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General OCS Frequently Asked Questions (FAQs)

Please find  answers to commonly asked questions related that pertain to an OCS activity below, regardless of unit or vessel type that is conducting the activity.

Answers in this FAQ section are not a substitute for applicable legal requirements, nor are they rules (however, some questions may have an answer that comes directly from existing regulation or policy). The answers are not intended to require or impose legally binding requirements on any party. Answers provided represent the OCSNCOE’s current thinking, after researching existing regulations and policy, as well as consultation with Coast Guard Subject Matter Experts. These answers are intended to assist industry, mariners, the public, the Coast Guard and other regulators in applying statutory and regulatory requirements. When available, the FAQ will direct the reader to the official documents, such as the Federal Register, the Code of Federal Regulations or NVICs and policies. The answers provided are subject to change with regulatory or policy updates.

General Policy

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MSM Vol II is the most commonly used by Coast Guard Marine Inspectors during various inspection activities and is the context of this FAQ.

The MSM is a guidance document to aid in interpretation of applicable laws and regulations. It essentially builds on the regulatory requirement, as far as how to consistently apply and verify a particular requirement. The manual is not a regulation in itself.

The MSM is divided into Volumes:
Vol I: Administration and Management; CIM 16000.6
Vol II: Materiel Inspection; CIM 16000.7B
Vol III: Marine Industry Personnel; CIM 16000.8B
Vol IV: Technical; CIM 16000.9
Vol V: Investigations and Enforcement; CIM 16000.10A
Vol VI: Ports and Waterways Activities; CIM 16000.11

The excerpt that follows comes from Change 2 of MSM Volume II (Materiel Inspection), from the part that is entitled "Purpose of Marine Safety Manual, Volume II..." (MSM II/A.1.E.2 on page A1-13):

"The following chapters contain information and guidance intended to promote consistent interpretation and application of U.S. and international laws and regulations related to merchant vessel inspections. The regulations and the guidance contained in this volume are not intended to cover all contingencies that may be encountered during vessel inspections. This manual generally does not restate requirements that are specifically and clearly covered in the law, Federal regulations, or international conventions. There is no substitute for experience and sound judgment to ensure that good marine practice is being followed. In addition, any information in this volume may be supplemented, altered, or waived in specific cases by the Commandant, district commander, or OCMI. To that end, it is imperative that the OCMI maintain a current and complete library containing the applicable laws and regulations."

The standard regulatory disclaimer applies, as listed on Commandant Change Notice 16000, dated 20Jul2016, promulgating the release of CH-2 to MSM Vol II:
"This guidance is not a substitute for applicable legal requirements, nor is it itself a rule. It is intended to provide operational guidance for Coast Guard personnel and is not intended to nor does it impose legally-binding requirements on any party outside the Coast Guard."

Personal Protective Equipment

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33 CFR 142.39(a) requires personnel to wear the type of respiratory protection for the atmospheres listed in American National Standards Institute (ANSI) Z88.2. The 1980 edition of this standard is listed as an incorporation by reference (IBR) at 33 CFR 140.7 (ANSI Z88.2-1980). However, the language contained within 33 CFR 142.39 does NOT reference the standard in its entirety, but makes reference to specific sections, or portions, of the standard. Note that those specific sections may refer to other sections within the standard.

33 CFR 142.39(b) requires the lessee, permittee and persons responsible for the actual operations (persons listed in §142.4) to ensure that the personnel that are entering an atmosphere specified within ANSI Z88.2-1980 follow the respirator selection, fit-testing and training requirements of the standard.

§142.39(c) also requires the equipment to be approved, used and maintained in accordance with the standard.

The following chart lists the sections of ANSI Z88.2-1980 that apply to any facility, unit or vessel that is subject to 33 CFR Subchapter N (i.e., while engaged in an OCS activity):

Subject Z88.2-1980 Citation Reference Cite
Definitions 2 Various
Selection of Respirators 6 (entire section) 33 CFR 142.39(b)(1)
Respirator Fit-Testing 6.11, 6.12 and Appendix A5 & A6 §142.39(b)(1)
Training (for wearer) 7.2.3 §142.39(b)(2)
   - Reasons for need 3.2 Z88.2/7.2.3(1)
   - Respiratory hazards & effects 4 & 6.3 §142.39(c); Z88.2/7.2.3(2)
   - Engineering Controls 3.2 Z88.2/7.2.3(3)
   - Respirator selection 6 Z88.2/7.2.3(4)
   - Respirator operation, capabilities & limitations 5, 6.5 & 6.6 Z88.2/7.2.3(5)
   - Respirator inspection, donning, fit-check & wear 7.4 & 7.6 Z88.2/7.2.3(6)
   - Respirator wear in safe & test atmospheres 7.4 & 7.6 Z88.2/7.2.3(7)
   - Maintenance & storage 8 Z88.2/7.2.3(8)
   - Recognizing & coping with emergency situations 7.1.1 Z88.2/7.2.3(9)
   - Special use/problems (as needed) 9 Z88.2/7.2.3(10)
Respirator approval 6.1, Appendix A3 §142.39(c)
   - Exceptions 1.4 Z88.2/6.1
Respirator use 7.3 thru 7.9 and Appendix A7 & A8 §142.39(c)
Respirator maintenance 8 (entire section) §142.39(c)
Special problems 9 (entire section) §142.39(c)
Oxygen deficiency/IDLH A10 Z88.2/Table 1


The respirator program requirements (e.g. Sections 3 and 10) of ANSI Z88.2-1980 are NOT invoked by 33 CFR 142.39, nor implied by any of the Federal Register (FR) Notices related to the rulemaking projects that added §142.39. The discussion of comments in the FR reveal that the worker is to be provided with the necessary equipment and training, with the persons listed at §142.4 additionally responsible for making the worker aware of the effects of not using respiratory protection when required.

Yes, but only for negative-pressure respirators. 33 CFR 142.39(b)(1) requires compliance with ANSI Z88.2-1980, section 6, for individual fit testing. 6.11 of the standard requires fit-testing (qualitative or quantitative) to determine the ability of each individual wearer to obtain a satisfactory fit. It also requires each wearer of a negative-pressure respirator to be fit-tested at least annually. Fit-testing is NOT required for positive-pressure respirators.

Each respirator wearer must be trained prior to use and retrained at least annually. 33 CFR 142.39(b)(2) requires the wearer to be trained in the matters listed in ANSI Z88.2-1980, section 7, which could be interpreted as a ‘one-time’ training. However, §142.39(c) requires “use” in accordance with the standard and 7.2.3.2 of the standard requires annual retraining.