Figure 1: Illustration of the many ship repair operations that require PPE:
Figure 1: Illustration of the many ship repair operations that require PPE: Cleaning Preparation, Rescue Teams, Ventilation, and Warning Signs and Labels.
Prep Before Cleaning Cleaning Operations Rescue Teams Ventilation Rescue Teams Warning Signs and Labels Warning Signs and Labels

Cleaning Preparation, Rescue Teams, Ventilation, and Warning Signs and Labels

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 Shipbreaking: 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
  • It is recommended 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
  • It is recommended that a written PPE Program that describes how the employer meets each element of the standard.