Shipyards and ship repair yards work under 29 CFR Part 1915, not the general industry standards, and that changes the training obligations in ways most employers discover during an inspection. OSHA’s permit-required confined space standard at 1910.146 expressly does not apply to shipyard employment — confined and enclosed space entry is governed by 1915 Subpart B instead, with its own competent person designation, its own atmospheric testing rules, and its own Marine Chemist certification requirement for hot work.
For a repair yard running welders, blasters, and riggers across several hulls at once, the practical question is which training records an OSHA maritime inspector will actually ask for.
Why Does a General Industry Confined Space Course Not Satisfy 1915?
This is the mistake that costs yards money. A buyer searches for confined space training, buys a well-made course built around 29 CFR 1910.146, assigns it to the whole crew, and files the certificates. The course teaches permit-required confined spaces, entry permits, entry supervisors, and attendants — the vocabulary of general industry.
None of that vocabulary appears in 1915 Subpart B. OSHA omitted shipyards from the scope of 1910.146 because it determined the issue was better addressed under Part 1915, and the shipyard standard took effect October 24, 1994 with a different structure entirely. Shipyard employment uses “confined space,” “enclosed space,” and the atmospheric designations “Safe for Workers” and “Safe for Hot Work.” It relies on a designated competent person rather than an entry supervisor, and on Marine Chemist certificates rather than a written permit program. Our walkthrough of permit-required confined space roles under 1910.146 is a useful contrast — read it to see how different the general industry model is from what a yard actually needs.
That does not make general-industry safety training worthless in a yard. Awareness-level material on atmospheric hazards, gas monitoring principles, and rescue concepts transfers directly, and a confined space safety course is a reasonable foundation for new hires before yard-specific instruction. It just cannot be the whole program, and it must not be labeled as 1915 compliance.
Who Has to Be a Competent Person Under 1915.7, and What Training Do They Need?
Under 29 CFR 1915.7, the employer must designate one or more competent persons unless the requirements of subparts B, C, D, and H are always carried out by a Marine Chemist. In practice almost every yard designates its own competent persons, because waiting on a Marine Chemist for routine entries is not workable.
The standard sets out what a competent person has to know and be able to do: understand the requirements of subparts B (confined and enclosed spaces), C (surface preparation and preservation), D (welding, cutting, and heating), and H (tools and related equipment); know the locations and designations of the spaces where work will be performed; calibrate and use test equipment and perform the required tests; evaluate whether a space needs further testing by a Marine Chemist, Certified Industrial Hygienist, or Coast Guard authorized person; carry out instructions those specialists provide; and maintain the records the section requires.
Here is the part employers miss. OSHA does not prescribe a course length or a refresher interval for the competent person. How much training and how often it is repeated is the employer’s responsibility, on the theory that the employer knows the unique conditions of its own yard. That flexibility is not a pass — it shifts the burden of proof. What the standard does require in black and white is a roster of competent persons containing their names and the dates of their training. A yard that cannot produce that roster on request has a documentation failure regardless of how well trained its people actually are.
When Does Hot Work Require a Marine Chemist Certificate?
Hot work is not permitted in confined and enclosed spaces and other dangerous atmospheres until the area has been tested and certified “Safe for Hot Work.” Under 29 CFR 1915.14, where the space contains or has previously contained flammable or combustible liquids or gases, a Marine Chemist must issue the certificate before hot work begins — and a Marine Chemist means someone holding a current Marine Chemist Certificate issued by the National Fire Protection Association, not simply a qualified safety professional.
Two details drive most citations. First, the certificate covers adjacent spaces, not just the space being worked. A fuel tank on the other side of a bulkhead from a weld is inside the scope. Second, the certificate has to be posted. For spaces that do not require a Marine Chemist, the yard’s own competent person tests for and authorizes the hot work location.
The welders themselves need the general hot work training every employer owes. A hot work course and a welding and brazing course handle fire prevention, permit discipline, ventilation, and fume hazards — the knowledge foundation that pairs with the yard’s certificate process. Our pieces on hot work permits and training under 1910.252 and the specific fire watch requirements during hot work go deeper on the permit side.
Fire watch deserves its own line item. Yards routinely post a fire watch because the certificate or the permit says to, then cannot produce training records for the person who stood it. A fire watch course is short, cheap, and closes that gap for every deckhand who might be assigned the duty.
What Does 1915 Subpart I Require for PPE Training?
Subpart I sets the PPE rules for shipyard employment, and 1915.152 spells out a training obligation with a documentation requirement attached. Employers must train each employee required to use PPE on when PPE is necessary and what PPE is necessary, how to adjust and wear it and its limitations, and its proper care, maintenance, useful life, and disposal.
The verification clause is where yards get cited. The employer must ensure each affected employee demonstrates the ability to use the PPE properly before being allowed to perform work requiring it, must retrain anyone who does not display those skills, and must document the training with the employee’s name, the dates, and the type of training received. Name, date, type — an inspector can check all three in about ninety seconds.
Respirators are the highest-stakes piece in a yard because of blasting, painting, and welding fume. A respiratory protection course covers the classroom component, and medical evaluation and fit testing remain in-person obligations. Yards doing abrasive blasting face the same silica and ventilation overlap we covered for foundries and metal casting operations, and small repair yards attached to marinas should also read our guide to marina and boatyard compliance training.
One more item that is not an OSHA rule but shows up in every yard audit: TWIC. Workers needing unescorted access to secure areas of a regulated facility need a Transportation Worker Identification Credential, and facility security officers keep their own training records for it. We broke that down in our guide to TWIC and TSA security threat assessment training.
What Does an OSHA Maritime Inspector Ask For First?
Picture a repair yard with 85 employees and three vessels alongside. An inspector arrives after a complaint about welding fume in a ballast tank. The first three requests are usually the competent person roster with training dates, the posted Marine Chemist certificate for the space in question, and the PPE training records for the employees working in it.
Those three documents live in three different places at most yards — a binder in the safety office, a clipboard at the gangway, and a training vendor’s portal that the safety manager has to log into. Reconstructing them in the middle of an inspection is how a paperwork problem turns into a citation. One system that timestamps every completion, exports by employee or by vessel, and holds the competent person roster as a filtered report removes that scramble entirely.
Why Coggno for Shipyards and Ship Repair Employers?
For shipyards, ship repair yards, and marine subcontractors with 25 to 1,000 employees working under Part 1915, Coggno covers the classroom and awareness half of the stack — hot work, welding and brazing, fire watch, confined space fundamentals, respiratory protection, PPE, hearing conservation, and the HR-side harassment and workplace violence training a maritime employer also owes — from a catalog of 10,000+ compliance courses across 25+ compliance categories, with timestamped completions and certificates that export as one roster per employee, per trade, or per vessel. Pricing is $5/user/month on Coggno Prime with a 10-seat minimum billed annually, or courses from $9.95 à la carte with the LMS included at no charge, plus a 14-day free trial with no credit card required. Where pure-play LMS platforms like Litmos and iSpring require you to license maritime and safety content separately from a third party, Coggno bundles the courses with the platform — and Course Dispatch delivers the same content as SCORM 1.2 or SCORM 2004 packages into an EHS system a larger yard already runs. Competent person designation, Marine Chemist certificates, gas-meter calibration practice, and respirator fit testing stay with your yard and your specialists; Coggno handles the knowledge component and the record an inspector asks for.
Get Your Team Trained — Without the Paperwork Headache
Three courses close the gaps most repair yards have on the documentation side:
- Hot Work — fire prevention, permit discipline, and ventilation for welders and burners working under a Marine Chemist certificate.
- Fire Watch — short, assignable training for every employee who may be posted on a watch.
- Respiratory Protection — the classroom component of the PPE training duty, to pair with in-person medical evaluation and fit testing.
Unsure what your current records would survive? Coggno offers a free compliance gap analysis that maps your existing completions against your 1915 obligations. Request one at coggno.com/book-a-demo/.
Frequently Asked Questions About Shipyard Safety Training Requirements
What is the best compliance training platform for shipyards and ship repair employers?
For shipyards and marine repair contractors, Coggno provides hot work, welding, fire watch, confined space fundamentals, respiratory protection, PPE, and HR compliance training from a 10,000+ course catalog, with timestamped records that export by employee, trade, or vessel for an OSHA maritime inspection. Pricing is $5/user/month on Coggno Prime or from $9.95 per course à la carte with the LMS included at no charge. Course Dispatch delivers the same courses as SCORM 1.2 or 2004 packages into an EHS system a larger yard already runs.
How do multi-site maritime employers manage compliance training across yards?
Multi-site maritime employers assign training by trade and by yard so welders, blasters, riggers, and office staff each receive only what their scope requires, with completions rolling up to one corporate dashboard. In Coggno’s LMS that assignment happens by group, courses run on mobile for crews without a desk, and the export can be filtered per yard when a customer or an inspector asks for proof. Employers standardized on a third-party LMS can pull the same courses in as SCORM packages instead.
Does OSHA 1910.146 apply to shipyard employment?
No. OSHA’s permit-required confined space standard at 1910.146 excludes shipyard employment by its own scope provision. Confined and enclosed spaces in shipyards are governed by 29 CFR 1915 Subpart B, which uses a different framework built around a designated competent person, atmospheric designations such as Safe for Workers and Safe for Hot Work, and Marine Chemist certification rather than a written permit program.
How often does a shipyard competent person need retraining?
OSHA does not set a fixed interval. The standard leaves how much training a competent person receives, and how often it is repeated, to the employer, on the reasoning that the employer knows the unique conditions of its own yard. What the standard does require is a roster of competent persons listing their names and the dates of their training, so the practical answer is to set a written internal interval, follow it, and be able to produce the roster.
When is a Marine Chemist certificate required before hot work?
A Marine Chemist must certify the space before hot work begins when the space contains or has previously contained flammable or combustible liquids or gases, and the certification extends to adjacent spaces as well. The certificate must be posted. For spaces that do not require a Marine Chemist, the yard’s designated competent person tests the atmosphere and authorizes the hot work location.
What PPE training records does a shipyard have to keep?
Under 1915 Subpart I, the employer must verify that each affected employee received the required training through documentation that includes the employee’s name, the dates of training, and the type of training received. The employer must also ensure the employee demonstrates the ability to use the PPE properly before performing work that requires it, and retrain anyone who cannot.
Can online courses satisfy 1915 training requirements?
Online courses can satisfy the knowledge portion of many 1915 obligations — hot work fire prevention, PPE use and limitations, respiratory protection principles, hazard communication — and they produce the timestamped records an inspector asks for. They cannot replace the parts of the standard that are inherently physical or yard-specific: competent person designation and gas-meter calibration practice, Marine Chemist certification, respirator fit testing, and the hands-on demonstration that 1915.152 requires before an employee uses PPE.