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.
[1915.152(b)]
Cleaning and cold work exposes workers to potentially hazardous atmospheres, as well as the following hazards:
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Respiratory 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.
Requirements and Example Solutions:
- Ensure adequate ventilation to maintain air concentrations below the
PEL. [1915.32(a)(2)]
- The Shipyard Competent Person (SCP) may require continual monitoring to
determine that air concentrations are within the PELs and below IDLH
levels. If they are not, additional engineering controls such as
ventilation, administrative controls, or PPE such as respirators must
be used. [1915.32(a)(3)]
- Airline respirators may be necessary if ventilation is not adequate.
- Respirators must comply with 1915.154.
[1910.134]
- A hazard assessment shall be made to determine the proper selection
of respirators. [1915.152(b)]
Additional Resources:
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Figure 6: Containers of cleaning materials labeled with their hazards.
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Figure 7: Ventilation hoses extending into confined space to ensure safe conditions.
Figure 8: Worker wearing airline respirator with emergency escape air cylinder.
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Corrosive and Toxic Materials |
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. [1915.1200]
Hazards include:
- Organ damage by absorption through the skin or eye
- Eye or skin
irritation
- Defatting of skin
Requirements and Example Solutions:
- Use adequate ventilation.
See Ventilation
in the Confined or Enclosed Space module.
- The Shipyard
Competent Person (SCP) may require continual monitoring to
determine that air concentrations are within the PELs and below IDLH
levels. If they are not, additional engineering controls such as
ventilation, administrative controls, or PPE such as respirators must
be used. [1915.32(a)(3)]
- Spills of hazardous materials must be cleaned up as work progresses.
[1915.13(b)(5)]
- Because of the corrosive nature of many of the materials used,
suitable facilities for quick drenching or flushing of the eyes and
body shall be available. [1910.151(c)
and Maritime
Labor/Industry Recommendations]
- Washing facilities must be available when working with materials
which may be harmful through skin contact. [1915.97(b)]
- Personal hygiene practices must be encouraged, such as washing hands
and face before eating, drinking, and smoking. [1915.97]
Additional Resources:
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Figure 9: Worker exposed to skin and eye contact hazards from cleaners and residues.
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Figure 10: Emergency eye wash located near cleaning operations.
Figure 11: Washing facilities for workers. |
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Maritime
Labor/Industry Recommendations |
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Fixed or portable eye wash stations/safety showers should meet ANSI
Z358.1-1998: Emergency Eye Wash and Shower Equipment.
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Excessive Noise |
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
Requirements and Example Solutions:
Additional Resources:
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Figure 12: Workers exposed to noise from pressure washing.
Figure 13: Workers wearing ear muffs for protection from excessive noise. |
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Biological 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.
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. [1915.12(d)(2)
and 1915.1200]
- Personal hygiene practices must be encouraged, such as: [1915.97]
- Decontamination (removal of biological matter from PPE and
equipment).
- Showers (removal of biological matter from the worker). [1910.141]
- Proper disposal of laundry/coveralls (prevention of exposure to
others).
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Figure 14: CHT tank poses hydrogen sulfide gas and other hazards.
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Figure 15: Worker removing trash from work area.
Figure 16: Washing station for workers. |
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Maritime
Labor/Industry Recommendations |
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SHAC recommends having a Bloodborne Pathogen program.
Additional Resources:
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Limited Access |
Potential Hazards:
When working in confined or enclosed spaces, egress may be blocked by:
- Improperly located equipment
- Ventilation ducts and hoses running through the opening
Requirements and Example Solutions:
- When employees work in confined or enclosed spaces with limited
access, the access must not be blocked or impeded by ventilation
ducts, hoses, or other equipment. [1915.76(b)(2)]
- More than one means of access must be provided where practical. [1915.76(b)(1)]
- Additional openings should be considered for ducts, hoses, and other
equipment.
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Figure 17: Confined space access hole blocked by ventilation hoses.
Figure 18: Flat ventilation hose used to allow room for access. |
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Slips and
Trips |
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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Figure 19: Hoses and welding leads present tripping
hazard.
Figure 20: Temporary lighting reduces tripping hazards.
Figure 21: Tripping hazards eliminated by raised walkway. |
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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.
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
Deck Openings and Edges
- Falls from deck openings
- Falls into open holes
Scaffolds
- Falls from ladders
- Falls from scaffolds
Requirements and Example Solutions:
High-Pressure Cleaning
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)]
- Fall protection (harness with lanyard) must be used during the installation of guards on large openings and deck
edges. [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 . [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)]
- Fall protection must be used during the installation of guards on
scaffolds. [1915.73(d)]
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Figure 22: Deck openings and holes create a significant fall hazard.
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Figure 23: Workers exposed to falls
from ladder and scaffold.
Figure 24: Workers protected at deck edge by guardrail.
Figure 25: Deck opening protected with guard.
Figure 26: Workers protected from falls while erecting scaffold. |
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Maritime
Labor/Industry Recommendations |
- SHAC 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.
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Work Environment Temperature Related Hazards |
Potential Hazards:
Extreme 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:
Additional Resources:
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Figure 27: Workers in protective suits are at higher risk of heat stress. |
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Maritime
Labor/Industry Recommendations |
Example Solutions:
SHAC recommends the following for heat related
illnesses:
- Plenty of fluids
- Frequent breaks
- Ice vest
- Shaded or cooled break areas
- Ventilation
- Awareness training
SHAC recommends the following for cold related
illnesses:
- Appropriate insulated PPE
- Warming areas for breaks
- Awareness training
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High-Pressure Hazards |
Potential Hazards:
The use of high-pressure cleaning equipment may expose the
operator and other workers in the area to the following hazards:
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Contact with high-pressure steam, water, or air streams from cleaning
equipment
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Contact by uncontrolled high-pressure hoses
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Contact with steam, water, or air leaks in the high-pressure
equipment
Injuries associated with these hazards include:
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Loss of body parts such as fingers, hands, etc.
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Lacerations
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Burns
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Loss of sight
Requirements and Example Solutions:
- Steam guns must be insulated to prevent heat burns to the
operator. [1915.33(e)]
- Appropriate PPE shall be used. [1915.152]
- Access to the area should be controlled.
- Hoses and connections should be inspected before use.
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Figure 28: Workers exposed to hazards of high
pressure water. |
Figure 29: Worker protected by PPE from high pressure hazards.
Figure 30: Hoses and connections should be inspected. |
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Electrical Hazards |
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. [1915.132(a)]
- Temporary lighting must be grounded. [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). [1915.36(a)(5)]
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Figure 31: Damaged electrical cable poses shock hazard. |
Figure 32: Portable power tools must be grounded or double insulated.
|Figure 33: Temporary lights should be inspected before use. |
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Maritime
Labor/Industry Recommendations |
- 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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