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Hot Work Operations » Hot Work in Enclosed Spaces
 
Click on an area for more specific information. Welder Fire Watch Fire Watch Rescue Teams Rescue Teams Labels Labels Ventilation Hot Work in Enclosed Spaces Also see: Fire Watch, Rescue Team, Ventilation,
Warning Signs and Labels, and Welder.
Hot work in shipyards is often performed in enclosed spaces that may expose workers to hazards. Listed below are the specific safety and health requirements for the majority of hot work operations. (Please see additional requirements for hot work in confined spaces and other locations.)

Specific Safety and Health Requirements  
The Confined/Enclosed Spaces and Other Dangerous Atmospheres module should be reviewed before continuing with this section. Also, this module, outlining the requirements for Hot Work in Enclosed Spaces, should be reviewed before reviewing the modules regarding hot work requirements for Confined Spaces and Other Locations.
Hot Work Operations
Potential Hazards:

Workers performing hot work or working in spaces adjacent to hot work are exposed to the following risks:
  • Fire and explosions caused by flammable or combustible materials or airborne gases, vapors, and particulates
  • Toxic gases and metal fumes produced from the hot operations (such as nitrogen oxides, and lead fumes)
  • Ultraviolet radiation from electric arcs

Requirements and Example Solutions:

Before beginning hot work, the following tasks must be performed: Note: When hot work is being performed, it is the employers' responsibility to ensure that precautions are taken in adjacent spaces. [1915.503(a)(2)]
 

 Figure 1: Reviewing of Marine Chemist Certificate.
Figure 1: Reviewing of Marine Chemist Certificate.

Figure 2: Removing of flammable and combustible material.
Figure 2: Removing of flammable and combustible material.

 Figure 3: Fire watch.
Figure 3: Fire watch.

 Figure 4: Inspecting welding equipment.
Figure 4: Inspecting welding equipment.
 
 Figure 5: Leak test.
Figure 5: Leak test.
 
Figure 6: Burner wearing respirator, tinted face shield and leather gloves.
Figure 6: Burner wearing respirator, tinted face shield and leather gloves.
 		 Figure 7: Welding UV screens.
Figure 7: Welding UV screens.		 Figure 8: Welding torch.
Figure 8: Welding torch.
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Inspection and Tests to Maintain Safe Conditions
Potential Hazards:

The work space is initially inspected by a Certified Marine Chemist or a Shipyard Competent Person. Conditions may change during work so the Shipyard Competent Person must inspect the hot work area as often as necessary. If the Shipyard Competent Person discovers a change that could adversely alter safe conditions (such as a missing fire watch, ventilation failure, piping system leak, or hazardous materials spill), work must be stopped. Work may not be resumed until the affected space is visually inspected and re-evaluated (by a Marine Chemist, if a marine chemist certificate was issued) to meet requirements. [1915.15(f)]

Requirements and Example Solutions:

Examples of items that can change conditions include:
  • Temperature changes: increased or decreased temperatures affect flammable and toxic vapor levels.
  • Type of work in tank: leaking torches, use of cleaning solvents, and removal of tank residue ("mucking out") may alter atmosphere.
  • Unattended tanks or spaces: if a period of time has elapsed, it is recommended that spaces be retested before re-entry and continuation of work. [1915 Subpart A and Subpart B]
  • Ballasting or trimming: changing the position of the vessel could release hazardous materials into a space or compartment.
  • Ventilation changes: ventilation duct damage or fans not in use.
 Figure 1: Inspection to maintain safe conditions.
Figure 1: Inspection to maintain safe conditions.
Maritime Labor/Industry Recommendations
  • SHAC recommends that tests before re-entry and continuation of work in unattended tanks and spaces should be conducted at the beginning of the shift and then at least every 24 hours between tests.
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Fall Hazards
Potential Hazards:

Fall hazards are a leading cause of shipyard fatalities. Shipyard employees are often required to work in dangerous environments that may include fall hazards. Accidents involving elevation equipment such as ladders, scaffolds, and aerial lifts are often serious, even fatal. Workers also risk falls from open deck edges.

Requirements and Example Solutions:

Guarding of Deck Openings and Edges
  • Openings and deck edges must be guarded. [1915.73]
  • Flush manholes and other small openings must be guarded 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)]
  • When floor plates or gratings (e.g. bilges, engine rooms, pump rooms, machinery spaces) are removed, the openings must be guarded or planked. [1915.73(f)]
Fall Protection for Scaffold Work
  • Guardrails or other appropriate fall protection must be used when working on scaffolds 5 feet above surfaces. [1915.71(j)]
  • During the installation of guards on scaffolds, fall protection must be used. [1915.73(d)]
Maritime Labor/Industry Recommendations
  • SHAC recommends that personal fall protection including lanyards and harnesses be used and secured during installation of guardrails and erection and dismantling of scaffolds.
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Ventilation Requirements
Potential Hazards:

 Workers performing hot work operations are exposed to toxic gases and metal fumes (such as nitrogen oxides, zinc, or iron oxide fumes) that may cause occupational illnesses.

Requirements and Example Solutions:

Ventilation removes or dilutes metal fumes and gases generated by hot work. The following ventilation requirements must be met:
  • Replace withdrawn air with clean respirable (breathable) air. [1915.51(b)(1)(v)]
  • Discharge contaminated air away from the source of the intake air. [1915.51(b)(1)(iv)]
  • Mechanically ventilate toxic metal fumes, including: zinc, lead, cadmium, chromium, beryllium, mercury, nickel, arsenic, and copper. [1915.51(d)]
    • Note: The presence of beryllium requires local mechanical exhaust ventilation and airline respirators. [1915.51(d)(1)(iv)]
  • Adjust local exhaust ventilation on an ongoing basis. [1915.51(b)(1)(iii)]
  • Warning: Do not use oxygen for ventilation or cleaning (blow-off). [1915.51(b)(1)(vi)]

 Figure 1: Local exhaust ventilation being properly used.
Figure 1: Local exhaust ventilation being properly used.

Figure 2: Air movers providing general ventilation to confined spaces.
Figure 2: Air movers provide general ventilation to confined spaces.

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Fire Prevention Requirements
Potential Hazards:

Workers performing hot work in enclosed spaces are exposed to the risk of fires from ignition of flammable or combustible materials in the space and from leaks of flammable gas into the space from hot work equipment.

Requirements and Example Solutions:

Fires caused by hot work in enclosed spaces can be prevented with the following precautions:
  • Performing hot work in a designated area, or with fire hazards removed or covered. [1915.503(a)]
  • Assigned additional personnel (fire watch) to guard against fire while hot work is being performed. [1915.504(b) and (c)]
    See Fire Protection: Fire Watch page.
  • Not placing gas manifolds in enclosed or confined spaces. [1915.55(e)(2)]
  • Not placing gas manifolds in enclosed or confined spaces. [1915.55(e)(2)]
  • For additional requirements, see the Fire Protection chapter.

Note: When hot work is being performed, it is the employers' responsibility to ensure that precautions are taken in adjacent spaces. [1915.503(a)(2)]
 

 Figure 1: Typical gas manifold.
Figure 1: Typical gas manifold.

 Figure 2: Fire watch.
Figure 2: Fire watch.
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PPE Requirements
Potential Hazards:

Injury and illness may be caused by hot work (such as welding fumes, UV light, sparks, noise, skin injury, etc.).

Example Solutions:   Personal protective equipment is used during hot work to protect workers. A PPE program consists of the following:
For more specific information, see PPE Selection: Hot Work. 		Figure 1: Respiratory protection.
Figure 1: Respiratory protection.


 Figure 2: Welding PPE.
Figure 2: Welding PPE.
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