Cleaning and Other Cold Work >> Cleaning Operations

Figure 1: A 'safe' set-up for cold work
Figure 1: A "safe" set-up for cold work

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

Cleaning and cold work exposes workers to potentially hazardous atmospheres, as well as the following hazards:

Figure 2: Improper practice - Worker covered with flammable oil

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/oil
  • Liquids with high flash points (greater than 100º 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 and Other Coatings [29 CFR 1915.35]
Figure 3: Warning Sign is posted to alert workers of the fire and explosion hazard of painting

Requirements and Example Solutions

When ship repair operations are capable of producing flammable/combustible atmospheres:

Figure 7: Containers of cleaning materials labeled with their hazards

Potential Hazards

Toxic vapors produced by cleaning agents such as freons and trichloroethane may present significant health hazards including oxygen-deficient atmospheres. When used in confined or enclosed spaces these agents produce vapors that are often heavier than air. This can cause displacement of air, reducing oxygen levels, which may be fatal.

Note: Paint strippers often contain methylene chloride, which has additional requirements.

Figure 8: Improper practice - Ventilation hoses extending into confined space to ensure safe conditions

Requirements and Example Solutions

  • Ensure adequate ventilation to maintain concentrations below the PEL. [29 CFR 1915.32(a)(2)]
  • The Shipyard competent person (SCP) may require continual monitoring to determine air concentrations are within the PELs and below IDLH levels. If they are not, additional engineering controls (e.g., ventilation), administrative controls or PPE (e.g. respirators) must be used. [29 CFR 1915.32(a)(3)]
  • Airline respirators may be necessary if ventilation is not adequate.
  • Respirators must comply with 29 CFR 1915.154. [29 CFR 1910.134]
  • A hazard assessment shall be made to determine the proper selection of respirators. [29 CFR 1915.152(b)]
Figure 9: Worker wearing airline respirator with emergency escape air cylinder

Additional Resources

Figure 10: Worker exposed to skin and eye contact hazards from cleaners and residues

Potential Hazards

Employees working with toxic solvents are at risk if skin and eye contact occurs. Note: Workers should understand the hazards associated with the materials used and contained in the space. This includes training in accordance with the Hazard Communication Standard. [29 CFR 1915.1200]

Hazards include

  • Organ damage through skin or eye absorption
  • Skin or eye burns and irritation
  • Ingestion of contaminated food
Figure 7: Emergency eye/face wash

Requirements and Example Solutions

Figure 12: Washing facilities for workers

Additional Information

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


  • Fixed or portable eye wash stations/safety showers should meet ANSI Z358.1-1998: Emergency Eye Wash and Shower Equipment.
Figure 13: Workers exposed to noise from pressure washing

Potential Hazards

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

  • Use of high-pressure water and steam guns
Figure 14: Workers wearing ear muffs for protection from excessive noise

Requirements and Example Solutions

Additional Resources

Figure 15: CHT tank poses hydrogen sulfide gas and other hazards

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.
Figure 16: Worker removing trash from work area Figure 17: Washing station for workers

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 practices must be encouraged, such as: [29 CFR 1915.88]
    • Decontamination (removal of biological matter from PPE and equipment)
    • Showers (removal of biological matter from the worker) [29 CFR 1915.88(f)]
    • Proper disposal of laundry/coveralls (prevention of exposure to others)


  • The Maritime/Labor Industry recommends having a Bloodborne Pathogen program.

Additional Resources

Figure 18: Improper practice - Confined space access hole blocked by ventilation hoses

Potential Hazards

When working in confined or enclosed spaces workers may become trapped and unable to exit due to:

Figure 19: Special ventilation hose (flat) to avoid blocking exit
  • Improperly located equipment.
  • Ventilation ducts and hoses running through the opening.
Figure 20: Two access holes for equipment or access

Requirements and Example Solutions

  • When employees work in confined spaces or enclosed spaces with limited access, the access must not be blocked or impeded by ventilation ducts, hoses or other equipment. [29 CFR 1915.76(b)(2)]
  • More than one means of access must be provided where practical. [29 CFR 1915.76(b)(1)]
  • Additional openings should be provided for ducts, hoses, and other equipment.
Figure 21: Improper practice - Hoses and welding leads present tripping hazard

Potential Hazards

Workers performing surface preparation are exposed to slippery working surfaces and tripping hazards.

  • Slipping off oily and greasy ladders
  • Slipping and falling on oily decks.
  • Tripping over equipment, hoses, and vessel structures.
Figure 22: Temporary lighting reduces tripping hazards

Requirements and Example Solutions

Figure 23: Tripping hazards eliminated by raised walkway
Figure 24: Improper practice - Deck openings and holes create a significant fall hazard

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.

High-Pressure Cleaning

  • Surges from drops in pressure in the hose line may throw a worker from the work surface
  • Cleaning can create static electricity. This may shock the worker and result in a fall
Figure 25: Improper practice - Workers exposed to falls from ladder and scaffold

Deck Openings and Edges

  • Falls from deck openings
  • Falls into open holes
Figure 26: Workers protected at deck edge by guardrail


  • Falls from ladders
  • Falls from scaffolds
Figure 27: Deck opening protected with guard

Requirements and Example Solutions

High-Pressure Cleaning

Figure 28: Workers protected from falls while erecting scaffold

Guarding of Deck Openings and Edges

  • Openings and deck edges must be guarded. [29 CFR 1915.73]
  • Flush manholes and other small openings must be guarded after opening. [29 CFR 1915.73(b)]
  • Fall protection (harness with lanyard) must be used during the installation of guards on large openings and deck edges. [29 CFR 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. [29 CFR 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. [29 CFR 1915.71(j)]
  • Fall protection must be used during the installation of guards on scaffolds. [29 CFR 1915.73(d)]
  • Maritime Labor/Industry recommends that personal fall protection including lanyards and harnesses be used and secured during installation of guardrails as well as erection and dismantling of scaffolds.
Figure 29: Workers in protective suits are at higher risk of heat stress

Potential Hazards

Environmental hazards include temperature, humidity, and air movement within the work area. A combination of PPE use, heat producing equipment, work activity, and environmental conditions can cause temperature-related illnesses.

Heat related illnesses include:.

  • Heat Stress
  • Heat Stroke
  • Heat Cramps
  • Dehydration

Cold related illnesses include:.

  • Hypothermia
  • Frost Bite

Additional Resources

  • OSHA Technical Manual (OTM). OSHA Directive TED 01-00-015 [TED 1-0.15A], (January 20, 1999). Identifies heat stress as part of the evaluation process in the following:
    • Heat Stress. Contains useful sections on the signs and symptoms of heat stress, sampling methods, control suggestions, and guidelines for investigating heat stress in the workplace.
  • Occupational Heat Exposure. OSHA Safety and Health Topics Page.

Example Solutions:

The following are recommended for heat-related illnesses:

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

It is recommended that the following be implemented to prevent cold related illnesses:

  • Appropriate insulated PPE
  • Warming areas for breaks
  • Conduct awareness training
Figure 30: Workers exposed to hazards of high pressure water

Potential Hazards

The use of high pressure equipment may expose the operator and other workers 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 from high-pressure equipment
Figure 31: Worker protected by PPE from high pressure hazards

Injuries associated with these hazards include:

  • Loss of body parts such as fingers, hands, etc.
  • Lacerations
  • Burns
  • Loss of sight
Figure 32: Hoses and connections should be inspected

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.
Figure 33: Improper practice - Damaged electrical cable poses shock hazard

Potential Hazards

Employees who work with or around 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
Figure 34: Portable power tools must be grounded or double insulated Figure 35: Temporary lights should be inspected before use

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 1915.82(b)(8)]
  • 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 prior to 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.