In shipyard employment, 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
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 then permitted to begin
hot
work operations.
Note:
During shipbuilding operations, the need for testing by a SCP
and CMC will depend on the progress of the vessel construction.
Until there is a potential for a hazard, such as after the introduction
of flammable liquids, testing may not be required.
Note: Confined space entry is one of the leading
hazards associated with barge cleaning. Review the
Shipbuilding: 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) |
Certified Marine Chemists (CMC) are required to test for hot work in confined and enclosed spaces, adjacent
spaces, and equipment (such as fuel tanks, cargo tanks, piping, pumps, etc.) containing, or that have previously contained,
flammable or combustible liquids or gases. Tests to be performed include:
A marine chemist issues a certificate for hot
work, which must be posted. The Marine Chemist Certificate identifies 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. [1915.11,
1915.14(a), 1915
Subpart P, and NFPA 306]
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Figure 1: Marine Chemist
testing enclosed space.
Figure 2: Marine Chemist certificate. |
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Shipyard Competent Person
(SCP) |
A
Shipyard Competent Person
(SCP) is required to test for hot work in certain spaces that do not require a Marine Chemist.
However, the employer may use a
Marine Chemist to conduct all the tests required by a Shipyard Competent Person. [1915.7(b)]
The Shipyard Competent Person's testing responsibilities
include:
- Calibrating and maintaining test equipment. [1915.7(c)(4)]
-
Testing and inspecting hollow structures including: [1915.54]
- skegs,
- pipe stanchions and handrails,
- booms,
- masts, and
- rudders.
- Testing and inspecting spaces not requiring Marine Chemist certification
including:
[1915.14(b)(1)]
- dry cargo holds,
- bilges,
- vessel modules,
- tanks, and
- landside
confined or enclosed spaces,
- Conduct tests and visual inspections to maintain a Marine
Chemist Certificate. [1915.15(c)]
Exception: On dry cargo, miscellaneous (such as tugs, barges, supply
boats, etc.) and passenger vessels and in the landside operations within
spaces which meet the standards for oxygen, flammability and toxicity in
1915.12, but are adjacent to spaces containing flammable gases or liquids,
as long as the gases or liquids have a flash point below 150 deg. F (65.6
deg. C) and the distance between such spaces and the work is 25 feet
(7.5m) or greater.
Note: For flammable liquids with flash
points above 150 deg. F (65.6 deg. C), see paragraph (b) of this section.
[1915.14(a)(1)(iv)]
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: Shipyard Competent Person,
with PFD, testing tanks on a barge prior to authorizing entry. Note:
Fall protection to be installed after testing for initial
entry.
Figure 4: SCP testing equipment.
Figure 5: Rudder being inspected for structural voids.
Figure 6: Testing and visual inspection to
maintain Marine Chemist Certificate.
Figure 7:
Sample Competent Person
Inspection Record. |
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