Potential Hazards

Mechanical paint removal operations include the following hazards:

• Working in or around spaces that are not "gas free."
• Flammable and combustible residues (e.g., combustible dust, oil residue).

Requirements and Example Solutions

• Equipment that can generate static electricity (e.g., ventilation systems, abrasive blasting) must be grounded/bonded. [29 CFR 1915.13(b)(11)]
• 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]
• Flame or heat must not be used to remove soft or greasy coatings. [29 CFR 1915.34(b)(2)]

Additional Resources

• See Shipbuilding: Hot Work (including Welding, Cutting and Brazing).

Potential Hazards

Mechanical paint removal operations produce dust, which may present significant health hazards when used in confined or enclosed spaces. Hazards include:

• Dry ice (C0₂) when used as blast media.
• Heavy metal dust including lead, arsenic, cadmium, chrome and beryllium.
• Silica dust.
• Toxic fumes produced by flame removal of paint.

Requirements and Example Solutions

• Ensure adequate ventilation to maintain concentrations below the PEL. [29 CFR 1915.34(a)(4)]
• Airline respirators may be necessary if ventilation is not adequate.
• Abrasive blasters working in enclosed and confined spaces must be protected by hoods and airline respirators. [29 CFR 1915.34(c)(3)]
• When not working in enclosed and confined spaces, abrasive blasters must be protected with appropriate respirators. [29 CFR 1915.34(c)(3)(ii)]
• Other employees near the area of operation require appropriate respiratory protection. [29 CFR 1915.34(c)(3)(ii)]
• Respiratory protection for heavy metal and silica dusts require as a minimum a high efficiency filter (HEPA). See Respiratory Protection eTool.
• Workers must be protected by an airline respirator when doing flame removal of paint. [29 CFR 1915.34(b)(1)]
• Respirators must be NIOSH approved and used in accordance with 29 CFR 1915.154. [29 CFR 1910.134]

Additional Resources

• Ventilation. See Confined or Enclosed Spaces and Other Dangerous Atmospheres.
• Respiratory Protection. OSHA eTool.
• Inspection procedures for the Respiratory Protection Standard. OSHA Directive CPL 02-00-120 [CPL 2-0.120], (September 25, 1998).

Potential Hazards

When working in confined or enclosed spaces workers may become trapped and unable to exit due to:

• Improperly located equipment.
• Ventilation ducts and hoses running through the opening.

Requirements and Example Solutions

• When employees work in confined spaces with limited access, the access must not be blocked or impeded by ventilation ducts, hoses or other equipment. [29 CFR 1915.76(b)(2)]
• More than one means of access must be provided where practical. [29 CFR 1915.76(b)(1)]
• Additional openings should be provided for ducts, hoses, and other equipment.

Potential Hazards

Workers performing surface preparation are exposed to slick conditions and tripping hazards.

• Slipping and falling on oily decks.
• Slipping on slick, wet or grit covered surfaces.
• Tripping over equipment, hoses, and vessel structures.
• Pressure changes causing surges in blast hoses.

Requirements and Example Solutions

• Inspect blasting hoses.[29 CFR 1915.34(c)(2)]
• Secure blasting hoses. [29 CFR 1915.34(c)(1)(ii)]
• Use dead man control on the blasting hoses. [29 CFR 1915.34(c)(1)(iv)]
• Visual Inspection. See Confined or Enclosed Spaces and Other Dangerous Atmospheres.
• Illumination. See General Working Conditions.
• Housekeeping. [29 CFR 1915.81]

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 and scaffolds are often serious, even fatal.

Abrasive and Water Blasting

• Surges from drops in pressure in the hose line may be able to throw the worker from the work surface.
• Blasting can create static electricity. This may shock the worker and result in a fall.

Deck Openings and Edges

• Falls from deck openings.
• Falls into open holes.

Scaffolds

• Falls from ladders.
• Falls from scaffolds.

Requirements and Example Solutions

Abrasive and Water Blasting

• Blasters shall be protected by proper fall protection. [29 CFR 1915.34(c)(3)(v)]
• Blasters who's vision is obstructed by the hood, shall not work from ladders. [29 CFR 1915.77(c)]
• Blaster should wear appropriate boots and gloves to insulate from static electricity.
• Blasting equipment should be grounded and bonded.

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 (e.g., 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 shall be used when working on scaffolds five feet above surfaces. [29 CFR 1915.71(j)]
• Fall protection must be used during the installation of guards on scaffolds. [29 CFR 1915.73(d)]

Potential Hazards

Environmental hazards include temperature, humidity, and air movement within the work area. A combination of PPE use, heat producing equipment, work activity, and environmental conditions can cause temperature related illnesses.

Heat related illnesses include:

• Heat Stress
• Heat Stroke
• Heat Cramps
• Dehydration

Cold related illnesses include:

• Hypothermia
• Frost Bite

Additional Resources

• OSHA Technical Manual (OTM). OSHA Directive TED 01-00-015 [TED 1-0.15A], (January 20, 1999). Identifies heat stress as part of the evaluation process in the following:
  • Heat Stress. Contains useful sections on the signs and symptoms of heat stress, sampling methods, control suggestions, and guidelines for investigating heat stress in the workplace.
• Heat Stress. OSHA Safety and Health Topics Page.

Maritime labor/industry recommendations

Example Solutions

The following are recommended for heat related illnesses:

• Drink plenty of fluids.
• Take frequent breaks.
• Use a cooling vest.
• Take breaks in shaded or cooled areas.
• Use ventilation.
• Reduce the inner temperature of work spaces by using water sprinklers on outside metal surfaces.
• Conduct awareness training.

It is recommended that the following be implemented to prevent cold related illnesses:

• Wear appropriate insulated PPE.
• Use warming areas for breaks.
• Conduct awareness training.

Potential Hazards

The use of high pressure equipment may expose the operator as well as bystanders 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 from high-pressure equipment.

Injuries associated with these hazards include:

• Loss of body parts (e.g., 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 must be used. [29 CFR 1915.152]
• Access to the area should be controlled.
• Use dead man control. [29 CFR 1915.34(c)(1)(iv)]
• Nozzle and hose couplings shall be secured with metal couplings. [1915.34(c)(1)(ii) and (c)(1)(iii)]
• Hoses and connections should be inspected prior to 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:

• Faulty electrical connections in power tools.
• Open lighting parts.
• Broken insulation on power cords.
• Blasting may cause shocks from static electricity.

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)]

Maritime labor/industry recommendations

• All electrical tools or equipment should undergo a visual inspection prior to use.
• All portable electric hand tools and temporary lighting systems should utilize Ground Fault Circuit Interrupters (GFCI).
• Electrical tools and equipment should correspond with the requirements of the job.
• Electrical equipment and tools should be used with proper circuit protection for the voltage and amperage used.
• Only qualified electricians should attempt repair of electrical tools and equipment in use.
• A Ground Assurance Program should be in place for all electrical tools and equipment used including:
  • Records of tools inspected and repaired.
  • Records of electrical boxes inspected and repaired.
  • Records of electrical extension cords inspected and repaired.
  • Recall of records of the above.
• The requirements of the Ground Assurance Program should be performed on a regular basis.

Potential Hazards

Mechanical paint removal produces excessive amounts of noise, which may cause hearing loss. Some of the loudest operations include:

• Abrasive Blasting
• Needle Gunning
• Scaling
• Grinding

Requirements and Example Solutions

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

Additional Resources

• Occupational Noise Exposure. OSHA Safety and Health Topics Page.
• Guidelines for Noise Enforcement; Appendix A. OSHA Directive CPL 02-02-035 [CPL 2-2.35A], (December 19, 1983).

Potential Hazards

Mechanical paint removal operations may expose workers to impact from:

• Blasting agents (e.g., sand)
• Sparks
• Mental particles
• Grinding debris
• Paint debris

Injuries may include

• Particles becoming imbedded in the skin
• Eye damage
• Skin burns
• Skin trauma

Requirements and Example Solutions

• Proper use of PPE.
• Portable rotating tools must be adequately guarded to protect both the operator and nearby workers from flying objects. [29 CFR 1915.34(a)(2)]