FactSheet
Hazard Communication in the Maritime Industry
This fact sheet describes the hazard communication requirements for work
performed in the maritime industry (see 29 CFR Parts 1915, 1917, and 1918), as
specified in the Hazard Communication Final Rule.
Hazard Communication Hazardous Chemicals
OSHA revised its Hazard Communication Under HCS 2012, a hazardous chemical means
Standard (HCS 2012), 29 CFR 1910.1200, on March any chemical which is classified as a physical
26, 2012, to align it with the United Nations’ hazard or a health hazard, a simple asphyxiant,
Globally Harmonized System of Classification combustible dust, pyrophoric gas, or hazard
and Labeling of Chemicals (GHS). HCS 2012 not otherwise classified (§1910.1200(c)). This
provides a standardized, coherent approach to definition mirrors the meaning of a hazardous
both classifying chemicals and communicating substance in shipyard employment, which
the hazards of those chemicals on labels and is defined as any substance that may cause
safety data sheets (SDSs). The changes to the injury, illness, or disease, or otherwise harm
HCS include revised criteria for classification of an employee by reason of being explosive,
chemical hazards; revised labeling provisions flammable, poisonous, corrosive, oxidizing,
to require the use of standardized signal irritating, or otherwise harmful (§1915.80(b)(9)).
words, pictograms, hazard statements, and Therefore, OSHA considers a substance to be
precautionary statements; a specified format for hazardous if it poses a physical or health hazard,
SDSs; and requirements for employee training or if it is classified as a simple asphyxiant, a
on labels and SDSs. The hazard communication combustible dust, a pyrophoric gas, or a hazard
requirements under HCS 2012 are applicable to not otherwise classified.
maritime employment. See §1915.1200 (shipyard
employment), §1917.1(a)(2)(vi) (marine terminals), The Effect of Revisions to the
§1918.1(b)(4) (longshoring). HCS on Standards Applicable
to the Maritime Industry
While several changes were made as part of The revisions made to the HCS in order to
the standard’s revision, employers’ obligations conform to the GHS necessitated modification
remain largely the same. Employers are still of several other OSHA standards that reference
responsible for maintaining a written hazard HCS definitions. For example, OSHA modified the
communication program at each workplace, definition of flammable liquids in §1910.106 in order
maintaining labels on shipped containers to align with the HCS 2012’s hazard categories
of chemicals, labeling secondary (in-house) for flammable liquids based on flashpoint
containers of chemicals, using SDSs, providing criteria. Additionally, modifications were made
workers information and training, and ensuring to most substance-specific health standards to
the effective communication of potential ensure that requirements for signs, labels, and
exposure to hazardous chemicals. Where SDSs are consistent with the HCS 2012.
multi-employer worksites exist, the hazard
communication program must also include steps The three tables below outline the requirements
for the communication of hazards to the workers in 29 CFR Part 1910 affected by the HCS 2012 that
of the other employers. apply to the maritime industry.
TABLE 1: 29 CFR Part 1915 – Shipyard Employment
General Industry
Standards Maritime Industry Applicability of General Industry Standards
1910.106 Flammable Applies on vessels and on shore for covered flammable and combustible
liquids liquids operations; not applicable for fuel tanks and bulk cargo tanks that are
part of the vessel.
The maritime industry generally does not use flashpoint criteria to distinguish
between flammable and combustible liquids. Section 1910.106 applies to
shipyard employment when the definitions of flammable and combustible
liquids are not specified in Part 1915 shipyard standards; however, where a
specific Part 1915 shipyard requirement provides flashpoint criteria, those
requirements take precedence over the definitions in §1910.106.
1910.107 Spray finishing Applies on vessels and on shore for spray booths; however, spray booths are
using flammable and usually located on shore in shipyards.
combustible materials
Specific applicable sections include:
§1910.107(c) on vessels and on shore for electrical and other sources of ignition.
§1910.107(d) on shore; however, §§1915.35 and 1915.36 apply to vessels for
ventilation and exhaust systems.
§1910.107(e) on vessels and on shore (§1915.36 also applies)
§1910.107(f) on shore for the protection of sprinklered buildings
§1910.107(g) on vessels and on shore, excluding §§1910.107(g)(2) and (g)(5),
which are preempted by §§1915.35(b)(6), 1915.32, and 1915.33
§1910.107(h) on vessels and on shore
§1910.107(i) on vessels and on shore
§1910.107(j) on vessels and on shore
§1910.107(k) on shore
§1910.107(l) on vessels and on shore
§1910.107(m) on vessels and on shore
1910.119 Process safety Applies on vessels and on shore for process safety management of highly
management of highly hazardous chemicals.
hazardous chemicals
1910.120 Hazardous Applies on vessels and on shore for hazardous waste operations.
waste operations and
emergency response
1910.123–1910.126 Dipping Applies on vessels and on shore for hazards associated with dip tanks; these
and coating operations standards are not preempted by §§1915.32 and 1915.33.
Dip tanks located in confined or enclosed spaces must meet the requirements
of 29 CFR Part 1915, Subpart B.
General Industry
Standards Maritime Industry Applicability of General Industry Standards
1910.252 General Applies on vessels and on shore for welding, cutting and brazing general
requirements (Welding, requirements.
Cutting, and Brazing)
Note:
On Vessels & On Shore
• 29 CFR Part 1915 Subpart P (§§1915.501 through 1915.509) applies for all
1910.252(a)(3)
shipyard employment fire protection.
1910.252(a)(4)(i)
1910.252(b)(1) • §1915.51 – Ventilation and protection in welding, cutting and heating take
1910.252(b)(2)(ii) precedence over General Industry standards.
1910.252(b)(2)(iii)
1910.252(c)(1)(i)–(ii)
1910.252(c)(1)(iv)
1910.252(c)(2)(ii)
1910.252(c)(3)(i)
1910.252(c)(3)(ii)
1910.252(c)(4)(iii)
1910.252(c)(4)(iv)
1910.252(c)(5)
1910.252(c)(11)–(13)
1910.252(d)
On Shore Only
1910.252(c)(6)–(10)
1910.1003 13 Carcinogens Applies on vessels and on shore for 13 carcinogens; incorporated by
reference — §1915.1003: 4-Nitrobiphenyl; §1915.1004: alpha-Naphthylamine;
§1915.1006: Methyl chloromethyl ether; §1915.1007: 3,3’-Dichlorobenzidine;
§1915.1008: bis-Chloromethyl ether; §1915.1009: beta-Naphthylamine;
§1915.1010: Benzidine; §1915.1011: 4-Aminodiphenyl; §1915.1012: Ethyleneimine;
§1915.1013: beta-Propiolactone; §1915.1014: 2-Acetylaminofluorene; §1915.1015:
4-Dimethylaminoazobenzene; and §1915.1016: N-Nitrosodimethylamine
1910.1017 Vinyl chloride Applies on vessels and on shore for vinyl chloride; incorporated by reference —
§1915.1017
1910.1018 Inorganic Applies on vessels and on shore for inorganic arsenic; incorporated by
arsenic reference — §1915.1018
1910.1025 Lead Applies on vessels and on shore for lead; incorporated by reference —
§1915.1025
1910.1027 Cadmium Applies on vessels and on shore for cadmium; incorporated by reference —
§1915.1027
1910.1028 Benzene Applies on vessels and on shore for benzene; incorporated by reference —
§1915.1028
1910.1029 Coke oven Applies on vessels and on shore for coke oven emissions
emissions
1910.1044 1,2-dibromo-3- Applies on vessels and on shore for 1, 2-dibromo-3-chloropropane;
chloropropane incorporated by reference — §1915.1044
1910.1045 Acrylonitrile Applies on vessels and on shore for acrylonitrile; incorporated by reference —
§1915.1045
1910.1047 Ethylene oxide Applies on vessels and on shore for ethylene oxide; incorporated by reference —
§1915.1047
1910.1048 Formaldehyde Applies on vessels and on shore for formaldehyde; incorporated by reference —
§1915.1048
General Industry
Standards Maritime Industry Applicability of General Industry Standards
1910.1050 Applies on vessels and on shore for methylenedianiline; incorporated by
Methylenedianiline reference — §1915.1050
1910.1051 1,3-Butadiene Applies on vessels and on shore for 1,3-Butadiene
1910.1052 Methylene Applies on vessels and on shore for methylene chloride; incorporated by
Chloride reference — §1915.1052
1910.1200 Hazard Applies on vessels and on shore for hazard communication; incorporated by
Communication reference — §1915.1200
1910.1450 Occupational Applies on vessels and on shore for occupational exposure to hazardous
exposure to hazardous chemicals in laboratories; incorporated by reference — §1915.1450
chemicals in laboratories
Asbestos – §1915.1001 RESPIRATORY PROTECTION AND PROTECTIVE
The revised Hazard Communication rule also CLOTHING IN THIS AREA.” Employers have until
included updates to §1915.1001, paragraphs (i) June 1, 2016, to implement this change.
(3), (k)(7), and (k)(8). New requirements include
the expectation that employers will ensure that Chromium (VI) – §1915.1026
contaminated clothing for transport are sealed The revised Hazard Communication rule also
and labeled appropriately (§1915.1001(i)(3)). made changes to §1915.1026, paragraphs (g)
(2)(iv) and (j)(1). Where bags or containers of
Further, in §1915.1001(k)(7), formerly contaminated protective clothing or equipment
§1915.1001(k)(8), the required warnings to be are removed from change rooms for laundering,
displayed on the labels of bags or containers cleaning, maintenance, or disposal, they must be
that hold protective clothing, equipment, labeled in accord with the requirements of the
scrap, waste, and debris have been adjusted Hazard Communication standard — §1910.1200
slightly. Previously labels were required to bear (§1915.1026(g)(2)(iv)). While this requirement has
the warning “CANCER AND LUNG DISEASE not changed, the new provision includes the
HAZARD” as one of four necessary warning expectation that ultimate responsibility lies with
statements (see 1915.1001(k)(7)(iii)). Now labels the employer.
have been revised and two parts of the required
label are “MAY CAUSE CANCER” and “CAUSES New to paragraph (j)(1), employers must ensure
DAMAGE TO LUNGS.” The new language each employee has the following:
takes effect June 1, 2015. Additionally, the
1. Access to labels on containers of chromium
same revision was made to warning signs that
(VI) and SDSs;
demarcate regulated areas under §1915.1001(k)
2. Training in accord with §1910.1200, as well
(8)(ii), previously §1915.1001(k)(7)(ii)(A). However,
as the requirements contained in paragraph
employers are not required to make this change
(j)(2); and
until June 1, 2016.
3. Knowledge of the hazards associated with
Also, in §1915.1001(k)(8)(iii), previously chromium (VI) that include at least cancer,
§1915.1001(k)(7)(ii)(B), where respirators must skin sensitization, and eye irritation.
be worn, the signage must state “WEAR
Table 2: 29 CFR Part 1917 – Marine Terminals
General Industry
Standards Maritime Industry Applicability of General Industry Standards
1910 Subpart Z Toxic and Applies to marine cargo handling activities except for:
Hazardous Substances • When a substance or cargo is contained within a sealed, intact means of
packaging or containment compliant with Department of Transportation or
International Maritime Organization requirements;
• Bloodborne pathogens;
• Carbon monoxide (See §1917.24(a));
• Hydrogen sulfide (See §1917.73(a)(2)); and
• Hexavalent chromium (See §1915.1026).
1910.1200 Hazard Applies for hazard communication; incorporated by reference in §1917.28
Communication (§1917.1(a)(2)(vi)). However, facilities used solely for bulk storage, handling and
transfer of flammable, non-flammable and combustible liquids and gases are
exempt from §1910.1200 requirements (§1917.1(a)(1)(i)).1
Table 3: 29 CFR Part 1918 – Longshoring
General Industry
Standards Maritime Industry Applicability of General Industry Standards
1910 Subpart Z Toxic and Applies to marine cargo handling activities except for:
Hazardous Substances
• When a substance or cargo is contained within a sealed, intact means
of packaging or containment compliant with U.S. Department of
Transportation or International Maritime Organization requirements;;
• Bloodborne pathogens;
• Carbon monoxide (See §1918.94(a));
• Hydrogen sulfide (See §1918.94(f)); and
• Hexavalent chromium (See §1915.1026).
1910.1200 Hazard Applies for hazard communication; incorporated by reference in §1918.90
Communication (§1918.1(b)(4)).
Reporting and Recordkeeping
An accurate record of any measurements Further, such records must be preserved and
taken to monitor worker exposure and medical maintained for at least the duration of the
services (consultations, exams, tests, and written worker’s employment plus 30 years (29 CFR
physician opinions) must be accurately recorded. 1910.1020(d)(1)(i)).
1
andling of Dangerous Cargo at Waterfront Facilities (Marine Terminals). Under Section 4(b)(1) of the OSH Act, OSHA has no
H
authority over a working condition if another federal agency has exercised statutory authority over that working condition. Pursu-
ant to 33 U.S.C. Section 1231, a provision of the Ports and Waterways Safety Act, the Coast Guard has promulgated regulations
(33 CFR Part 126) dealing with working conditions for the loading and discharging of vessels at “designated waterfront facilities”
involving the handling and storage of “dangerous cargo,” “designated dangerous cargo,” or “cargo of a particular hazard.”
Further, pursuant to this same section, the Coast Guard has promulgated regulations (33 CFR Part 154) for working conditions involving
facilities capable of transferring oil or other hazardous liquids or gases, in bulk, to or from a vessel (see 29 CFR Part 1917.1(a)(1)(i)). “In
bulk” is defined by the U. S. Coast Guard as 250 barrels or more, where a barrel holds 42 U.S. gallons (i.e., 250 barrels = 10,500 U.S.
gallons). If the cargo handled at the “designated waterfront facility” is of the type specified in these Coast Guard regulations (33 CFR
Parts 126 and 154), then OSHA authority is preempted with respect to those hazards addressed by those regulations (e.g., fire, explosion
and toxic hazards). All other working conditions at the facility are subject to OSHA regulation (such as activities related to production,
manufacturing, construction, ship repair including tank cleaning operations, and the movement of general cargo).
Safety Data Sheets (SDSs) protect against the hazards, the new information
Under the revised standard, chemical must be added to the SDS within three months.
manufacturers, distributors, or importers are Labels must be updated within six months of
required to provide SDSs (formerly material becoming aware of significant information
safety data sheets), for all hazardous chemicals. regarding the hazards of a chemical.
SDSs must present information on these
chemicals in a user-friendly, 16-section format,
Labels
containing the following information: Starting on June 1, 2015, all labels on
incoming containers of hazardous chemicals
Section 1 - Identification; from manufacturers and importers must
Section 2 - Hazard(s) identification; have pictogram(s), a signal word, hazard and
Section 3 - Composition/information precautionary statements, the product identifier,
on ingredients; and supplier identification (see OSHA QuickCard:
Section 4 - First-aid measures; Hazard Communication Standard Labels).
Section 5 - Firefighting measures; However, employers may receive containers with
Section 6 - Accidental release measures; HCS 1994 compliant labels from distributors until
Section 7 - Handling and storage; December 1, 2015.
Section 8 - Exposure controls/personal protection;
Section 9 - Physical and chemical properties; Pictograms are symbols used to communicate
Section 10 - Stability and reactivity; specific information about the hazards of a
Section 11 - Toxicological information; chemical. There are nine pictograms under the
Section 12 - Ecological information; GHS used to convey the health, physical, and
Section 13 - Disposal considerations; environmental hazards of a chemical; OSHA has
Section 14 - Transport information; adopted all of these pictograms except for the
Section 15 - Regulatory information; and environmental pictogram. These pictograms are
Section 16 - Other information, including date of depicted below.
preparation or last revision.
Pictograms
OSHA requires that Sections 12 through
15 be present on each SDS; however, the
agency is not enforcing the content of these
sections. Appendix D of §1910.1200 outlines the
information that must be present in each section.
SDSs must be readily accessible to workers
for all hazardous chemicals in their workplace.
There are a number of ways this can be
accomplished. For example, employers may
keep SDSs in a binder or on a computer.
Regardless of the method used, employees
must have immediate access to the information
when needed without leaving their work area
and a back-up system must be available for
immediate access in case of power outage
or other emergency. Employers may want to
designate a person or group as responsible
for obtaining and maintaining SDSs. Where
hazardous chemicals are received without an
SDS, the employer or its representative must
make a good-faith effort to obtain the SDS.
Whenever chemical manufacturers, importers,
or employers responsible for preparing the SDS
become aware of any significant information
regarding the hazards of a chemical, or ways to
For secondary or in-house containers, the Workers must also be informed of the
employer may either provide all of the required requirements of the HCS, any operations in
information that is on the label from the chemical their work area where hazardous chemicals
manufacturer, or the product identifier and words, are present, and the location and availability
pictures, symbols or a combination thereof, which of the written hazard communication program,
provide at least general information regarding including the required lists of hazardous
the chemical hazards, and which, in combination chemicals and SDSs.
with other information immediately available to
workers, provide specific information regarding Help for Employers
the hazards of the chemicals. For more information on the HCS, as well as
common and logical approaches to training and
Information and Training communicating hazard information on labels and
Workers must be trained on hazardous chemicals SDSs, see the OSHA webpage at www.osha.gov/
that they may be exposed to during work in a dsg/hazcom.
manner and language that they can understand.
At a minimum, training must be conducted at the OSHA’s On-site Consultation Program offers free
time of initial assignment to the work area, and and confidential advice to small and medium-
whenever a new hazard is introduced. sized businesses in all states across the country,
with priority given to high-hazard worksites.
The topics of training to be covered must, at a On-site Consultation services are separate from
minimum, include: enforcement and do not result in penalties or
citations. Consultants from state agencies or
• Detection of hazardous chemicals (e.g., visual
universities work with employers to identify
appearance, odor, monitoring devices);
workplace hazards, provide advice on compliance
• Effects of hazardous chemical exposure
with OSHA standards, and assist in establishing
that cover physical, health, asphyxiation,
safety and health management systems. To
combustible dust, pyrophoric gas, and
locate the OSHA On-site Consultation Program
hazards not otherwise classified;
nearest you, call 1-800-321-6742 (OSHA) or visit
• Worker protection measures (e.g., work
www.osha.gov/dcsp/smallbusiness.
practices, emergency procedures, personal
protective equipment); and Note: States with OSHA-approved state plans
• Detailed overview of the employer’s written may have additional requirements. For more
hazard communication program, including an information, please visit: www.osha.gov/dcsp/
explanation of the labels received on shipped osp/statestandards.html.
containers and SDS sections. Employers must
train workers on HCS 2012 label elements and
SDS format by December 1, 2013.
Disclaimer: This OSHA Fact Sheet provides a general overview of the requirements of the Hazard Communication standard applicable
to the maritime industry. It does not alter or determine compliance responsibilities in the standard or the Occupational Safety and
Health Act of 1970. Since interpretations and enforcement policy may change over time, the reader should consult current OSHA
interpretations and decisions by the Occupational Safety and Health Review Commission and the courts for additional guidance on
OSHA compliance requirements.
This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards.
It does not impose any new compliance requirements. For a comprehensive list of compliance
requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal Regulations.
This information will be made available to sensory-impaired individuals upon request. The voice phone
is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.
DSG FS-3694 11/2013