Shipbuilding and ship repairing

Yes — 1926.30(a) states that shipbuilding, ship repairing, alterations, and maintenance performed on ships under Government contract (except naval ship construction) are work subject to the OSH Act.

• This means OSHA standards and enforcement apply to those government-contracted shipbuilding and repair activities unless another law specifically preempts OSHA authority for that work.

(Cited: 1926.30(a).)

No — 1926.30(a) explicitly excludes naval ship construction from the work covered by this section.

• If you are working on naval ship construction, consult the specific contracting or agency rules that apply to that work because 1926.30(a) does not make it subject to this particular provision.

(Cited: 1926.30(a).)

For work covered by 1926.30, the safety and health regulations in part 1915 (Shipyard Employment) apply, as stated in 1926.30(b).

• Practically, this means employers performing shipbuilding or repair under the circumstances described in 1926.30 should follow shipyard-specific requirements in part 1915 rather than the general construction provisions in many 1926 subparts for those activities covered by this section.

(Cited: 1926.30(b) and part 1915).

No — 1926.30(a) applies to shipbuilding and ship repair work performed on ships under Government contract; it does not by itself convert all private ship repair work into the scope of this specific subsection.

• Private ship repair and shipyard work may still be covered by OSHA, but whether part 1915 applies depends on context and other regulatory provisions; employers should check part 1915 and general OSHA requirements in part 1926 to determine which standards govern their operations.

(Cited: 1926.30(a), part 1915, and part 1926).

No — 1926.30(b) requires that the safety and health regulations in part 1915 apply for work carried out under 1926.30, but employers must still ensure compliance with any other OSHA requirements that apply to their operations.

• In practice, shipyard-specific requirements in part 1915 will govern shipbuilding and repair work covered by 1926.30, while other OSHA standards (including some in part 1926) may still apply where not inconsistent or where they address hazards not covered by part 1915.

(Cited: 1926.30(b) and part 1915).

Asbestos work performed in the course of construction, repair, or similar activities is covered by the construction asbestos standard, 29 CFR 1926.1101, and OSHA has confirmed that remediation activities involving asbestos-containing materials in such contexts are governed by the construction standard rather than the general industry standard (see OSHA's interpretation on asbestos remediation protocols: https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14).

• For ship repair on government contracts falling under 1926.30, apply the shipyard rules in part 1915 together with the applicable asbestos provisions (see OSHA's asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14) to determine respirator, monitoring, and work-practice requirements.

(Cited: OSHA asbestos interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and part 1915).

Employers must provide full facepiece supplied-air respirators (SARs) operated in pressure-demand mode with an auxiliary positive-pressure self-contained breathing apparatus (SCBA) whenever Class I asbestos exposures exceed 1 f/cc as an 8-hour TWA, according to OSHA's respirator selection interpretation for asbestos work (https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04).

• If exposures are at or below 1 f/cc, employers may provide tight-fitting PAPRs or full facepiece SARs with HEPA egress cartridges or SCBA backup unless a negative exposure assessment (NEA) demonstrates exposures will be below the PELs.

(Cited: OSHA respirator selection interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04; see also asbestos rules in 29 CFR 1926.1101 as referenced in that interpretation.)

Yes — employers must assess the workplace to determine if hazards are present and whether PPE is required, and OSHA's guidance on PPE hazard assessments confirms that employers must conduct an assessment and provide a written certification when PPE will be required (see OSHA's PPE hazard assessment interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

• For ship repair work subject to 1926.30, follow the shipyard requirements in part 1915 and perform hazard assessments to select appropriate PPE, using OSHA's recommended practices and the PPE interpretation for specifics on conducting and documenting assessments.

(Cited: OSHA PPE hazard assessment interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 and part 1915).

Yes — temporary elevated platforms or conveyances suspended by ropes or other non-rigid means meet the definition of a suspended scaffold and must meet scaffold fall protection and falling object protection requirements in 29 CFR 1926 Subpart L, as clarified by OSHA in its scaffold and fall protection interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05).

• For shipbuilding and repair operations covered by 1926.30, apply shipyard rules in part 1915 and scaffold/fall protection requirements in part 1926 where appropriate; OSHA's interpretation explains that many conveyances configured with temporary suspension or guides are treated as suspended scaffolds.

(Cited: OSHA scaffold/fall protection interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2023-12-05 and 1926.30).

OSHA's sanitation requirements apply except where another federal agency has statutory authority to prescribe or enforce occupational safety and health standards and has exercised that authority to cover the specific working conditions; OSHA's sanitation interpretation explains that when another agency (e.g., FRA) does not cover sanitation for particular work, OSHA's sanitation rules apply (see OSHA sanitation interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-05-14).

• For shipbuilding and repair under 1926.30, employers should determine whether any other federal agency has exclusive statutory authority over sanitation for their specific operations; if not, OSHA sanitation standards in part 1915 or applicable sections apply.

(Cited: OSHA sanitation interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-05-14 and part 1915).

For shipbuilding and repair work performed under 1926.30, employers must follow the shipyard rules in part 1915 as required by 1926.30(b), while also ensuring compliance with any other OSHA rules that apply and are not inconsistent with part 1915.

• If a specific hazard is addressed differently in part 1915 and part 1926, apply the part 1915 provision for work covered by 1926.30; consult OSHA guidance and applicable interpretations for complex situations.

(Cited: 1926.30(b) and part 1915).

No — OSHA's PPE guidance emphasizes that employers should not rely solely on PPE and must assess hazards and consider the hierarchy of controls (elimination, substitution, engineering, administrative, then PPE); OSHA's PPE hazard assessment interpretation explains that assessments should be used to determine if controls beyond PPE are needed (https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28).

• For ship repair under 1926.30, implement engineering and administrative controls where feasible under part 1915 before relying on PPE, and document PPE hazard assessments when PPE is required.

(Cited: OSHA PPE hazard assessment interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 and part 1915).

Look to the shipyard employment regulations in part 1915, because 1926.30(b) makes those shipyard standards applicable to the work described in 1926.30.

• The OSHA website hosts the full text of part 1915 and related guidance; for specific interpretive questions you can consult OSHA letters of interpretation such as those linked in these answers (for example, asbestos or PPE interpretations) for additional practical guidance.

(Cited: part 1915 and 1926.30(b).)

When ship repair work under 1926.30 exposes workers to specific hazards such as lead or respirable crystalline silica, employers must comply with the applicable substance-specific OSHA standards and the shipyard rules in part 1915 that govern those hazards.

• For example, OSHA enforces silica and lead standards and targeted initiatives where exposures are known hazards; consult the relevant OSHA substance standards and enforcement guidance along with part 1915 to determine monitoring, respiratory protection, medical surveillance, and control requirements.

(Cited: part 1915 and general OSHA standards and interpretations referenced in agency guidance.)

Yes — OSHA letters of interpretation provide authoritative explanations of how OSHA standards apply in particular situations and can clarify how to implement requirements in practice; for example, OSHA's asbestos remediation interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14) and PPE hazard assessment interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28) offer practical guidance that can inform compliance with part 1915 obligations.

• Use LOIs to understand OSHA's interpretation of standards, but remember LOIs do not create new requirements beyond the standards themselves; always apply the regulatory text in part 1915 and consult LOIs for practical clarification.

(Cited: OSHA interpretations: https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28; see also 1926.30(b).)