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Shipyard Employment eTool: Shipbreaking
General Requirements Shipbuilding Ship Repair Shipbreaking Barge Cleaning

Cleaning and Other Cold Work » Cleaning Operations


Figure 1: Workers using suction hose for removing residue from below deck
Figure 1: Workers using suction hose for removing residue from below deck.

Figure 2: Containers of cleaning materials labeled with their hazards
Figure 2: Containers of cleaning materials.

Figure 3: Workers wearing filter respirator, ear muffs and other PPE
Figure 3: Workers wearing filter respirator, ear muffs and other PPE.

Cleaning and cold work in shipbreaking may include tank cleaning, mucking, or wiping down salvaged equipment.

After the spaces are evaluated by the Shipyard Competent Person (SCP), Certified Marine Chemist (CMC), or Certified Industrial Hygienist (CIH),  the personnel, equipment, and materials required for the cleaning and cold work must be determined. In addition, a hazard assessment must be conducted for selecting appropriate personal protective equipment (PPE). See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

Cleaning agents may include:

Hazards associated with cleaning and cold work include:

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.



Toxic Cleaning Solvents (for example, mineral spirits, diesel fuel, degreasers)
Cleaning and cold work may range from simply wiping down equipment to totally stripping off coating. Cleaning solvents and degreasers may expose workers to:

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

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Chemical Removers (for example, paint stripper, methylene chloride)
Figure 4: Fall hazards present in area where paint is removed from vessel hull
Figure 4: Fall hazards present in area where paint is removed from vessel hull.

Chemical paint strippers and removers used for cleaning include corrosive acids, (for example, hydrochloric and phosphoric), alkalis (e.g., sodium hydroxide/lye), chlorinated hydrocarbons (for example, trichloroethane) and carcinogens (for example, methylene chloride). These chemicals may present severe eye, skin, and respiratory exposure hazards.

Paint strippers and removers potentially expose workers to:

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

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Flammable and Combustible Liquids
Figure 5: Cleaning equipment tank (ADLER) containing flammable liquids
Figure 5: Cleaning equipment tank (ADLER) containing flammable liquids.
Flammable and combustible liquids are used in shipbreaking operations for cleaning tanks and equipment. The use, storage, and containment of these materials may expose workers to:

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

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Fire and Explosion Hazards
Figure 6: Improper practice - Worker covered with flammable oil
Figure 6: Improper practice - Worker covered with flammable oil.

Figure 7: Warning Sign is posted to alert workers of the fire and explosion hazard of painting
Figure 7: Warning Sign is posted to alert workers of the fire and explosion hazard of painting.

Figure 8: Ventilation equipment used to maintain safe conditions for entry
Figure 8: Ventilation equipment used to maintain safe conditions for entry.

Figure 9: Worker testing space to see that safe conditions are maintained during cleaning
Figure 9: Worker testing space to see that safe conditions are maintained during cleaning.

Figure 10: Fire extinguishers located near cleaning operations
Figure 10: Fire extinguishers located near cleaning operations.
Potential Hazards:

Fire and explosions may be caused by:

  • Flammable and combustible cleaning solvents such as Methyl Ethyl Ketone (MEK), mineral spirits, and diesel fuel or oil.
  • Liquids with high flash points (greater than 100 F) applied as a fine mist.
  • Airborne particulate or dust.
  • Hydrogen gas generated during cleaning processes.
  • Reactive cargos such as iron-ore, fertilizer, or incompatible chemicals.
  • Painting. See Painting [29 CFR 1915.35]

Requirements and Example Solutions:

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Excessive Noise
Figure 11: Workers exposed to noise from pressure washing
Figure 11: Workers exposed to noise from pressure washing.

Figure 12: Workers wearing ear muffs for protection from excessive noise
Figure 12: Workers wearing ear muffs for protection from excessive noise.
Potential Hazards:

Use of high-pressure cleaning equipment may produce high levels of noise, which could lead to permanent hearing loss, and often necessitates a hearing conservation program. An example of an excessively loud operation is:

  • Use of high-pressure water and steam guns

Requirements and Example Solutions:

Additional Resources:

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Biological Hazards
Figure 13: CHT tank poses hydrogen sulfide gas and other hazards
Figure 13: CHT tank poses hydrogen sulfide gas and other hazards.

Figure 14: Worker removing trash from work area
Figure 14: Worker removing trash from work area.

Figure 15: Washing station for workers
Figure 15: Washing station for workers.

Potential Hazards:

Some operations expose employees to biological hazards from sewage and human waste, fungi and molds, and decomposing organic products.

  • Collection, holding, and transfer (CHT) tanks, which workers are often required to enter and clean, may contain dangerous, even fatal, levels of hydrogen sulfide or other toxic gases, which are products of decomposing human waste.
  • Toxic spores inhaled from fungi and molds growing on grain and lumber may pose an inhalation hazard.

Requirements and Example Solutions:

  • Employees shall be trained to recognize the potential hazards, use proper work practices, recognize adverse health effects, and understand the physical signs and reactions related to exposures. They shall also be trained to select and use appropriate PPE. [29 CFR 1915.12(d)(2) and 29 CFR 1915.1200]
  • Personal hygiene is required. [29 CFR 1915.97] This includes the following:
    • Decontamination (removal of biological matter from PPE and equipment)
    • Showers (removal of biological matter from the worker) [29 CFR 1910.141]
    • Proper disposal of laundry/coveralls (prevention of exposure to others)

Additional Resources:

  • Maritime Labor/Industry recommends having a Bloodborne Pathogen program.
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Slips and Trips
Figure 16: Hoses and welding leads present tripping hazard
Figure 16: Hoses and welding leads present tripping hazard.

Figure 17: Temporary lighting reduces tripping hazards
Figure 17: Temporary lighting reduces tripping hazards.

Figure 18: Tripping hazards eliminated by raised walkway
Figure 18: Tripping hazards eliminated by raised walkway.
Potential Hazards:

Workers performing cleaning and cold work operations are exposed to slippery working surfaces and tripping hazards. This places workers at risk of:

  • Slipping off oily and greasy ladders
  • Slipping and falling on oily decks
  • Tripping over equipment, hoses, and vessel structures

Requirements and Example Solutions:

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High-Pressure Hazards
Figure 19: Workers exposed to noise from pressure washing
Figure 19: Workers exposed to hazards of high pressure water.

Figure 20: Worker protected by PPE from high pressure hazards
Figure 20: Worker protected by PPE from high pressure hazards.

Figure 21: Hoses and connections should be inspected
Figure 21: Hoses and connections should be inspected.
Potential Hazards:

The use of high-pressure cleaning equipment may expose the operator and other workers in the area to the following hazards:

  • Contact with high-pressure steam, water, or air streams from cleaning equipment
  • Contact by uncontrolled high-pressure hoses
  • Contact with steam, water, or air leaks in the high-pressure equipment

Injuries associated with these hazards include:

  • Loss of body parts such as fingers, hands, etc.
  • Lacerations
  • Burns
  • Loss of sight

Requirements and Example Solutions:

  • Steam guns must be insulated to prevent heat burns to the operator. [29 CFR 1915.33(e)]
  • Appropriate PPE shall be used. [29 CFR 1915.152]
  • Access to the area should be controlled.
  • Hoses and connections should be inspected before use.
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Electrical Hazards
Figure 22: Damaged electrical cable poses shock hazard
Figure 22: Damaged electrical cable poses shock hazard.

Figure 23: Portable power tools must be grounded or double insulated
Figure 23: Portable power tools must be grounded or double insulated.

Figure 24: Temporary lights should be inspected before use
Figure 24: Temporary lights should be inspected before use.

Potential Hazards:

Employees who work with electrical equipment in wet or damp locations have an increased risk of getting shocked or electrocuted due to:

  • Exposed energized electrical parts
  • Open lighting parts
  • Damaged insulation on power cords

Requirements and Example Solutions:

  • Portable electrical tools must be grounded or double insulated. [29 CFR 1915.132(a)]
  • Temporary lighting must be grounded. [29 CFR 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). [29 CFR 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 repair of electrical tools and equipment in use.
  • 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
    • Recall of records of the above
  • The requirements of the Ground Assurance Program should be performed on a regular basis.
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