U.S. Department of Labor
Process: Surface Preparation and Preservation
This guidance document is not a standard or regulation, and it creates no new legal obligations. The information provided is designed to highlight safety and health hazards associated with surface preparation and preservation operations in the shipbuilding and ship repair industries only. Suggested preventative measures as well as descriptions of mandatory safety and health standards are also included. The recommendations are advisory in nature, informational in content, and are intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act require employers to comply with safety and health standards and regulations promulgated by either federal OSHA or through an OSHA-approved State program. In addition, the Act’s General Duty Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm.
Standards Applicable to Surface Preparation and Preservation
The standards applicable to the hazards associated with surface preparation and preservation are:
- 29 CFR 1915, Subpart B – Confined and Enclosed Spaces and Other Dangerous Atmospheres
- 29 CFR 1915, Subpart C – Surface Preparation and Preservation
- 29 CFR 1915, Subpart D – Welding, Cutting and Heating
- 29 CFR 1915, Subpart H – Tools and Related Equipment
The diversity and dynamism of surface preparation work makes it impossible to list all applicable standards here. Requirements contained in 29 CFR Part 1915 apply to all shipbuilding and repair operations. The General Industry standards, such as 29 CFR 1910, Subpart G – Occupational Health and Environmental Control and 29 CFR 1910, Subpart Z – Toxic and Hazardous Substances, may also apply in some cases.
OSHA's Shipyard "Tool Bag" Directive, CPL 02-00-157*, dated April 1, 2014, provides guidance on the applicability of standards. See Appendix A for the application of 29 CFR Part 1910 standards where 29 CFR Part 1915 provisions do not address a recognized hazard in Shipyard Employment.
See the Shipyard e-Tool for additional compliance guidance at www.osha.gov/SLTC/etools/shipyard/index.html.