OSHA Considerations for Marina Employee Training

Marina employees are an integral part of the daily operations of marinas and yacht clubs. These personnel perform a wide range of tasks and are often required to have extensive knowledge and training in complex marina operations. For marina owners, it is important to remember that there may be regulatory requirements for employee training. Regulators like the Occupational Safety and Health Administration (OSHA) mandate specific training for marina employees. As a risk management strategy working in concert with marina insurance, training that meets regulatory standards serves to protect marina employees, facilities, and customers alike.

Marina Size and Employee Training Under OSHA Regulations

Since the passage of the Occupational Health and Safety Act in 1970, employers have been required to provide their employees with information and training on workplace hazards at the time of the employee’s initial hiring. Overseen by OSHA, training may also be required as an ongoing practice for marina employees.

The size of a given business determines the training and recordkeeping processes that marinas must adhere to. For smaller facilities with under 11 employees, those marinas are considered small businesses under OSHA guidelines. Facilities with 11 or more employees are considered large businesses. Many marinas operate seasonally, hiring additional seasonal personnel, and may fluctuate above or below the 11-employee threshold. In those cases, it is important to count the number of employee W-2s generated in any given calendar year; once the eleventh is reached, the marina is considered a large business. These marinas should consider following training guidelines for larger businesses even if they do not always employ 11 or more personnel.

Documentation and Recordkeeping

Whether a marina operation is classified as a small or large business under OSHA guidelines determines what is required in terms of training documentation and recordkeeping. For smaller businesses, these requirements are fairly basic. To meet OSHA requirements, a small business can:

• Host a safety meeting or briefing on a particular safety topic; for example, a briefing on fuel system use or fire prevention.
• Create and circulate a document that lists the date of the meeting, the topic discussed, and collects the signatures of employees attending the briefing.

Large businesses have additional recordkeeping requirements. In addition to the two requirements above, large businesses must also provide an outline of the training topic and content to OSHA.

Documentation and recordkeeping for training is only one part of the requirements mandated by OSHA. No matter the size or makeup of the marina operation, marina owners must have certain policies and procedures documented and available to employees. These may include:

• Emergency action plans
• Pollution/spill response plans
• Exposure to blood-borne pathogens plans
• Chemical handling and storage policies
• Policies on personal protective equipment (PPE), including respirators
• Slip and fall hazard protection policies
• Fire protection plans

A Range of Training Options for Marina Employees

Marinas and yacht clubs across the country provide a range of services for their clients. Some are basic, only offering launching, dockage, and fuel services, while others may include amenities like shops, restaurants, long-term storage, maintenance, and recreation options. Because of the diversity inherent in marina operations, training needs and requirements for employees may vary immensely. The type of marina employee may necessitate specific training as well; seasonal dock hands may only require basic safety and procedure training, while service technicians and dockmasters may need specialized training.

Training programs for marina employees may include:

• Dock Hand Training
• Fueling and Pumpout Equipment Operation
• Spill Response
• Electrical Safety/Electric Shock Drowning (ESD) Response
• Fire Prevention
• PPE Use
• Hazardous Chemical Storage and Handling
• Heat Related Illnesses and Emergency First Aid

Again, specific requirements for certain classes of marina employees may apply. It is a good practice to review OSHA standards or to speak with an OSHA inspector to verify training requirements. Finally, it is crucial that marina owners and operators understand that failure to adequately train employees or to maintain records may result in significant penalties. OSHA inspections have cost marine facilities hundreds of thousands of dollars in fines. By implementing training programs, marinas can better protect their employees and guests while managing the risks and expenses associated with violations of established regulations.

About Merrimac Marine Insurance

At Merrimac Marine, we are dedicated to providing insurance for the marine industry to protect your clients’ business and assets. For more information about our products and programs, contact our specialists today at (800) 681-1998.