1. Liquids/substances with flashpoints above 80º F.
2. Liquids/substances with flashpoints below 80º F.

• Hot work must not be performed in the space or adjacent spaces during painting operations. [1915.36(a)(1) and 1915 Subpart P]
• Rags soaked with solvents must be kept in covered metal containers. [1915.36(a)(3) and 1915.91(e)]
• Paints, thinners, and solvents must be kept in fire-resistant covered containers when not in use. [1915.91(e)]
• Smoking and open flames must be prohibited in the area. [1915.36(a)(1)]
• Arc and spark producing equipment and tools must not be used. [1915.36(a)(1)]
• Equipment that may generate static electricity (e.g., ventilation systems) must be grounded/bonded to the vessel's structure. [1915.35(a)(4)]
• Only approved explosion-proof lights must be used. [1915.36(a)(4)]
• Adequate ventilation must be maintained in storage, mixing, and transfer areas. [1915.36(a)(2)]
• Frequent tests by a Shipyard Competent Person (SCP) must be required during painting operations to determine if air concentrations are below 10 percent of the lower explosive limit (LEL). [1915.36(a)(2)]
• Suitable fire fighting equipment must be immediately available. [1915.36(a)(6)]
• 30-gallon drums and containers of flammable or toxic liquids must be placed in an area where they will not be subject to physical damage. [1915.173(d)]
• 55-gallon drums containing flammable or toxic liquids must be surrounded by dikes or pans. [1915.173(e)]
• Power and lighting cables must be inspected by a person competent to evaluate electrical hazards, and ensure that there are no connections within 50 feet of the painting operations (not necessarily the Shipyard Competent Person). [1915.36(a)(5)]

• Sufficient exhaust ventilation must be provided to keep the concentration of solvent vapors below 10 percent of the LEL. Frequent tests must be made by a shipyard competent person (SCP) to determine concentrations. [1915.35(b)(1)]
• If the concentration exceeds 10 percent of the LEL, work must be stopped until the concentration falls below 10 percent of the LEL. [1915.35(b)(2)]
• Ventilation must be continued after painting is completed until the space or compartment is "gas-free." [1915.35(b)(3)]
• Exhaust ducts must discharge clear of working areas and away from sources of possible ignition. [1915.35(b)(4)]
• Periodic tests must be conducted by the Shipyard Competent Person to ensure that the exhausted vapors are not accumulating in other areas within or around the vessel or dry dock. [1915.35(b)(4)]
• Explosion-proof motors, fan blades, and portable air ducts must be non-ferrous. [1915.35(b)(5)]
• All footwear worn during painting operations must be non-sparking. [1915.35(b)(9)]
• PPE must not produce static electrical sparks. [1915.35(b)(9)]
• No matches, lighted cigarettes, cigars, pipes, cigarette lighters, or other ferrous articles are allowed into the work area. [1915.35(b)(10)]
• All solvent drums taken into the compartment where painting operations are being performed must be placed on nonferrous surfaces and grounded to the vessel. [1915.35(b)(11)]
• All metallic parts of paint spraying equipment must be electrically bonded and the assembly grounded to the vessel. [1915.35(b)(12)]
  
   

• A hazard assessment must be conducted to determine the proper selection of respirators. [1915.152(b)]
  • The components of epoxy, isocyanate, anti-fouling, and coal tar pitch paints may be particularly dangerous to workers' health and requires special precautions.
  • Many of these paints cause respiratory, skin sensitization and allergic reactions, which may be life threatening.
  • Respirators must be used in accordance with the PPE section 1915.154. [1910.134]

• Continual Air Monitoring
  • The Shipyard Competent Person (SCP), Certified Marine Chemist (CMC), or Certified Industrial Hygienist (CIH) may require continual monitoring to determine that vapor/mist air concentrations are within the permissible exposure limit (PELs) and below immediately dangerous to life or health (IDLH) levels while workers are in the area.
  • If the concentrations are above appropriate levels, additional administrative controls (e.g., exposure time limits), engineering controls (e.g., ventilation), or PPE (e.g., respirators) are required.

• Use of Airline Respirators
  • Airline respirators are required in confined spaces to protect employees who are continuously exposed to toxic materials during coating operations. [1915.35(a)(1)(i)]
  • Airline respirators are required in enclosed spaces to protect workers when mechanical ventilation is not provided, [1915.35(a)(1)(ii)] or when the flash point of the paint or solvent is less than 80º F. [1915.35(b)(13)]

• Use of Air Purifying Respirators (Filter Respirators)
  • In tanks and compartments where mechanical ventilation is provided, employees continuously exposed must be protected by filter respirators, at a minimum, in accordance with Subpart I (1915.154). [1915.35(a)(1)(ii)]
  • In large and well-ventilated areas, employees exposed to spray painting must be protected by filter respirators in accordance with Subpart I. [1915.35(a)(1)(iii)]
  • All employees doing exterior spray painting with material containing solvents with flash points below 80º F must be protected by suitable filter cartridge-type respirators, at a minimum, in accordance with Subpart I (1915.154). [1915.35(b)(14)]
  • Employees continually in a compartment where spray painting is being done with paints containing solvents with a flash point below 80º F, for a limited time, must be protected with filter cartridge type respirators, at a minimum, in accordance Subpart I. [1915.35(b)(13)]

• Air Purifying Respirators (Filter Respirators). [1915.154]
• When brush application of paints containing toxic solvents in confined spaces or in other areas where lack of ventilation creates a hazard, employees must be protected by suitable filter respirators at a minimum in accordance with Subpart I (1915.154). [1915.35(a)(2)]

Additional Resources:

• Ventilation. Ship Repair: Confined or Enclosed Space module.
• Respiratory Protection Advisor. OSHA.
• Inspection procedures for the Respiratory Protection Standard. OSHA Instruction CPL 2-0.120 (1998, September 25).

• Organ damage through chemical absorption through the skin or eyes;
• Chemical burns, irritation, sensitization, and allergic reaction to skin or eyes; and
• Ingestion of food contaminated with toxic materials due to poor hygiene.

• A hazard assessment for each operation and condition must be conducted to determine the proper selection of PPE. [1915.152(b)] This assessment should include:
  • The nature of the hazardous materials involved;
  • Anticipated concentrations of the materials;
  • How the materials will be used;
  • Performance of the PPE; and
  • Actions workers will perform.
• All body parts, including face, eyes, head, and hands must be protected from highly volatile paints. [1915.35(b)(9)]
• Spills or other releases of painting materials should be cleaned up as soon as possible.
• Washing facilities (such as facilities for quick-drenching of the eyes and body) must be available in case employees have skin contact with paint and paint solvents that may be absorbed through the skin. [1915.97(b) and 1910.151(c)]
• Workers must be trained about potential hazards involved with the materials they work with, as well as precautions, in accordance with Hazard Communication Standard. [1915.1200]

• Hazard Communication Guidelines for Compliance. OSHA 3111 (2000).
• Hazard Communication. OSHA Safety and Health Topics Page.

• Fixed or portable eye wash stations/safety showers should meet ANSI Z358.1-2004: Emergency Eye Wash and Shower Equipment.

• Slipping off oily and greasy ladders;
• Slipping and falling on oily decks;
• Tripping over equipment, hoses, and vessel structures; and
• Slipping on freshly painted surfaces.

• Slippery conditions must be eliminated as they occur. [1915.91]
• Visual Inspection will be conducted. [1915.11] Also see Confined or Enclosed Space module.
• Adequate illumination will be provided. [1915.92(a)] Also see Confined or Enclosed Space module.
• Housekeeping will be maintained as described in 1915.91.

• Falls from deck openings;
• Falls into open holes.

• Falls from ladders;
• Falls from scaffolds;
• Falls from aerial lifts.

• Openings and deck edges must be guarded. [1915.73]
• Flush manholes and other small openings must be guarded or covered after opening. [1915.73(b)]
• During the installation of guards on large openings and deck edges, fall protection (harness with lanyard) must be used. [1915.73(d)]
• Openings must be guarded or planked when floor plates or gratings (e.g., bilges, engine rooms, pump rooms, machinery spaces) are removed. [1915.73(f)]

• Guardrails or other appropriate fall protection must be used when working on scaffolds 5 feet above surfaces. [1915.71(j)]
• Fall protection must be used during the installation of guardrails on scaffolds. [1915.73(d)]
• Personal fall protection (such as harness and lanyard) must be worn when working from aerial lifts. [1910.67(c)(2)(v)]
• Defective ladders must not be used and must be removed immediately. [1915.72(a)(1)] 
• Portable ladders must be secured and extend 3 feet above the landing surface. [1915.72(a)(3)]
• For additional information on Ladders, see the Shipyard Ladders module.

• Contact with high-pressure painting equipment;
• Contact by uncontrolled high-pressure hoses; and
• Contact with air leaks from high-pressure equipment.

• Loss of body parts (e.g., fingers, hands, etc.)
• Lacerations
• Burns
• Loss of sight

• Access to the area should be controlled.
• Avoid contact with high-pressure nozzle.
• Maintain high-pressure spray equipment according to the manufacturer's requirements.
• Inspect hoses and connections before use.
• Use paint pots with appropriate pressure regulators/ratings.

• Heat Stress
• Heat Stroke
• Heat Cramps
• Dehydration

• Hypothermia
• Frostbite

• Section III: Chapter 4, Heat Stress. OSHA Technical Manual.
• Heat Stress. OSHA Safety and Health Topics Page.
• Heat Stress Card. OSHA Publication 3154 and 3155, (2002).
  • English [PDF - 23 KB]
  • Spanish [PDF - 73 KB]
• Cold Stress Cards. OSHA Publications 3156 and 3158, (1998).
  • English [PDF - 21 KB]
  • Spanish [PDF - 21 KB]

• Plenty of fluids
• Frequent breaks
• Ice vest
• Shaded or cooled break areas
• Ventilation
• Awareness training

• Appropriate insulation (PPE)
• Warming areas for breaks
• Awareness training

• Exposed energized electrical parts;
• Open lighting parts (such as broken bulbs, exposed conductors);
• Damaged insulation on power cords.

Note: Arcing and spark producing tools are not to be used where flammable liquids are capable of creating a flammable atmosphere.  [1915.36]

• Portable electrical tools must be grounded or double-insulated. [1915.132(a)]
• Temporary lighting must be grounded and explosion-proof. [1915.36(a)(4) and 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)]

• 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 to repair or maintain electrical tools and equipment.
• 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; and
  • Recall of records of the above.
• The requirements of the Ground Assurance Program should be performed on a regular basis.

• Improperly located equipment blocking egress.
• Ventilation ducts and hoses running through an opening blocking egress.

• When employees work in confined spaces with limited access, the access must not be blocked or impeded by ventilation ducts, hoses, or other equipment. [1915.76(b)(2)]
• More than one means of access must be provided where practical. [1915.76(b)(1)]
• Additional openings should be provided for ducts, hoses, and other equipment.