Hot Work (including Welding, Cutting and Heating) » Testing and Certifying for Hot Work

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 work operations.

The Confined or Enclosed Spaces and Other Dangerous Atmospheres module should be reviewed before continuing with this section.

Figure 1: Marine Chemist

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:

Figure 2: Marine Chemist certificate

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 "Atmosphere 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 Subpart D]

Figure 1: Shipyard Competent Person, with PFD, testing tanks on a barge prior to authorizing entry. Note: Fall protection to be installed after testing for initial entry

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)]

The Shipyard Competent Person's testing responsibilities include:

  • 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 Chemist Certificate.
Figure 2: SCP testing equipment

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 3: Rudder being inspected for structural voids
Figure 4: Testing and visual inspection to maintain Marine Chemist Certificate
Figure 5: Sample Competent Person Record of Inspection