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Subchapter 18. Ship Building, Ship Repairing and Ship Breaking Safety Orders
Article 4. Control of Hazardous Work
§8355. Confined and Enclosed Spaces and Other Dangerous Atmospheres,
Appendix A. Compliance Assistance Guidelines for Confined and Enclosed Spaces and Other Dangerous Atmospheres
This Appendix is a non-mandatory set of guidelines provided to assist employers in complying with the requirements of this section. This Appendix neither creates additional obligations nor detracts from obligations otherwise contained in the standard. It is intended to provide explanatory information and educational material to employers and employees to foster understanding of, and compliance with, the standard. The requirements of this standard are minimum safety standards for entering and working safely in vessel tanks and compartments.
Section 8354 Definition of “Hot work.” There are several instances in which circumstances do not necessitate that grinding, drilling, abrasive blasting be regarded as hot work. Some examples are:
1. Abrasive blasting of the external surface of the vessel (the hull) for paint preparation does not necessitate pumping and cleaning the tanks of a vessel.
2. Prior to hot work on any hollow structure, the void space should be tested and appropriate precautions taken.
Section 8354 Definition of “Lower explosive limit.” The terms lower flammable limit (LFL) and lower explosive limit (LEL) are used interchangeably in fire science literature.
Section 8354 Definition of “Upper explosive limit.” The terms upper flammable limit (UFL) and upper explosive limit (UEL) are used interchangeably in fire science literature.
Section 8355(e)(1). After a tank has been properly washed and ventilated, the tank should contain 20.8 percent oxygen by volume. This is the same amount found in our normal atmosphere at sea level. However, it is possible that the oxygen content will be lower. When this is the case, the reasons for this deficiency should be determined and corrective action taken.
An oxygen content of 19.5 percent can support life and is adequate for entry. However, any oxygen level less than 20.8 percent and greater than 19.5 percent level should also alert the competent person to look for the causes of the oxygen deficiency and to correct them prior to entry.
Section 8355(e)(2) Flammable atmospheres. Atmospheres with a concentration of flammable vapors at or above 10 percent of the lower explosive limit (LEL) are considered hazardous when located in confined spaces. However, atmospheres with flammable vapors below 10 percent of the LEL are not necessarily safe.
Such atmospheres are too lean to burn. Nevertheless, when a space contains or produces measurable flammable vapors below the 10 percent LEL, it might indicate that flammable vapors are being released or introduced into the space and could present a hazard in time. Therefore, the cause of the vapors should be investigated and, if possible, eliminated prior to entry.
Some situations that have produced measurable concentrations of flammable vapors that could exceed 10 percent of the LEL in time are:
1. Pipelines that should have been blanked or disconnected have opened, allowing product into the space.
2. The vessel may have shifted, allowing product not previously cleaned and removed during washing to move into other areas of the vessel.
3. Residues may be producing the atmosphere by releasing flammable vapor.
Section 8355(e)(2) Flammable atmospheres that are toxic. An atmosphere with a measurable concentration of a flammable substance below 10 percent of the LEL may be above the permissible exposure limit for that substance. In that case, refer to subsection (e)(3)(B), (C), and (D).
Section 8355(f)(2)(D), (h)(3) and (h)(5). The frequency with which a tank is monitored to determine if atmospheric conditions are being maintained is a function of several factors that are discussed below:
1. Temperature. Higher temperatures will cause a combustible or flammable liquid to vaporize at a faster rate than lower temperatures. This is important since hotter days may cause tank residues to produce more vapors and that may result in the vapors exceeding 10 percent of the LEL or an overexposure to toxic contaminants.
2. Work in the tank. Any activity in the tank could change the atmospheric conditions in that tank. Oxygen from a leaking oxyfuel hose or torch could result in an oxygen-enriched atmosphere that would more easily propagate a flame. Some welding operations use inert gas, and leaks can result in an oxygen-deficient atmosphere. Manual tank cleaning with high pressure spray devices can stir up residues and result in exposures to toxic contaminants. Simple cleaning or mucking out, where employees walk through and shovel residues and sludge, can create a change in atmospheric conditions.
3. Period of time elapsed. If a period of time has elapsed since a Marine Chemist or Coast Guard authorized person has certified a tank as safe, the atmospheric condition should be rechecked by the competent person prior to entry and starting work.
4. Unattended tanks or spaces. When a tank or space has been tested and declared safe, then subsequently left unattended for a period of time, it should be retested prior to entry and starting work. For example, when barges are left unattended at night, unidentified products from another barge are sometimes dumped into their empty tanks. Since this would result in a changed atmosphere, the tanks should be retested prior to entry and starting work.
5. Work break. When workers take a break or leave at the end of the shift, equipment sometimes is inadvertently left in the tanks. At lunch or work breaks and at the end of the shift are the times when it is most likely someone will leave a burning or cutting torch in the tank, perhaps turned on and leaking oxygen or an inert gas. Since the former can produce an oxygen-enriched atmosphere, and the latter an oxygen-deficient atmosphere, tanks should be checked for equipment left behind, and atmosphere, monitored if necessary prior to re-entering and resuming work. In an oxygen-enriched atmosphere, the flammable range is severely broadened. This means than an oxygen-enriched atmosphere can promote very rapid burning.
6. Ballasting or trimming. Changing the position of the ballast, or trimming or in any way moving the vessel so as to expose cargo that had been previously trapped, can produce a change in the atmosphere of the tank. The atmosphere should be retested after any such move and prior to entry or work.
Section 8355(g)(1) and (2) Hot work. This is a reminder that other sections of the shipyard safety and health standards in subchapter 18 should be reviewed prior to starting any hot work. Most notably, Article 7 Welding, Cutting and Heating, places additional restrictions on hot work begun on any metal that is toxic, covered by a preservative coating or is begun on any structural voids.
Section 8355(e)(1)(B). During hot work, more than 20.8 percent oxygen by volume can be unsafe since it extends the normal flammable range. The standard permits the oxygen level to reach 22 percent by volume in order to account for instrument error. However, the cause of excess oxygen should be investigated and the source removed.
Section 8355(i)(2). If the entire vessel has been found to be in the same condition, then employers shall be considered to be in compliance with this requirement when signs using appropriate warning language in accordance with subsection (i)(1) are posted at the gangway and at all other means of access to the vessel.