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OSHA 1918.110

COVID-19 requirements for longshoring

Subpart K

13 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.110, which COVID-19 standard applies to longshoring work?

The COVID-19 requirements for longshoring are identical to those in 29 CFR 1910.501, so longshoring employers must follow the provisions in that rule. See 1918.110 and the corresponding requirements in 1910.501.

Under 1918.110, do the COVID-19 rules for longshoring apply to both shipboard and shore-based longshoring activities?

Yes — the section adopts the COVID-19 requirements in 1910.501 for longshoring, so any longshoring activity covered by 29 CFR part 1918 must comply with the same 1910.501 provisions that apply to that work. See 1918.110.

Under 1918.110, where can a longshoring employer find the full text of the COVID-19 requirements they must follow?

A longshoring employer must read and follow the full text of 29 CFR 1910.501, because 1918.110 makes the requirements identical to that rule. For the short pointer to the longshoring adoption, see 1918.110.

Under 1918.110, must longshoring employers implement the specific measures (training, masking, testing, etc.) listed in 1910.501?

Yes — because 1918.110 makes the longshoring requirements identical to 1910.501, longshoring employers must implement the specific controls and programs required by 1910.501 (for example, any training, engineering/administrative controls, or other items that the 1910.501 text requires).

Under 1918.110, must longshoring employers keep the same COVID-19 records that appear in other OSHA COVID rules?

Longshoring employers must follow the recordkeeping and documentation requirements that are part of 1910.501 if that rule requires them, because 1918.110 makes the longshoring requirements identical to 1910.501. Note, however, that a separate OSHA memorandum temporarily stayed enforcement of the COVID-19 recordkeeping and reporting requirements in 29 CFR 1910.502 (the Healthcare ETS); that enforcement stay specifically addresses 29 CFR 1910.502 and does not by its terms change the text of 1910.501 or the adoption in 1918.110. See the enforcement stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 for details specific to 1910.502.

Under 1918.110, does the OSHA COVID-19 rule for longshoring differ in any way from 1910.501?

No — by operation of 1918.110, the COVID-19 requirements for longshoring are identical to those in 1910.501; there are no separate or different longshoring-specific COVID provisions in 1918.110 itself.

Under 1918.110, if an employer operates in a State with an OSHA-approved State Plan, which COVID-19 rules apply to longshoring?

Employers in OSHA State Plan states must follow the State Plan's requirements where those are in effect; for federal longshoring requirements, 1918.110 points to the federal 1910.501 text, but States may adopt equivalent or more stringent rules. See the discussion about State Plans in OSHA guidance such as the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 for how State Plan coverage can affect federal guidance.

Under 1918.110, where should a longshoring employer look for practical steps to respond to an employee COVID-19 exposure or case?

Follow the response and control steps contained in 1910.501, because 1918.110 makes those requirements applicable to longshoring work. The specific actions (isolation, contact identification, testing, workplace cleaning, etc.) are described in the 1910.501 text.

Under 1918.110, do longshoring employers have to provide employee training on COVID-19 requirements?

Yes — if 1910.501 requires training, those training obligations apply to longshoring because 1918.110 makes the longshoring requirements identical to 1910.501. Consult the training and communication sections of 1910.501 for the specific topics and timing.

Under 1918.110, do longshoring employers have to follow the same PPE and engineering control measures found in 1910.501?

Yes — the controls (including PPE, engineering, and administrative measures) required in 1910.501 apply to longshoring under 1918.110. Employers should review 1910.501 to determine which specific control measures are required for their operations.

Under 1918.110, where can a longshoring employer find official OSHA enforcement or interpretation guidance related to COVID-19?

For federal interpretation memos and enforcement guidance that might affect COVID-19 rules, consult OSHA's Letters of Interpretation and memoranda; for example, the enforcement-stay memorandum addressing COVID-19 recordkeeping under 29 CFR 1910.502 is at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05. For the longshoring rule itself, rely on 1918.110 and the text of 1910.501.

Under 1918.110, who enforces the COVID-19 requirements at longshoring workplaces?

Federal OSHA enforces the standards in 29 CFR part 1918, and because 1918.110 adopts the text of 1910.501 for longshoring, inspectors will evaluate longshoring operations against those requirements. In State Plan states, the State Plan agency enforces its OSHA-approved rules; see related guidance in OSHA interpretation letters such as https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 for how State Plans are applied.

Under 1918.110, if an employer believes a provision in 1910.501 is unclear for longshoring, how should they proceed?

If a provision is unclear, the employer should follow the plain language of 1910.501 because 1918.110 adopts it verbatim for longshoring, and consider requesting an official clarification from OSHA or reviewing OSHA Letters of Interpretation for similar topics. OSHA publishes interpretation letters and memoranda (for example, the recordkeeping enforcement-stay memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05) that may clarify enforcement positions.