Ultrasonic Testing (UT) Requirements Under OSHA 1915
Sensitivity setting is the auditable step: the reference block used must itself be in calibration and traceable, and its identity recorded on the report. OSHA 1915, enforced by Occupational Safety and Health Administration (OSHA), US Department of Labor; State Plan.: There is no NDT certification scheme here at all, and that is the confusion this regime creates.
An auditor examining UT asks for instrument, probes, cables, couplant, and the calibration and reference blocks used to set sensitivity. Part 1915 is the safety regime an inspection crew actually works under inside a shipyard, and it is the one most likely to stop a job. Subpart B governs confined and enclosed spaces: before entry the space must be visually inspected and tested by a competent person, in the order oxygen content, then flammability, then toxicity. Subpart A section 1915.7 defines the competent person and the records that person must keep. Hot work in or adjacent to spaces that contain or last contained fuel or flammable liquids needs a Marine Chemist or Coast Guard authorized person certificate. Subpart I covers PPE and respiratory protection, Subpart P fire protection, and Subpart Z the exposure limits tank and hull work generates.
Source: 29 CFR Part 1915 as published on osha.gov, retrieved August 2026 — Subpart A–P index; §1915.7 Competent person (paragraphs (c)(1)–(c)(7) and (d)); §1915.12 Precautions and the order of testing before entering confined and enclosed spaces and other dangerous atmospheres (oxygen 19.5–22.0 percent, flammable vapours below 10 percent of the lower explosive limit, toxicity and the training certification at (d)(5)); §1915.14 Hot work; §1915.1000 Air contaminants; and the complete Subpart Z section index. Penalty amounts from osha.gov/penalties. Verified fact worth noting: Part 1915 Subpart Z contains no ionizing radiation section and does not incorporate 29 CFR 1910.1096, so radiographic source control for shipyard RT rests on the firm's NRC or Agreement State radioactive materials licence rather than on Part 1915.
| Item | What applies | Why it matters |
|---|---|---|
| Regime | 29 CFR Part 1915 — Occupational Safety and Health Standards for Shipyard Employment | Enforced by Occupational Safety and Health Administration (OSHA), US Department of Labor; State Plan agencies in states operating their own programmes |
| Method | Ultrasonic Testing (UT) | Needs its own procedure and its own qualified personnel |
| Procedure approval | The employer's Level III, qualified in this method | The signature an auditor traces |
| Other methods in scope | MT, PT, VT, RT | Each needs separate qualification |
| Renewal | No certificate and no renewal. The obligations are continuous: atmospheric testing before each entry and as often as necessary to ensure conditions are maintained, training and retraining as the employer's programme requires, and retention of competent person records for at least three months after completion of the job. Marine Chemist certificates are job- and condition-specific rather than periodic. OSHA's published maximum civil penalties, stated on osha.gov/penalties as the amounts assessable after 15 January 2026, are $16,550 per serious, other-than-serious or posting violation, $16,550 per day beyond the abatement date for failure to abate, and $165,514 per willful or repeated violation. | Applies to the personnel certification behind this method |
Does OSHA 1915 require a separate procedure for UT?
Yes. Every method in scope needs its own written procedure, approved by someone qualified in that method, describing technique, equipment, calibration, scanning or coverage, acceptance criteria and reporting. A single combined "NDT procedure" covering several methods is a finding under every regime that names procedures individually.
Who can approve a UT procedure under OSHA 1915?
A Level III qualified in UT. Because OSHA 1915 accepts employer-based certification, that Level III may be contracted rather than employed — but their own qualification must cover UT, and an auditor will check that before accepting the signature.
What UT records does a OSHA 1915 audit sample?
The approved procedure, the technician's UT certification on the date of work, and the equipment evidence — instrument, probes, cables, couplant, and the calibration and reference blocks used to set sensitivity. The auditor works backwards from a finished job, so every item has to reconcile with the report and its stated acceptance criteria.
What is the most common UT finding at audit?
An in-calibration instrument used with an unidentified or out-of-calibration reference block. It is a records failure rather than a technique failure — the examination was performed correctly and the evidence supporting it cannot be produced, which under OSHA 1915 is recorded the same way as not having done the work.
Can a technician certified elsewhere perform UT under OSHA 1915?
Not automatically. Employer-based certification ends when the holder leaves, so the new employer must certify them under its own written practice. Prior training and documented experience transfer as evidence; the certificate itself does not.
What equipment evidence does UT need under OSHA 1915?
Calibration status traceable to the day of use, covering the instrument and its accessories — probes, cables, blocks and reference standards for ultrasonics; sources and densitometers for radiography. An in-calibration instrument with an out-of-calibration reference block fails the same way as an uncalibrated one.
How do UT requirements differ from the other methods in OSHA 1915?
Scope, qualification and evidence are method-specific, so the differences are real rather than administrative. OSHA 1915 also covers MT, PT, VT, RT, and each carries its own procedure, its own personnel qualification and its own equipment evidence.
Personnel certification for UT
There is no NDT certification scheme here at all, and that is the confusion this regime creates. Part 1915 turns on the employer's own designation of a competent person, who under 1915.7(c) must understand and carry out instructions left by Marine Chemists, Coast Guard authorized persons and Certified Industrial Hygienists; know subparts B, C, D and H; calibrate and use oxygen, combustible gas, carbon monoxide and carbon dioxide indicators and interpret the results accurately; perform the required tests and inspections; judge when further testing by a Marine Chemist or Certified Industrial Hygienist is needed; and maintain the section's records. An outsourced Level III has no standing under Part 1915 unless the employer designates them and they meet 1915.7(c) in full.
Related: the OSHA 1915 overview, outsourced ASNT Level III cover, written practice development, NDT procedure development, a programme gap assessment, interim Level III cover.