Figure 1: Illustration of the many shipyard operations that require PPE
Figure 1: Illustration of the many shipyard operations that require PPE.

The first step in the development of a PPE program is to conduct a comprehensive hazard assessment. [29 CFR 1915.152(b)]

The Non-mandatory Guidelines for Hazard Assessment contain examples of procedures for a hazard assessment. [29 CFR 1915 Subpart I Appendix A]

The following section addresses:

Note: Confined space entry is one of the leading hazards associated with barge cleaning. Review the Ship Repair: Confined or Enclosed Spaces and Other Dangerous Atmospheres chapter for information on how to protect workers from this hazard.

A determination of whether hazards are present or are likely to be present must be conducted. [29 CFR 1915.152(b)] If such hazards are present or are likely to be present the employer shall select the type of PPE.

Hazards to evaluate may include:

  • Impact (falling objects, struck-by hazards, impact tools)
  • Puncture and cuts (tools, knives, slag, nails, wire rope, sheet metal)
  • Compression/Crushing (gears, struck-by hazards, shifting loads)
  • Chemical (solvents, corrosives, paints, fumes)
  • Heat/Cold (welding, burning, environmental temperatures)
  • Burns (thermal, chemical)
  • Vibration (pneumatic tools)
  • Dust (heavy metals, silica)
  • Light (optical) radiation (arc welding, lasers)
  • Excessive noise (abrasive blasting, needle gunning, scaling, grinding, metal straightening)
  • Falling (from elevations, into water)
  • Drowning
  • Maritime /Labor Industry recommends that the PPE hazard assessment be part of a broader assessment (such as Job Safety Analysis) which includes a demolition plan, engineering, administrative, and other hazard controls.

The hazard assessments must be documented [29 CFR 1915.152(b)(4)] and include the following information:

  • Occupation
  • Dates of the hazard assessment
  • Name of the person performing the hazard assessment
  • Maritime /Labor Industry recommends that a written PPE Program that describes how the employer meets each element of the standard.