Hot Work Operations and Maintaining Safe Conditions >> Hot Work in Confined Spaces

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Figure 1: Hot Work in Enclosed Spaces
Figure 1: Hot Work in Enclosed Spaces. Also see: Fire Watches, Establishing Rescue Teams, Ventilation, Warning Signs and Labels, and Hot Work.
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Fire Watches, Establishing Rescue Teams, Ventilation, Warning Signs and Labels, and Hot Work

In addition to the requirements and recommendations for working in enclosed spaces and due to the unique hazards associated with hot work in confined spaces, the following controls are required:

Note: During shipbuilding operations, the need for testing by a SCP and CMC will depend on the progress of the vessel construction. Until there is a potential for a hazard, such as after the introduction of flammable liquids, testing may not be required.

Also, the module outlining the requirements for Hot Work in Enclosed Spaces should be reviewed before reviewing this module.

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

Potential Hazards

Due to the isolation and difficulty of egress, hot work operations in confined spaces present additional hazards. These include:

  • Impeded egress from the space under emergency conditions.
  • Delayed treatment of injured workers.

Requirements and Example Solutions

Potential Hazard

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 opening in decks and unguarded edges.

Requirements and Example Solutions

Guarding of Deck Openings and Edges

  • Openings and deck edges must be guarded. [29 CFR 1915.73]
  • Flush manholes and other small openings must be guarded after opening. [29 CFR 1915.73(b)]
  • During the installation of guards on large openings and deck edges, fall protection (harness with lanyard) must be used. [29 CFR 1915.73(d)]
  • When floor plates or gratings (e.g. bilges, engine rooms, pump rooms, machinery spaces) are removed, the openings must be guarded or planked. [29 CFR 1915.73(f)]

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)]
  • During the installation of guards on scaffolds, fall protection must be used. [29 CFR 1915.73(d)]
  • Maritime Labor/Industry recommends that personal fall protection including lanyards and harnesses be used and secured during installation of guardrails.
Figure 2: Local exhaust ventilation works

Potential Hazard

Confined spaces usually do not have adequate natural ventilation, which may expose workers to hazardous fumes and gases.

Requirements and Example Solutions

  • Use adequate mechanical ventilation or airline respirators for hot work in confined spaces. [29 CFR 1915.51(b)]
  • Keep access clear of blockage from ventilation equipment. [29 CFR 1915.51(c)]
  • If the ventilation equipment blocks access to the space, airline respirators as well as a stand-by employee must be available. [29 CFR 1915.51(c)(3)]

See Confined or Enclosed Space Entry and Other Dangerous Atmospheres for additional information regarding ventilation.

Figure 3: Removal of torches and hoses

Potential Hazard

Because confined spaces have little natural ventilation, flammable gases may accumulate to hazardous levels, even when unoccupied, exposing workers to risk of fire or explosion upon re-entry.

Requirements and Example Solutions

Work in confined spaces requires certain restrictions regarding what equipment can be taken inside and what equipment can be left inside when unoccupied.

  • Torches and hoses must be removed from confined spaces when not in use (lunch breaks, shift changes, etc.). [29 CFR 1915 Subpart P]
  • Oxygen and fuel gas cylinders must not be taken into confined spaces. [29 CFR 1915.55(b)(4)]
  • For additional requirements, see the Fire Protection chapter.

Potential Hazard

Due to the difficulty of providing adequate ventilation to protect workers, personal protective equipment requirements, especially respiratory protection, are extremely restrictive when performing hot work in confined spaces.

Requirements and Example Solutions

The following are specific requirements for PPE during hot work operations in confined spaces.

  • Use airline respirators when access to the space is blocked. [29 CFR 1915.51(c)(3)]
  • Use airline respirators when welding on beryllium-containing base or filler metals. [29 CFR 1915.51(d)(2)(iv)]
  • Use PPE in accordance with requirement for hot work in enclosed spaces if not superseded by the above requirements. [29 CFR 1915.51(d)]

For more specific information, see PPE Selection: Hot Work.