Written Practice for OSHA 1915
OSHA 1915 names this requirement as "Written certification of confined space training under 1915.12(d)(5), giving the employee's name, the name of the certifier and the date(s)". The employer's Level III owns it, and a contracted Level III can author and sign it.
The finding auditors record against this document is: No written certification of confined space training naming the employee, the certifier and the date. 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 |
| Document | Written Practice | the document that defines how the employer qualifies and certifies its own NDT personnel |
| Owner | the employer's Level III | The signature an auditor traces back |
| Where it is checked | Closing conference; citations issued with proposed penalties and abatement dates; Abatement certification submitted, or the citation contested within. | Usually against a sampled job, not in isolation |
| Common failure | Atmospheric testing performed out of order — flammability or toxicity checked before oxygen content, which 1915.12 sequences explicitly | The gap between the manual and the job file |
What must a written practice contain under OSHA 1915?
It has to satisfy OSHA 1915 as Occupational Safety and Health Administration (OSHA), US Department of Labor; State Plan agencies in states operating their own programmes enforces it: the document that defines how the employer qualifies and certifies its own NDT personnel. The test is not completeness on paper but traceability — an auditor picks a finished job and works backwards to this document, so anything it claims must be demonstrable on that job.
Who signs the written practice for OSHA 1915?
The employer's Level III. Because this regime accepts employer-based certification, that role can be filled by a contracted Level III rather than a staff appointment, provided they are qualified in the methods they sign for.
How does a OSHA 1915 auditor test this document?
By sampling. They take a completed job, find the technicians and equipment used, and trace each back through this document to the evidence behind it. A document that reads well but cannot survive that trace is the most common finding across every regime, not just this one.
How long must OSHA 1915 records be kept?
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. Retention is set by the regime and by the client contract above it, and the longer of the two governs. Firms that set one retention period for everything and document it fare better at audit than firms tracking different periods per record type and losing track.
Does a generic template satisfy OSHA 1915?
No. A downloaded template describes a generic firm, and the first question an auditor asks is whether the document describes THIS firm — its methods, its equipment, its people, its actual workflow. Templates are a starting structure; the content has to be the firm's own or the trace fails immediately.
What happens if this document is missing at a OSHA 1915 audit?
It is a finding, and depending on the regime it can suspend the certificate rather than merely generate a corrective action. The related finding auditors record most often is: Atmospheric testing performed out of order — flammability or toxicity checked before oxygen content, which 1915.12 sequences explicitly
Where this sits in the OSHA 1915 evidence pack
- Competent person records under 1915.7(d): location, time, date, location of the inspected spaces, the operations performed, test results and any instructions — posted near the space and retained at least three months after the job is completed
- Marine Chemist certificate or Coast Guard authorized person certificate where hot work falls under 1915.14(a)
- Written certification of confined space training under 1915.12(d)(5), giving the employee's name, the name of the certifier and the date(s)
- Calibration records for oxygen, combustible gas, carbon monoxide and carbon dioxide indicators
- Written respiratory protection programme, medical evaluations and fit-test records (1915.154)
- Hazard communication programme and safety data sheets (1915.1200)
- Exposure monitoring and medical surveillance records under the applicable Subpart Z substance standards — lead (1915.1025), chromium (VI) (1915.1026), respirable crystalline silica (1915.1053), asbestos (1915.1001)
- Personal fall arrest system inspection and training records (1915.159)
Personnel certification context
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.