
Figure 1:
Workers using suction hose for removing residue from below deck.

Fig 2: Containers of cleaning materials.

Figure 3:
Workers wearing filter respirator, ear muffs and other PPE. |
Cleaning and cold work in shipbreaking may
include tank cleaning, mucking, or wiping down salvaged equipment.
After the spaces are evaluated by the Shipyard Competent
Person (SCP), Certified Marine Chemist (CMC), or Certified Industrial
Hygienist (CIH), the personnel, equipment, and materials required for the cleaning and cold
work must be determined. In
addition, a hazard assessment must be conducted for selecting appropriate
personal protective equipment (PPE).
See PPE for Cleaning Operations.
[1915.152(b)]
Cleaning agents may include:
Hazards associated with cleaning and cold work include:
Note: Confined space entry is one of the leading
hazards associated with barge cleaning. Review the
Shipbreaking: Confined/Enclosed
Spaces and Other Dangerous Atmospheres
chapter for information on how to protect workers from this hazard.
| Toxic
Cleaning Solvents
(for example, mineral spirits, diesel fuel, degreasers)
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Cleaning and cold work may range from simply wiping down equipment to totally stripping off coating. Cleaning solvents and degreasers may expose workers to:
In
addition, a hazard assessment must be conducted for selecting appropriate PPE.
See
PPE for Cleaning Operations.
[1915.152(b)]
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Chemical Removers (for example, paint stripper, methylene chloride)
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Chemical paint strippers and removers used for cleaning include
corrosive acids, (for example, hydrochloric and phosphoric), alkalis (e.g., sodium hydroxide/lye),
chlorinated hydrocarbons (for example, trichloroethane) and carcinogens (for example, methylene
chloride). These chemicals may present severe eye, skin, and respiratory exposure hazards.
Paint strippers and removers potentially expose workers to:
In
addition, a hazard assessment must be conducted for selecting appropriate PPE.
See
PPE for Cleaning Operations.
[1915.152(b)]
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Figure 4: Fall hazards present in area where paint is removed from vessel hull.
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Flammable and Combustible Liquids |
Flammable and combustible liquids are used in
shipbreaking operations for cleaning tanks and equipment. The use, storage,
and containment of these materials may expose workers to:
In
addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [1915.152(b)]
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Figure 5: Cleaning equipment tank (ADLER) containing flammable liquids.
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Fire and Explosion |
Potential Hazards:
Fire and explosions may be caused by:
- Flammable and combustible cleaning
solvents such as Methyl Ethyl
Ketone (MEK), mineral spirits, and diesel fuel or oil.
- Liquids with high flash points
(greater than 100º F) applied as a fine mist.
- Airborne particulate or dust.
- Hydrogen gas generated during cleaning processes.
- Reactive cargos such as iron-ore, fertilizer, or incompatible
chemicals.
- Painting. See Painting [1915.35]
Requirements and Example Solutions:
- Hot work
must not be
performed in the space and/or adjacent spaces when flammable or
combustible cleaning solvents are being used. [1915
Subpart P]
- Rags soaked with solvents must be placed in covered metal
containers. [1915.36(a)(3)]
- No smoking or open flames should be allowed. [1915.36(a)(1)]
- Arcing and sparking equipment and tools must not be used. [1915.36(a)(1)]
- Equipment that may generate static electricity such as ventilation
systems must be grounded/bonded. [1915.13(b)(11)].
- Explosion-proof
lights must be used. [1915.36(a)(4) and
1915.13(b)(9)]
- Adequate ventilation must be maintained (less than 10 percent of
lower explosive limit (LEL)). [1915.13(b)(3)
and 1915.36(a)(2)]
- Frequent tests shall be required during cleaning operations to determine if air concentrations are below 10
percent of
the LEL. [1915.36(a)(2)]
- The Shipyard Competent Person
(SCP) must test the exhaust location to ensure that exhausted vapors do
not accumulate to hazardous levels. [1915.13(b)(7),
(b)(8),
(b)(11),
and (b)(12)]
- Suitable fire fighting equipment must be immediately available. [1915.36(a)(6)
and 1915
Subpart P]
- Personnel using fire fighting equipment must be instructed in
anticipated fire hazards and how to use the equipment. [1915
Subpart P]
- Spills of solvents must be cleaned up immediately. [1915.13(b)(5)]
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Figure 6: Improper practice: Worker covered with flammable oil.

Figure 7: Warning Sign is posted to alert workers of the fire and explosion hazard of painting.

Figure 8: Ventilation equipment used to maintain safe conditions for entry.

Figure 9: Worker testing space to see that safe conditions are maintained during cleaning.

Figure 10: Fire extinguishers located near cleaning operations. |
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Excessive Noise |
Potential Hazards:
Use of high-pressure cleaning equipment may produce high levels of
noise, which could lead to permanent hearing loss, and often necessitates a hearing
conservation program. An example of an excessively loud operation is:
- Use of high-pressure water and steam guns
Requirements and Example Solutions:
Additional Resources:
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Figure 11: Workers exposed to noise from pressure washing.

Figure 12: Workers wearing ear muffs for protection from excessive noise. |
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Biological Hazards |
Potential Hazards:
Some operations expose employees to biological hazards from sewage and human
waste, fungi and molds, and decomposing organic products.
- Collection, holding, and transfer (CHT) tanks, which workers are often required to enter and clean, may
contain dangerous, even fatal, levels of hydrogen sulfide or other
toxic gases, which are products of decomposing human waste.
- Toxic spores inhaled from fungi and molds growing on grain and
lumber may pose an inhalation hazard.
Requirements and Example Solutions:
- Employees shall be
trained to recognize the potential hazards, use proper work practices,
recognize adverse health effects, and understand the physical signs
and reactions related to exposures. They shall also be trained
to select and use appropriate PPE. [1915.12(d)(2)
and 1915.1200]
- Personal hygiene is required. [1915.97]
This includes the following:
- Decontamination (removal of biological matter from PPE and
equipment)
- Showers (removal of biological matter from the worker) [1910.141]
- Proper disposal of laundry/coveralls (prevention of exposure to
others)
Additional Resources:
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Figure 13: CHT tank poses hydrogen sulfide gas and other hazards.

Figure 14: Worker removing trash from work area.

Figure 15: Washing station for workers. |
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Maritime
Labor/Industry Recommendations |
- Maritime Labor/Industry recommends having a Bloodborne Pathogen program.
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Slips and Trips
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Potential Hazards:
Workers performing cleaning and cold work operations are exposed
to slippery working surfaces and tripping hazards. This places
workers at risk of:
- Slipping off oily and greasy ladders
- Slipping and falling on oily decks
- Tripping over equipment, hoses, and vessel structures
Requirements and Example Solutions:
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Figure 16: Hoses and welding leads present tripping
hazard.

Figure 17: Temporary lighting reduces tripping hazards.

Figure 18: Tripping hazards eliminated by raised walkway. |
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High-Pressure
Hazards
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Potential Hazards:
The use of high-pressure cleaning equipment may expose the
operator and other workers in the area to the following hazards:
-
Contact with high-pressure steam, water, or air streams from cleaning
equipment
-
Contact by uncontrolled high-pressure hoses
-
Contact with steam, water, or air leaks in the high-pressure
equipment
Injuries associated with these hazards include:
-
Loss of body parts such as fingers, hands, etc.
-
Lacerations
-
Burns
-
Loss of sight
Requirements and Example Solutions:
- Steam guns must be insulated to prevent heat burns to the
operator. [1915.33(e)]
- Appropriate PPE shall be used. [1915.152]
- Access to the area should be controlled.
- Hoses and connections should be inspected before use.
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Figure 19: Workers exposed to hazards of high
pressure water.

Figure 20: Worker protected by PPE from high pressure hazards.

Figure 21: Hoses and connections should be inspected. |
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Electrical Hazards
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Potential Hazards:
Employees who work with electrical equipment in wet or damp
locations have an increased risk of getting shocked or electrocuted
due to:
- Exposed energized electrical parts
- Open lighting parts
- Damaged insulation on power cords
Requirements and Example Solutions:
- Portable electrical tools must be grounded or double
insulated. [1915.132(a)]
- Temporary lighting must be grounded. [1915.92(c)]
- Power and lighting cables must be inspected by a person
competent to evaluate electrical hazards. (Note: This
is not the Shipyard Competent Person). [1915.36(a)(5)]
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Figure 22: Damaged electrical cable poses shock hazard.

Figure 23: Portable power tools must be grounded or double insulated.

Figure 24: Temporary lights should be inspected before use. |
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Maritime
Labor/Industry Recommendations |
- All electrical tools or equipment should undergo a visual
inspection before use.
- All portable electric hand tools and temporary lighting
systems should use Ground Fault Circuit Interrupters (GFCI).
- Electrical tools and equipment should correspond with the
requirements of the job.
- Electrical equipment and tools should be used with proper
circuit protection for the voltage and amperage used.
- Only qualified electricians should attempt repair of
electrical tools and equipment in use.
- A Ground Assurance Program should be in place for all
electrical tools and equipment used including:
- Records of tools inspected and repaired
- Records of electrical boxes inspected and repaired
- Records of electrical extension cords inspected and
repaired
- Recall of records of the above
- The requirements of the Ground Assurance Program should be performed on a
regular basis.
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