OSHA AI Agent
Get instant answers to any safety question.
Request Demo
OSHA 1917.31

COVID-19 requirements for terminals

Subpart B

17 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.31, are marine terminal employers required to follow the COVID-19 workplace requirements in 29 CFR 1910.501?

Yes. Under 1917.31 the COVID-19 requirements that apply to marine terminal work are identical to those in 29 CFR 1910.501, so employers performing covered marine terminal operations must comply with the same obligations set out in 1910.501.

Under 1917.31, where can I read the exact COVID-19 requirements that apply to marine terminals?

You must read the text of the COVID-19 workplace standard at 29 CFR 1910.501 because 1917.31 states that the requirements for marine terminals are identical to those in 1910.501.

Under 1917.31, do the COVID-19 rules apply to contractors and subcontractors working on marine terminal operations?

Yes. If the contractor or subcontractor is performing work that qualifies as marine terminal operations covered by 1917.31, they must follow the same COVID-19 requirements set forth in 29 CFR 1910.501.

Under 1917.31, if OSHA updates 29 CFR 1910.501, do the changes automatically apply to marine terminals?

Yes. Because 1917.31 makes the marine terminal requirements identical to 29 CFR 1910.501, any final changes to 1910.501 will also apply to marine terminal work covered by 1917.31 unless OSHA specifically amends 1917.31 itself.

Under 1917.31, which OSHA standard should I consult for COVID-19 prevention procedures at a dockside terminal?

Consult 29 CFR 1910.501 for COVID-19 prevention procedures that apply to dockside and other marine terminal activities because 1917.31 makes those requirements identical to 1910.501.

Under 1917.31, do marine terminals in states with their own OSHA-approved plan follow federal 1910.501 or the state rule?

Marine terminals in a State with an OSHA-approved State plan must follow that State's COVID-19 requirements if the State's rules are at least as effective as federal requirements and may be more stringent; otherwise, the federal standard at 29 CFR 1910.501 applies via 1917.31.

Under 1917.31, does the COVID-19 workplace standard for marine terminals require the same written programs or written policies as 1910.501?

Yes. Because 1917.31 makes the marine terminal requirements identical to 29 CFR 1910.501, any written programs, policies, or procedures required by 1910.501 must be implemented for marine terminal work covered by 1917.31.

Under 1917.31, which standard governs enforcement and compliance inspections for COVID-19 at marine terminals?

OSHA enforces the COVID-19 requirements for marine terminals using the same criteria and inspection approach it applies under 29 CFR 1910.501, because 1917.31 makes the requirements identical; State-plan agencies enforce their own comparable or more stringent requirements where applicable.

Under 1917.31, are marine terminal employers required to maintain COVID-19 logs and report COVID-19 fatalities under 29 CFR 1910.502?

Not directly under 1917.31; marine terminals must follow 29 CFR 1910.501 for COVID-19 workplace requirements, while recordkeeping and reporting historically came from other COVID-related ETS provisions such as 29 CFR 1910.502 and separate guidance. Importantly, OSHA has announced it will not enforce the COVID-19 recordkeeping and reporting requirements under the Healthcare ETS at 29 CFR 1910.502 effective immediately until further notice, and OSHA continues to enforce general recordkeeping requirements under 29 CFR part 1904. See the OSHA memorandum titled "Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502" at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 for details.

Under 1917.31, if a marine terminal wants to develop site-specific COVID-19 controls, can they tailor measures differently than those in 1910.501?

Yes, but only to the extent permitted by the standard. 1917.31 requires marine terminals to meet the same requirements as 29 CFR 1910.501, and 1910.501 allows employers to implement site-specific policies or alternative control measures if those meet or exceed the performance criteria and protections required by the standard.

Under 1917.31, do the COVID-19 requirements apply to all areas of a marine terminal, such as offices, cranes, and vessel gangways?

If the activity is part of marine terminal operations covered by 1917.31, the COVID-19 workplace requirements in 29 CFR 1910.501 apply to those areas; employers should apply the standard's provisions to the specific workplace settings and job tasks performed at the terminal.

Under 1917.31, does an employer's obligation to train workers about COVID-19 protections at marine terminals come from 1910.501?

Yes. Because 1917.31 ties marine terminal COVID-19 requirements to 29 CFR 1910.501, any training, communication, or employee notification requirements included in 1910.501 must be followed for covered marine terminal workers.

Under 1917.31, who should a marine terminal employer contact for clarification about how the COVID-19 rules apply on their site?

Employers should consult the text of 29 CFR 1910.501 (which 1917.31 adopts) and can contact their regional OSHA office or the State-plan agency for interpretation and enforcement guidance; State-plan agencies may have additional contact points if the State administers its own program under federal law.

Under 1917.31, if a marine terminal is also a healthcare facility or provides healthcare services, do different COVID-19 rules apply?

Marine terminals follow 29 CFR 1910.501 via 1917.31; separate OSHA Healthcare ETS provisions were codified at 29 CFR 1910.502 but OSHA later withdrew many non-recordkeeping parts of the Healthcare ETS and has announced a temporary enforcement stay of the MSM recordkeeping/reporting requirements at 29 CFR 1910.502. Employers providing healthcare services should carefully compare which specific standard applies to their operations and may need to follow additional public health or agency guidance.

Under 1917.31, can marine terminal employers rely on OSHA letters of interpretation for practical guidance on COVID-19 compliance?

Yes. OSHA letters of interpretation and memoranda (for example the memorandum on enforcement of COVID-19 recordkeeping at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05) provide clarifying guidance about how OSHA interprets and enforces its standards; however, the primary obligations for marine terminals come from 1917.31 and the underlying standard it adopts, 29 CFR 1910.501.

Under 1917.31, if an employer has already implemented a COVID-19 plan different from 1910.501, is that automatically acceptable for marine terminals?

Not automatically. 1917.31 requires marine terminals to meet the same requirements as 29 CFR 1910.501; an alternative plan is acceptable only if it provides protections that meet or exceed the performance and specific requirements of 1910.501.

Under 1917.31, how should marine terminal employers treat updates or guidance that OSHA issues after the standard was adopted?

Marine terminal employers should follow the current requirements of 29 CFR 1910.501 as implemented and interpreted by OSHA; 1917.31 makes the marine terminal rules identical to 1910.501, so substantive updates, enforcement guidance, and official interpretation memos (for example the enforcement stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05) should be monitored and applied as appropriate.