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OSHA 1917.24

Carbon monoxide exposure limits

1917 Subpart B

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.24(a), what are the permissible carbon monoxide exposure limits in enclosed spaces at marine terminals?

The carbon monoxide concentration must be kept at or below 50 parts per million (ppm) as an eight‑hour average, and employees must be removed if the concentration exceeds a ceiling of 100 ppm. See 1917.24(a) for the exact limits.

Under 1917.24(a), what does "eight hour average area level" mean for carbon monoxide testing?

The eight‑hour average area level means the carbon monoxide concentration averaged over an eight‑hour work period in the area where employees work, and that average must not exceed 50 ppm. Employers should use measurements that represent the atmosphere in the room, building, vehicle, railcar, or enclosed space over that eight‑hour period. See 1917.24(a).

Under 1917.24(a), what must an employer do if the carbon monoxide concentration in an enclosed space exceeds 100 ppm?

You must remove employees from the enclosed space if the carbon monoxide concentration exceeds the 100 ppm ceiling. The standard requires employee removal at concentrations above the ceiling to protect worker health. See 1917.24(a).

Under 1917.24(b), when are carbon monoxide tests required in marine terminal enclosed spaces?

Tests must be made whenever necessary to ensure that employee exposures do not exceed the limits in paragraph (a). That means testing whenever there is reason to suspect CO could be high — for example after equipment changes, complaint or symptoms, visible exhaust or smoke, start‑up of engines in an enclosed space, or other changes in conditions. See 1917.24(b).

Under 1917.24(c), who may perform carbon monoxide tests and what instruments are acceptable?

Designated persons must perform the tests using either NIOSH‑certified gas detector tube units (under 30 CFR part 11) or other measuring instruments whose accuracy is as great or greater. Employers should ensure the designated testers are trained to use the chosen instruments and understand their accuracy limits. See 1917.24(c).

Under 1917.24(c), can an employer use personal CO monitors or must tests be area measurements?

The standard specifies area testing by designated persons using certified or equivalently accurate instruments, but it does not prohibit using personal monitors so long as the measuring method provides accuracy at least equal to the specified instruments and the tests are performed by designated persons. Employers should ensure whichever method they use reliably represents employee exposure and meets the accuracy requirement in 1917.24(c).

Under 1917.24(d), how long must carbon monoxide test records be kept and what must they include?

A record of the date, time, location, and results of carbon monoxide tests must be available for at least 30 days. Make sure records include those four elements so you can show compliance and track trends. See 1917.24(d).

Under 1917.24(d), what specific details must be recorded after a carbon monoxide test?

You must record the date, time, location, and the test results for each carbon monoxide measurement and keep those records available for at least 30 days. Those are the explicit record elements required by the rule. See 1917.24(d).

Under 1917.24(a) and (b), if your eight‑hour average CO reading is above 50 ppm but below 100 ppm, do you have to remove employees immediately?

You do not have to remove employees solely because an eight‑hour average exceeds 50 ppm, but you must take action to reduce and control exposures because the standard requires maintaining the eight‑hour average at not more than 50 ppm. Immediate removal is required only if the concentration exceeds the 100 ppm ceiling; however, if eight‑hour averages exceed 50 ppm, you must investigate, implement controls, and retest to comply with 1917.24(a) and 1917.24(b).

Under 1917.24, can the employer rely on measurements taken outside an enclosed space to determine compliance for that enclosed space?

No. The standard requires maintaining the carbon monoxide content of the atmosphere in the specific room, building, vehicle, railcar, or enclosed space at or below the limits, so measurements should be taken in the actual enclosed space to determine compliance. Tests done elsewhere may not represent the atmosphere inside the space. See 1917.24(a) and 1917.24(b).

Under 1917.24(c), are continuous electronic CO monitors acceptable to demonstrate compliance with the eight‑hour average requirement?

Yes — continuous electronic monitors are acceptable if they have accuracy equal to or better than the NIOSH‑certified gas detector tube units referenced in the standard. The rule allows "other measuring instruments whose accuracy is as great or greater." Ensure the instrument is operated by designated persons and the data are documented. See 1917.24(c).

Under 1917.24, who should be the "designated persons" performing CO tests and what training should they have?

The employer must designate qualified persons to perform CO tests; those individuals should be trained in use of the chosen instruments, understand instrument accuracy and limitations, and know how to record and interpret results to protect employees. The requirement that tests be made by "designated persons" is in 1917.24(c).

Under 1917.24(b), how often should carbon monoxide testing be repeated?

Testing frequency is "as necessary" to ensure employee exposures do not exceed the limits — that is, repeat testing after any change that could affect CO levels (new equipment, altered ventilation, employee complaints, unusual readings, or after corrective actions) and periodically as part of a monitoring plan. See 1917.24(b) and 1917.24(d) for recordkeeping of tests.

Under 1917.24, if a test instrument is not NIOSH‑certified under 30 CFR part 11, when is it still acceptable to use it?

An instrument that is not NIOSH‑certified may still be acceptable if its accuracy is as great as or greater than the NIOSH‑certified gas detector tube units referenced in the rule. Employers must ensure designated persons properly operate and maintain the instrument and can demonstrate its accuracy. See 1917.24(c).

Under 1917.24, are employers permitted to use respirators instead of removing employees when CO exceeds the ceiling of 100 ppm?

No. The standard explicitly requires that employees be removed from the enclosed space if the concentration exceeds the 100 ppm ceiling. Relying solely on respirators does not satisfy the removal requirement in 1917.24(a). Employers should instead reduce the atmospheric concentration and follow applicable testing and recordkeeping requirements in 1917.24(b)–(d).

Under 1917.24, what actions should be taken if periodic testing shows a trend toward rising CO levels but readings are still below 100 ppm?

You must investigate and implement corrective measures (improve ventilation, change equipment or work practices, limit time in the space) to bring the eight‑hour average back to 50 ppm or below, and continue testing to verify control effectiveness. The standard requires maintaining the eight‑hour average at not more than 50 ppm and testing as necessary under 1917.24(a)–(b).

Regarding applicability: does Part 1917, including 1917.24, apply to "designated waterfront facilities"?

No — certain facilities designated as "designated waterfront facilities" are not covered by Part 1917. OSHA's letter of interpretation explains that Part 1917's specific requirements do not apply to such facilities, so you must confirm whether your operation falls within Part 1917's scope before relying on 1917.24. See the OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31 for details.

Under 1917.24, what information should be available to employees or their representatives about CO testing?

Employers must keep a record of the date, time, location, and results of CO tests and make that information available for at least 30 days; employees or their representatives should be able to review those records on request. See 1917.24(d).

Under 1917.24(c), are disposable gas detector tube units acceptable for spot checks of CO?

Yes, provided the gas detector tube units are NIOSH‑certified under 30 CFR part 11 or have accuracy equal to or better than the certified tubes; they must be used by designated persons and handled per manufacturer and certification guidance. See 1917.24(c).

Under 1917.24, do employers need to document corrective actions taken when CO test results exceed the 50 ppm eight‑hour average?

While 1917.24(d) requires recording date, time, location, and results of tests for at least 30 days, employers should also document corrective actions and follow‑up testing to demonstrate they addressed exceedances and brought atmospheres back into compliance with 1917.24(a) and 1917.24(b). Recording corrective actions is a practical compliance step even if not listed word‑for‑word in 1917.24(d).