Transcript SURVEY RESULTS - Marine Chemist Association
SURVEY RESULTS
A QUESTIONER WAS PASSED OUT AT THE 2012 MINI SEMINARS. THE RESULTS WERE TABULATED AND ARE PROVIDED WITH THE INTENT OF REVIEWING HOW CHEMISTS TREAT SPACES WHEN USING SAFE FOR HOT WORK AND SAFE FOR LIMITED HOT WORK
OBJECTIVE
To develop an understanding on the treatment of adjacent spaces when using Safe for Hot Work and Safe for Limited Hot Work
What does a space certified as “Safe for Hot Work” Mean to You? Does it Mean Something Else to a Welder?
306 MINIMIUM
In the first situation all you are told is that the space is
Safe for Hot Work
There are no restrictions or limitations listed.
The response requested is:
What is the minimum requirement in 306.
Question 1. 1C is certified, Atmosphere Safe for Workers, Safe for Hot Work. What is (are) the hot work spaces? Product = FP 97°F
Space FORWARD RAKE 1P 1C 1S SSV/DB-1 2P 2C 2S SSV/DB-2 3P 3C 3S SSV/DB-3 AFT RAKE Number of Responses 10 19 50 8 8 1 1 1 1 1 8 8 8 8
Fwd Rake, 1C,P,S 2C,P,S Double Bottom Voids 1,2 } ASFW/SFHW Adjacent spaces 3C,P,S Double Bottom Void 3, written below the test result section with test instrument readings. 1C } ASFW/SFHW Adjacent spaces, Fwd Rake, 1C,P,S - 2C,P,S Double Bottom Voids 1,2. written below the test result section with test instrument readings. This would not allow access into the adjacent spaces, and would not permit hot work on bulkheads
Aft Rake Void 3 3P 3C 3S Void 3 Aft Rake Void 3 3P 3C 3S Void 3 Void 2 2P 2C 2S Void 2 Void 1 1P 1C 1S Void 1 Fwd Rake ASFW ASFW SFHW NSFHW Void 2 2P 2C 2S Void 2 Void 1 1P 1C 1S Void 1 Fwd Rake
Question 1b. What are the adjacent spaces?
Space Number of Responses FORWARD RAKE 1P 1C 1S SSV/DB-1 2P 2C 2S 44 23 4 49 45 49 49 48 SSV/DB-2 3P 3C 3S SSV/DB-3 AFT RAKE 46 2 2 2 0 0
Response
Fully clean all adjacent spaces Partially clean some adjacent spaces
Number of Responses
31 9 Partially clean all adjacent spaces to prevent the spread of fire Inert all adjacent spaces Secure Other 20 15 4 Test spaces only (1)
4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.
Area Under the SSD In with the SSD’s In body following SSD’s At the bottom in a separate section In with the safety instructions Number of Responses 14 3 16 16 1
Certificate of Style
Method
Secure piping to 1C and tag out with no hot work on piping Secure and tag out all piping with no hot work on piping Clean and blown down and test to make all piping SFHW Clean and blow down and test piping to 1C only to make SFHW Isolate piping from hot work in 1C with partitions Drain and secure piping to 1C and tag out with no hot work on piping Drain, secure and tag out all piping with no hot work on piping
Number of Responses
3 13 10 9 5 11 6
This will change with the next edition of 306
Response
No Yes
Number of Responses
46 4 One person noted that this was an improper use of the SFHW designation and SFLHW should have been used. Best response: Since you use the Safe for Hot Work designation and it is a tank vessel then 306 states: 4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.
So, the treatment of adjacent spaces should not have changed.
Response
No Yes Maybe
Number of Responses
16 25 1 Best Response: Since you use the Safe for Hot Work designation and it is a tank vessel then 306 states: 4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.
So, cleaning should not have changed and no is the correct response. It should be noted that 7 chemists did not respond to this question.
Question 2 1C is certified as Atmosphere Safe for Workers and Safe for Limited Hot Work, and the hot work is limited to burning and welding to cut out and install an insert on the bulkhead between 1P and 1C and all hot work will stay 3 feet away from 2P and 2C.( See right hand note on diagram.)
Question 2a
What is the hot work space(s)?
Space
FORWARD RAKE 1P 1C 1S SSV/DB-1 2P 2C 2S SSV/DB-2 3P 3C 3S SSV/DB-3 AFT RAKE
Number of Responses
3 49 50 4 3 3 3 3 3 0 0 0 0 0
Best Response: The majority of chemists indicated the correct response, 1C and 1P. This could indicate that the concept of Safe for Limited Hot Work is better understood than Safe for Hot Work and Safe for Hot Work with Restrictions.
Question 2b
What are the adjacent space(s)?
Space FORWARD RAKE 1P 1C 1S SSV/DB-1 2P 2C 2S SSV/DB-2 3P 3C 3S SSV/DB-3 AFT RAKE Number of Responses 45 8 4 45 46 46 46 46 46 1 1 1 1 1
Best Response: If 1C is certified for SFLHW and the hot work is on the bulkhead with 1P then they are both hot work spaces and the adjacent spaces become: Forward Rake 1S SSV/DB 1 and 2 2C,S,P
Question 2c
How do you treat the adjacent spaces?
Response Number of Responses
Fully clean all adjacent spaces 21 Partially clean some adjacent spaces Partially clean all adjacent spaces to prevent the spared of fire 6 20 Inert all adjacent spaces Secure Other 4 0 0 Best Response: Following the reasoning below, the correct response is to clean all adjacent spaces to prevent the spread of fire or inert. 4.3.6 SAFE FOR LIMlTED HOT WORK indicates that all of the following criteria shall be met at the time the Certificate is issued: (1) Any compartment or space so designated meets the requirements of 4.3.4(1) and 4.3.4(2) (unless inerted in accordance with 4.3.8). (2) The Certificate shall include a statement describing the specific location and type of the hot work. The Marine Chemist shall also be permitted to list any areas to be excluded from hot work. These areas shall be listed on the Certificate under the heading "limitations." (3) The space meets one of the following conditions: (a) The space or compartment is inerted in accordance with 4.3.8, adjacent spaces shall be treated in accordance with 4.3.4( 4), and the hot work shall be limited to the specific location or locations described in the "limitations" in 4.3.6(2).
(b) The space or compartment meets the requirements of 4.3.4 (1), (2), (3),
and (4);
the hot work shall not be allowed on adjacent spaces or pipelines, or both as applicable; and the hot work limitations shall be described in the "limitations" in 4.3.6(2). (c) Portions of the space or compartment meet the requirements of 4.3.4(3) and (4), as well as the applicable portions of 5.1.3, and the hot work shall be limited to the location or locations described in the "limitations" in 4.3.6(2).
4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted. (States SFHW, not SFLHW)
Question 2d
How do you treat the pipelines?
Method Secure piping to 1C and tag out with no hot work on piping Secure and tag out all piping with no hot work on piping Clean and blown down and test to make all piping SFHW Clean and blow down and test piping to 1C only to make SFHW Isolate piping from hot work in 1C with partitions Drain and secure piping to 1C and tag out with no hot work on piping Drain and secure and tag out all piping with no hot work on piping Number of Responses 6 4 7 13 8 11 5
Best Response: Section 5.1.3 describes cleaning for limited hot work, however this section provides no instructions on how to treat pipelines. Since you may assume that the hot work spaces were fully cleaned then section 5.1 will be invoked. 5.1 Where a Safe Condition Is to Be Obtained Entirely by Cleaning. [See Figure B.I, part (b).] 5.1.1 All cargo pumps, cargo lines, inert gas lines, crude oil wash lines, piped cargo fire-extinguishing lines, vapor control and recovery lines, and vent lines shall have been flushed with water, blown with steam or air, or inerted.
It could be possible to confuse this requirement with section 4.2.2(5) which states: 4.2.2(5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERE SAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by a positive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict, operation