Shipyard Employment eTool
Hot Work (including Welding, Cutting and Heating) >> Hot Work in Enclosed Spaces
Hot work is often performed in enclosed spaces and may expose workers to hazards. Listed below are the specific safety and health requirements for the majority of hot work operations. (Please see additional requirements for hot work in confined spaces and other locations.)
Specific Safety and Health Requirements
- Hot work operations
- Inspection and tests to maintain safe conditions
- Fall hazards
- Ventilation requirements
- Fire preventionrequirements
- PPE requirements
This module outlining the requirements for Hot Work in Enclosed Spaces must be reviewed for the basic requirements before reviewing the module regarding hot work requirements for Confined Spaces and Other Locations.
Note: Confined space entry is one of the leading hazards associated with barge cleaning. Review the Shipbreaking: Confined or Enclosed Spaces and Other Dangerous Atmospheres chapter for information on how to protect workers from this hazard.
Potential Hazards
Workers performing hot work or working in spaces adjacent to hot work are exposed to the following risks:
- Fire and explosions caused by flammable or combustible materials or airborne gases, vapors, and particulates
- Toxic gases and metal fumes produced from the hot operations (such as nitrogen oxides, and lead fumes)
- Ultraviolet radiation from electric arcs
Requirements and Example Solutions
Before beginning hot work, the following tasks must be performed:
- Review the marine chemist certificate and shipyard competent person inspection record. [29 CFR 1915.7 and 29 CFR 1915.14] If hot work permits are available, they should be reviewed.
- A shipyard competent person must perform testing on any surface of which the flammability is not known. [29 CFR 1915.53(b)]
- Toxic preservative coatings must be stripped back at least 4 inches, otherwise airline respirators must be used. [29 CFR 1915.53(d)(1)]
- Maintain good housekeeping conditions. [29 CFR 1915.81]
- Ensure the availability of adequate fire protection equipment. [29 CFR 1915 Subpart P]
- Inspect welding and cutting equipment before use (for example, for arc or gas welding/burning). [29 CFR 1915.55 and 29 CFR 1915.56]
- Test gas torches, gauges, and hoses for leaks. [29 CFR 1915.55(g)(2)]
- Use appropriate PPE for the welder, burner, and other exposed employees. [29 CFR 1915.51(c)(3) and 29 CFR 1915.152(a)]
- Provide UV shielding for arc welding where practical. [29 CFR 1915.56(e)]
- Remove electrodes from electrode holder when not in use. [29 CFR 1915.56(d)(1)]
Remember: When hot work is being performed, it is the employer's responsibility to ensure that precautions are taken in adjacent spaces. [29 CFR 1915 Subpart P]
Potential Hazards
The work space is initially inspected by a Certified Marine Chemist or a Shipyard Competent Person. Conditions may change during work so the Shipyard Competent Person must inspect the hot work area as often as necessary. If the Shipyard Competent Person discovers a change that could adversely alter safe conditions (such as ventilation failure, piping system leak, or hazardous materials spill), work must be stopped. Work may not be resumed until the affected space is visually inspected and re-evaluated (by a Marine Chemist, if a marine chemist certificate was issued) to meet requirements. [29 CFR 1915.15(f)]
Requirements and Example Solutions
Examples of items that can change conditions include:
- Temperature changes: increased or decreased temperatures affect flammable and toxic vapor levels.
- Type of work in tank: leaking torches, use of cleaning solvents, and removal of tank residue ("mucking out") may alter atmosphere.
- Unattended tanks or spaces: if a period of time has elapsed, it is recommended that spaces be retested before re-entry and continuation of work.[29 CFR 1915 Subpart A and Subpart B]
- Ballasting or trimming: changing the position of the vessel could release hazardous materials into a space or compartment.
- Ventilation changes: ventilation duct damage or fans not in use.
- It is recommends that tests before re-entry and continuation of work in unattended tanks and spaces should be conducted at the beginning of the shift and then at least every 24 hours between tests.
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. Workers also risk falls from open deck edges.
Potential Hazards
Deck Openings and Edges
- Falls from deck edges
- Falls from deck openings
- Falls into open holes
Scaffolds
- Falls from ladders
- Falls from scaffolds
Requirements and Example Solutions:
Personal Fall Protection
- If fall hazards are identified through the Hazard Assessment required in 29 CFR 1915.152(b), employees must be protected from falls by the use of personal fall protection equipment. [29 CFR 1915.152(a)]
- Guard rails may be used in lieu of personal fall protection, even though they are not required in shipbreaking. For guard rail specifications, see 29 CFR 1915.71(j).
Fall Protection for Scaffold Work
- Guardrails or other appropriate fall protection must be used when working on scaffolds 5 feet above surfaces. [29 CFR 1915.71(j)]
For more detailed information, review Personal Fall Protection Equipment.
Potential Hazards
Workers performing hot work operations are exposed to toxic gases and metal fumes (such as but not limited to nitrogen oxides, zinc, or iron oxide fumes) that may cause occupational illnesses.
Requirements and Example Solutions
Ventilation removes or dilutes metal fumes and gases generated by hot work. The following ventilation requirements must be met:
- Replace withdrawn air with clean respirable (breathable) air. [29 CFR 1915.51(b)(1)(v)]
- Discharge contaminated air away from the source of the intake air. [29 CFR 1915.51(b)(1)(iv)]
- Mechanically ventilate toxic metal fumes, including: zinc, lead, cadmium, chromium, beryllium, mercury, nickel, arsenic, and copper. [29 CFR 1915.51(d)]
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Note: The presence of beryllium requires local mechanical exhaust ventilation and airline respirators. [29 CFR 1915.51(d)(1)(iv)]
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- Adjust local exhaust ventilation on an ongoing basis. [29 CFR 1915.51(b)(1)(iii)]
- Warning: Do not use oxygen for ventilation or cleaning (blow-off). [29 CFR 1915.51(b)(1)(vi)]
Potential Hazards
Workers performing hot work in enclosed spaces are exposed to the risk of fires from ignition of flammable or combustible materials in the space and from leaks of flammable gas into the space from hot work equipment.
Requirements and Example Solutions
Fires caused by hot work in enclosed spaces can be prevented with the following precautions:
- Performing hot work in a safe location, or remove or cover fire hazards. [29 CFR 1915.503(a)]
- Make suitable fire extinguishing equipment immediately available and ensure that personnel assigned to use this equipment are adequately trained. [29 CFR 1915 Subpart P]
- Do not place gas manifolds in enclosed or confined spaces. [29 CFR 1915.55(e)(2)]
- Take the above precautions in all adjacent spaces.[29 CFR 1915 Subpart P]
Note: OSHA Shipbreaking standards do not require a firewatch, however a firewatch is typically used and may be required by a marine chemist or local authority.
Potential Hazard
Injury and illness may be caused by hot work (such as welding fumes, UV light, sparks, noise, skin injury).
Example Solutions
Personal protective equipment is used during hot work to protect workers. A PPE program consists of the following:
- A PPE Hazard Assessment for all work activity [29 CFR 1915.152(b)]
- Worker training [29 CFR 1915.152(e)]
- Appropriate PPE use [29 CFR 1915.152(a)]
For more specific information, see PPE Selection: Hot Work.