Before performing cold work, prepare spaces for entry and work by:
A Shipyard Competent Person (SCP) must conduct atmospheric testing and
a visual inspection of the space. [See Confined
or Enclosed Spaces]
Following the pre-entry inspection, shipyard personnel must:
Preparation for cleaning and cold work also includes coordinating the
necessary personnel, equipment, and materials required for Cleaning
and Cold Work Operations.
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Removing Residues
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Residues often remain in spaces when the
vessel reaches the shipbreaking facility, even though the vessel's crew
may have off-loaded the cargo and pumped out and washed the spaces.
Potential Hazards:
- Residues may be toxic (for example, styrene, and urea), corrosive (for example, caustic
soda, and pencil pitch), or flammable/combustible (for example, crude oil,
and gasoline). These residues can cause illness, fire,
or explosion.
Requirements and Example Solutions:
- Liquid residues of hazardous materials must be removed from
work spaces as thoroughly as possible before employees begin cleaning operations. [1915.13(b)(1)]
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Figure 1: ADLER Tank used to suction residue from vessel tanks and other spaces
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Secure Piping and Pumping
Systems
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Potential Hazards:
Piping and pumping systems that enter the space may contain residual
liquids, flammable or combustible gases or vapor and toxic, corrosive, or irritant
materials. These materials may be released or inadvertently pumped
into the space, exposing workers to safety and health hazards.
Requirements and Example Solutions:
- Piping and pumping systems entering the work space must be disconnected, blanked off, and secured by a positive method, if they
are possibly carrying hazardous materials. [1915.15(a)]
- Pumps within the system must be secured (for example, disabled). [1915.15(a)]
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Figure 2: Marine Chemist verifying that piping into space to be cleaned is properly blanked
off.
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Determine Ventilation Needs
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Potential Hazards:
- Workers entering a space containing flammable, combustible,
toxic, corrosive or irritant vapors, mists, or gases are at risk
of fire and explosion, as well as health hazards.
- Cleaning operations may also generate concentrations of flammable, combustible,
toxic, corrosive or irritant vapors, mists, or gases through interaction of cleaning agents, or
reactions of cleaning agents with residues.
Requirements and Example Solutions:
- Testing must be conducted by a Shipyard Competent Person (SCP) to determine
the concentration of flammable, combustible, toxic, corrosive,
or irritant vapors within the space.[1915.13(b)(2)]
- Continuous ventilation must be provided at volumes and flow
rates sufficient to ensure that the concentrations of:
- Flammable vapor is maintained below 10 percent of the lower
explosive limit. [1915.13(b)(3)(i)]
- Toxic, corrosive, or irritant vapors are maintained within
the permissible exposure limits and below IDLH. [1915.13(b)(3)(ii)]
- All air-moving equipment and its component parts, including
duct work, capable of generating a static electric discharge of
sufficient energy to create a source of ignition must be
electrically bonded to the structure of a vessel or vessel section,
or
in the case of landside spaces, grounded to prevent an electric
discharge in the space. [1915.13(b)(11)]
- Fans must have non-sparking blades and portable air ducts
shall be of non-sparking materials. [1915.13(b)(12)]
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Figure 3: Work area inside vessel not yet properly illuminated.
Figure 4: Shipyard Competent Person testing space to determine how much ventilation will be
needed for safety.
Figure 5: Ventilation equipment.
Figure 6: Sign warning workers to carry flashlight. |
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Posting Warning Signs
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Potential Hazards:
Without adequate warnings, workers may enter unsafe spaces and be exposed to safety
and health hazards. In addition, workers that are unable to read
or understand signs are not protected.
Requirements and Example Solutions:
- Posted signs or labels must be presented in a manner (languages or symbols) that can be perceived and understood by every worker. [1915.16(a)]
See Figure 7.
- If the space contains an oxygen-deficient
or oxygen-enriched atmospheres, the space must be labeled "Not
Safe for Workers" and workers must not enter until the oxygen content is between 19.5 percent and 22 percent. [1915.12(a)(2)]
See Figure 8.
- If the concentration of flammable vapors or gases in the space is equal to or greater than 10 percent
of the lower explosive limit (LEL) the space must be labeled "Not
Safe for Workers" and workers must not enter until the concentration of flammable vapors is maintained below 10 percent of
the LEL. [1915.12(b)(2)]
- If the space contains an air concentration of a material which exceeds a Part 1915 Subpart Z permissible exposure
limit (PEL) or is IDLH, the space shall be labeled "Not
Safe for Workers." [1915.12(c)(2)]
- The shipyard competent person report and/or marine chemist
certificate must be posted in the immediate vicinity of the
effected operation while work is in progress. [1915.7(d)(2)
and
1915.14(a)(2)]
- Signs prohibiting sources of ignition within or near
spaces that previously contained flammable or combustible
liquids or gases must be posted at the entrance to those
spaces, in adjacent spaces, and in the open area
adjacent to those spaces. [1915.13(b)(10)]
- A warning sign or label may be posted at the means of
access if the entire work area has been tested. [1915.16(b)]
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Figure 7: A clearly understood warning sign.
Figure 8: A space containing insufficient oxygen to enter safely is properly labeled.
Figure 9: Posted results of Shipyard Competent Person testing of space.
Figure 10: SCP report and other warning signs at gangway entrance to vessel.
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Determine Illumination
Needs
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Potential Hazards:
- Workers entering spaces containing flammable or
combustible vapors and gases are at risk of fire and
explosion if the space also contains improper electrical
equipment.
- Inadequate illumination in a space can lead to injuries
from slips,
trips, and falls.
- Workers entering inadequately illuminated spaces may become disoriented and fail to find the exit.
This prevents the worker from safely exiting the space.
- Inadequate illumination can prevent workers from safely
performing tasks.
Requirements and Example Solutions:
- Only explosion-proof, self-contained portable lamps (for example, explosion-proof flashlight) or other electric
equipment approved for hazardous locations by a National Recognized Testing Laboratory
(NRTL), shall be used until the space is deemed "Safe
for Workers." [1915.13(b)(9)]
See Figure 11.
- All means of access and walkways leading to work areas as well as working areas themselves must be adequately illuminated. [1915.92(a)] See Figure 12.
- Temporary lights must meet the requirements of
1915.92(b)
and
(c).
- Where temporary lighting from sources outside the vessel
is the only means of illumination, portable emergency
lighting equipment must be available to provide
illumination for employees to move about safely. [1915.92(d)]
- Employees must not be permitted to enter dark spaces
without a suitable portable light. [1915.92(e)]
- The use of matches and open-flame lights is prohibited.[1915.92(e)]
- In non-gas free spaces, portable lights must meet the
requirements of
1915.13.
[1915.92(e)]
- All illumination equipment must meet the requirements of
1915.92.
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Figure 11: Explosion-proof light for hazardous locations.
Figure 12: Proper temporary lighting.
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Select PPE for Workers |
Potential Hazards:
- The use of toxic, corrosive, irritant, or high pressure/temperature cleaning agents
and their
application equipment, may put the safety and health of workers
at risk.
Requirements and Example Solutions:
- A hazard assessment must be made to determine the appropriate
PPE. [1915.152(b)]
- Also see the PPE requirements for specific cleaning
operation hazards that may be encountered:
Additional Resources:
See the Shipbreaking: PPE module for information on general PPE
requirements and example specific cleaning operation PPE.
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Figure 13: Containers of cleaning materials labeled with their hazards.
Figure 14: Assessment of asbestos hazard.
Figure 15: A good hazard assessment results in proper PPE for the job.
Figure 16: Burner wearing ear muffs. |
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