Hot Work
» Testing and Certifying for Hot Work
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In a shipyard, typically two types of individuals
conduct tests and authorize spaces for hot work:
The Marine Chemist certifies spaces and equipment containing, or that have
previously contained, flammable and combustible materials, as well as all adjacent spaces. The
Shipyard Competent Person tests for and authorizes hot work locations that do not
require a Marine Chemist (their specific areas of jurisdiction are listed below). When a Marine chemist is
not available, a
US Coast
Guard Authorized Person (CGAP) can also conduct tests and
authorize spaces for hot work.
When the testing is complete and the spaces
are certified, workers are permitted to begin hot
work operations.
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.
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Certified Marine Chemist
(CMC)
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OSHA standards require a
Certified Marine Chemist (CMC) to test for hot work in confined and enclosed spaces, adjacent
spaces, and equipment (such as fuel tanks, cargo tanks, piping, pumps, and so
forth) containing, or that have previously contained,
flammable or combustible liquids or gases. Required tests include:
A marine chemist issues a certificate for hot
work, which must be posted. The Marine Chemist Certificate identifies the condition of
spaces, such as "Safe for Hot Work" or "Atmosphere
Safe for Workers." Spaces that are designated "Not
Safe for Workers" or "Not
Safe for Hot Work" must be labeled. [NFPA 306, 1915.14(a)
and 1915
Subpart D]
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Figure 1: Marine Chemist.
Figure 2: Marine Chemist certificate. |
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Shipyard Competent Person
(SCP)
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OSHA requires a
Shipyard Competent Person
(SCP) to test for hot work in certain spaces that do not require a Marine Chemist. A
Marine Chemist may conduct all the tests assigned to the
Shipyard Competent Person. [1915.7(b)]
The Shipyard Competent Person's testing responsibilities
include:
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Calibrating and maintaining test equipment. [1915.7(c)(4)]
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Inspecting and testing hollow structures such as skegs,
pipe stanchions, booms, and masts. [1915.54]
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Testing other spaces such as dry cargo holds, bilges, vessel modules, and landside
confined or enclosed spaces, not requiring Marine Chemist certification.
[1915.14(b)(1)]
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Conducting tests and visual inspections in order to maintain a Marine
Chemist Certificate.
The Shipyard Competent Person must complete the Inspection
Record, which must be posted. This record identifies conditions of
spaces, such as "Safe for Hot Work" or "Safe for
Workers." Spaces that are designated "Not
Safe for Workers" or "Not
Safe for Hot Work," must have warning signs and labels posted at
the entrance of the space. [1915.16] The shipyard must maintain and
make available a roster of shipyard competent persons. [1915.7(b)(2)(i)]
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Figure 3: A Shipyard Competent Person,
with PFD, testing tanks on a barge prior to authorizing entry.
Figure 4: Testing equipment.
Figure 5: Rudder - hollow space.
Figure 6: Testing and visual inspection to maintain
Marine Chemist Certificate.
Figure 7: Sample Competent Person
Inspection Record. |
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www.osha.gov
