Does "Subpart P - Fire Protection in Shipyard Employment" Apply to You?

Subpart P covers employees engaged in shipyard employment aboard vessels and vessel sections, and on land-side operations regardless of geographic location and requires employers to protect all employees from fire hazards in shipyard employment, including employees engaged in fire response activities. It provides the standards for fire protection including fire safety plans, hot work precautions, fire watches, fire response, hazards of fire extinguishing systems, land-side fire protection systems, and training.

Do you have employees that are engaged in shipyard employment aboard vessels and vessel sections, and on land-side operations? If yes, then this subpart applies to you. The standard on general provisions provides the scope of the subpart along with the requirements for employee participation and multi-employer worksites. The standard requires a written fire safety plan that includes the identification of significant fire hazards, procedures for employees, reviewing plan with employees, keeping plan accessible, conducting plan reviews, and fire safety plans for contract employees. A model fire safety plan is provided in appendix A.

This subpart also provides the standard on training which includes requirements for providing training on emergency alarm signals, primary and secondary evacuation routes, and additional training requirements for employees that are expected to fight incipient stage fires, fire response employees, employees providing fire watch duty, and maintaining records. It also provides definitions applicable to this subpart including:

Fire watch - The activity of observing and responding to the fire hazards associated with hot work in shipyard employment and the employees designated to do so. 

Fire response - The activity taken by the employer at the time of an emergency incident involving a fire at the worksite, including fire suppression activities carried out by internal or external resources or a combination of both, or total or partial employee evacuation of the area exposed to the fire. 

Fire response employee - A shipyard employee who carries out the duties and responsibilities of shipyard firefighting in accordance with the fire safety plan. 

Incipient stage fire - A fire, in the initial or beginning stage, which can be controlled or extinguished by portable fire extinguishers, Class II standpipe or small hose systems without the need for protective clothing or breathing apparatus. 

Additional related information can be found on the A-Z topics pages for fire prevention plans and exits and exit routes.

Do employees conduct hot work? Do employees provide fire response and/or does an outside organization? Do you have fixed extinguishing systems? Do you have fixed or portable fire protection systems? If you said yes to any of these questions, click on the tabs below to see if they apply to you.

 

Subpart P - Fire Protection in Shipyard Employment

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If yes, then you need to comply with the standard on precautions for hot work. It includes requirements for designated and non-designated areas and specific requirements related to maintaining fire hazard-free conditions, work in confined spaces, and fuel gas and oxygen supply lines. You must also comply with the standard on fire watches for any hot work being conducted. It provides requirements for having a written fire watch policy, training employees on personal protective equipment, performance of duties, and equipment to be used (also reference the standard on training), posting fire watches, and assigning employees to fire watch duty. 

Additional related information can be found on the A-Z topics pages for welding and cuttingpersonal protective equipment and confined spaces.

Do your employees provide fire response? If yes, then you need to comply with the standard on fire response, except paragraph (b)(2) - outside fire response and paragraph (b)(3) - a combination of internal and outside fire response. This standard provides the requirements for deciding the type of response to fires (i.e., internal, external, combination), and creating, maintaining and updating a written policy. The policy must include structure of fire response organization, number of trained personnel, fire response functions, standard operating procedures for internal fire response, and use of personal protective equipment.

In addition, the policy must include employee evacuation, rescue and emergency response, medical requirements for shipyard fire response employees (also reference the standard on access to employee exposure and medical records), fire response functions, personal protective clothing and equipment (also reference the standard on respiratory protection), and equipment maintenance. It also references National Fire Protection Association consensus standards which are incorporated by reference.

Does an outside organization provide fire response? If yes, then your written policy must also include the elements listed in paragraph (b)(2) - outside fire response, which includes fire suppression incidents that they will respond to, procedures to request their assistance, familiarizing outside organization with your facility and layout.

Do both employees and an outside organization provide fire response? If yes, then the elements listed in paragraph (b)(2) - outside fire response and paragraph (b)(3) - a combination of internal and outside fire response must be included in your policy. Paragraph (b)(3) includes type, amount and frequency of joint training.

Emergency operations - Activities performed by fire response organizations that are related to: rescue, fire suppression, emergency medical care, and special operations or activities that include responding to the scene of an incident and all activities performed at that scene. 

Fire response employee - A shipyard employee who carries out the duties and responsibilities of shipyard firefighting in accordance with the fire safety plan. 

Fire response organization - An organized group knowledgeable, trained, and skilled in shipyard firefighting operations that responds to shipyard fire emergencies, including fire brigades, shipyard fire departments, private or contractual fire departments, and municipal fire departments. 

Rescue - Locating endangered persons at an emergency incident, removing those persons from danger, treating the injured, and transporting the injured to an appropriate health care facility. 

Additional assistance with consensus standards can be obtained by contacting the NCDOL Library

If yes, are employees exposed to fixed extinguishing systems that could create a dangerous atmosphere when activated in vessels and vessel sections (regardless of geographic location)? If yes, then you need to comply with the standard on hazards of fixed extinguishing systems on board vessels and vessel sections. It provides requirements for automatic and manual systems, sea and dock trials, doors and hatches, testing the system, conducting system maintenance, and using fixed manual extinguishing systems for fire protection.

Fixed extinguishing system - A permanently installed fire protection system that either extinguishes or controls fire occurring in the space it protects. 

Fire protection - Methods of providing fire prevention, response, detection, control, extinguishment, and engineering. 
 

If yes, are they needed to meet an OSHA standard for employee safety or employee protection from fire hazards in land- side facilities, including, but not limited to, buildings, structures, and equipment? If yes, then you need to comply with the standard on land-side fire protection systems. It provides the requirements for portable fire extinguishers and hose systems, and for fixed extinguishing systems. It also references National Fire Protection Association consensus standards which are incorporated by reference.

Hose systems - Fire protection systems consisting of a water supply, approved fire hose, and a means to control the flow of water at the output end of the hose. 

Fixed extinguishing system - A permanently installed fire protection system that either extinguishes or controls fire occurring in the space it protects. 

Additional assistance with consensus standards can be obtained by contacting the NCDOL Library