservation work in a way that controls exposures and environmental hazards, following the procedures and limitations in Subpart C and any referenced environmental or hazardous-materials requirements. Review relevant guidance in the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, what is the best first step if a supervisor is unsure whether a particular surface task falls under Subpart C requirements?

The best first step is to review the text of Subpart C and compare the task details to the subpart’s defined scope and operation descriptions. Consult the official Surface Preparation and Preservation requirements in 1915SubpartC for authoritative guidance.

Under 1915SubpartC, how can employers demonstrate compliance with the surface preparation standard during an inspection?

Employers can demonstrate compliance by producing written procedures, training records, hazard assessments, and any monitoring or maintenance records required for surface preparation operations as specified in Subpart C. Inspectors will refer to the provisions in the Surface Preparation and Preservation requirements in 1915SubpartC when evaluating compliance.

Under 1915SubpartC, where can I find official cross-references and related resources for shipyard surface preparation rules?

Official cross-references and related regulatory resources are listed with Subpart C on OSHA’s website, which links to other applicable shipyard standards and external guidance. See the Surface Preparation and Preservation requirements in 1915SubpartC for the complete list of cross-references and resources.

Under 1915SubpartC, what documentation should be kept on-site for surface preparation and preservation activities?

Employers should keep on-site documentation such as written procedures, hazard assessments, worker training records, and any monitoring or maintenance logs that Subpart C requires or references. Maintain and present these documents in accordance with the Surface Preparation and Preservation requirements in 1915SubpartC.

Under 1915SubpartC, who can I contact for clarification about how the standard applies to a specific shipyard activity?

For official clarification, contact OSHA regional offices or consult the OSHA website resources linked from the Subpart C page. The primary reference for official requirements is the Surface Preparation and Preservation requirements in 1915SubpartC.