OSHA revamps shipbreaking operations directive

All government vessels contracted to be recycled with Navy and MARAD will be inspected

Posted March 15, 2016

On March 7, OSHA published a revised version of National Emphasis Program (NEP) on Shipbreaking (CPL 03-00-020). The instruction provides policies and procedures for continued implementation of a NEP to reduce and eliminate workplace hazards associated with shipbreaking operations.

In 2015, OSHA renewed the Memorandum of Agreement (MOA) between the Department of Defense (DOD) [U.S. Navy (Navy)], Department of Transportation (DOT) [Maritime Administration (MARAD)], Department of Labor (DOL) [Occupational Safety and Health Administration (OSHA)], and Environmental Protection Agency (EPA) on Coordination and Information Sharing of Domestic Ship Recycling (i.e., shipbreaking).

The MOA requires OSHA, as requested, to conduct safety and health inspections on all government vessels contracted to be recycled under contract with the Navy and MARAD.

The Agency also has established a goal to reduce injuries and illnesses among Latino workers (a significant portion of the shipbreaking workforce) by enhancing knowledge of their workplace rights and improving their ability to exercise those rights. The instruction is issued in support of the Interagency MOA and OSHA’s goal to reduce injuries and illnesses among Latino workers.

Specifically, the revised directive includes the following changes:

  • Supports the renewed 2015 MOA requiring OSHA interventions in the recycling of Navy and MARAD vessels under contract; provides a scheduling system for the inspection of Navy and MARAD shipbreaking operations for vessels covered by the Interagency MOA; reaffirms coordination between the Navy, MARAD, OSHA, and EPA for shipbreaking operations; and provides a national reporting system for all OSHA shipbreaking inspections, not just those involving Navy and MARAD vessels;
  • Updates guidance pertaining to OIS recording of shipbreaking operations;
  • Updates the contact information for the Navy and MARAD approved shipbreaking sites;
  • Supports the Agency’s goal to reduce injuries and illnesses among Latino workers;
  • Provides further explanation of the exemption in 29 CFR 1915.73(a) concerning the guarding of deck openings and edges;
  • Delivers available shipbreaking safety and health information in a web-based format with electronic links to noted references, particularly within the 21 identified inspection focus areas; and
  • Adds Appendix A: Memorandum of Agreement between the DOD, DOT, DOL, and EPA on Coordination and Information Sharing of Domestic Ship Recycling Operations (i.e., shipbreaking).

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