Hot Work (including Welding, Cutting and Heating) » Testing and Certifying for
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 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
Note: Confined space entry is one of the leading
hazards associated with barge cleaning. Review
Shipbreaking: Confined or Enclosed
Spaces and Other Dangerous Atmospheres
for information on how to protect workers from this hazard.
|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, 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 "
Safe for Workers." Spaces that are designated "Not
Safe for Workers" or "Not
Safe for Hot Work" must be labeled. [NFPA 306, 29 CFR 1915.14(a)
and 29 CFR 1915
Figure 1: Marine Chemist.
Figure 2: Marine Chemist certificate.
|Shipyard Competent Person (SCP)
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. [29 CFR 1915.7(b)]
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
Figure 4:Testing equipment.
Figure 7: Sample Competent Person Record of Inspection.
The Shipyard Competent Person's testing responsibilities
Calibrating and maintaining test equipment. [29 CFR 1915.7(c)(4)]
Inspecting and testing hollow structures such as skegs,
pipe stanchions, booms, and masts. [29 CFR 1915.54]
Testing other spaces such as dry cargo holds, bilges, vessel modules, and landside
confined or enclosed spaces, not requiring Marine Chemist certification.
[29 CFR 1915.14(b)(1)]
Conducting tests and visual inspections in order to maintain a Marine
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. [29 CFR 1915.16] The shipyard must maintain and
make available a roster of shipyard competent persons. [29 CFR 1915.7(b)(2)(i)]
Figure 5: Rudder - hollow space.
Figure 6: Testing and visual inspection to maintain
Marine Chemist Certificate.