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OSHA 1915SubpartI

Personal Protective Equipment

Subpart I

22 Questions & Answers
2 Interpretations

Questions & Answers

Under 1915 Subpart I, who is responsible for selecting and providing personal protective equipment (PPE) on a shipyard worksite?

The employer is responsible for selecting, providing, and ensuring the use of appropriate PPE for shipyard employees when hazards are present. Employers must assess workplace hazards, choose PPE that protects against those hazards, supply it to workers, and make sure it is used and maintained properly as required under 1915 Subpart I.

  • Assess hazards before work begins and whenever conditions change.
  • Provide PPE that fits and is appropriate for the specific hazard (impact, chemical splash, heat, etc.).
  • Ensure PPE is inspected, cleaned, repaired, or replaced as needed.

Reference: 1915 Subpart I.

Under 1915 Subpart I, must employees be trained to use PPE and what must that training cover?

Yes — employers must train employees to correctly use and care for PPE before assignment and whenever procedures or equipment change. Training must teach when PPE is necessary, what PPE is necessary, how to don/doff and adjust it, its limitations, and how to inspect and maintain it in accordance with 1915 Subpart I.

  • Training should be in a language and vocabulary workers understand.
  • Retrain when workplace hazards, PPE, or employee performance indicate the need.

Reference: 1915 Subpart I.

Under 1915 Subpart I, when is eye protection required in shipyard operations?

Eye protection is required whenever employees are exposed to hazards that could injure the eyes, such as flying particles, molten metal, chemical splashes, or intense light. Employers must provide and require appropriate eye protection for those exposures under 1915 Subpart I.

  • Use safety glasses or goggles for impact hazards or dust.
  • Use face shields plus goggles for chemical splash or high-velocity particles.
  • Use welding lenses or filter plates for protection from radiant energy.

Reference: 1915 Subpart I.

Under 1915 Subpart I, when must head protection (hard hats) be worn in shipyards?

Head protection must be worn whenever there is a risk of head injury from falling or flying objects, protruding objects, or potential head contact with fixed objects that could cause injury. Employers must provide appropriate head protection and enforce its use under 1915 Subpart I.

  • Use hard hats with the right impact and electrical protection class as the hazard requires.
  • Inspect hard hats for dents, cracks, or degradation; replace when damaged.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what types of foot protection are required for shipyard employees?

Employers must provide foot protection when employees face hazards such as falling or rolling objects, punctures, compression, or electrical hazards. The footwear must be appropriate to the hazard (steel-toe, metatarsal guards, puncture-resistant soles, electrical hazard-rated) as required by 1915 Subpart I.

  • Select safety footwear based on the specific hazards of the task and work area.
  • Ensure proper fit and maintain footwear in good condition.

Reference: 1915 Subpart I.

Under 1915 Subpart I, how should employers select gloves for hand protection in shipyard work?

Employers must select gloves based on the specific hazards (e.g., cuts, abrasions, chemicals, heat, electrical) and the glove material's protective properties. The chosen gloves must adequately protect workers from the identified hazards as required by 1915 Subpart I.

  • Match glove material (leather, cut-resistant fibers, chemical-resistant polymers, heat-resistant) to the hazard.
  • Consider dexterity, fit, and any contamination/degradation issues.
  • Inspect and replace gloves when damaged or when protection is compromised.

Reference: 1915 Subpart I.

Under 1915 Subpart I, are employers required to provide respirators when airborne hazards are present, and what other standard applies?

Yes — when workplace exposures create respiratory hazards that PPE must control, employers must provide appropriate respirators and implement a respiratory protection program consistent with 1915 Subpart I and the OSHA Respiratory Protection standard, 29 CFR 1910.134.

  • Use monitoring or hazard assessment to determine if respirators are needed.
  • Implement medical evaluations, fit testing, training, and maintenance per [29 CFR 1910.134].
  • Maintain records and ensure workers understand respirator limitations.

Reference: 1915 Subpart I and 29 CFR 1910.134.

Under 1915 Subpart I, when using wet abrasive blasting, what respirator protection may be required?

When wet or vapor-abrasive blasting creates airborne toxic dust that may exceed permissible exposure limits and the operator is not physically separated from the blast, NIOSH-approved abrasive-blasting respirators (Type CE or equivalent) are required. OSHA explains this requirement and the conditions for exemptions in its interpretation on respiratory protection for wet blasting, available at Respiratory protection for wet blasting and applies the PPE rules in 1915 Subpart I.

  • Employers must demonstrate exposures are below PELs with representative personal sampling if claiming an exemption.
  • Exemption also depends on operator separation in an exhaust-ventilated enclosure.
  • Even when exposures are low, employers must follow the Respiratory Protection standard [29 CFR 1910.134] for program elements if respirators are used.

References: Respiratory protection for wet blasting and 1915 Subpart I.

Under 1915 Subpart I, does an employer have to pay for PPE provided to employees?

Employers are responsible for providing necessary PPE to protect employees from hazards encountered on the job as required by 1915 Subpart I. Employers must supply appropriate PPE and ensure it is maintained and used properly.

  • Some limited items (varies by standard and industry practice) like everyday clothing or non-specialty safety-toe footwear may be handled differently, but PPE required to protect workers from recognized hazards must be made available.
  • Check related OSHA standards for specifics that may affect employer cost responsibility in particular situations.

Reference: 1915 Subpart I.

Under 1915 Subpart I, can employees use their own PPE on shipyard jobs?

Employees may use their own PPE only if it provides equivalent protection, is maintained in a safe condition, and the employer verifies it meets the required protection. The employer remains responsible for ensuring that any employee-owned PPE is adequate and that workers are trained in its safe use as required by 1915 Subpart I.

  • Employer should inspect and approve employee-owned PPE before use.
  • Employer must provide PPE when employee-owned equipment does not offer sufficient protection.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what are employer responsibilities for cleaning and maintaining PPE?

Employers must ensure PPE is kept clean, sanitary, and in good repair so it continues to protect employees as intended under 1915 Subpart I. Damaged or contaminated PPE must be repaired or replaced before further use.

  • Establish cleaning schedules and procedures appropriate for the equipment and contaminant.
  • Train employees to inspect PPE before each use and report problems.
  • Keep records when other standards require documented maintenance or inspections.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what PPE is recommended for workers handling corrosive chemicals in shipyards?

Workers handling corrosive chemicals must be provided and required to wear appropriate PPE such as chemical-resistant gloves, goggles or splash goggles combined with face shields, aprons, and protective footwear to prevent skin and eye contact under 1915 Subpart I.

  • Use splash goggles plus a face shield for high-volume splashes.
  • Select glove materials resistant to the specific chemical (consult manufacturer data).
  • Provide emergency wash stations and train workers on decontamination procedures.

Reference: 1915 Subpart I.

Under 1915 Subpart I, when is face protection (face shields) required in addition to eye protection?

Face protection is required whenever hazards extend beyond the eyes to the face—such as chemical splashes, molten metal, hot liquids, or high-velocity particles—so using a face shield with goggles is necessary for full-face protection per 1915 Subpart I.

  • Goggles protect the eyes; face shields protect the remainder of the face.
  • Combine goggles and face shields when both splash and impact hazards exist.

Reference: 1915 Subpart I.

Under 1915 Subpart I, are employers required to perform a hazard assessment to determine what PPE is needed?

Yes — employers must perform a hazard assessment of the workplace to identify hazards and determine what PPE is necessary to protect employees, as required under 1915 Subpart I.

  • Assess tasks, materials, and processes for physical, chemical, radiological, and biological hazards.
  • Document the assessment where other related OSHA standards require documentation.
  • Use the assessment results to select appropriate PPE and training topics.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what should employers do if PPE fails during use or an incident occurs?

If PPE fails or an incident occurs, the employer must remove affected equipment from service, investigate the failure or incident, and take corrective action to prevent recurrence while ensuring employees are protected, consistent with 1915 Subpart I.

  • Tag and quarantine failed PPE until inspected.
  • Review selection, maintenance, and training practices to identify gaps.
  • Replace or upgrade PPE if it proved inadequate for the hazard.

Reference: 1915 Subpart I.

Under 1915 Subpart I and OSHA guidance, how does the beryllium standard affect PPE and exposure controls in shipyards?

The shipyard beryllium standard requires employers to control exposures and use PPE as part of the overall protection strategy where beryllium is present; the OSHA interim enforcement guidance for the 2020 beryllium standards clarifies scope, monitoring, and controls that apply to shipyards under 1915 Subpart I and the beryllium rule at [1915.1024]. See the interim guidance at 2020 Beryllium Standards Guidance for specific enforcement and implementation details.

  • Employers must determine whether beryllium exposure exists and then implement engineering controls, work practices, and PPE where necessary.
  • The guidance describes inspection procedures and citation elements for enforcing the beryllium standards in shipyards.

Reference: 2020 Beryllium Standards Guidance and 1915 Subpart I.

Under 1915 Subpart I, what are the employer's responsibilities for PPE when workers change tasks or there is a change in workplace conditions?

When tasks or workplace conditions change, employers must reassess hazards and update PPE selection, training, and procedures to ensure continued protection under 1915 Subpart I.

  • Re-evaluate hazards before introducing new equipment, materials, or processes.
  • Provide new or additional PPE and retrain affected employees as needed.
  • Document hazard reassessments where other standards require records.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what should employers do about PPE for visitors or contractors on a shipyard site?

Employers must ensure visitors and contractors are provided with and wear appropriate PPE when exposed to shipyard hazards on the employer's premises, and must communicate site-specific hazards and PPE requirements as required by 1915 Subpart I.

  • Provide or require equivalent PPE for visitors and contractors entering hazardous areas.
  • Communicate hazards, PPE rules, and any training or supervision requirements before work begins.

Reference: 1915 Subpart I.

Under 1915 Subpart I, are employers required to document PPE hazard assessments or keep training records?

Employers must perform hazard assessments to determine necessary PPE under 1915 Subpart I; where other OSHA standards require written programs or records (for example, the Respiratory Protection standard [29 CFR 1910.134]) employers must maintain those specific records as required.

  • Keep written respiratory program records, fit-test records, and medical evaluations per [29 CFR 1910.134] when respirators are used.
  • Maintain other records as required by related OSHA standards that apply to the specific hazard.

References: 1915 Subpart I and 29 CFR 1910.134.

Under 1915 Subpart I, how should employers handle PPE for electrical hazards?

Employers must provide PPE specifically rated for electrical hazards—such as electrical-protective gloves, insulated tools, and dielectric footwear—when workers face shock or arc-flash risks, and ensure those items meet appropriate testing and maintenance requirements under 1915 Subpart I.

  • Select PPE with the correct voltage rating and testing frequency.
  • Train employees on proper use, inspection, and limits of electrical PPE.
  • Replace or remove from service any electrical PPE showing damage or contamination.

Reference: 1915 Subpart I.

Under 1915 Subpart I, what PPE is recommended for welding and cutting operations in shipyards?

For welding and cutting, employers must provide eye and face protection (welding helmets, filter lenses, and safety goggles as appropriate), hand protection (welding gloves), protective clothing to prevent burns and sparks, and respiratory protection when fume exposures are present, in accordance with 1915 Subpart I.

  • Use filter lenses rated for the welding process to protect against radiant energy.
  • Use flame-resistant clothing and proper gloves to prevent thermal burns.
  • Assess welding fume exposures and implement engineering controls; use respirators per [29 CFR 1910.134] when controls are insufficient.

References: 1915 Subpart I and 29 CFR 1910.134.

Under 1915 Subpart I, how should employers ensure compatibility when multiple PPE items are worn together?

Employers must ensure that different PPE items used together do not interfere with each other's protective functions and that the combination provides the intended protection, as required by 1915 Subpart I.

  • Test combinations (e.g., respirator with safety glasses, hard hat with face shield) to confirm fit and function.
  • Train workers how to don and adjust multiple PPE items properly.
  • Modify PPE choices if incompatibility reduces protection.

Reference: 1915 Subpart I.