OSHA's Shipyard Employment standards, 29 CFR Part 1915, set safety and health requirements for ship repairing, shipbuilding, shipbreaking and related employments. They cover confined and enclosed spaces, hot work, surface preparation, scaffolds and access, general working conditions, rigging gear, tools, personal protective equipment, fire protection and toxic substances.
Shipyard work combines many of the most dangerous hazards in industry: entry into tanks and voids with toxic or flammable atmospheres, hot work near fuel, work at height on staging, heavy lifts and exposure to metals and coatings. Part 1915 addresses those hazards in the shipyard setting, where vessels change and conditions shift every day.
What Is Part 1915?
Part 1915 is organized into subparts, including:
- Subpart A: general provisions, including definitions and competent person requirements.
- Subpart B: confined and enclosed spaces and other dangerous atmospheres.
- Subpart C: surface preparation and preservation.
- Subpart D: welding, cutting and heating.
- Subpart E: scaffolds, ladders and other working surfaces.
- Subpart F: general working conditions, including housekeeping, lighting, sanitation, first aid and the control of hazardous energy.
- Subparts G through L: rigging gear, tools, PPE, ship's machinery and piping, pressure vessels and electrical machinery.
- Subpart P: fire protection in shipyard employment.
- Subpart Z: toxic and hazardous substances, such as asbestos, lead and hexavalent chromium.
Where Part 1915 has no specific standard, certain general industry standards apply to shipyard employment.
Who Must Comply?
Employers engaged in ship repair, shipbuilding, shipbreaking and related employments are covered, whether work happens in a shipyard, at a pier or on a vessel afloat. Longshoring and marine terminal work fall under separate standards in Parts 1918 and 1917.
Key Requirements
Confined and enclosed spaces
Subpart B requires testing of confined and enclosed spaces and other dangerous atmospheres before entry and before hot work. Depending on the space and the work, testing must be done by a Marine Chemist, a Certified Industrial Hygienist or a shipyard competent person. Spaces are labeled with designations such as "Safe for Workers," "Safe for Hot Work" or "Not Safe for Workers," and conditions must be maintained and retested as needed. Employers must also establish rescue teams and train employees who enter these spaces.
Shipyard competent person
Under 1915.7, a shipyard competent person must be trained to test atmospheres, use testing equipment and interpret results, and must understand the Marine Chemist certificate and the hazards of the spaces involved. Employers must keep a roster of designated competent persons.
Welding, cutting and heating
Subpart D addresses ventilation and protection during hot work, gas cylinder handling, arc welding equipment and preservative coatings. Hot work in or on spaces that contained flammable or combustible materials requires testing and certification first.
Fire protection
Subpart P requires a written fire safety plan, fire watches for hot work in specified conditions, trained fire response, and fire protection during work aboard vessels and in shipyard facilities. Fire watches must be trained and must stay in the area for at least 30 minutes after hot work ends, unless the employer determines there is no further fire hazard.
Control of hazardous energy
Subpart F includes requirements for controlling hazardous energy during servicing of machinery, equipment and systems, including a "tags-plus" system where lockout is not possible on vessel systems.
PPE and toxic substances
Subpart I requires hazard assessments and appropriate eye, face, head, foot, hand and fall protection. Subpart Z applies exposure standards for substances common in shipyards, such as lead, asbestos, cadmium and hexavalent chromium from welding and coatings.
Penalties and Enforcement
OSHA conducts shipyard inspections through regional emphasis and complaint programs. Common citations include confined space testing failures, missing fire watches, inadequate fall protection on staging, and poor control of welding fumes. Penalties are adjusted annually for inflation.
Common Compliance Mistakes
- Entering or starting hot work in spaces without valid testing and certification.
- Not retesting after conditions change, such as after painting or breaks in work.
- Fire watches leaving immediately after hot work.
- Missing a current roster of shipyard competent persons.
- Overlooking welding fume and coating exposures.
How to Comply: Step by Step
- Map your work. Identify confined spaces, hot work, coatings, rigging and fall exposures by vessel and task.
- Designate competent persons. Train and list shipyard competent persons and arrange Marine Chemist support.
- Test before work. Test atmospheres before entry and hot work, and post results at the space.
- Write a fire safety plan. Define fire watch duties, response and training.
- Control energy. Apply lockout or tags-plus procedures on vessel systems.
- Assess PPE and exposures. Complete PPE assessments and monitor toxic exposures.
- Train and audit. Train workers on Part 1915 hazards and audit compliance on each job.
How SMS360 Helps
SMS360's Work Permits module controls hot work and confined space entry with sign-offs and attached test results. Compliance Management tracks shipyard obligations and certifications, Training Management keeps the competent person roster and fire watch training current, and Audits & Inspections supports vessel walkdowns. Learn more about SMS360 for maritime operations.
Frequently Asked Questions
What does Part 1915 cover?
Ship repairing, shipbuilding, shipbreaking and related employments, whether on land, at piers or on vessels.
Who can test a confined space in a shipyard?
Depending on the space and work, a Marine Chemist, a Certified Industrial Hygienist or a designated shipyard competent person.
How long must a fire watch stay after hot work?
At least 30 minutes after hot work ends, unless the employer determines there is no further fire hazard.
Do general industry standards apply in shipyards?
Some do. Where Part 1915 does not address a hazard, certain general industry standards apply.
