Cleaning and cold work may range from simply wiping down equipment to totally stripping off coating. Cleaning solvents and degreasers may expose workers to:

• Fire and explosion
• Respiratory hazards (See Shipbreaking Common Hazards)
• Skin contact hazards
• Limited access (See Shipbreaking Common Hazards)
• Slips and trips
• Fall hazards (See Shipbreaking Common Hazards)
• Work environment temperature related hazards (See Shipbreaking Common Hazards)
• Electrical hazards

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

Chemical paint strippers and removers used for cleaning include corrosive acids, (for example, hydrochloric and phosphoric), alkalis (e.g., sodium hydroxide/lye), chlorinated hydrocarbons (for example, trichloroethane) and carcinogens (for example, methylene chloride). These chemicals may present severe eye, skin, and respiratory exposure hazards.

Paint strippers and removers potentially expose workers to:

• Fire and explosion
• Respiratory hazards (See Shipbreaking Common Hazards)
• Skin contact hazards
• Limited access(See Shipbreaking Common Hazards)
• Slips and trips
• Fall hazards (See Shipbreaking Common Hazards)
• Work environment temperature related hazards (See Shipbreaking Common Hazards)
• Electrical hazards

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

lammable and combustible liquids are used in shipbreaking operations for cleaning tanks and equipment. The use, storage, and containment of these materials may expose workers to:

• Fire and explosion
• Respiratory hazards (See Shipbreaking Common Hazards)
• Skin contact hazards
• Electrical hazards

In addition, a hazard assessment must be conducted for selecting appropriate PPE. See PPE for Cleaning Operations. [29 CFR 1915.152(b)]

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 or 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 [29 CFR 1915.35]

Requirements and Example Solutions

• Hot work must not be performed in the space and/or adjacent spaces when flammable or combustible cleaning solvents are being used. [29 CFR 1915 Subpart P]
• Rags soaked with solvents must be placed in covered metal containers. [29 CFR 1915.36(a)(3)]
• 
  No smoking or open flames should be allowed. [29 CFR 1915.36(a)(1)]
• Arcing and sparking equipment and tools must not be used. [29 CFR 1915.36(a)(1)]
• Equipment that may generate static electricity such as ventilation systems must be grounded/bonded. [29 CFR 1915.13(b)(11)].
• Explosion-proof lights must be used. [29 CFR 1915.36(a)(4) and 29 CFR 1915.13(b)(9)]
• Adequate ventilation must be maintained (less than 10 percent of lower explosive limit (LEL)). [29 CFR 1915.13(b)(3) and 29 CFR 1915.36(a)(2)]
• 
  Frequent tests shall be required during cleaning operations to determine if air concentrations are below 10 percent of the LEL. [29 CFR 1915.36(a)(2)]
• The Shipyard competent person (SCP) must test the exhaust location to ensure that exhausted vapors do not accumulate to hazardous levels. [29 CFR 1915.13(b)(7), (b)(8), (b)(11), and (b)(12)]
• Suitable fire fighting equipment must be immediately available. [29 CFR 1915.36(a)(6) and 29 CFR 1915 Subpart P]
• Personnel using fire fighting equipment must be instructed in anticipated fire hazards and how to use the equipment. [29 CFR 1915 Subpart P]
• 
  Spills of solvents must be cleaned up immediately. [29 CFR 1915.13(b)(5)]

Potential Hazard

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

• Use of high-pressure water and steam guns

Requirements and Example Solutions

• Hearing protection. [29 CFR 1910.95(a)]
• Hearing conservation program. [29 CFR 1910.95(c)]

Additional Resources

• Hearing Protection. See the PPE: Hearing Protection chapter.
• Noise. OSHA Technical Manual Chapter.
• Occupational Noise Exposure. OSHA Safety and Health Topics Page.
• CPL 02-02-035 (CPL 2-2.35A): 29 CFR 1910.95(b)(1), Guidelines for Noise Enforcement; Appendix A. OSHA Directive (December 19, 1983).

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. [29 CFR 1915.12(d)(2) and 29 CFR 1915.1200]
• Personal hygiene is required. [29 CFR 1915.97] This includes the following:
  • Decontamination (removal of biological matter from PPE and equipment)
  • Showers (removal of biological matter from the worker) [29 CFR 1910.141]
  • Proper disposal of laundry/coveralls (prevention of exposure to others)

Additional Resource

• Bloodborne Pathogens. OSHA Safety and Health Topics Page.

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

• Spills shall be cleaned up immediately. [29 CFR 1915.13(b)(5) and 29 CFR 1915.81]
• Visual Inspection will be conducted. See Confined or Enclosed Space module.
• Adequate illumination will be provided. See Confined or Enclosed Space module.
• Housekeeping as described in 29 CFR 1915.81 will be maintained.

Potential Hazards

The use of high-pressure cleaning equipment may expose the operator and other workers in the area 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 in the high-pressure equipment

Injuries associated with these hazards include

• Loss of body parts such as fingers, hands, etc.
• Lacerations
• Burns
• Loss of sight

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.

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. [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)]