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Occupational Safety and Health Administration
Directorate of Standards and Guidance
Office of Maritime
Shipyard Fire Protection FAQs
This document provides general guidance about OSHA's shipyard fire protection
standard (29 CFR Part 1915 Subpart P). The questions and answers in this
document do not themselves impose enforceable obligations; such obligations are
imposed only by the standard. The FAQs are divided into three sections: general
questions, fire watch questions, and questions about fuel gas and oxygen supply
A. General Questions
A-1. When did the final rule go into effect?
The final rule went into effect on December 14, 2004. Some of the training
requirements did not go into effect until 90 days later, on March 14, 2005. OSHA
delayed enforcement of the requirement to train fire watch workers using live
fire training. Employers were given until June 30, 2005 to conduct the practical
portion of the live fire training for fire watch employees.
A-2. Who is required to comply with the new standard?
The standard applies to shipyard employment. Contractors are covered only when
they are engaged in shipyard employment. The standard does not apply to
employment in general industry or construction; these employers are covered by
29 CFR Part 1910 and
29 CFR Part 1926 standards, respectively. If you have
questions about whether or not you are covered by the new standard, contact your
local OSHA or State Plan office.
A-3. Does the standard apply to municipal or volunteer fire departments?
No. Federal OSHA does not have jurisdiction over State and municipal fire
departments or volunteers in States under the jurisdiction of Federal OSHA, so
in those States the standard does not cover them. In those States with
jurisdiction over occupational safety and health, State and local workers are
covered by the State’s standards and information can be obtained from the State.
OSHA intends to promote coordination between the shipyard and local fire
response organizations so they can work together safely. OSHA believes that any
fire response organization that expects to respond to shipyard fires will
benefit from the coordination of activities required by this standard, and will
be able to respond to fires faster, more effectively, and with greater safety
for the shipyard workers and their own fire response members.
A-4. The standard incorporates a number of National Fire Protection Association
(NFPA) standards. If I am using a more recent edition of an NFPA standard than
the one used in the OSHA standard, could I be cited for not following the NFPA
standard listed in the OSHA Standard?
Yes. However, under OSHA's de minimis policy, where OSHA has adopted an earlier
consensus standard, employers who are in compliance with the updated version
will not be cited for a violation of the old version as long as the new one is
at least equally protective (OSHA Field Operations Manual (FOM) OSHA Instruction, CPL 02-00-150).
OSHA has reviewed the newer NFPA standards in the following table
and found that they all provide equal or greater protection than the NFPA
standards incorporated in the OSHA rule. Therefore, employers will not be cited
for using the newer NFPA standards in the table. OSHA is updating the shipyard
fire protection standard to incorporate these newer NFPA standards.
NFPA Standards Currently Incorporated by Reference in Subpart
P of 29 CFR Part 1915
Latest Version of
29 CFR 1915.505 Fire Response
NFPA 1981-1997 Standard on Open-Circuit
Self-Contained Breathing Apparatus for the Fire Service
NFPA 1981-2002 Standard on Open-Circuit Self-Contained Breathing Apparatus for
Fire and Emergency Services
29 CFR 1915.507 Land-side fire protection systems
NFPA 10-1998 Standard for Portable Fire Extinguishers
NFPA 10-2002 Standard for Portable Fire Extinguishers
NFPA 72-1999 National Fire Alarm Code
NFPA 72-2002 National Fire Alarm Code
NFPA 14-2000 Standard for the Installation of Standpipe, Private Hydrant,
and Hose Systems
NFPA 14-2003 Standard for the Installation of Standpipe and Hose Systems
NFPA 13-1999 Standard for the Installation of Sprinkler Systems
NFPA 13-2002 Standard for the Installation of Sprinkler Systems
NFPA 750-2003 Standard on Water Mist Fire Protection
NFPA 11-1998 Standard for Low-Expansion Foam
NFPA 11A-1999 Standard for
Medium- and High-Expansion Foam Systems
NFPA 11-2005 Standard for Low-, Medium-, and High-Expansion Foam Systems
NFPA 12A-1997 Standard on Halon 1301 Fire Extinguishing Systems
NFPA 12-2000 Standard on Carbon Dioxide Extinguishing Systems
NFPA 2001-2000 Standard on Clean Agent Fire Extinguishing Systems
NFPA 12A-2004 Standard on Halon 1301 Fire Extinguishing Systems
NFPA 12-2005 Standard on Carbon Dioxide Extinguishing Systems
Standard on Clean Agent Fire Extinguishing Systems
A-5. The standard requires employers to provide ways for employees to
participate in reviewing the programs and policies required by the standard
(29 CFR 1915.501(c)). Does OSHA require employers to document employee participation?
No. Some employers may decide to document their employee participation
activities, but the standard does not require employers to produce written
documentation of employee participation.
A-6. When multiple employers have responsibility for fire protection at a single
facility, the standard requires the host employer or employers to coordinate
their activities, assign fire protection duties to other employers, and
communicate relevant fire hazard information to each other (29 CFR 1915.501(d)(1)(iii)).
When the ship acts as a host employer, who is in charge, the ship’s master or
the shipyard employer?
When there are multiple host employers, the standard does not designate or
require either party to be "in charge" of the overall fire protection activity.
The employers are jointly responsible for determining which responsibilities
will be assigned to each host employer. It is extremely important for the host
employers to agree on the details of the incident command system that will be
used in the event of a fire. If a fire occurs, a clear chain of command is
needed to ensure the effectiveness of fire response and suppression activities.
A-7. The standard includes requirements for fire emergency plans (29 CFR 1915.502). Do
I still need to comply with the 1910.38 and 1910.39 standards requiring fire
prevention and emergency plans?
Yes. Shipyard employers who are currently complying with
29 CFR 1910.38 and
29 CFR 1910.39
will now also be required to comply with the additional requirements of 29 CFR 1915.502. However, there
is no need to produce three separate emergency plans. OSHA will accept one unified plan that meets all of the requirements in
29 CFR 1910.38,
1910.39, and 1915.502.
A-8. When employees are working in a space onboard a vessel or vessel section
that is equipped with a fixed fire extinguishing system, the standard requires
employers to protect employees from the accidental discharge of that system with
physical isolation, or by providing employees with specific training
(29 CFR 1915.506(b)). Does this requirement apply only to hot work, or to any kind of
The requirement applies to any work done in a space on a vessel or vessel
section with a fixed fire extinguishing system. While hot work has the greatest
potential for causing accidental activation of the system, other work, such as
rigging material into or out of a space, can also result in accidental
activation. Moreover, when a vessel is undergoing sea or dock trials, the
employer must ensure that all fire extinguishing systems remain operational
(29 CFR 1915.506(c)).
A-9. What types of training are required by the new standard?
The standard requires four levels of training that become more complex for
workers who are expected to perform more sophisticated fire response and
suppression. The training that must be performed includes evacuation procedures
for all employees, basic firefighting for employees who may be called upon to
fight incipient stage fires, additional firefighting training for fire watch
employees, and advanced training for fire response employees. The details of
each type of training can be found at
29 CFR 1915.508.
A-10. Why does the standard use a definition of "hot work" that is different
from the definition in
29 CFR Part 1915 Subpart B - Confined and Enclosed Spaces
and Other Dangerous Atmospheres in Shipyard Employment?
29 CFR Part 1915 Subpart B uses a definition of hot work that excludes grinding,
drilling, blasting, and other spark producing operations that are physically
isolated from any atmosphere containing more than 10% of the lower explosive
limit of a flammable or combustible substance. That definition is appropriate
for protecting workers from the hazards posed by confined and enclosed spaces
and other dangerous atmospheres. Subpart P uses a broader definition of hot work
to ensure that all hot work operations are evaluated for fire hazards.
B. Fire Watch Questions
B-1. Is a fire watch always needed when an employee is performing hot work, such
as welding or cutting?
No. A fire watch is only required under certain circumstances outlined in the
standard at 1915.504(b), when the following conditions are present during hot
- Slag, weld splatter, or sparks might pass through an opening and cause a
- Fire-resistant guards or curtains are not used to prevent ignition of
combustible materials on or near decks, bulkheads, partitions, or overheads;
- Combustible material closer than 35 ft. (10.7m) to the hot work in either
the horizontal or vertical direction cannot be removed, protected with
flameproof covers, or otherwise shielded with metal or fire-resistant guards or
- The hot work is carried out (performed) on or near insulation, combustible
coatings, or sandwich-type construction that cannot be shielded, cut back, or
removed, or in a space within a sandwich-type construction that cannot be
- Combustible materials adjacent to the opposite sides of bulkheads, decks,
overheads, metal partitions, or sandwich-type construction may be ignited by
conduction or radiation;
- The hot work is close enough to cause ignition through heat radiation or
conduction on the following:
- Insulated pipes, bulkheads, decks, partitions, or overheads; or
- Combustible materials and/or coatings;
- The work is close enough to unprotected combustible pipe or cable runs to
cause ignition; or
- A Marine Chemist, a U.S. Coast Guard-authorized person, or a Shipyard
Competent Person, as defined in
29 CFR Part 1915 Subpart B, requires that a
fire watch be posted.
B-2. Do I need to remove all combustible and flammable materials closer than 35
feet before performing hot work?
No. The standard states that you must evaluate hot work areas to make sure the
area is free of fire hazards (29 CFR 1915.503(a)(2)) and maintain fire-hazard free
conditions (29 CFR 1915.503(b)(1)). The most effective method is to remove combustible
and flammable materials a safe distance away from ignition sources (35 feet).
The next most effective methods are to shield the combustible or flammable
material with metal or flame-resistant guards, use flame-proof covers, or inert
sandwich type material with appropriate precautions. When these methods are not
used, a fire watch must be posted.
B-3. Is the "35-foot" rule for hot work a new requirement?
No. OSHA’s general industry welding and brazing rules at
29 CFR 1910.252(a)(2)(vii) and NFPA’s 51B-2003 Standard for Fire Prevention During
Welding, Cutting, and Other Hot Work, use a 35-foot limit as an appropriate
B-4. When hot work is to be performed at a location within 35 feet of
combustible material, can I choose to post a fire watch instead of removing or
shielding the combustible material, even though it could be removed or shielded?
Yes. You can authorize employees to perform hot work only in areas that are free
of fire hazards, or that have been controlled by physical isolation, fire
watches, or other positive means (29 CFR 1915.503(a)(2)(ii)).
B-5. Is a fire watch required if the combustible material is treated to be
fire-resistant or fire retardant?
No. If the employer has purchased fire-resistant or fire retardant material, or
has treated normally combustible material so that it is no longer combustible,
then a fire watch is not required.
B-6. Can a worker performing hot work, such as welding, act as his or her own
No. A worker who is performing hot work is concentrating on his or her own work,
and may be too distracted to quickly observe a fire as it ignites. Therefore,
another employee or employees must be assigned the fire watch duty.
B-7. Can an employee engaged in fire watch duties also perform other kinds of
No. When a worker is actively engaged in fire watch duty, he or she cannot
perform other duties (29 CFR 1915.504(c)(1)). Because the situations requiring a fire
watch carry a high risk of fire, a fire watch must have only one task at hand –
to watch for and respond to fires that occur during hot work. The fire watch
employee must also have the authority to stop the hot work and assist with fire
prevention activities, such as wetting down a fire blanket, repositioning a fire
curtain, and removing combustible debris that has entered the area. After the
hot work is completed, the fire watch must remain in the area for at least 30
minutes to ensure that there is no further fire hazard, unless the employer or
its representative surveys the area and determines that there is no further fire
hazard. During this 30-minute period, the fire watch can perform other duties.
B-8. Can one employee perform fire watch duty for more than one employee
performing hot work?
Yes. One employee can perform fire watch duty for several employees performing
hot work, as long as the fire watch meets all the requirements of the standard.
For example, the fire watch employee must have a clear view of and immediate
access to all areas included in the fire watch, must be able to communicate with
all workers exposed to hot work, and must be authorized to stop work and restore
safe conditions when necessary (29 CFR 1915.504(c)(2)). If the fire watch employee
stops work for one employee performing hot work to restore safe conditions, he
or she must also stop the remaining hot work covered by the fire watch.
B-9. Are there situations where more than one fire watch employee is needed?
Yes. A fire watch employee must have a clear view of all areas assigned.
Depending on the specific circumstances, two or more employees may be required
in the fire watch to ensure that all areas are within view. For example, a fire
watch employee may be needed on each side of a bulkhead on which hot work is
being performed. Similarly, where hot material from hot work could spread or
fall over more than one level, as in trunks and machinery spaces, a fire watch
must be stationed at each affected level unless positive means are available to
prevent the spread or fall of hot material.
B-10. Can the fire watch or an employee performing hot work be the designated
employer representative to determine that it is safe to vacate the watch before
the 30-minute period is over?
Yes. The employer can designate any employee to perform this function. Of
course, OSHA requires that person to have the necessary training, experience, or
both to make appropriate decisions concerning the monitoring of recently
completed hot work.
B-11. The employer is required to ensure that employees assigned to fire watch
duty are physically capable of performing the work. How does the employer
determine the physical qualifications of employees assigned to perform fire
OSHA expects the employer to evaluate the hot work, the environment in which it
is performed, and the employee to make sure that the employee can physically
perform the work. The employee must have the strength and physical ability to
handle fire extinguishing equipment, to access and exit the location, to observe
fires, and to extinguish incipient stage fires. The physical requirements may
vary. For example, if the hot work in question is in an area that can only be
accessed with ladders, an employee who cannot climb ladders is not physically
capable of performing fire watch duty. However, the employee may be capable of
performing fire watch duties at ground level.
B-12. Do I have to train all fire watch employees with live fire exercises?
Yes. Each fire watch employee is expected to extinguish one fire using a fire
extinguishing method the employee is likely to use (29 CFR 1915.508(e)). You do not
have to use live fire training for each medium or extinguishing method the
employee may use; only one is required. Merely watching another employee
extinguish a fire does not meet the requirements of the standard.
B-13. Must a shipyard build a permanent training facility or contract for the
use of a geographically separated training facility for live fire training?
No. Employers may decide to build a permanent facility or contract with a
facility to provide the training, but they are not required to do so. OSHA
specifies the material the training must cover, and that it must be performed by
an instructor with adequate fire watch knowledge and experience, but does not
specify the location where training must be given or provide other
specifications for the training. Shipyard employers are free to determine the
training methods and locations that meet their needs, and may consider quality,
cost and convenience issues when making these decisions. Alternative ways to
provide training include building permanent facilities, contracting with an
outside facility, using shipyard areas designated for hot work, using other safe
areas of the shipyard, or using off-site locations. Likewise, some shipyards
will employ their own trainers, some will use contract trainers, and others may
obtain training from a local fire department.
B-14. Has OSHA thought of the practical realities, cost, and time needed to seek
permits for live fires, assuming the local jurisdiction will permit them?
Yes. OSHA recognizes that some shipyard employers will need to seek permission
from local authorities to set the fires that are needed to provide live fire
training. OSHA expects employers to make a diligent effort to obtain any needed
permits or licenses to provide this important training. OSHA believes that most
local authorities will grant this permission when they understand the need for
the training and that the employer will be using very short-lived fires in a
controlled environment under the supervision of a knowledgeable and experienced
instructor. It is also likely that local authorities will issue annual or
blanket authorizations so that employers are not required to obtain permits for
each individual fire. The standard recognizes that a few employers may not be
able to get permission from local authorities. When this occurs, despite their
diligent efforts, the employer may use simulated fire training.
B-15. Has OSHA developed acceptable alternatives to reduce the number of fire
watch personnel who must be trained?
No. Paragraph 29 CFR 1915.504(b) sets forth the eight specific circumstances when
employers are required to post a fire watch. However, as long as fire watches
are used in these circumstances and otherwise follow the requirements of the
standard, shipyards are free to seek alternatives to control the cost of the
training. For example, a shipyard could train a limited number of personnel and
then use them exclusively for fire watch duties. The shipyard could schedule
work to reduce the need for fire watches, or make greater use of designated hot
work areas. A shipyard could also contract fire watch duties to a specialty
service and then use the contract personnel on an "as needed" basis. Others may
find that it is better to train large numbers of employees so fire watches can
be assigned quickly. OSHA expects that each shipyard will find the most
effective method for its individual circumstances.
B-16. How does a shipyard provide training to subcontractor employees performing
work in the shipyard?
In general, each covered employer is required to train its own employees.
29 CFR 1915.501(d) of the standard requires host and contract employers to
share information about their fire safety plans and share information about
fire-related hazards associated with their work. The host employer is required
to make sure that responsibilities for fire protection are assigned to other
employers as appropriate. These requirements extend to fire watches and fire
watch training, and employers are expected to coordinate their activities to
make sure that any employees performing fire watch are properly trained.
C. Fuel Gas and Oxygen Hose Line Management Questions
C-1. The standard requires employers to ensure that unattended fuel gas and
oxygen hose lines or torches are not left in a confined space (29 CFR 1915.503(b)(2)(i)).
Can a fire watch employee attend these hose lines when the employee performing
hot work exits the confined space?
Yes. Any employee can attend the lines to make sure that they are not damaged.
C-2. Can the fire watch employee attend the hose lines for one worker while
performing fire watch duty for another worker?
No. When a worker is actively engaged in fire watch duty, he or she cannot
perform other duties (29 CFR 1915.504(c)(1)).
C-3. The standard requires employers to make sure that charged fuel gas and
oxygen hose lines are not left unattended in an enclosed space for more than 15
minutes (29 CFR 1915.503(b)(2)(ii)). For hose lines that pass through several enclosed
spaces, does the entire length of hose line have to be pulled back to open air
No. If the charged hose line (any hose line that is connected to the manifold
and filled with gas) is going to be left unattended for more than 15 minutes,
the employer can either roll back the hose lines to open air or disconnect the
lines at the manifold to allow the gas to discharge. If the hose lines are left
in place and disconnected at the manifold, then the employer is required to make
sure that the hose lines are given a positive means of identification to keep
them from being improperly reconnected. When the hose lines are reconnected,
they must be tested to ensure their integrity before the work can resume.
C-4. If the torch hose line assembly has a quick disconnect device, or the torch
is left attached to the hose line, will this be sufficient to allow the torch to
be disconnected without pulling the hose line from a confined or enclosed space?
No. The objective is to remove unattended gas-filled hose lines from enclosed
and confined spaces. In the situation described above, the hose line is still
filled with flammable fuel or oxygen gases and is a potential fire and health
hazard. The hose line must be rolled back and/or disconnected at the manifold if
left unattended for more than 15 minutes in an enclosed space, and immediately
from an unattended confined space. (29 CFR
C-5. Can a hose line be disconnected at the manifold or cylinder instead of
being removed from a confined space?
No. A fuel gas and oxygen hose line in a confined space must always be removed