On February 11, 2014, OSHA issued a long awaited Shipyard Employment “Tool Bag” Directive (CPL 02-00-156).  While the Directive provides compliance guidance to Compliance Safety & Health Officers (CSHO) for inspections of shipyard employers, it also provides guidance to covered employers.  The Directive is a source of information on how OSHA interprets various requirements and provides answers to commonly asked questions relating to the shipyard industry.

A significant portion of the Directive covers the relatively new requirements in Part 1915, Subpart F – General Working Conditions in Shipyard Employment.  On August 1, 2011, OSHA issued a final standard for General Working Conditions in Shipyard Employment, which set out requirements in the following areas:

  • Housekeeping, Lighting, and Working Alone
  • Medical Services/First Aid and Sanitation
  • Lockout/Tags-Plus (control of hazardous energy)
  • Motor Vehicles

Many of the revisions in the new rule are simply updates to existing requirements; however, the final rule is significant in that it is the first time that OSHA has established requirements for the control of hazardous energy (lockout/tagout) in the shipyard industry.  The new Directive provides guidance, including answers and questions regarding the application of lockout/tags plus in the shipyard industry.

A copy of the Directive can be found here:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=5799

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Tressi L. Cordaro Tressi L. Cordaro

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state…

Tressi L. Cordaro is a Principal in the Washington, D.C. Region office of Jackson Lewis P.C. She is co-leader of the firm’s Workplace Safety and Health Practice Group. She advises and represents employers on occupational safety and health matters before federal and state OSHA enforcement agencies.

Ms. Cordaro has advised employers faced with willful and serious citations as the result of catastrophic events and fatalities, including citations involving multi-million dollar penalties. Ms. Cordaro’s approach to representing an employer cited by OSHA is to seek an efficient resolution of contested citations, reserving litigation as the option if the client’s business objectives cannot otherwise be achieved. As a result, she has secured OSHA withdrawals of citations without the need for litigation.

Ms. Cordaro’s unique experience with government agencies involved in OSHA enforcement enables her to provide employers with especially insightful guidance as to how regulators view OSHA compliance obligations, and evaluate contested cases.

Ms. Cordaro served as the Presidentially-appointed Legal Counsel and Special Advisor to the past Chairman and Commissioner Horace A. Thompson, III at the U.S. Occupational Safety & Health Review Commission (OSHRC) in Washington, DC, the agency that adjudicates contested federal OSHA citations. As the Commissioner’s chief counsel, Ms. Cordaro analyzed all cases presented to the OSHRC and advocated the Commissioner’s position during decisional meetings.

In addition, Ms. Cordaro worked at the U.S. Department of Labor’s Occupational Safety & Health Administration developing OSHA standards, regulations and enforcement and compliance policies, with emphasis on the construction industry. She has in-depth experience on technical issues including, in particular, issues related to cranes and derricks in construction.

Read more about Tressi L. Cordaro
Show more Show less